Independent Pricing and Regulatory Tribunal Audit of Sydney Catchment Authority s Asset Management System Report to the Minister Water Licensing Compliance Report April 2009
Audit of Sydney Catchment Authority s Asset Management System Report to the Minister Water Licensing Compliance Report April 2009
Independent Pricing and Regulatory Tribunal of New South Wales 2009 This work is copyright. The Copyright Act 1968 permits fair dealing for study, research, news reporting, criticism and review. Selected passages, tables or diagrams may be reproduced for such purposes provided acknowledgement of the source is included. ISBN 978-1-921328-82-4 CP-44 The Tribunal members for this review are: Dr Michael Keating, AC, Chairman Mr James Cox, Chief Executive Officer and Full Time Member Ms Sibylle Krieger, Part Time Member Independent Pricing and Regulatory Tribunal of New South Wales PO Box Q290, QVB Post Office NSW 1230 Level 8, 1 Market Street, Sydney NSW 2000 T (02) 9290 8400 F (02) 9290 2061 www.ipart.nsw.gov.au ii IPART Audit of Sydney Catchment Authority s Asset Management System
Contents 1 Introduction and Overview 1 1.1 Background 1 1.2 Audit Process 1 1.3 Audit Scope 2 2 Overview of Findings 2 3 Agreed Actions 5 4 Next Steps 6 Appendices 7 A B Licence clauses relating to SCA s asset management obligation and to auditing the management system of the assets 9 WorleyParsons Services Limited Audit of System Catchment Authority s Asset Management System 14 Audit of Sydney Catchment Authority s Asset Management System IPART iii
1 Introduction and Overview The Independent Pricing and Regulatory Tribunal of New South Wales (IPART) advised the Minister on 30 June 2008 of its intention to conduct an audit of Sydney Catchment Authority s (SCA s) Asset Management System in accordance with the requirements of its operating licence (the licence). IPART has completed the audit with the assistance of the consultant, WorleyParsons Services Limited. The purpose of this report is to inform the Minister for Water of IPART s findings in relation to SCA s performance against its asset management obligation contained in the licence and set out IPART s recommendations in response to these findings. Appendix A sets out those licence clauses relating to SCA s asset management obligation and to auditing the management system of the Assets, comprising parts 7 and 11 of the licence. A copy of the consultant s audit report is provided at Appendix B. 1.1 Background The SCA was established in July 1999 to manage Sydney s water catchment areas and infrastructure within its jurisdiction to improve water quality, protect public health and protect the environment. SCA also has the primary responsibility for supplying bulk water to Sydney Water Corporation and several smaller customers. SCA draws bulk water from the catchments of four major river systems the Warragamba, Upper Nepean, Woronora and Shoalhaven. Clause 7.3 of the licence requires that at least once during the term of the licence, IPART may conduct an audit of SCA s compliance with the asset management provisions in the licence. Accordingly, IPART undertook the audit of SCA s asset management system in concurrence with IPART s review of the Capital and Operational Expenditure of the SCA. The audit concentrated on identifying the asset management systems and practices and the value they provided in SCA s compliance with the licence, the degree to which the systems were utilised and proof of the delivery of the expected value from the systems. To achieve this, IPART s consultant reviewed the implementation of the asset management processes for a representative sample set of assets, randomly selected from SCA s high criticality assets. 1.2 Audit Process The consultant reviewed key documents, held discussions with the relevant asset management personnel, asked supplementary questions and compared SCA s approach to Asset Management with current Australian and international best practice. Audit of Sydney Catchment Authority s Asset Management System IPART 1
In particular, the audit assessed the robustness of SCA s risk-based approach, the use of whole-of-life costing, and the quality and quantity of the underlying data and information used to predict asset lifecycle behaviour. The consultant provided IPART and SCA with a draft report for comment and considered the comments received before finalising their report. 