South West Water Accounting Separation Methodology 31 March 2013

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1 South West Water Accounting Separation Methodology 31 March 2013 southwestwater.co.uk

2 Background Prior to 2009/10 South West Water s Regulatory Accounts reported the Company s appointed activities analysed between Water Services and Sewerage Services in respect of operating costs, current cost capital maintenance charges and current cost fixed asset values. 2010/11 was the first year that Accounting Separation tables were submitted as part of the June Return for all companies, alongside the previous water and sewerage business separation. For 2011/12, as part of Ofwat s Regulatory compliance a proportionate and targeted approach publication, companies were no longer required to submit a June Return. As part of this approach, as noted in IN 12/01 published in January 2012, companies were still asked to provide accounting separation data to Ofwat with an accompanying Methodology Statement. Companies were given the option to replace the existing Water & Sewerage pro-forma tables within the Regulatory Accounts with the supplementary tables for accounting separation. South West Water decided to take this option and included accounting separation data within the Company Annual Performance Report and Regulatory Accounts Current Cost Regulatory Accounts. Activity costing analysis (Water, Sewerage and Retail business units) Analysis of fixed assets by asset type (Water, Sewerage and Retail business units) For 2012/13, South West Water continue to publish activity costing analysis and analysis of fixed assets by business unit as detailed in the revised Regulatory Accounting Guidelines (RAG 4.04 as published in February 2013) and supported by Information Notice IN 13/ /13 Commentary To coincide with the publication of the new Regulatory Accounting Guidelines SWW undertook a project to develop the approach to accounting separation reporting. The project included: updating allocations and methodology for the new RAGs 4.04 with the key changes being the transfer of costs between retail and wholesale for services to developers, trade effluent compliance and disconnections, and the movement of customer meters from retail into the water wholesale business a detailed review of business unit boundaries to ensure where possible costs were directly attributable to each business unit. Discussions were held with key personnel across the business to apply the principles for each unit to SWW sites and business structure the allocation drivers for key areas such as IS, accommodation and central charges were updated allocations were updated for new cost drivers (such as power assessments for joint sewerage and sludge sites) and changes within SWW directorate and team structures. A new and updated allocation model was developed which improved the traceability of costs back to SWW general ledger and clarity in the allocation of corporate costs. As part of South West Water s review and refinement all M&G assets were assigned to an M&G sub-category within the CCA register e.g. HR, Finance, Energy, M&G Depots, etc enabling a more precise allocation southwestwater.co.uk Page 2

3 between relevant business areas accordingly to how the related operating expenditure category has been allocated. For example M&G IS assets and related depreciation have been allocated based on user accounts. Whilst changes were identified through this project, there were no significant movements in costs between business units. Methodology Overview This methodology statement provides an overview of the process followed by South West Water in preparing the accounting separation tables for the year ended 31 March These tables are included on pages 90 to 94 of the Company Annual Performance Report and Regulatory Accounts. The methodology covers three key areas: Operating cost analysis (Opex) (page 90 to 91) Current cost depreciation and infrastructure renewals charge (page 90 to 91) Current cost analysis of fixed assets (page 92 to 94) South West Water s operational structure has been determined by the Company s assessment of the most efficient and effective way to deliver its business objectives. These include achieving the highest standards of customer service, good levels of health & safety and the delivery of regulatory outputs. The data hierarchies used in South West Water s financial systems primarily support the management structure of the Company to support accountability and to most effectively analyse performance against budgets, targets or prior periods. However, the coding used to record financial transactions is designed to also record activity-based information to support regulatory accounting as well as budgetary accounting, particularly in relation to direct costs. While South West Water does not have a formal activity-based costing system, it has, as part of accounting separation, reviewed the cost centre structures of the business and allocated the specific areas identified into either wholesale or retail business units. Existing and well-established processes exist to allocate operating costs, capital maintenance costs and fixed assets to the separate water, sewerage and retail business areas. Detailed methodology Systems Operating cost analysis Operating cost information is derived from the Company s general ledger system, Ellipse. The data is adjusted to ensure compliance with the Regulatory Accounting Guidelines for the appointed business only (e.g. removal of income, interest expense and historic cost depreciation). This data is input into a Microsoft Excel model to analyse costs between business units where there is a direct correlation or allocated costs to business units based on key drivers. The cost centre, process code and expense elements of South West Water s account code structure are used to aid the direct allocation to business unit. southwestwater.co.uk Page 3

