the electricity distribution network allowed …...electricity to approximately 2.4 million irish...

An Coimisiún um Rialáil Fóntas Commission for Regulation of Utilities

0

Information Paper

Reference: CRU/20/084 Date Published: 31/07/2020 Queries to: [email protected]

An Coimisiún um Rialáil Fóntas

Commission for Regulation of Utilities

The Electricity Distribution Network Allowed

Revenues for 2021 and the

Distribution Use of System (DUoS) Tariffs &

Distribution Loss Adjustment Factors

(DLAFs) for 2020/2021

Information Paper

www.cru.ie

An Coimisiún um Rialáil Fóntas

Commission for Regulation of Utilities

mailto:[email protected]


i

Public/ Customer Impact Statement ESB Networks owns and operates the electricity distribution system in Ireland, which supplies

electricity to approximately 2.4 million Irish customers. Roughly, two million of these are Irish

homes (i.e. residential customers).

The CRU allows ESB Networks to charge money towards the cost of building, operating and

maintaining the electricity distribution system in Ireland. These charges, which are reflected in

customers’ electricity bills, account for c.25% of the average residential electricity bill. The CRU’s

role is to protect electricity customers by ensuring that ESB Networks spends customers’ money

appropriately and efficiently to deliver necessary services. The CRU does this through what is

called a Price Review which is carried out every 5-years. The current Price Review (PR4) started

in 2016 and will end in 2020. The CRU is in the process of setting the new Price Review (PR5),

which will cover the period from 2021 to 2025. It is expected that the CRU’s PR5 Final

Determination will be published later this year. For each year of the Price Review, ESB Networks

is allowed to collect an efficient amount of money to develop, operate and maintain the network

for that year. The CRU reviews and updates these revenues each year of the Price Review.

2021 is a transition year between Price Reviews and this paper details the 2021 allowed

revenues. The CRU has increased the 2020 allowed revenues by 2.5% to get the 2021 revenue

figure and has applied the 2019 and 2020 k-factor adjustments to the result to get the final 2021

allowed revenues. The difference between the outcome of this paper and the outcome of the

CRU’s PR5 Final Determination, regarding the 2021 allowed revenues, will be corrected in future

years through the so-called k-factor mechanism. The main driver for the increase in distribution

tariffs is the estimated under-recovery of revenues in 2020 due to Covid-19, i.e. €64m, and

reduced demand forecasts for the next tariff year. Significant uncertainty surrounds these

forecasted amounts. ESB Networks has estimated that along with the impact on revenue

recovery in 2020, there could be significant additional under-recovery of operating costs given

the impact of Covid-19 on ESB Networks’ capital work programme (with some costs moving

from capex to opex). However, the total impact of the pandemic is extremely difficult to forecast

accurately. Due to this uncertainty, the CRU has only included the estimated under-recovery of

revenues during 2020 in this year’s tariffs i.e. the €64m. Any remaining under-recovery will be

accounted for in next year’s tariffs, when the accurate figure will be known.

The CRU expects that the combined transmission and distribution adjustments will result in the

average residential customer’s annual electricity bill1 rising by c.€29 in October 2020. However,

bills depend on other factors, i.e. wholesale market costs (driven by international commodity

prices), capacity market costs and other system costs. Further detail on these costs are in CRU’s

Retail Markets Reports2. The currently forecast fall in wholesale electricity prices may serve to

mitigate some of the costs increases elsewhere e.g. transmission and distribution adjustments.

1 DG1, standard 24h tariff. 2 The Electricity and Gas Retail Markets Monitoring Report 2019 will be published on the CRU’s website shortly.


ii

Executive Summary

Background

In 2015, the CRU published its PR4 decision (CER/15/295) on distribution network revenues for

each year from 2016 to 2020. The five-year approach is best international practice and is used

by a number of European regulators as well as in a number of other regulated sectors. The CRU

is currently working on the next Price Review (PR5) and the Final Determination will be

published later this year. PR5 will set the distribution network revenues for each year from 2021

to 2025.

The revenues allowed under a Price Review enable ESB Networks to build, maintain, and

operate the electricity distribution network in Ireland. The Price Review revenues are collected

through the Distribution Use of System (DUoS) tariffs. These are reviewed and updated annually

to reflect adjustments such as:

• Inflation movements;

• changes in interest rates;

• more up-to-date forecasts (such as electricity demand);

• adjustments related to unforeseen/uncertain items – as 2021 is a transition year

between Price Reviews, the CRU has applied a 2.5% increase to the 2020 revenues

to account for this; and

• adjustments that relate to the outcome of previous years through the so-called k-

factors – the 2019 and 2020 k-factor are accounted for in this paper.

