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Evolution of DNO Regulation in the UK Tooraj Jamasb Durham University Business School and Durham Energy Institute (DEI) [email protected] Regulation Workshop, Indian Institute of Technology Kanpur Kanpur, May 2019 Supported by 1

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Page 1: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Evolution of DNO Regulation in the UKTooraj Jamasb

Durham University Business School

and

Durham Energy Institute (DEI)

[email protected]

Regulation Workshop, Indian Institute of Technology

Kanpur Kanpur, May 2019

Supported by

1

Page 2: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

2

Outline

Background

Example of a distribution price control review

Performance of regulation in early years

A view into the future

Lessons of experience

Page 3: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

DNO Regulation in the UK:Background

3

Page 4: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

UK Experience in Regulated Industries (date of second price control period)

4

Telecoms (1989)

Gas (1992) Electricity Transmission (1993) Electricity Distribution (1995)

Water (1995) Rail (2000) Airports (from 2003) Postal Services (from 2006)

Page 5: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

First electricity companies in late 1880s

Early incentive regulation models

Municipal and private firms the norm

1933-34: 635 utilities 19 systems

1947: 569 DISCOs at nationalisation

Consolidation and standardisation of the industry5

The British Sector – History

Page 6: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

RECs privatised 1990

NGC shares sold 1995

Golden share lifted 1995 - takeovers begin

Separation of supply businesses - 1999

The UK ESI: Background

6

Page 7: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

DNO Activities (Ofgem)

7

Network asset ownership

Secondary system assets ownership

Approval of new connections

Realisation of new connections

Network maintenance

Secondary system maintenance

Network operation

Asset management

Secondary system asset management

Customer services

Metering

Corporate activities

Page 8: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Distribution Price Controls in Britain

8

Year England and Wales Scotland

April 1990-arch 1995Post privatisation price

control

Post privatisation price

control

Aprial 1995-March 1996 DPCR1

April 1996-March 2000DPCR2 after Offer reopened

the price review in 1995

April 2000-March 2005DPCR3 after merger of the regulatory process for all British

distribution companies

April 2005-March 2010 DPCR4

April 2010-March 2015 DPCR5

April 2015-March 2023 RIIO-ED1

Source: Meeus and Glachant (2018)

Page 9: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

1990-91 to 1994-95: variable up to 2.5% above the inflation rate

1995 to 1995-96: 11-17% (average of 14%)

1996 to 1996-97: 10-13%

1997 to April 2000: average of 3% p.a.

2000 to 2004-05: one-off cut in distribution revenue by 23.4% in 2000-01; then a 3% p.a. fall in unit revenue until 2005

Distribution Price Controlsin the UK (X-factors)

9

Page 10: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Operating expenditures: Benchmarking

Capital expenditures: Assessment of spending and menu of contracts

Quality of service: Performance targetso Number of interruptionso Length of interruptions

Energy losses: Composite performance standard

10

Elements of Incentive Regulation of Electricity Networks in Britain

Page 11: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Initial consultation document issued 18 months before end of current price control period

Several subsequent documents with responses invited each time. Responses placed in library unless marked confidential

Final document within 6 months of end of current control period

Company has a month to appeal to competition authority (MMC/CC) if unhappy with proposals at this stage

Basic Characteristics of OFFER/OfGEM Approach

11

Page 12: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

June 2004 - Initial proposals

September 2004 - Update document

November 2004 - Final proposals

December 2004 - DNOs decide to accept/reject proposals

Early 2005 - License modifications or referral to Competition Commission

April 2005 - New price controls implemented

12

DPCR4 (2005-2010)

Page 13: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

‘Much of the political debate now centres around distributional issues, focussing on allegations that consumers have not received a sufficient share of the benefits....