4 Depreciation & Fixed assets A historic cost fixed asset register (Real Asset Management) is used to record the detail of fixed assets and related depreciation charges. Summary control amounts from the fixed asset register are posted monthly to Ellipse. Current cost accounting information, including fixed asset values and depreciation charges, are not processed through Ellipse but controlled through a separate current cost fixed asset register. This includes the full data from the MEA Revaluation and all non-infrastructure additions since 1 April The register is used as the source for the current cost depreciation charge and gross book valuations. Operating Expenditure - Activity Costing Analysis In preparing the information required for the accounting separation tables, the company has established processes to allocate operating costs and capital maintenance costs. The Company has a well defined basis for allocating directly related general and support costs, such as vehicles, accommodation and human resources costs. Where there are elements of business support and corporate costs which have no obvious connection to operational activities, and which do not increase or reduce in line with the level of operational activities, judgement has been used to select the most appropriate method of allocation. The allocation of operating costs within South West Water to specific business unit within the appointed business is based on activity analysis and principles which result in both direct (where applicable) and support costs being apportioned. For example: Cost Accommodation Vehicle and plant Human Resource Basis Floor area Usage records Headcount Information Services (IS) costs have historically have been allocated based on the numbers of PC s. Following a review of methodology current year costs have been apportioned based on users accounts which is considered a more accurate measure of consumption. Costs are charged directly to business units where possible. For activities where this is not practical (for example business support & corporate overheads) judgement has been used to select the most appropriate method of allocation for example headcount. Where support costs are not specifically allocated costs are allocated pro rata to the relevant elements of direct or total cost within the prime service, subject to management assessment of the effect of direct costs such as doubtful debt, power and EA charges which do not generate the same level of support. The internal charging rates adopted by the Company are reviewed for appropriateness both annually and through previous activity-based analysis of overhead and indirect costs. southwestwater.co.uk Page 4

5 The general ledger coding structure is continually under review to ensure costs are directly allocated to business units wherever possible. However there remains a requirement to apportion certain costs using appropriate cost drivers. Sewerage units Allocations are required for certain costs of the sewerage business units (for example where there are combined sewage and sludge treatment works). Information required to complete the sewerage elements of the table was obtained using the Company s general ledger system together with analysis of cost factors for Sludge Treatment & Disposal including direct identification of chemical costs specific to sludge treatment. Other analysis The accounting separation tables also require the allocation of total operating expenditure into different operating cost categories. The table below lists the main cost categories within total operating expenditure and outlines the sources of the cost contained within each line and where apportionments have been used. Operating Expenditure heading Power Income treated as a negative expense Service charges Bulk supply imports Other operating expenditure Costs included and method of allocation All energy costs including the climate change levy. Power costs are allocated to individual sites which are in turn allocated to specific business units. At combined sites an allocation of the power costs is determined based on an assessment of the power usage of individual items of equipment. Income received from energy generation. Energy generation income is allocated to sites which are in turn allocated to specific business units. Income received from solar and wind power generation is classified as non-appointed income and is excluded from the accounting separation tables. Total cost of service charges by the Environment Agency or British Waterways for water abstraction and discharge consents. Service charges are identified from the general ledger and allocation to business unit through reference to the specific cost centre posting. Total payments for bulk imports. South West Water does not rely on bulk imports and sources all water from resources within the South West Water region. All other operating costs. Allocated to business units are based on the underlying cost driver of the specific cost. Where possible other operating expenditure is allocated directly to southwestwater.co.uk Page 5

