6 June Cathyrn Blair Stakeholder Engagement 2015 to 2020 Directions and Priorities SA Power Networks GPO Box 77 ADELAIDE SA 5001.
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1 ABN Greenhill Road Unley SA 5061 Telephone Fax June 2014 Cathyrn Blair Stakeholder Engagement 2015 to 2020 Directions and Priorities SA Power Networks GPO Box 77 ADELAIDE SA 5001 Dear Cathryn We write to you in relation to SA Power Networks (SAPN) recently released report entitled The South Australian Distribution Network: Directions and Priorities 2015 to Executive Summary Business SA is extremely concerned about the cost of doing business in South Australia, which includes but is not limited to the rising cost of utilities, including electricity. We acknowledge that electricity reliability is important, but the reality is that businesses have had to absorb significant electricity price rises, particularly over the past five years. This has been compounded by other rising utility costs and high State based taxes and levies which have all served to decrease the competiveness of South Australian business. We recognise that forecast price rises for electricity distribution should remain under CPI for the next four years and this is welcomed by Business SA. However, South Australian businesses still face the highest electricity costs in the country and if SAPN wants to support economic growth in this State, it can play a pivotal role through finding efficiencies within its forecast operating and capital expenditure across the next regulatory period from 2015 to We support SAPN s move towards cost reflective tariffs and enabling new technologies concomitant with the roll out of smart meters and are encouraged that SAPN recognise battery storage as playing a more significant role in the future electricity grid. Business is already pursuing energy efficiency as a first response to rising electricity prices, but it is increasingly important that the right price signals are been sent to reflect the actual network costs associated with usage at various times.
2 Background 1. Business SA welcomes the indicative estimates from SAPN which forecast network distribution charges to decline by 4% in 2015/16 and then increase by no more than CPI over the following four years. This equates to average annual rises in network distribution charges of approximately 1.6% over the next regulatory period, considerably less than businesses have faced in recent years. We also recognise SAPN s efforts to focus on prolonging the life of its assets with examples such as reinforcing stobie poles with steel base plates to avoid replacement. Notwithstanding any reduction in network charges is welcomed, we are still concerned that South Australia s electricity prices remain the nation s highest and that our member businesses, including mostly small businesses, have endured price rises of approximately 80% over the past 5 years 1. This is a particular concern for manufacturers who are typically more energy intensive and also face significant gas prices rises, particularly over the next three years. South Australian businesses also face significant tariff price rises in 2014/15, before the next regulatory period begins, with most tariff class supply and block usage rates rising well in excess of CPI and in some cases above 10%. We acknowledge that some of those rate changes are as a result of changes to ensure more cost reflectivity in pricing, as well as increased vegetation management charges which were approved by the Australian Energy Regulator (AER). However, the simple fact is that many businesses have to pay much more for an essential service which is only adding to the already high cost of doing business in South Australia. 2. We acknowledge from P11 of the report, amongst the list of what SAPN has learnt from its stakeholders and customers is that SAPN should: Continue managing assets and investment to drive reliability, manage risk and support economic growth We are encouraged that SAPN acknowledges its place in supporting economic growth and remind SAPN that the most effective role it can play is by reducing price pressure of network distribution charges on business, particularly small business. Only business can drive economic growth but essential service providers such as SAPN can facilitate that growth by distributing electricity at the lowest possible cost. SAPN will benefit from the growth of the South Australian economy, but this growth will only occur if both Governments and essential service providers work to bring down the costs of doing business in South Australia. Business SA recently conducted a workshop with its members to gauge the impact rising electricity prices were having on them. Of the businesses in attendance, 42% reported electricity cost increases of between 10% and 25% in the previous12 1 ABS, Consumer Price Index Adelaide electricity sub-group, March
3 months. Furthermore, 46% of attendees reported increases between 25% and 50% over the past three years and a further 15% reported increases of over 50% during the same period. We also received historical data from some attendees which included one regional engineering workshop s electricity costs having risen 64.8% in just the last three years. While we acknowledge that this feedback only came from a limited cohort of Business SA members, it is indicative of the reality that businesses, particularly small businesses are facing. Over half of the workshop attendees also said that rising electricity prices had either a significant or very significant impact on their business which resulted in 92% reporting reduced profit as a result; largely due to an inability to pass these costs on which is being exacerbated in the current economic climate. On a more positive note, 64% of the workshop attendees were looking at measures to improve energy efficiency, lower usage or lower peak demand. 