...Because the UK system depends on independent regulators who have used their (typically British) discretion to develop a variety of regulatory review procedures, they display considerable variation in using productivity studies...’ (p.11)

13

Waddams (EWEPA, 1999)

Page 14: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

‘The overwhelming impression of regulatory and governance case studies is that sample size, variable choice, model specification and choice of methodology has been governed by different objectives from those in the theoretical literature.’ (p.25)

14

Weyman-Jones (NAPW, 2006)

Page 15: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Best to see process as involving ‘interactive preference target setting’ (Thanassoulis et al, 2008)

A negotiation (Beesley and Littlechild, 1989)

Competition Commission (CC) is an external restraint on use of regulatory models

Mid Kent Water appealed against price control on basis of non-use of panel data. CC (2000) ruled difficult to decide between models

CC has power to condemn approach of regulators (e.g. Ofgemon value of comparators)

Price Review Process in the UK

15

Page 16: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

GB regulator uses a range of techniques No over emphasis on one method

Detailed cost analysis is important

Lack of transparency in GB over data and methods

However consultation and co-operation is high

Norwegian regulator relies heavily on DEA Data accuracy checked carefully

DEA scores checked and scaled down for X setting

Norway has a lot of utilities for benchmarking

Moving away from pure DEA approach next time

Conclusions

16

Page 17: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Performance of DCPRs:Initial Years

17

Page 18: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Sources of Price Reduction to Domestic Users 1991/92-1998/99

Source %

Lower generation costs (mainly fuel) 10

Lower distribution and transmission charges 9

Lower supply business margin 1

Lower fossil fuel levy* 9

Total 29

* The fossil fuel levy was introduced to limit the effect of reform of the sector

on coal industry. The levy was gradually phased out. Price reduction due

to lower levy can therefore not be attributed to the effect of reform on

prices.

18Source: Littlechild (2000)

Page 19: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Partial evidence Electricity prices

Access charges

Quality of service

Network losses

Investments

Competitiveness/affordability

Efficiency and productivity analysis

Cost-benefit analysis

19

Performance of Distribution Network Regulation

Page 20: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Electricity Price Development

20

40.0

60.0

80.0

100.0

120.0

140.0

160.0

1970 1975 1980 1985 1990 1995 2000 2005

Electricity component of the retail

prices index in real terms 1990=100

Electricity fuel price index for the

industrial sector in real terms 1990=100

Source: Department of Trade and Industry

Page 21: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Distribution Access Charges

Domestic unrestricted charges (2005/06 prices)

0.0

0.5

1.0

1.5

2.0

2.5

1990/91 1992/93 1994/95 1996/97 1998/99 2000/01 2002/03 2004/05

Un

it c

har

ge

p/K

Wh

0

2

4

6

8

10

12

Fix

ed c

har

ge

p/M

PA

N/d

ay

Unit charge Fixed charge

Domestic Economy 7 charges (2005/06 prices)

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

1990/91 1992/93 1994/95 1996/97 1998/99 2000/01 2002/03 2004/05

Pea

k a

nd

off

pea

k p

/KW

h

0

2

4

6

8

10

12

14

16

Fix

ed c

har

ge

p/M

PA

N/d

ay

Peak charge Offpeak charge Fixed charge

Non-domestic unrestricted (2005/06 prices)

0.0

0.5

1.0

1.5

2.0

2.5

1998/99 1999/00 2000/01 2001/02 2002/03 2003/04 2004/05 2005/06

Unit c

harg

e p

/MP

AN

/day

0

1

2

3

4

5

6

7

8

9

10

Fix

ed c

harg

e p

/KW

h

Unit charge Fixed charge

Non-domestic Economy 7 charges(2005-06 prices)

0

1

1

2

2

3

1998/99 1999/00 2000/01 2001/02 2002/03 2003/04 2004/05 2005/06

Peak a

nd o

ff-p

eak p

/MP

AN

/day

0

2

4

6

8

10

12

14

Fix

ed

ch

arg

e p

/KW

h

Peak charge Offpeak charge Fixed charge

21

Page 22: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

22

Cost vs. Quality of Service Benchmarking

0

2

4

6

8

10

12

14

16

Opex Totex Quality Totex-Quality

Average annual company rankings from Models Opex, Totex, Quality and Totex-Quality (1 is best, 14 is worst) 1991/92-1998/99

Page 23: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

IncentiveArrangement

DPCR3 DPCR4

Interruption incentive scheme:- Duration of interruptions- Number of interruptions