The 2021 Calendar Year Revenues

As 2021 is a transition year between Price Reviews, the CRU has increased the 2020 allowed

revenues by 2.5% to get an assumed revenue figure for 2021 and has applied the 2019 and

2020 k-factor adjustments to the result to get the final 2021 allowed revenues. This will account

for adjustments between 2020 and 2021 and will facilitate the DSO commencing its PR5

programme of work – particularly new activities related to the Climate Action Plan (CAP). The

difference between the revenue assumption used to calculate tariffs in this paper and the

outcome of the CRU’s PR5 Final Determination, regarding the 2021 allowed revenues, will be

corrected in future years through the so-called k-factor mechanism.

The 2.5% increase will facilitate ESB Networks additional funding to carry out the ramping work

related to the CAP from the beginning of 2021. This is a reasonable increase in the context of

ESB Networks PR5 request for 2021, which was an increase of circa 7% to the 2020 allowed

revenues.

The 2021 revenue figure is €875.73m (2021 monies). The adjustments to the 2021 revenues

i.e. k2019 and k2020 factors, as shown in table 1 (overleaf), have led to a final 2021 allowed

revenues amount of €920.74m (2021 monies). This is an increase of c.10% from the 2020

allowed revenues of €839.3m (2020 monies).

The main driver for the increase in the final 2021 allowed revenues relates to the impact of the

covid19 pandemic i.e. estimated lower electricity demand than forecasted resulting in a


iii

significant expected under-recovery in 2020, i.e. €64m. ESB Networks has estimated that along

with the impact on revenue recovery in 2020, there could be significant additional under-

recovery of operating costs given the impact of Covid-19 on ESB Networks’ capital work

programme (with some costs moving from capex to opex). However, the total impact of the

pandemic is extremely difficult to forecast accurately. Due to this uncertainty, the CRU has only

included the estimated under-recovery of revenues during 2020 in this year’s tariffs, i.e. the

€64m. Any remaining under-recovery will be accounted for in next year’s tariffs, when the

accurate figure will be known.

Other key drivers, which are accounted for in both the k2019 and k2020 factors, include:

• An increase related to the Strategic Innovation Fund (€10.16m) – k2019 factor;

• an increase related to an under collection of revenues over 2019 (€18.76m) – k2019

factor; and,

• an increase related to a forecast under collection of revenues over 2020, due to lower

demand levels than expected (€64.26m) – k2020 factor.

This is offset to some extent by:

• A reduction for incentives performance (-€12.17m) – k2019 factor;

• lower than expected Rates (-€11.63m) – k2019 factor;

• a reduction related to Miscellaneous Incomes (-€7.65m) – k2019 factor; and,

• a reduction related to the effect on the 2020 revenues of indexation being different to

forecast (-€17.41m) – k2020 factor.

The DUoS Tariffs from 1st October 2020 to 30th September

2021

The final 2021 allowed revenues of €920.74m (nominal 2021) leads to a tariff year revenue of

€899m, which is to be recovered during the tariff period 1 October 2020 to 30 September 2021.

This is a c.8% increase relative to the €836.1m that was approved for recovery during the

previous tariff year.

CRU’s Average Unit Price v DSO’s calculation of the DUoS

Tariffs

The CRU’s Average Unit Price (AUP) is calculated by dividing the total allowed revenue by the

total forecast units of electricity sold (measured in kWh) for the 2020/21 tariff period. This

calculation is available in the CRU’s revenue model published alongside this paper.

The AUP calculation is a straightforward way of comparing average unit prices when moving

from one “tariff period” (12-month period, starting each October) to the next. This is different to

the DSO’s tariffs calculation (outlined below). The DSO’s calculation includes forecasts of the

number of electricity customers, and customers’ contracted electricity demand capacity, as well

as electricity units sold. The DUoS tariffs calculation is also influenced by Large Energy User

(LEU) rebalancing, as per CER/10/198.


iv

DSO’s calculation of the DUoS Tariffs – Impact Analysis

Based on the DSO’s customer impact analysis, the percentage change in the DUoS tariffs for

2020/21 is an increase of c.11.62%. The DSO’s customers impact analysis showing the DUoS

paid by an average customer is provided in Appendix 1 of this paper.


average residential customer’s annual electricity bill3 rising by circa €29 in October 2020.