3. Business SA is concerned at the forecast growth in the size of SAPN s regulatory asset base (RAB) which earns a regulated return recouped from end users. The RAB was $2.47 billion in 2004 and has already increased to $4 billion in 2014, a growth rate of 6.2% per annum, which is in addition to regulated returns. Furthermore, the RAB is forecast to grow to $5.5 billion by 2020, again a growth rate of 6.2% per annum. We acknowledge that there is a program of asset replacement over the next few years, but we are still concerned about the indirect impact of a rising RAB on consumers, particularly small businesses. 4. We note that SAPN s workforce has grown by over 90% since By comparison, South Australia s population in 1999 was million and today stands at million, an increase of 12%. We encourage SAPN s strong focus on training apprentices and acknowledge that it is necessary to ensure the older cohort of technical staff can be adequately replaced in coming years. However, we are concerned about any significant rise in costs, whether it be for labour or otherwise, which are ultimately borne by consumers, including small businesses. Business, particularly small business, have become accustomed to doing more with less over the past several years in response to trying economic circumstances. This drive in productivity has been necessary just to remain viable and we encourage SAPN to focus on productivity across its operations. 5. We support SAPN s move to transition towards cost reflective tariffs. In our pre-state election survey of members, 63% of respondents were in favour of electricity supply charges being based on the actual cost of supplying electricity, not the volume consumed, while 15% of respondents were opposed. It is important that businesses are given appropriate price signals which enable them to make decisions in the best long term interest of their businesses. 3
4 Notwithstanding, it is crucial for SAPN to manage this transition carefully to ensure consumers, particularly small businesses, have time to adequately adjust where necessary. Businesses are increasingly looking at ways in which to improve energy efficiency and to reduce their reliance on the network at peak times and SAPN s tariff structures need to continually evolve to allow businesses to lower their electricity costs through proactive measures. It is in SAPN s and the business sectors best interest to lower the costs of distributing electricity, but there must be mutually beneficial outcomes. 6. From Business SA s perspective, SAPN is doing a solid job of ensuring electricity distribution in South Australia is reliable, even amongst what are often very trying circumstances. As SAPN acknowledges, it is critical that the focus on electricity reliability across the State be maintained as a foundation for economic growth. In a March 2014 survey of members, Business SA found that 82.1% of respondents were satisfied with the level of electricity reliability provided by SAPN during the summer heatwave. We acknowledge the trying circumstances during this time and commend SAPN for its efforts in managing expectations as best as possible. 7. From Business SA s pre-state election survey of members, 80% of respondents supported investment in a smart grid, including the roll out of smart meters, in order to bring down costs of managing the grid and lower supply charges. We endorse SAPN s focus on smart meter technology within the report and the drive to facilitate further connection of new technologies to advance the two-way network of the future. However, as we have been saying for some time, the introduction of smart meters must enable consumers, including small businesses, to take proactive measures to reduce their electricity costs. Furthermore, while we acknowledge the upfront cost of installing smart meters, we have always understood that they will ultimately reduce the costs of managing the grid, one simple example being the reduced need for manual meter reads. We accept that some of the grid management savings associated with smart meters will only be realised with economies of scale and that the current State Government s New and Replacement Policy may take some time to achieve a high penetration of smart meters. However, any savings that smart meters create for SAPN should be passed back to consumers and we are concerned that the advised small incremental annual cost of installing smart meters will become embedded into the tariff structure. We would also like to understand how SAPN plans to structure their smart meter tariff structure such that retailers can dovetail in with innovative tariff offerings to end users, including small businesses. 8. We recognise that the significant increase in solar PV generation has caused some issues for SAPN in managing the low voltage (LV) network, particularly in specific localised areas. We note that SAPN plans to selectively monitor the LV network and that this would include the installation of voltage monitoring devices at a transformer 4
5 level. While accepting that it will take some time to roll out smart meters in South Australia, Business SA acknowledges that a broad roll out of smart meters should enable SAPN to monitor voltage at an end user level. Perhaps there is a means of installing smart meters in areas with identified low voltage problems as a means to avoid interim expenditure on specific voltage monitoring equipment? Obviously this would be cost dependent and SAPN is best placed to understand those costs, but alternative solutions should at least be considered. We accept that this may require the State Government to amend its proposed New and Replacement Policy for smart meters and consequently we encourage SAPN to work with the State Government to find a solution. 