+/-1.25%+/-0.5%

+/-1.8%+/-1.2%

Storm compensation arrangements

-1% -2%

Other standards of performance Uncapped Uncapped

Quality of telephone response +/- 0.125% +0.05% to -0.25%

Quality of telephone response in storm conditions

+/- 0.125%0 initially+/-0.25% for 3 years

Discretionary reward scheme Not applicable Up to + 1m pounds

Overall cap/total +2% to -2.875%4% on downsideNo overall cap on upside

23

Revenue Exposure to Quality of Service

Page 24: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Quality of Service Performance

24

0

20

40

60

80

100

120

91/9

2

92/9

3

93/9

4

94/9

5

95/9

6

96/9

7

97/9

8

98/9

9

99/0

0

00/0

1

01/0

2

02/0

3

03/0

4

04/0

5

Inte

rruptions p

er

100 c

usto

mers

For some DNOs substantial changes were made for accuracy as new measurement systems were

introduced

0

20

40

60

80

100

120

91

/92

92

/93

93

/94

94

/95

95

/96

96

/97

97

/98

98

/99

99

/00

00

/01

01

/02

02

/03

03

/04

04

/05

Min

ute

s lo

st p

er

co

nn

ecte

d c

usto

me

r For some DNOs substantial changes were made for accuracy as new measurement systems

were introduced in the course of 2001/02

Average number of minutes lost per connected customer

Average number of interruptions per 100 customers

Source: Ofgem

Page 25: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

25

Network Energy Losses

5.0%

5.5%

6.0%

6.5%

7.0%

7.5%

8.0%

1990-

91

1991-

92

1992-

93

1993-

94

1994-

95

1995-

96

1996-

97

1997-

98

1998-

99

1999-

00

2000-

01

2001-

02

2002-

03

2003-

04

..

Distribution losses in the UK as % of energy deliveredSource: Ofgem

Page 26: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

26

Capital Investments in Electricity Distribution Networks

0

500

1000

1500

2000

2500

3000

60

/61

62

/63

64

/65

66

/67

68

/69

70

/71

72

/73

74

/75

76

/77

78

/79

80

/81

82

/83

84

/85

86

/87

88

/89

90

/91

92

/93

94

/95

96

/97

98

/99

00

/01

02

/03

Year

Cap

ex

m, 9

7/9

8 p

ric

es

)

Page 27: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

End-use price (lower)

Network access charge (lower)

Quality of service (higher)

Investments (sufficient)

Competitiveness (higher)

Affordability (higher)

27

Performance of Incentive Regulation

Page 28: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

UK DNOs: From 2000 to 2019

28

Page 29: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

A Look into Future Regulation

29

Page 30: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Future Network Regulation

30

Ends Investment efficiency

Smart grids

o Large scale renewable

o Active demand

o Local solutions

Smart meters

Quality of service

Network losses

Security of supply

Fuel poverty

Innovation

Means New models of regulation

o Benchmarking

o Incentives

o Access charging

New R&D arrangements

Use of competition and marketo “competition for markets” vs.

o “competition in markets”

Reorganise existing institutional responsibilities

Page 31: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Need to evolve as performance gap closes

Not useful as forward looking tools –o e.g. investment, innovation

New benchmarking methodso Sweden, UK (RPI@20), Peru, …

Some use of norm models?

31

Search for New Regulation

Page 32: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

The use of auctions in investments

Negotiated settlements

Consumer engagement

Academic advisory panels

32

Some New Regulation Ideas

Page 33: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Tension between market-driven power sector and climate policy objectives o Something may have to give in

New conceptions of consumer as: Load, customer, citizens, …

Low-probability high-impact events

High-level economic conditions

33

Contextual Factors to Watch

Page 34: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Companies activities should be customer-oriented and focus on:

o Outputs to improve services to network users

o Incentives for cost reduction

o Innovation in order to provide new services and cost reduction in the long run …

34

RIIO: Revenue-Incentive-Innovation-Output

Source: Meeus and Glachant (2018)

Page 35: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Outputs in RIIO

Output Categories

Customer satisfaction

Reliability and availability

Safety

Conditions for connection

Environmental impact

Social obligations

Criteria for Outputs

Material

Controllable

Measurable

Comparable

Applicable

Compatible with promotion of competition and compliant with legislation

35

Source: Meeus and Glachant (2018)

Page 36: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Incentive regulation and the wider reform Reform implementation Legislation and independent regulation Unbundling and ring-fencing distribution

Quality of service Information and data requirement Number of networks and priorities

Economies of scale and rationalisation Regulation for future electricity systems Ensure that benefits of reform are accrued to customers

36

Some Lessons of Experience

Page 37: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Thank you!