However, customer’s annual bills depend, on other factors, such as wholesale market costs

(which are in turn driven by factors such as international commodity prices), capacity market

costs and other system costs. Further detail on these costs can be found in CRU’s annual Retail

Markets Report4. The currently forecast fall in wholesale electricity prices may serve to mitigate

some of the costs increases elsewhere e.g. transmission and distribution adjustments.

CRU’s Average Unit Price (AUP) – Impact Analysis

Based on the CRU’s Average Unit Price (AUP), the AUP for the 1 October 2020 to 30 September

2021 period is 3.75c/kWh. This is a 11.64% increase relative to the AUP of 3.36c/kWh for the 1

October 2019 to 30 September 2020 period.

As noted above, because the methodologies are different, the AUP and DUoS tariffs may vary

from one tariff year to another somewhat differently. It happens that for the 2020/21 tariff year,

the AUP and the DUoS tariffs are varying very similarly. It is worth noting that the LEU

rebalancing is not included in the CRU’s AUP calculation, but it is in the DUoS tariffs calculation.

The CRU will shortly start considering whether the application of the LEU rebalancing remains

necessary for future tariff years.

DLAFs

In the electricity market, electricity suppliers must pay for energy (kWh) measured at the

customer meter and the associated losses (DLAFs). This information paper details the

Distribution Loss Adjustment Factors (DLAFs) for the 1 October 2020 to 30 September 2021

period (see section 5 of this paper).



v

The k-factor adjustments applied to the 2021 revenue figure:

k-factors adjustments to revenue for 2021, nominal €m

Adjustments relating to customer numbers,

indexation & GWhs K2019 (k-2)

K2020 (k-1)

Total

Higher (lower) customer numbers relative to

those included in PR4 decision 0.01 -0.03 -0.02

Indexation & over-collection

Effect on total revenue of indexation being

different to forecast 0.82 -17.41 -16.59

Revenue forecast for collection based on latest

assumptions re demand (or outturn collected

where available)

18.76 64.26 83.02

Incentives

Incentives, nominal, €m -12.17 - -12.17

Strategic innovation Fund 10.16 - 10.16

Pass-through costs

Regulatory levy -0.35 - -0.35

Rates -11.63 - -11.63

Uncertain costs, non-capitalised

CRU Safe Electric Campaign -0.14 0.46 0.32

Miscellaneous Incomes -7.65 0 -7.65

Electronic Certification (RECI) -0.15 0 -0.15

Smart Opex -1.20 0.93 -0.27

Secure Solution of Supplier of Last Resort 0.04 0.04 0.08

Uncertain costs, capitalised

Smart Metering -0.01 0.28 0.27


Total adjustment (excluding interest

adjustment), nominal, €m -3.48 48.58 45.10

Total adjustment (including interest

adjustment) -3.45 48.47 45.01

Table 1: k-factors adjustments applied to the 2021 revenue figure to get the final 2021 allowed revenues.


vi

Table of Contents

Public/ Customer Impact Statement ........................................................................ i

Executive Summary ................................................................................................. ii

Glossary of Terms .................................................................................................... 1

1. Introduction ........................................................................................................ 2

1.1 Commission for Regulation of Utilities ........................................................................... 2

1.2 Background ................................................................................................................... 2

1.3 Legal basis ..................................................................................................................... 2

1.4 Purpose of this information paper ................................................................................. 3

1.5 Other related documents .............................................................................................. 3

1.6 Structure of this document ............................................................................................ 4

2. The revenue setting process ............................................................................ 5

2.1 CRU’s revenue setting process ....................................................................................... 5

2.2 Determination of the DUoS tariffs for each tariff period ................................................. 6

2.3 Determination of DLAFs ................................................................................................ 6

3. The DSO’s revenue allowance for 2021 ........................................................... 7

3.1 Summary of the DSO’s revenues 2021 ............................................................................ 7

3.2 The DSO’s revenue control formula ............................................................................... 8

3.3 K-factors adjustments (explanations below)................................................................... 9

3.4 Comparing the 2021 with the 2020 revenues ............................................................... 14

4. The DUoS tariffs for the 1 Oct 2020 to 30 Sept 2021 period ......................... 15

4.1 Revenue for recovery during Oct 2020 to Sept 2021 ..................................................... 15

4.2 The DUoS tariffs for Oct 2020 to Sept 2021 .................................................................. 15

5. Distribution Loss Adjustment Factors ........................................................... 17

6. Summary of review .......................................................................................... 18

Appendix 1: The DUoS payments made by the average customer.................... 19


1

Glossary of Terms

Abbreviation or Term Definition or Meaning

AUP

The Average Unit Price (AUP), that is, the total revenue

divided by total kWh, when moving from one tariff period to

another.