6 business units. Where direct allocation is not possible management assessment is used to allocate the costs. Local authority rates Corporate and support costs are allocated to business units using the most appropriate underlying cost driver. Where costs cannot be specifically allocated costs are apportioned pro-rate to direct or total cost. The cost of local authority rates (including local authority rates, cumulo rates and sewerage site rates). Water Cumulo are allocated on basis of MEAV ( Modern Equivalent Asset valuation ). Sewerage rates are allocated direct to sites via local authority bill, At combined sewage and sludge treatment centres rates are apportioned on MEAV. Local authority rates for support buildings are apportioned between functions by floor area. Exceptional items Exceptional items as defined by UK GAAP. Retail unit The Ofwat definitions of the activities within the retail business units are used to identify and extract both direct and allocated general & support costs. In other cases, whilst costs are readily identified from the Ellipse general ledger, they are not directly attributable to one particular line within the retail business unit. Where this is the case, the most appropriate form of apportionment or allocation has been identified by the Management team. A significant proportion of costs relate to work undertaken by the wholly owned subsidiary (Source Contact Management Limited Source ) which was incorporated to undertake the customer contact and account activities on behalf of South West Water and is identified as a separate cost centre. The cost of Source is allocated to retail activities in accordance with the cost drivers set out in the Ofwat guidelines based on a detailed analysis, by the customer service contractor, of its activities carried out during the year. This analysis includes an allocation of the costs of contacting customers via outbound calls. The cost of each outbound customer contact is allocated to the retail activity to which it relates. Where applicable general support costs have been allocated to specific retail activities where they are considered to be directly attributable. Other general and support expenditure which cannot be directly allocated to a specific retail activity is included within the other operating expenditure line of the retail table. Costs have been allocated between household and non-household based on the key driver (e.g. bill volumes, property numbers). southwestwater.co.uk Page 6

7 As a result of the revised RAG s costs in relation to meter maintenance and installation, support for trade effluent compliance and costs of performing disconnections which previously were included within Retail are now allocated and classified within the relevant wholesale business unit. Furthermore the revised RAG s have clarified that only managing developer queries and providing information to developers costs should now be included within the Retail Services to Developers activity. All other Services to Developers costs have been either capitalised or included within the relevant wholesale business unit. Capital maintenance costs Infrastructure renewals charge It has been assumed that the infrastructure renewals charge ( IRC ) should only be allocated to the following business units that have infrastructure fixed assets allocated to them: Water resources Raw water distribution Treated water distribution Sewage collection Sewage treatment (in respect of outfalls) The IRC is calculated by reference to the asset management plan which looks at five years historical spend and ten years future projected spend. The difference between the IRE (infrastructure renewals expenditure) and IRC is treated as an accrual or prepayment. Current cost depreciation charge The total depreciation cost reported in the accounting separation tables is consistent with other information reported within the Company Annual Performance Report and Regulatory Accounts. Depreciation is not usually charged by the Company on capital work in progress balances as these balances mainly relate to incomplete projects for which no depreciation is appropriate. The charge for the year of capitalisation is identical to the historical cost accounting ( HCA ) part year charge as no indexation is applied in the first year. Depreciation is calculated monthly with a part year charge for most assets in the year of capitalisation. No depreciation is charged on infrastructure assets. Fixed Assets by Asset Type The Company has extracted the necessary fixed asset information for accounting separation from its existing fixed asset records and has performed validation and re-analysis where it has seen opportunities within these data sources to improve the quality of the information to be entered in the tables. A full Modern Equivalent Asset ( MEA ) revaluation was carried out as at 31 March 2008 for PR09. This data was incorporated into the previously reported June Return in JR 11. The data used in the tables for CAPR13 includes the MEA Revaluation as at 31 March 2008 (and then re-valued annually with RPI). Additions since 31 March 2008 are re-valued annually using RPI (excluding year of capitalisation). southwestwater.co.uk Page 7