37

Page 38: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Main differences between RIIO-1 and RIIO-2

38

Incentive

mechanismRIIO-1 RIIO-2

Rational for

change/Possible impact

Length of price

control8 years 5 years

Rational: Reduces risk of setting too high/low

allowances ex-ante due to asymmetry of

information

Possible impact: Might impact expenditure on

innovation as shorter time period to recover cost

of any investment

Totex incentive

mechanisms

Information Quality Incentive

(IQI)- consisting of an upfront

penalty/reward

None

Rational: incentive did not operate as intended

possibly due to assumptions on which it is based

not holding in reality

Sharing factors (ranged from

47%-70%)- each company had a

different sharing factor

determined by the IQI

Blended sharing factor (15-50%) derived as

average of sharing factors assigned to

different cost categories based on historical

cost information

Rational: from initial analysis it does not appear

to be any relationship between sharing factors

and how much companies underspent the totex

allowances in RIIO-1. It makes therefore harder to

justify a higher sharing factor

Incentive on

business plans

Fast-tracking – early settlement

of the price control. Companies

received the highest sharing

factor available (without going

through the IQI process). An

additional upfront reward

equivalent of 2.5% of totex

Business plan Incentive- upfront

reward/penalty equivalent to a maximum of

+/- 2% of totex with competed pot of money.

Rational: provide companies with an additional

incentive to reward effort for ambitious service

quality and cost targets. Also intended as reward

for specific information that might be revealed

and used for other companies in the same sector

(eg better understanding of risks, uncertainty,

particularly those that do not go in favour of

regulated companies)

Possible impact: from feedback received from

companies, proposed size of reward might not

be enough to incentive participation and effort.

Page 39: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

39

Incentive

mechanismRIIO-1 RIIO-2

Rational for

change/Possible impact

Output delivery

incentives

Targets for different output set

ex-ante for the entire RIIO

period.

Dynamic targets which might change

throughout the RIIO-2 period

depending on relative performance

Rational: Targets were achieved early in RIIO-1.

Proposal for RIIO-2 removes risks associated with

setting outputs at a low level by maintaining flexibility

to increase targets for these outputs over time

Innovation

Innovation stimulus provided

as part of the price control

through three mechanisms:

1) Annual Innovation

Competition- worth

$500m over RIIO-1

2) Network Innovation

allowance awarded to

each company (0.5-0.7%

of each company’s

allowed

revenues≈$500m over

RIIO-1)

3) Innovation Roll-out

mechanism –funding to

enable transition of

innovation into business

as usual

Remove 2) and 3). Companies should

use totex allowance to finance

innovation projects

Replace 1) with a new pot focussed on

big strategic innovation challenges

and open to third parties

Rational: evidence that 2) has been used to finance

operational and maintenance works which should

have been funded through the totex allowance.

Difficult to track benefits achieved from these type of

projects

Possible impact: More operational and maintenance

works funded by totex for those innovations close to

transition into BAU. Might reduce scope for

innovation for innovation at early stage of

development. Complexity on governance on new

form of 1) might further reduce scope for innovation

when at early stage

Page 40: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

40

Incentive

mechanismRIIO-1 RIIO-2

Rational for

change/Possible impact

Allowance for

cost of equity6-7% (real terms) 3-4% (real terms)

Rational: Align allowed cost of equity with risk

faced by regulated network companies and to

account for expectations of outperformance due to

asymmetric of information

Possible impact: Likely to reduce overall return on

regulated equity but it might affect cost capital in

future

Asset resilienceSome measures included in

RIIO-1

Enhancement of previous measures

to further constrain companies’

ability to cut expenditure on asset

maintenance.

Rational: No possibility of underspending cost

allowances by deteriorating health of assets.