CAP Climate Action Plan

CEP Clean Energy Package

DAO Distribution Asset Owner

DLAFs Distribution Loss Adjustment Factors

DSO Distribution System Operator

DUoS Distribution Use of System

ESBN ESB Networks

GWh Gigawatt hours

HICP Harmonised Index of Consumer Prices

Interbank market –

Euribor3 (3-month fixed)

Euribor is the rate at which euro interbank term deposits are

offered by one prime bank to another, within the euro area.

Daily data are available from www.euribor.org

K-factors

K-factors are the correction factors, which ensure that prices

in 2021 are adjusted by an amount equal to the difference

between what was actually charged in year 2019 (k-2) or

2020 (k-1) and the forecast of what should have been

charged.

PR4 Price Review 4

PR5 Price Review 5


2

1. Introduction

1.1 Commission for Regulation of Utilities

The Commission for Regulation of Utilities (CRU) is Ireland’s independent energy and water

regulator. Our mission is to protect the public interest in water, energy and energy safety. Further

information on the CRU’s role and relevant legislation can be found on the CRU’s website at

www.cru.ie.

1.2 Background

The CRU is responsible for the economic regulation of the system operators and asset owners

for electricity transmission and distribution. Price controls, which limit the revenues that the

relevant licensees can recover from electricity consumers are set every five-years.

In December 2015, the CRU set its price control for the Price Review 4 (PR4) period for ESB

Networks (ESBN) as Distribution System Operator (DSO)/Distribution Asset Owner (DAO). PR4

set annual revenues for each of the years for the period 2016-2020, which are collected through

the distribution use of system charges (DUoS tariffs) each year. The next Price Review (PR5)

is underway and will set annual revenues for each of the years for the 2021-2025 period. It is

expected that the CRU will publish the PR5 Final Determination later this year.

The annual revenues are reviewed and adjusted each year of the Price Review when setting

the annual distribution use of system charges (DUoS tariffs). The annual revenues review

includes adjustments to account for more up to date forecasts such as latest number of

customers and level of demand. It also captures adjustments that relate to the outcome of the

previous two years – through the so-called k-factors. This paper details the 2021 allowed

revenues.

1.3 Legal basis

Under the Electricity Regulation Act, 1999 (as amended), the CRU is the independent body

responsible for overseeing the regulation of Ireland's electricity sector. Section 35 of the

Electricity Regulation Act 1999 (“the Act”), provides the CRU the legal basis to approve charges

for the use of the electricity systems in Ireland.

In accordance with Section 35 of the Act, the CRU’s electricity Price Review decisions outlines

the revenue that the Distribution System Operator (“DSO”) can recover from DUoS customers

during a Price Review period. Consistent with Section 36 of the Act, the DSO’s statement of

charges, prepared in accordance with Section 35, must be submitted to the CRU for approval

annually and will not take effect until approved by the CRU. Once the Statement of Charges is

approved, it is then published by ESB Networks on its website.

http://www.cru.ie/


3

1.4 Purpose of this information paper

The purpose of this document is to set out the CRU’s decision in respect of the 2021 allowed

revenues for ESB Networks. These revenues will be recovered from the distribution customers

through the distribution use of system charges (“DUoS"). This paper also provides details on:

• the approved DUoS tariffs to apply from 1 October 2020 to 30 September 2021; and,

• the approved Distribution Loss Adjustment Factors (“DLAFs”) to apply from 1 October

2020 to 30 September 2021.

In addition, the following four accompanying documents are published alongside this paper:

• the approved DSO’s schedule of the DUoS tariffs which will apply during the 1 October

2020 to 30 September 2021 period;

• the excel model that was used to update the 2021 DSO’s revenues;

• an explanatory note from the DSO on the analysis of the 2021 DSO’s revenues; and,

• the approved DLAFs which will apply during the 1 October 2020 to 30 September 2021

period.