1.3 Audit Scope The audit assessed SCA s compliance with the asset management obligations included in the licence. These include SCA: Ensuring that its assets are managed consistent with: its obligations in the licence and all applicable laws, policies and guidelines, including the requirements of the NSW Dam Safety Committee, the principles of the Strategic Management Framework and the Total Asset Management Policy the lowest lifecycle cost and acceptable risk of the assets its assessment of the risk of loss of the assets, and capacity to respond to a potential failure or reduced performance of the assets. Reporting the state of each group of assets it manages. A summary of the audit findings are listed below. Further details of the assessment of SCA s Asset Management performance are provided in the consultant s report which is included at Appendix B. 2 Overview of Findings It was found that the SCA has achieved overall High Compliance with the asset management obligations in the operating licence. Specifically, IPART found that the SCA: Fully complied with the licence condition to manage its Assets consistent with its obligations in the licence and all applicable laws, policies and guidelines. The audit found that SCA has developed Asset Management Plans in accordance with the NSW Treasury Total Asset Management (TAM) Guidelines 06-01, 06-03 and 06-04. Additionally, SCA met the Bulk Water Supply targets and has dam safety processes certified to ISO14001. 2 IPART Audit of Sydney Catchment Authority s Asset Management System
Achieved High Compliance with the licence condition to ensure that its Assets are managed consistent with the principles of the Strategic Management Framework and the TAM Policy. The audit found that SCA undertakes strategic planning in its asset management and has compiled a Surplus to Needs Assets Report dealing with asset disposal 1. However, the report was dated 2005 and is therefore due for review and update. (Recommendation 1) Achieved High Compliance with the licence conditions to manage its Assets consistent with the lowest life cycle cost and acceptable risk of the Assets, and with the whole of life 2 of the Assets. The audit found that SCA has developed Asset Life Cycle Cost (LCC) Analysis processes for all its assets. The processes include Lifecycle Assessment, Risk Costing, Predictive Analysis and Return on Investment Analysis. Although the LCC steps are in place across each discrete phase of the asset life cycle (comprising planning, acquisition, operate, maintain and disposal), there is no evidence of a fully integrated LCC plan that would demonstrate the lowest LCC. (Recommendation 2) Achieved High Compliance with the licence condition to demonstrate consideration of the risk of loss of the Assets and capacity to respond to a potential failure or reduced performance of the Assets. The audit found that SCA applies a risk management process based on AS4360 principles for asset criticality ratings and condition assessment. The identification and classification of risk and allocation of asset criticality for risk treatment is considered best practice. This is evidenced through SCA s high performance rating in the Water Services Association of Australia (WSAA) 2008 Asset Benchmarking report. However, SCA is yet to implement the WSAA 2008 Benchmarking recommendation of progressing towards a corporate wide software system (Risk Management Information System) to contain and manage its corporate risks. (Recommendation 3) Achieved High Compliance with the licence condition to provide information to IPART on the state of each group of assets managed by the SCA, including how the SCA satisfies its licence conditions and legal obligations relating to asset management. However, the documentation did not contain details of how the documents and processes satisfy the legislative requirements. Additionally, the information was not consolidated into one report. (Recommendation 4) 1 TAM 06-04 (Asset Disposal Strategic Planning) broadly details asset disposal planning, which involves detailed assessment of assets identified as surplus to needs (not required or unsuitable for service delivery, or uneconomical to operate) in the Asset Strategy, followed by an analysis of the physical disposal of the assets. 2 Whole-of-life (WOL) cost refers to the total cost of ownership over the life of an asset. For some assets a balanced view between maintenance strategies and renewal/rehabilitation is required. The WOL asset cost assessment is based on the performance expected of the asset, the consequences and probabilities of failures occurring, and the level of expenditure in maintenance to keep the service available and to avert disaster. Audit of Sydney Catchment Authority s Asset Management System IPART 3
Achieved High Compliance with the licence condition to report to IPART on the processes, practices, systems and plans for managing its Assets, and on the progress of implementing these processes, systems and plans. The audit found that SCA is in the process of implementing a Maintenance Outcomes Hierarchy 3 comprising a complete suite of processes and tools for asset management, from condition monitoring and the documentation of individual assets to return on investment analysis. However, there was no evidence that SCA had developed a documented plan for the full implementation of the Maintenance Outcomes Hierarchy that included: timelines for the key stages of the Maintenance Outcomes Hierarchy systems in its reporting mechanism, and identification of assets for which there is no value in implementing all aspects of the asset management processes. (Recommendation 5) Achieved Full Compliance with the