Return

adjustment

mechanisms

None

Considering company specific

sculpting for ET and GT and anchoring

for GD if return deviate ±3%.

Rational: protect consumers against excessive

returns which result from information asymmetry

faced by regulator in setting level of revenues.

Protecting investors from downside risk

Possible impact: Might distort companies

incentives in terms of efforts to achieve higher

return and affect totex submission

Cash flow floor None Introduction of cash flow floor Rational: protect debt investors from downsize risk

Page 41: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

41

Relationship of quality, efficiency and firm size

Subadditivity in network industries:

Supplied energy

Costs

Connected customers0

C(Y1)

C(Y1+Y2)

C(Y2)

Joint service

)()(

11

m

i

im

i

i YCYC

Efficiency rises with firm size

Page 42: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Kjølle (2002)42

Page 43: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Availability and reliability of service is of great economic value

A clean energy source at consumption – but related to a variety of environmental aspects at production

Homogenous product

Non-storable – supply and demand matched continuously and instantaneously

Capital intensive industry

Large sunk costs

Long economic life of assets43

Electricity

Page 44: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Generation: Production and conversion of electric energy

Transmission: Transportation of electricity at high voltage over long distances

Distribution: Transportation of low voltage electricity in local networks - consists of overhead lines, cables, switchgear, transformers, control systems, meters

Supply: Sale of electricity to end-users – metering, billing, purchasing, contracting

44

The Industry: Vertically independent activities

Page 45: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Unbundling and restructuring Generation and supply - competitive

Transmission grid and distribution networks - monopolies

Competition

Regulation Access for competition over networks

Incentive regulation for improving efficiency

Privatization

45

Elements of Electricity Reform

Page 46: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

From an economic point of view, the aim of electricity reform in general and incentive regulation of networks in particular is to provide utilities with incentives to improve their operating and investment efficiency and to ensure that consumers benefit from the gains

Incentive regulation aims to achieve these objectives through financial reward or penalty incentive schemes

A price or revenue cap is set and the company retains the profit from achieved cost savings

Benchmarking in modern incentive regulation 46

Incentive Regulation of Distribution Networks

Page 47: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

Shleifer (1985) suggests that incentive regulation can mimic the outcome of competitive markets by setting an external performance standard that represents some average industry performance excluding the firm in question.

Benchmarking can broadly be defined as comparison of some measure of actual performance against a reference or benchmark performance.

The main issue is the choice of benchmark

Incentive regulation and benchmarking mimic market pressure in regulated companies.

47

What is benchmarking?

Page 48: Evolution of DNO Regulation in the UK · Year England and Wales Scotland April 1990-arch 1995 Post privatisation price control Post privatisation price ... (p.11) 13 Waddams (EWEPA,

DEA / SDEA / COLS / SFA

Large / high quality dataset

Panel data

Consistency with engineering / well behaved

Bootstrapping / confidence interval

Consistency with non-frontier methods

Quality / environmental / input price variables

Value added in efficiency analysis

Best practice efficiency analysis (f.Lovell, 2006)

4848

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1 transmission company

18 distribution utilities

Electricity Act 1998

Consultation document July 99

Draft benchmarking results Jan 00

Guidelines for price cap regulation Feb 00

Final Results Aug 00

Revised X factors Sept 00

Competition Authority Hearing March 01

Dutch Electricity Experience of Benchmarkingh

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1) Recognise that price review is a negotiation and is not subject to legal standards of proof

2) The regulator is in the superior position:

Legislative backing

Political support

Future reviews

3) Techniques not robust and subject to specification and measurement errors

Company Strategy under Benchmarking (1)

50

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4) Eliminate measurement errors by providing accurate data

5) Engage in debate about model specification

6) Check information provided and verify workings

7) Produce own analysis

Company Strategy under Benchmarking (2)

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From Benchmarkingto price-cap setting

Dr Michael Pollitt

Judge Institute of Management

University of Cambridge

52

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How do benchmarking exercises translate into price caps?

What are the debates surrounding the determination of price caps?

How should a company engage with these debates?