1.5 Other related documents

Further background relevant to this information paper can be found in the following documents:

CER/15/295 Decision on the DSO’s revenue for 2016 to 2020

CER/15/217 Information note on the 2016 Distribution System Operator allowed

revenue, DUoS tariffs & DLAFs


revenue, DUoS 2016/2017 tariffs & Distribution Loss Adjustment Factors



CRU/18/087 Reporting and Incentives under Price Review 4 Decision

CRU/18/146

CRU/19/102

Information note on the 2019 Distribution System Operator allowed


Information note on the 2020 Distribution System Operator allowed


https://www.cru.ie/wp-content/uploads/2015/07/CER15295-Decision-on-DSO-PR4-Distribution-Revenue-2016-to-2020.pdf

https://www.cru.ie/wp-content/uploads/2015/07/CER15217-2016-Revenue-DUoS-tariffs-DLAFs.pdf

https://www.cru.ie/wp-content/uploads/2016/07/CER16249-Information-Note-on-2017-DSO-Revenue-DUoS-tariffs-Distribution-Loss-Adjustment-Factors.pdf

https://www.cru.ie/wp-content/uploads/2017/09/CER17273-Electricity-Distribution-Network-Allowed-Revenue-2018-Distribution-Tariffs-20172018-DLAFs.pdf

https://www.cru.ie/wp-content/uploads/2018/05/CRU18087-Reporting-and-Incentives-under-Price-Review-4-Decision-Paper.pdf

https://www.cru.ie/wp-content/uploads/2018/08/CRU18146-Electricity-Distributioution-Tariffs-2018-2019-DLAF.pdf

https://www.cru.ie/wp-content/uploads/2019/12/CRU19152-Discussion-Paper-on-the-Approach-for-Transmission-Distribution-Price-Review-5.pdf


4

1.6 Structure of this document

This paper has six sections and each section is described below:

Section 1 describes the context and outlines the purpose of this information note.

Section 2 describes the revenue setting process, which includes how adjustments are

applied to the calendar year revenues and how the calendar year revenues

translate into DUoS tariffs.

Section 3 provides a summary of the DSO’s allowed revenues for 2021. Following that

summary, sections 3.3 and 3.4 provide further detail on the k-factor adjustments

and a comparison between the 2020 and 2021 allowed revenues.

Section 4 provides detail on how portions of the calendar years’ revenues are allocated for

recovery within the DUoS tariffs that are implemented from 1 October 2020 to 30

September 2021.

Section 5 provides detail on the Distribution Loss Adjustments Factors (DLAF) that are

approved for implementation from 1 October 2020 to 30 September 2021.

Section 6 provides a summary of the CRU’s decisions regarding the DSO’s allowed

revenues for 2021.


5

2. The revenue setting process In this section we describe the revenue setting process, which includes how adjustments are

made to the relevant calendar year’s revenues and how calendar year’s revenues translate into

DUoS tariffs.

2.1 CRU’s revenue setting process

The CRU’s calculation of allowed revenues is based on the CRU’s Price Review process, which

is conducted every five years. The CRU is currently in its fourth Price Review period, known as

PR4, spanning the years 2016 to 2020. The next Price Review period, PR5, is underway and

will cover the period from 2021 to 2025. The CRU’s PR5 Final Determination will be published

later this year.

While the Price Review process sets the allowed revenues for the DSO for a five-year period, it

also facilitates yearly updates to those revenues. This process is shown at a high level in table

2 (overleaf).

Overview of price review process

Year Scope of Review

2020

Five-year price review, PR5, including:

• Ex-post adjustments on the previous five years of expenditure (2016 to 2020).

• Ex-ante setting of revenues for the next five years of expenditure (2021 to 2025).

2021

CRU’s annual reviews and updates to revenues. 2022

2023

2024

2025

Five-year price review, PR6, including:

• Ex-post adjustments on the previous five years of expenditure (2021 to 2025).

• Ex-ante setting of revenues for the next five years of expenditure (2026 to 2030).

Table 2: Overview of price review timeline (process).

As part of the annual review process, existing forecast items are updated as appropriate.

Furthermore, an opportunity is provided for the network company to request revenue for

additional items that were not envisaged or captured at the time of setting the five-year revenue

allowances.