8 The full analysis from the 2008 revaluation has been reviewed, mapped to the accounting separation business units and uploaded to the separate current cost fixed asset register. The assets are split into the following categories: Infrastructure assets Non-infrastructure assets (comprising operational and other tangible assets) Where possible assets have been allocated directly to the business unit to which they relate. For 31 March 2013 assets which are utilised by more than one business unit have been allocated on the following basis (as detailed in Information Notice IN13/01 published in February 2013): Asset Direct assets utilised by one business unit Direct assets used by more than one wholesale business unit Direct assets used by both wholesale and retail business units General and support assets where part of the asset can be directly identified as being a primarily retail (or wholesale asset) with the asset also used in part by wholesale (or retail) General and support assets Allocation Asset recorded in business unit Asset is allocated between the wholesale assets that used the asset based on usage Asset is recorded in the business unit of principal use with recharges made to the other business unit Where part of a general and support asset is separately identifiable as being used primarily in a particular business unit the asset is recorded in the business unit of principal use and recharges made by the other Where a general and support asset is used to support the entire business the asset is allocated across the business units For the year ended 31 March 2013 no assets are considered to give rise for the need to record and disclose recharges between the retail and wholesale business units in line with the guidance contained within IN 13/01 as South West Water does not have any direct assets that straddle the boundary between the retail and wholesale areas of business. All assets that do straddle the retail and wholesale areas of business are considered to be general and support assets. Within the CCA Register, indexation is applied annually on the opening gross and net book values and the depreciation charges are calculated as NBV divided by remaining life. Completion of the accounting separation tables for non-infrastructure assets requires an analysis code relating to the area of service to have been given to each asset. The detailed MEA valuation has been reviewed and each asset was assigned an area of service for use in CAPR13. This analysis has been included within the current cost fixed asset register for each asset to allow for easier reporting on an accounting separation basis. Additions since 1 April 2008 are linked to business units by automatic cross-referencing based on cost centres. Cost centres relating to specific operational sites are based on the equipment numbers used in asset registration and Ellipse. In addition to specific cost centres there are general cost centres covering assets such as vehicles and health, safety and security. southwestwater.co.uk Page 8

9 In certain instances area of service codes applied to particular assets have been changed on review where this is necessary to improve the analysis and because main process categories do not always precisely correspond to asset codes. This method of amending the analysis has been used primarily to identify (from the descriptions / titles given to items on the fixed asset register) IS assets that relate to customer service (Retail) and to improve the analysis of clean water and management and general assets. The most significant change for 31 March 2013 is the reclassification of customer meters which the revised RAG s now stipulate as Treated Water Distribution assets. Previously all meters were allocated to the Retail business unit in line with historical guidance. Infrastructure assets Infrastructure assets are not included in the current cost register. They are instead tracked in a separate model with additions each year in line with infrastructure costs within the historical cost register and work in progress. Sludge Disposal No infrastructure or operational assets are allocated to this business unit. South West Water does not have specialist assets relating to this business unit and, in particular, no incineration facilities. Assets related to disposal of treated sludge, which are generally not recognised separately in the fixed assets records from other sludge assets, are included within the sludge treatment business unit. Management and General Management and general expenditure is reviewed annually on a project-by-project basis. This results in specific retail, wholesale costs being allocated to the appropriate business units. The remaining projects are allocated either across the water and sewerage business units or across all the business units, depending on the nature of the project. As part of South West Water s continuing review and refinement of M&G assets allocations, for 31 March 2013 all M&G assets were assigned a more detailed M&G sub-category within the CCA register e.g. HR, Finance, Energy, M&G Depots, etc enabling a more precise allocation between relevant business areas accordingly to how the related operating expenditure category has been allocated. For example M&G IS assets and related depreciation have been allocated based user accounts. The revised allocations have resulted in certain reclassification adjustments between business units which reflect the more precise allocations. Retail assets Retail assets are principally represented by: customer related IS Systems (including billing systems, telephony, etc) directly attributable vehicles (e.g. vehicles used for meter reading) allocation of the general and support assets total. The split of costs and depreciation between household and non-household has been allocated based on the number of properties. southwestwater.co.uk Page 9

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