Questions for this session

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How benchmarking results translate to Xs for UK Regional Electricity Companies (RECs)

How the distribution price controls were set

How the supply price controls were set

The use of benchmarking in transmission

The use of benchmarking in Norway

Company Strategy under benchmarking

Outline of Session

54

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5 major Gencos National Grid Company 14 Distribution businesses

2 fully vertically integrated 2 merged with regional water company 2X2 horizontally merged

19 supply businesses for domestic customers 14 related to local distribution businesses 2 owned by major Gencos some being merged

The Structure of the UK ESI

55

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RECs privatised 1990

NGC shares sold 1995

Golden share lifted 1995 - takeovers begin

Separation of supply businesses - 1999

Distribution price controls:

1990-95 RPI-0; 1995-6 RPI-14; 1996-97 RPI-11.5;

1997-2000 RPI-3; 2000-01 RPI-23.4; 2001-05 RPI-3

Supply price controls (on costs to 1999):

1990-95 RPI-0; 1995-98 RPI-2; 1998-99 RPI-5;

1999-00 RPI-3; 2000-01 RPI-5.7 (Economy 7, 2.1)

The UK ESI : Background

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See Tables

WACC = 6.5%

Line 3: From estimates of required CAPEX

Line 8: From estimated cost of capital (WACC)

Line 10: From efficiency studies

Line 13: Is the regulated revenue required

Actually, there exists an infinite combination of P0s and Xs for every regulated revenue.

From Benchmarking to X setting: Southern and NORWEB

57

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Initial consultation document issued 18 months before end of current price control period

Several subsequent documents with responses invited each time. Responses placed in library unless marked confidential

Final document within 6 months of end of current control period

Company has a month to appeal to competition authority (MMC/CC) if unhappy with proposals at this stage

Basic Characteristics of OFFER/OfGEM approach

58

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Consultation paper (July 98 replies 25 Sept) To be considered in review:

Statistical analysis of costs

Best operating practices

Attributions between supply and distribution

Examination of company forecasts

Consideration of accounting policies

Consultants to be appointed

PES business plans (Dec 98 replies 2 Mar) Some companies e.g. NORWEB mention COLS efficiency score

Distribution Price Control2000-2005 (1)

59

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Consultation paper (May 99 replies 2 July)

Some Issues:

Context past forecasts higher than actual

Problems with capitalisation of costs

Mis-allocation of costs to distribution

Advertising and marketing should be zero

Customer services

Corporate overhead (D=90%, S=10%, later D=2/3, S=1/3)

Key factors in past efficiency improvements:

Organisational structures; Outsourcing and procurement; Engineering policy; IT strategy; Corporate costs

Distribution Price Control2000-2005 (2)

60

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Efficiency analysis of OPEX to be conducted by PKF/PB Power for 1997-98, specifically looking at:

Engineering costs

Customer service costs

Corporate costs

Regression analysis of costs:

Composite size = 0.7 customer numbers, 0.15 units, 0.15 network size

Regress base operating cost on composite size variable

Distribution price control2000-2005 (3)

61

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Draft proposals (Aug 99, replies 17 Sept) Regression analysis:

Composite output: 0.5 customer numbers, 0.25 units, 0.25 network length

Efficiency study: Engineering costs:

Cost per km based on costs from 4 best RECs

Based on asset profile and best practice cost

Historic cost savings achieved

Review of field efficiency and practices

Metering costs - Costs per customer in 4 better RECs

Corporate costs - 4 better RECs averaged

Customer service costs - Savings small

Distribution Price Control2000-2005 (4)

62

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Calculating X:

Previous cost savings passed to customer

Further cost savings of 7.5% expected for most efficient firms

Inefficient firms assumed to close gap with most efficient by end of period

Merger savings (1/2 of fixed costs saved passed to customers)

X=3 and P0 adjusted to maintain NPV

Average demand growth of 1.25% assumed within revenue cap

Distribution Price Controls2000-2005 (5)

63

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Final Proposals (Dec 99)

+/-1% for quality of supply from 2002/3

Standardised costs increased slightly

Slight increase in efficiency study savings

Inefficient firms go 3/4 to frontier by 2001/2 and then retain relative position

IT costs and separation of supply allowances

Frontier not tightened from 1998/99 onwards

Distribution Price Control2000-2005 (6)

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Context of supply liberalisation

Large customers from 1990

Medium customers from 1994

Full supply competition from 1998 (?)