6

2.2 Determination of the DUoS tariffs for each tariff

period

The CRU approves the DUoS tariffs on an annual basis to cover the period from 1 October to

30 September. The DUoS tariffs are set to recover 26.7%5 of the revenues associated with the

first calendar year included in the tariff period and 73.3% for the second calendar year. The

DUoS tariffs set out in this information paper relate to the tariff period from 1 October 2020 to

30 September 2021 and represent 26.7% of the 2020 calendar year’s revenues and 73.3% of

the 2021 calendar year’s revenues.

2.3 Determination of DLAFs

Details on the Distribution Loss Adjustment Factors (DLAFs) for the 1 October 2020 to 30

September 2021 period are provided within section 5 of this paper. Information on the

methodology which the DSO uses to determine these values is available on ESB Networks’

website6.

5 This is based on the percentage of demand that relates to the relevant period of the year. 6 The methodology used by the DSO to determine DLAFs is available here.

https://www.esbnetworks.ie/tns/publications/search-results?indexCatalogue=our%2Dpublications&searchQuery=distribution+loss+adjustment+factors&wordsMode=0


7

3. The DSO’s revenue allowance for 2021 This section provides a summary of the annual DSO’s revenues for 2021. Following that

summary, sections 3.3 and 3.4 provide further detail on the k-factor adjustments and a

comparison between the 2020 and 2021 allowed revenues.

3.1 Summary of the DSO’s revenues 2021

The CRU is currently in its fourth Price Review period, known as PR4, spanning the years 2016

to 2020. The next Price Review period, PR5, is underway and will set the allowed revenues for

the period from 2021 to 2025, inclusive. The CRU’s PR5 Final Determination will be published

later this year.

As 2021 is a transition year between Price Reviews, the CRU has increased the 2020 allowed

revenues by 2.5% to get the 2021 revenue figure and has applied the 2019 and 2020 k-factor

adjustments to the result to get the final 2021 allowed revenues. The difference between the

outcome of this paper and the outcome of the CRU’s PR5 Final Determination, regarding the

2021 allowed revenues, will be corrected in future years through the so-called k-factor

mechanism.

The 2.5% increase will facilitate ESB Networks additional funding to carry out the ramping work

related to the Climate Action Plan (CAP) from the beginning of 2021. This is a reasonable

increase in the context of ESB Networks PR5 request for 2021, which was an increase of circa

7% to the 2020 allowed revenues.

The CRU considers that the 2021 revenue figure should be higher than the 2020 revenues as:

• the DSO must deliver the PR5 programme over the 2021-2025 period (e.g. CEP7 and

CAP); and,

• an increase in the 2021 revenues will facilitate that ESB Networks does not continue to

build up its k-factors due to lower electricity demand levels;

The 2021 revenue figure is €875.73m (2021 monies). The adjustments to the 2021 revenues

i.e. k2019 and k2020 factors, as shown in table 1 (overleaf), have led to a final 2021 allowed

revenues amount of €920.74m (2021 monies). This is an increase of c.10% from the 2020

allowed revenues of €839.3m (2020 monies).

The main driver for the increase in the final 2021 allowed revenues relates to the impact of the

covid19 pandemic i.e. lower electricity demand than forecasted resulting in a significant

expected under-recovery of €64m in 2020. ESB Networks has estimated that along with the

impact on revenue recovery in 2020, there could be significant additional under-recovery of

operating costs given the impact of Covid-19 on ESB Networks’ capital work programme (with

7 Clean Energy Package.


8

some costs moving from capex to opex). However, the total impact of the pandemic is extremely

difficult to forecast accurately. Due to this uncertainty, the CRU has only included the estimated

under-recovery of revenues during 2020 in this year’s tariffs, i.e. the €64m. Any remaining under-

recovery will be accounted for in next year’s tariffs, when the accurate figure will be known.

Other key drivers, which are accounted for in both the k2019 and k2020 factors, include:

• An increase related to the Strategic Innovation Fund (€10.16m) – k2019 factor;

• an increase related to an under collection of revenues over 2019 (€18.76m) – k2019

factor; and,

• an increase related to a forecast under collection of revenues over 2020, due to lower

demand levels than expected (€64.26m) – k2020 factor.

This is offset to some extent by:

• A reduction for incentives performance (-€12.17m) – k2019 factor;

• lower than expected Rates (-€11.63m) – k2019 factor;

• a reduction related to Miscellaneous Incomes (-€7.65m) – k2019 factor; and,

• a reduction related to the effect on the 2020 revenues of indexation being different to

forecast (-€17.41m) – k2020 factor.