9. We encourage SAPN s aim to adapt to the changing ways in which consumers use the electricity network, including through enabling the installation of battery storage. It is becoming increasingly evident that battery storage will play a major role in reducing consumers reliance on the electricity grid, particularly during peak periods. There are also various options for SAPN to employ storage through its network as an alternative to other forms of capital investment which has begun to occur interstate. We would like to see more detail in the regulatory proposal as to any plans SAPN has for distributed energy storage throughout its network. Furthermore, we acknowledge SAPN s recent announcement that consumers with battery storage will no longer be able to claim solar feed-in-tariff premiums from the State Government. While we accept the technological constraints on cost efficiently delineating energy fed directly into the grid from solar panels, as opposed to coming from a battery, we would like to see an acknowledgement in the regulatory proposal that SAPN will revisit this constraint should the technology become viable. 10. Business SA notes that a significant portion of the increase in SAPN s tariffs for 2014/15 stemmed from the AER decision to allow SAPN to pass through $35 million in additional costs for vegetation management. SAPN advises that it currently spends approximately $40 million per annum on vegetation management with costs driven by highly prescriptive statutory requirements in terms of inspection regimes and clearance zones around power lines and goes onto say that there is a need to move away from a one-size-fits-all approach and work towards a more sustainable and long-term approach that may include strategic removal and tree replacement and improved trimming practices. Business SA supports SAPN s pragmatic approach and suggests that it outlines in its regulatory proposal what legislative changes are necessary to adopt a more efficient approach to vegetation management. At this same time, can SAPN provide details of the likely cost savings from adopting this approach? 11. We acknowledge the good intention of SAPN s focus on addressing road safety hazards from stobie poles and its aim to target busy main roads and intersections with a modest programme of undergrounding works to reduce the potential for vehicle collisions. 5
6 Notwithstanding, issues of road safety relating to stobie poles require analysis much broader than whether or not removing the stobie pole results in an optimal outcome given the impact of accidents potential moving to the next barrier, be that a building, tree or otherwise. However modest SAPN s proposed spending, road safety is ultimately the responsibility of the State Government and SAPN should not spend time or resources on such issues when its costs are ultimately borne by the end users of electricity, including small businesses. Furthermore, consideration should be given to how SAPN access Motor Accident Commission (MAC) funds for such expenditures. 12. We request that for its regulatory proposal, SAPN only provide analysis of price impacts for the distribution charge component of the average residential and the average small business bill, similar to what was provided for the current regulatory proposal. Further to that, we would like to see a forecast of price impacts for each business tariff class. It is important for reasons of transparency that stakeholders know what the likely increases are for costs under SAPN s control without extrapolation of the impacts to the entire bill. For example, on page 9, SAPN asks do you support the overall program of work noting that the expected price impact of the directions and priorities is less than a 1% annual increase in the average residential bill?. In this instance, we could only give a meaningful response about the impact on the distribution part of the average bill. Analysis of impacts on the entire bill, as SAPN points out on page 5, assumes that all other things remain equal. This is more than likely not to be the case and regardless, stakeholders will form their own views on such matters. 13. Business SA supports the upgrade of the Kangaroo Island undersea cable to ensure electricity reliability for this very important part of South Australia s economy. Like all proposed capital expenditure in its regulatory proposal, Business SA reminds SAPN that it should focus on giving local businesses, particularly small businesses, every opportunity to participate in the tender process. This includes consideration of alternative technologies which may not be part of the tender document but which could provide for an optimal outcome. We are encouraged by SAPN s sentiment to support economic growth and stress that this is one of the best opportunities for SAPN to make a real impact on the local economy. 14. We note the significant capital expenditure forecast from 2015 to 2020 on the basis of replacing aging assets. We would expect that an appropriate breakdown of costings per item of capital expenditure will be incorporated into the regulatory proposal and be available to all stakeholders. 6
7 Who we are As South Australia s peak Chamber of Commerce and Industry, Business SA is South Australia s leading business membership organisation. We represent thousands of businesses through direct membership and affiliated industry associations. These businesses come from all industry sectors, ranging in size from micro-business to multinational companies. Business SA advocates on behalf of business to propose legislative, regulatory and policy reforms and programs for sustainable economic growth in South Australia. Should you require any further information or have any questions, please contact Rick Cairney, Director of Policy, Business SA on (08) or rickc@business-sa.com. Yours sincerely Nigel McBride Chief Executive Officer 7
I write in response to your request for feedback on SAPN s electricity tariff reforms. Executive Summary
ABN 14 725 309 328 Level 1, 136 Greenhill Road Unley SA 5061 Telephone (08) 8300 0000 Fax 08 8300 0001 Email customerservice@business-sa.com www.business-sa.com 23 October 2015 Ms Jessica Vonthehoff Communications
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