Consultation paper (July 98 replies 25 Sept)

Nothing about efficiency

Consultation document (June 99 replies 4 July)

Three options:

A revised price control

Relative price control (to competitive tariff)

No price control

Supply price restraints2000-2002 (1)

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Initial Proposals (Oct 99 replies 29 Oct)

Prices to be set high to encourage switching

Only domestic tariffs to be regulated

Regulated price is sum of:

Allowed generation cost

Profiled pool price+allowed losses+fixed premium

Passed through transmission and distribution cost

Allowed supply business cost

Fixed element + per customer allowance

Allowed supply margin

Fixed at 1.5%

Levy

Supply price restraints2000-2002 (2)

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Final proposals (Dec 1999) Factual changes lead to falls in X Generation loss factors added Fixed cost £8.3m, cost per customer £31.30

Based on weighted average of 12 businesses Fixed cost per customer= (average fixed cost per company) x

(share of domestic customers in first tier sub 100KW costs) / (number of domestic customers less 19%)

Variable cost per customer is similarly calculated and adjusted for data management services revenue, separation costs and working capital

Note: Efficiency analysis as such is not used

Supply price restraints2000-2002 (3)

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NGC created from CEGB 1990

Privatised as part of Regional Electricity Companies (RECs) Dec 1990

Floated Dec 1995

Energis telecoms division established 1993

Energis part floated Dec1997 (retains 48.3%)

Transmission Price controls:

RPI-0 (1990-3)

RPI-3 (1993-7)

RPI-4 (1998-01, P0 reduction = 20%)

NGC transmission price controls: Background

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1st Consultation Document (CD) Nov 95, replies by 31 Jan 96 - no mention of efficiency analysis

2nd CD Mar 96, replies by 18 Apr 96 - mentioned as being difficult

3rd CD May 96, replies by 14 Jun 96 - no mention of efficiency analysis

4th CD Aug 96, replies by 10 Sept 96

OPEX examined by PKF, management consultants

CAPEX reviewed by Merz and McLellan

NGC Price Control 1997-2001 (1)

69

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Regulator proposes 4-6% fall in controllable costs

NGC benchmarking study of 15 transcos on uni-dimensional measures

AA survey of energy utility execs predict further cuts of up to 15%

LE DEA of 40 transcos world-wide

PKF analysis of costs suggests 2.5-3% p.a. possible

Debates about proposed CAPEX

Proposals Oct 96 respond by 30 October

Proposals ‘on basis of consultants, international policies and policies of well managed companies’

NGC Price Control 1997-2001 (2)

70

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GB regulator uses a range of techniques

No over emphasis on one method

Detailed cost analysis is important

Lack of transparency in GB over data and methods

However consultation and co-operation is high

Norwegian regulator relies heavily on DEA

Data accuracy checked carefully

DEA scores checked and scaled down for X setting

Norway has a lot of utilities for benchmarking

Moving away from pure DEA approach next time

Conclusions

71

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Norway

72

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1991 Deregulation

Regulator NVE

200 Distribution and regional network utilities

Stattnet - Transmission utility

1994-1997 Revenue Cap: RPI-0

1997-1998 Revenue Cap: RPI-2

1998-2001 Revenue Cap: X=1.5-4.5

Norway: Regulatory Background

73

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Rate of Return regulation until 1997: allowed revenue includes 8.3% return on capital

From 1997 Xs based on 1994-95 efficiencies

Co-ordinated annual data collection

Data provided to regulator in pre-formatted form

Data audited and fines for mis-reporting

DEA used to calculated individual Xs

Norway: Price Cap Implementation

74

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Labour (hours)

Transmission losses (MWh)

Capital (lines, transformers, connectors) (Kr)

Goods and services (Kr)

Norway Inputs(Distribution utilities)

(see Kittelsen, 97)

75

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Number of customers

Energy delivered (MWh)

Distance Index (min)

= travel time from each basic district to the municipal centre average for all

basic districts multiplied by number of customers

Norway: Outputs(Distribution utilities)

76

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The underlying rate of technological progress needs to be estimated

This can be done using measures of TFP

Tornqvist Index

Malmquist Index

This measure may be based on other industries

It is not clear whether there are any efficient firms to act as benchmarks

Norway: Estimating technical Efficiency

77

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If measured DEA score is 70%

Target reduction is 3%p.a.