Further details can also be found in the following documents published alongside this paper:

• The “DSO’s information note to CRU on analysis of the 2021 Distribution Revenue”

detailing the adjustments made to the DSO’s revenues based on inputs (i.e. GWh,

inflation, and DSO outturn values for opex & capex) provided by the DSO; and,

• the “CRU’s Revenue Model”, which details the calculation of the DSO’s revenues and

the adjustments outlined in the DSO’s information note.

3.2 The DSO’s revenue control formula

The revenue control formula is set out in detail in Section 13 of CER/15/295 and will also be

included in the PR5 decision. It is presented as equation 1 below. In a normal year of a Price

Review, the Price control formula would take the ‘base’ allowed revenue, as set in the relevant

Price Review, inflate that revenue into nominal figures, and adjusts it for specific revenue

parameters, the formula is as follows:

𝑅𝑡 = ∏ [1 + 𝐼𝑛𝑓𝑡

100]

𝑡

2014

∗ 𝐵𝑡 + ∏ [1 + 𝐼𝑛𝑓𝑡

100]

𝑡

2014

∗ [𝐼𝑁𝐶𝐸𝑁𝑇𝑡 + 𝑃𝐶𝑢𝑠𝑡𝑡 ∗ (𝐹𝐶𝑢𝑠𝑡𝑡 − 𝐶𝑢𝑠𝑡𝑡 )] + ∆𝑃𝑡

+ ∆𝑈𝑡 + 𝐾𝑡−1 + 𝐾𝑡−2

Equation 1: Price control formula from CER/15/295 (it will also be included in the PR5 decision).

As 2021 is a transition year between Price Reviews, the Price control formula applied to

calculate the final 2021 allowed revenues has been simplified to the below formula. Please note

that the 2.5% increase has been made to capture some of the items of the Price Control formula.

𝑅𝑡 = [(2020 𝑎𝑙𝑙𝑜𝑤𝑒𝑑 𝑟𝑒𝑣𝑒𝑛𝑢𝑒𝑠 ∗ 2.5%) ∗ 𝑓𝑜𝑟𝑒𝑐𝑎𝑠𝑡 𝑖𝑛𝑓𝑙𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 2021] + 𝐾𝑡−1 + 𝐾𝑡−2

Equation 2.1: Simplified Price control formula for the 2021 calendar year.

http://www.cer.ie/docs/001044/CER15295%20Decision%20on%20DSO%20PR4%20Distribution%20Revenue%202016%20to%202020.pdf


9

Where:

• Rt, the maximum level of revenues allowed in 2021 is €920.74m (2021 prices);

• the 2020 allowed revenues are 839.3m (2020 prices);

• Kt-1, the correction factor for 2020, is €48.47m (nominal); and,

• Kt-2, the correction factor for 2019, is -€3.45m (nominal);

These figures are explained in more detail in the following section.

3.3 K-factors adjustments (explanations below)

k-factors adjustments to revenue for 2021, nominal €m

Adjustments relating to customer numbers, indexation &

GWhs K2019 (k-2)

K2020 (k-1)

Total

Higher (lower) customer numbers relative to those included in

PR4 decision 0.01 -0.03 -0.02

Indexation & over-collection

Effect on total revenue of indexation being different to forecast 0.82 -17.41 -16.59

Revenue forecast for collection based on latest assumptions re

demand (or outturn collected where available) 18.76 64.26 83.02

Incentives

Incentives, nominal, €m -12.17 - -12.17

Strategic innovation Fund 10.16 - 10.16

Pass-through costs

Regulatory levy -0.35 - -0.35

Rates -11.63 - -11.63

Uncertain costs, non-capitalised

CRU Safe Electric Campaign -0.14 0.46 0.32

Miscellaneous Incomes -7.65 0 -7.65

Electronic Certification (RECI) -0.15 0 -0.15

Smart Opex -1.20 0.93 -0.27


Uncertain costs, capitalised

Smart Metering -0.01 0.28 0.27


Total adjustment (excluding interest adjustment), nominal, €m -3.48 48.58 45.10

Total adjustment (including interest adjustment) -3.45 48.47 45.01

Table 3: k-factors adjustments applied to the 2021 revenue figure to get the final 2021 allowed revenues.