licence condition to provide IPART with a description of each group of assets. Achieved High Compliance with the licence condition to report to IPART on the assessment of the expected capability of SCA s Assets to deliver the required services, and on information relating to the strategies and expected costs of future investments in the Assets. The audit found that the funding level for maintenance recorded in the Annual Information Return to IPART dated September 2008 was lower than that required by the SCA s Asset Strategy dated January 2008. Although SCA has provided explanation for the majority of the variation in maintenance cost estimates and evidence of the review of its capital expenditure plan, it did not provide evidence of changes made to the original asset management driven investment as a consequence of the review. (Recommendations 6 and 7) Achieved High Compliance with the licence condition to provide IPART with an assessment of the major issues or constraints on current and future performance of the Assets. The audit found that SCA has identified and captured forward planning issues in reports, and are working towards implementing improvement actions identified. However, inconsistency exists in the documentation (between the Annual Information Return provided to IPART dated September 2008 and SCA s Asset Strategy dated January 2008) as explained above. (Recommendations 6 and 7) 3 A set of systems that together satisfy Stage 6 of the NSW Treasury TAM Guideline 06-03, which requires the SCA to implement maintenance plans and programs. 4 IPART Audit of Sydney Catchment Authority s Asset Management System
3 Agreed Actions The audit has identified a number of actions that would further enhance SCA s strong compliance in this area. These actions have been discussed with SCA and the following actions have been agreed. SCA will: 1. Review and update the Surplus to Needs Assets Plan (2005) using current asset strategy information (this was last completed in 2005). 2. Develop a Life Cycle Cost (LCC) methodology by 1 September 2010 to differentiate which asset classes will be subject to the full implementation of the Maintenance Outcomes Hierarchy. IPART acknowledges that a fully integrated LCC plan may not be as relevant for managing long lived, large scale assets such as the Warragamba dam. For this reason, it was agreed that the SCA should develop and provide IPART with a LCC methodology that examines the risk and the asset value thresholds for which the Maintenance Outcomes Hierarchy is applicable to its assets. This will provide confidence to the stakeholders that SCA s asset investment is prudent and will deliver the right balance of service and value for money. 3. Act on the Water Services Association of Australia (WSAA) 2008 Asset Management Benchmarking recommendation to implement a corporate wide Risk Management Information System to better understand and control its business risks, improve tracking and reporting and to facilitate workflow management of identified risks. 4. Provide a matrix document that will serve as a guide for the state of the Assets information required under licence condition 7.2. SCA has provided a number of documents during the audit that together provide information to IPART on the state of each group of Assets managed by the SCA. To assist future audits of this area and SCA s compliance generally, it has been agreed that SCA will prepare a matrix document so that all of this information can be readily assessed. IPART considers that provision of such document will achieve the same outcomes as a consolidated report (which was recommended by WorleyParsons) without the additional regulatory costs associated with preparing a separate consolidated report. 5. Set timeframes and accountabilities for the key stages of the Maintenance Outcomes Hierarchy systems and report progress against these targets to the Asset Management Committee. This will facilitate full implementation of the Maintenance Outcomes Hierarchy which is used to implement maintenance plans and programs as required by the NSW Treasury Total Asset Management Guideline 06-03. 6. Update the expenditure forecasts in the Asset Strategy to reflect SCA s current assessment of forward expenditure requirements. This will eliminate inconsistency between the Asset Strategy dated January 2008 and the Annual Information Return to IPART dated September 2008. Audit of Sydney Catchment Authority s Asset Management System IPART 5
7. Fully implement the Maintenance Outcomes Hierarchy to assist in the documentation of the optimum forward asset investment requirements. This will provide the elements of and information for lowest lifecycle cost decisions in managing SCA s assets. 4 Next Steps IPART will continue to monitor and report SCA s compliance with the obligations under the operating licence. As part of this process, IPART will request SCA to provide it with a report on its progress in implementing the agreed actions by 1 September 2010. 6 IPART Audit of Sydney Catchment Authority s Asset Management System