If measured DEA score is 100%

Target reduction is 0%p.a.

Linear scale between 0 and 3%

In addition utility has to meet the general productivity requirement of 1.5%p.a.

X is between 1.5% and 4.5%

Norway: Setting the Price Cap

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NVE has indicated it will supplement future DEA analysis

Price cap regulation has resulted in under-investment as quality was not included

Next regulatory period (from 2001) will incorporate losses and companies will be penalised if their delivered quality is low

Norway: Setting the Price Cap from 2001

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OPEX = operating expenditure

CAPEX = capital expenditure

WACC = weighted average cost of capital

RECs=regional electricity companies

COLS = corrected ordinary least squares

DEA = data envelopment analysis

Terms

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Distribution price controls:o 1990-95 RPI-0; 1995-6 RPI-14; 1996-97 RPI-11.5;

o 1997-2000 RPI-3; 2000-01 RPI-23.4; 2001-05 RPI-3; 2015-2023 RIIO

Supply price controls (on costs to 1999):o 1990-95 RPI-0; 1995-98 RPI-2; 1998-99 RPI-5;

o 1999-00 RPI-3; 2000-01 RPI-5.7 (Economy 7, 2.1); 2018, Retail price control

81

Price Controls

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Anatomy of a Distribution Price Control:

DPCR 2000-2005

82

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Consultation paper (July 98, replies 25 Sept) To be considered in review:

o Statistical analysis of costs

o Best operating practices

o Attributions between supply and distribution

o Examination of company forecasts

o Consideration of accounting policies

Consultants to be appointed

PES business plans (Dec 98, replies 2 Mar) Some companies mention COLS efficiency score

Distribution Price Control2000-2005 (1)

83

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Consultation paper (May 99 replies 2 July) Some Issues:

Context past forecasts higher than actual

Problems with capitalisation of costs

Mis-allocation of costs to distribution

o Advertising and marketing should be zero

o Customer services

o Corporate overhead (D=90%, S=10%, later D=2/3, S=1/3)

Key factors in past efficiency improvements: Organisational structures; Outsourcing and procurement; Engineering

policy; IT strategy; Corporate costs

Distribution Price Control2000-2005 (2)

84

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Efficiency analysis of OPEX to be conducted by PKF/PB Power for 1997-98, specifically looking at:Engineering costs

Customer service costs

Corporate costs

Regression analysis of costs:Composite size = 0.7 customer numbers, 0.15 units, 0.15

network size

Regress base operating cost on composite size variable

Distribution Price Control2000-2005 (3)

85

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Draft proposals (Aug 99, replies 17 Sept)

Regression analysis: Composite output (0.5 customer number, 0.25 units, 0.25 network length)

Efficiency study: Engineering costs:

o Cost per km based on costs from 4 best RECs

o Based on asset profile and best practice cost

o Historic cost savings achieved

o Review of field efficiency and practices

Metering costs - Costs per customer in 4 better RECs

Corporate costs - 4 better RECs averaged

Customer service costs - Savings small

Distribution Price Control2000-2005 (4)

86

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Calculating X:

Previous cost savings passed to customer

Further cost savings of 7.5% expected for most efficient firms

Inefficient firms assumed to close gap with most efficient by end of period

Merger savings (1/2 of fixed costs saved passed to customers)

X=3 and P0 adjusted to maintain NPV

Average demand growth of 1.25% assumed within revenue cap

Distribution Price Controls2000-2005 (5)

87

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Final Proposals (Dec 99)

+/-1% for quality of supply from 2002/3

Standardised costs increased slightly

Slight increase in efficiency study savings

Inefficient firms go 3/4 to frontier by 2001/2 and then

retain relative position

IT costs and separation of supply allowances

Frontier not tightened from 1998/99 onwards

Distribution Price Control2000-2005 (6)

88