Appendices Audit of Sydney Catchment Authority s Asset Management System IPART 7
8 IPART Audit of Sydney Catchment Authority s Asset Management System
A Licence clauses relating to SCA s asset management obligation and to auditing the management system of the assets Part 7 Asset management 7.1 Asset management obligation The SCA must ensure that its Assets are managed consistent with: a) its obligations in the Licence, and all applicable laws, policies and guidelines with which the SCA must comply, including the requirements of the NSW Dams Safety Committee; b) the principles of the Strategic Management Framework and the Total Asset Management Policy; c) subject to clause 7.1(a), the lowest lifecycle cost and acceptable risk of the Assets; d) the whole of life of the Assets; and e) its assessment of the risk of loss of the Assets, and capacity to respond to a potential failure or reduced performance of the Assets. 7.2 Reporting on the management system of the Assets 7.2.1 At least once during the term of the Licence at a time agreed with IPART, the SCA must provide information to IPART on the state of each group of Assets managed by the SCA. 7.2.2 The information provided must include the following: a) a description of the processes, practices, systems and plans the SCA uses in managing the Assets; b) a description of each group of Assets; c) an assessment of the expected capability of the assets to deliver the services required to be delivered by the SCA and meet the existing obligations of the SCA consistent with the Licence and all applicable laws with which the SCA must comply; d) an assessment of the major issues or constraints on current and future performance of the Assets; e) the strategies and expected costs of future investments in the Assets; f) progress in implementing the management of the SCA s Assets and any recommended improvements in processes, practices, systems and plans for the management of the Assets; and g) such other information reasonably required by IPART. Audit of Sydney Catchment Authority s Asset Management System IPART 9
7.3 Auditing the management system of the Assets 7.3.1 At least once during the Licence, IPART may (at a time it determines) conduct an audit of SCA s compliance with clauses 7.1 and 7.2. The audit may form part of an Annual Audit or be conducted separately from an Annual Audit, at the discretion of IPART. 7.3.2 In addition, IPART may at any time audit the SCA s compliance with clauses 7.1 and 7.2 for the purpose of: a) investigating and reporting on, or reviewing the pricing of SCA s bulk water services under the Independent Pricing and Regulatory Tribunal Act 1992; or b) investigating compliance by SCA with specific areas of its Asset management. 7.3.3 An audit undertaken under clause 7.3.1 or 7.3.2, must comply with the scope and audit specifications determined by IPART. 7.3.4 The provisions of Part 11 apply to an audit under clause 7.3 as if the audit under clause 7.3 is an Annual audit. 7.3.5 IPART must advise the Minister of its decision to conduct an audit under clause 7.3.1 or 7.3.2 and, subsequent to the audit, provide the Minister with a report on the outcomes of the audit. 10 IPART Audit of Sydney Catchment Authority s Asset Management System
Part 11 Annual Audit of the Licence 11.1 Commission of audits 11.1.1 IPART must initiate an operational audit of the SCA as soon as practicable after 30 June each year covering the preceding financial year, as required by this Part 11 (the Annual Audit). 11.1.2 The Annual Audit must be conducted by IPART or by a person that IPART considers is suitably qualified to perform the Annual Audit. 11.1.3 As part of the Annual Audit, IPART must invite members of the public to make submissions to it. IPART may also undertake any other Public Consultation it considers appropriate. 11.1.4 IPART may include in its Annual Audit all or any of the matters referred to in clause 11.2 and where in any Annual Audit a matter is not made the subject of that Annual Audit, IPART may require the SCA to provide IPART with a report on the matter not included in the Annual Audit. 11.2 What the audit is to report on 11.2.1 IPART or the person undertaking the Annual Audit may investigate and prepare a report on any or all of the following: a) compliance by the SCA with its obligations in each of Parts 3, 4, 5, 6, 7, 8 and 9; b) the SCA s compliance with its obligations under each Memorandum of Understanding referred to in clause 2.3; and c) any other matter required by the Licence, the Act or administrative direction to be assessed and considered as part of the Annual Audit. 11.2.2 Despite clause 11.2.1, neither IPART nor the person undertaking the Annual Audit may investigate a matter under clause 11.2.1 if the investigation of that matter is ordinarily within the regulatory activities of DEC, NSW Health or DNR and the relevant agency has undertaken an investigation of the matter. 11.2.3 Nothing in this Part 11 restricts the capacity of IPART, as part of the Annual Audit from: a) satisfying the requirement in clause 11.2.1 to investigate and prepare a report on a matter under clause 11.2.1 by including in its report consideration of the findings and the SCA s response to those findings, of any investigation of the matter by DEC, NSW Health or DNR; and b) requesting the SCA to provide information relating to an investigation of a matter by DEC, NSW Health or DNR which is ordinarily within the regulatory activities of those agencies. Audit of Sydney Catchment Authority s Asset Management System IPART 11
11.2.4 IPART must ensure that, subject to clause 11.2.2, the report of the Annual Audit addresses the matters in clause 11.2.1 and advises the Minister on the following matters: a) areas in which the SCA s performance under the Licence may be improved; b) any changes to the Licence that IPART considers necessary; c) any penalties or remedial action required as a result of the SCA s performance under the Licence; d) whether the Minister should recommend that the SCA s Licence be cancelled by the Governor under section 30 of the Act for reasons identified in the report of the Annual Audit; and e) any other matter relating to the Annual Audit or the SCA s Functions that it considers appropriate. 11.3 Reporting of audit 11.3.1 IPART must ensure that the report of the Annual Audit is presented to the Minister within 1 month after its receipt by IPART. 11.3.2 If the report of the Annual Audit has identified areas of non-compliance with the Licence, in addition to whatever other action is taken or required to be taken, the SCA must comply with any requirement that may be imposed on the SCA by the Minister to do the following: a) advertise publicly and notify Customers of the areas of the non-compliance; b) provide reasons for the non-compliance; c) identify the measures that will be taken by the SCA to address the noncompliance; and d) provide such other advice concerning the non-compliance as is requested by the Minister. 11.4 Additional audits 11.4.1 IPART must initiate additional audits of the SCA if required by the Minister. 11.4.2 An additional audit may address one or more of the matters in clause 11.2.1 or any other matter required by the Minister. 11.4.3 The provisions of this Part 11 applying to the Annual Audit will apply equally to additional audits under clause 11.4.1 (all necessary changes having been made), to the extent that those provisions are relevant. 12 IPART Audit of Sydney Catchment Authority s Asset Management System
11.5 Provision of information 11.5.1 The SCA must provide IPART (or a person appointed by IPART under clause 11.1.2) with all information within its possession or under its control necessary to the conduct of the Annual Audit or an additional audit, including whatever information is requested in writing by IPART or the person appointed by IPART. 11.5.2 The information sought under clause 11.5.1 must be made available within a reasonable time of it being requested. 11.5.3 For the purposes of the Annual Audit or an additional audit under clause 11.4.1, the SCA must, within a reasonable time of being required by IPART (or the person appointed by IPART), permit IPART (or the person appointed): a) to have access to any works, premises or offices occupied by the SCA; b) to carry out inspections, measurements and tests on, or in relation to, any such works, premises or offices; c) to take on to or into any such premises, works or offices any other persons or equipment as necessary for the purposes of performing the audit; d) to inspect and make copies of, and take extracts from, any books and records of the SCA that are maintained in relation to the performance of the SCA s obligations under the Licence; and e) to discuss matters relevant to the audit with the SCA s employees. 11.5.4 If the SCA contracts out any of its activities to third parties (including a subsidiary) it must take all reasonable steps to ensure that, if required by IPART, any such third parties provide information and do the things specified in Part 11 that extend to the SCA as if that third party were the SCA. 11.5.5 For the purpose of an Annual Audit or an additional audit under clause 11.4.1, the information to be provided by the SCA or a third party under clause 11.5.1 may include information over which the SCA or a third party claims confidentiality or privilege. IPART (or the person appointed by IPART) must (if required) enter into reasonable arrangements with the SCA or such third party to ensure that the confidential information or privileged information is kept confidential or privileged. [Note: This clause is limited by section 24FF and section 25A of the Independent Pricing and Regulatory Tribunal Act 1992 (IPART Act). For example: if IPART is advised by the SCA that the information provided by it is confidential, section 24FF of the IPART Act sets out the manner in which IPART is to deal with that information; or under section 25A of the IPART Act, IPART cannot require the SCA to produce a cabinet document.] Audit of Sydney Catchment Authority s Asset Management System IPART 13
B WorleyParsons Services Limited Audit of System Catchment Authority s Asset Management System 14 IPART Audit of Sydney Catchment Authority s Asset Management System
Audit of Sydney Catchment Authority's Asset Management System 301015-00417 - 00-GE-RPT-0002 27-Feb-09 Infrastructure Level 12, 333 CollinsStreet Melbourne Vic 3000 Australia Telephone: +61 3 8676 3500 Facsimile: +61 3 8676 3505 www.worleyparsons.com WorleyParsons Services Pty Ltd ABN 61 001 279 812 Copyright 2009 WorleyParsons Services Pty Ltd
SYNOPSIS This report presents the findings of an audit of the Sydney Catchment Authority s Asset Management. It specifically considers the degree of compliance of the Sydney Catchment Authority Asset Management with the requirements of clauses 7.1 and 7.2 of the authorities Operating Licence... Disclaimer This report has been prepared on behalf of and for the exclusive use of IPART, and is subject to and issued in accordance with the agreement between the IPART and WorleyParsons Services Pty Ltd. WorleyParsons Services Pty Ltd accepts no liability or responsibility whatsoever for it in respect of any use of or reliance upon this report by any third party. Copying this report without the permission of IPART or WorleyParsons Services Pty Ltd is not permitted. 301015-00417-00-GE-RPT-0002 - AUDIT OF SYDNEY CATCHMENT AUTHORITY'S ASSET MANAGEMENT SYSTEM REV DESCRIPTION ORIG REVIEW WORLEY- PARSONS APPROVAL DATE CLIENT APPROVAL DATE A Outline Draft [ ] S Wise [ C Berberich [ ] P Draayers 2-Oct-08 B Amended Draft Issued for Internal Review [ ] S Wise [ C Berberich [ ] P Draayers 31-Oct-08 C Amended Draft - Issued for IPART Review [ ] S Wise [ C Berberich [ ] P Draayers 7-Nov-08 0 Issue to client 1 Minor modifications 2 Minor modifications S Wise C Berberich P Draayers S Wise C Berberich P Draayers C Berberich S Wise P Draayers 9-Jan-09 18-Feb-09 27-Feb-09 c:\documents and settings\carsten.berberich\my documents\worleyparsons\301015 00413 ipart\sca assessment 2008\report\finalisation\2009 versions incorporating final ipart comments\clean\ipart am report round 2\00417_00_ge_rpt_0002_rev2 sca am audit clean2.doc Page ii
CONTENTS GLOSSARY/DEFINITIONS...6 Abbreviations...6 Glossary/Definitions...7 Compliance Table Assessment...7 EXECUTIVE SUMMARY...8 1. INTRODUCTION...11 1.1 Background...11 1.2 Sydney Catchment Authority...11 1.2.1 SCA s Purpose...11 1.2.2 Regulatory Framework...12 1.3 Asset Management Issues Identified in Previous Reviews/Audits...12 1.4 Approach to this Asset Management Audit...13 1.5 Scope of Services of this Audit...14 2. METHODOLOGY...15 2.1 Overview...15 2.2 Draft Audit Plan...15 2.3 SCA Audit Interviews...16 2.4 Conduct of the Audit...16 2.5 Audit Team...16 2.6 SCA Asset Management Key Performance Indicators (KPIs)...17 2.7 Verification/Proof of Performance...17 3. SCA S ASSET MANAGEMENT PLAN...19 3.1 Introduction...19 3.2 Reference Documents for the Audit...19 3.3 SCA Asset Management Framework...23 3.3.1 Regulatory Requirements...23 c:\documents and settings\carsten.berberich\my documents\worleyparsons\301015 00413 ipart\sca assessment 2008\report\finalisation\2009 versions incorporating final ipart comments\clean\ipart am report round 2\00417_00_ge_rpt_0002_rev2 sca am audit clean2.doc Page 3
3.3.2 Key Performance Indicators...24 4. AUDIT FINDINGS BY SECTION...27 4.1 Operating Licence Clause 7.1 Compliance with Asset Management Obligations...27 4.1.1 Clause 7.1(a) Compliance with Regulatory Obligations...27 4.1.2 Clause 7.1(b) Compliance with Strategic Management Framework and TAM Policy 28 4.1.3 Clause 7.1(c) Compliance with Lowest Life Cycle Cost (LCC) and Acceptable Asset Risk 31 4.1.4 Clause 7.1(d) Demonstration of Whole Of Life (WOL) Asset Cost Assessment.32 4.1.5 Clause 7.1(e) Demonstration of Asset Risk Assessment (Loss, Capacity to Respond to a Potential Failure or Reduced Performance)...34 4.2 Operating Licence Clause 7.2 Compliance with Management System: Reporting on Assets...35 4.2.1 Clause 7.2.1 State of the Asset Report Submission...35 4.2.2 Clause 7.2.2(a) Description of SCA Asset Management Processes, Practices, Systems and Plans...37 4.2.3 Clause 7.2.2(b) Description of SCA Asset Groupings...37 4.2.4 Clause 7.2.2(c) Description of SCA Asset Capability to Meet Service Delivery and Existing Legal Obligations...38 4.2.5 Clause 7.2.2(d) Assessment of SCA Asset Current and Future Performance Issues or Constraints...39 4.2.6 Clause 7.2.2(e) Assessment of SCA Strategies and Expected Future Asset Investment Cost...41 4.2.7 Clause 7.2.2(f) Assessment of SCA progress in implementing asset management and any recommended Improvements...43 4.2.8 Clause 7.2.2(g) Assessment of any Other SCA Asset Management Information Required by IPART...45 5. CONCLUDING REMARKS...51 c:\documents and settings\carsten.berberich\my documents\worleyparsons\301015 00413 ipart\sca assessment 2008\report\finalisation\2009 versions incorporating final ipart comments\clean\ipart am report round 2\00417_00_ge_rpt_0002_rev2 sca am audit clean2.doc Page 4