10

• Global assumptions for the k-factor adjustments

The k2019 factor accounts for the actual inflation rate in 2019, actual revenue collection in 2019,

incentive payments based on performance over 2019 and actual pass-through, uncertain non-

capitalised and uncertain capitalised costs in 2019. The k2020 factor accounts for the actual

inflation rate in 2019 and an updated forecast for 2020, updated forecast of revenue collection

in 2020 and updated forecast of pass-through, uncertain non-capitalised and uncertain

capitalised costs in 2020. The following are the global assumptions used to calculate the k-factor

adjustments:

HICP (Harmonised Index of Consumer Prices): The HICP in the table below are based on

Central Bank figures8.

GWh: In previous years, ESB Networks’ demand forecasting has been based on a regression

analysis taking into account forecasted population growth, customer numbers and GDP/GNP.

However, given the very significant level of uncertainty surrounding the impact of the Covid19

crisis on those inputs, it has not been possible for ESB Networks to use a similar regression

analysis. Therefore, ESB Networks has prepared demand forecasts taking into account (i) actual

2019 outturn, (ii) pre-Covid19 forecasts (using ESB Networks’ regression model), (iii) other

available economic forecasts on the impact of the Covid19 crisis on electricity demand and the

wider economy and (iv) the current demand patterns since the beginning of the Covid19

pandemic. This forecast represents a best endeavors, point-in-time indicative estimate. The

forecasts imply a GWh decrease of c.6% in 2020 and increase of c.0.2% in 2021, compared to

the actual demand in 2019.

Euribor (Euro Interbank Offered rate): Euribor is the rate at which euro interbank term

deposits are offered by one prime bank to another, within the euro area. The Euribor rates in

table 5 show the 3-month fixed rates which are available in the European Money Markets

Institute’s page (EMMI9).

New Connections: ESB Networks has updated the new connections forecast for 2020 in order

to carry out the k-factor calculations. As indicated by ESB Networks, the number of expected

new connections for 2020 is very difficult to forecast in the current environment due to the

unknown full year impact of covid19. In the absence of any current data on the expected impact,

ESB Networks has maintained the 2020 forecast new connections figure at the 2019 actual

outturn i.e. 30,206. It is worth noting that the new connections figure does not have a material

impact on the revenues.

8 Central Bank Quarterly Bulletin Q1 2020 and Central Bank Quarterly Bulletin Q2 2020. 9 It can be found here.

https://www.centralbank.ie/docs/default-source/publications/quarterly-bulletins/qb-archive/2020/quarterly-bulletin---q1-2020.pdf?sfvrsn=9

https://www.centralbank.ie/docs/default-source/publications/quarterly-bulletins/qb-archive/2020/quarterly-bulletin---q2-2020.pdf?sfvrsn=14

https://www.emmi-benchmarks.eu/euribor-org/euribor-rates.html


11

Table of Global Assumptions

# 2019 (actual) 2020 (forecast) 2021 (forecast)

HICP 0.9% -0.9% 1.8%

GWh (demand) 24,297 22,845 24,350

Euribor -0,36 -0,41 N/A

New Connections 30,206 30,206 Tbd in PR5

Table 4: Global Assumptions.

• Explanations related to the k-factor adjustments

3.3.1. Adjustments relating to the numbers of customers (-€0.02m)

This decrease is driven by a lower number of customer connections than forecasted. This is

essentially the difference between forecast number of connections, updated within relevant year

forecasts and actual number of customer connections, for 2020 and 2019.

3.3.2. Adjustments relating to Indexation (-€16.59m)

This accounts for indexation being different to 2019 and 2020 forecasts. This is essentially the

difference between HICP forecasts, updated within year HICP forecasts and actual HICP for

2019 and 2020.

3.3.3. Adjustments relating to under-collection (€83.02m)

An increase of €83.02m has been included in the k-factor adjustments to account for less

revenues being collected than forecasted through DUoS tariffs over 2019 and 2020. This is

essentially the difference between revenue collection forecasts, updated within year revenue

collection forecasts and actual revenue collection over 2019 and 2020.

As mentioned throughout the paper, ESB Networks has estimated an under-recovery of

revenues in 2020 due to Covid-19, i.e. €64m. This one of the main drivers for the increase in

distribution tariffs.

3.3.4. Adjustments for incentives (-€12.17m)

A reduction of €4.04m has been applied to the k2019 factor to account for 2019 calendar year

incentives outturn values (outturn values for 2020 are not available at this stage). The incentives

were calculated using the values in the table below and incentive values applying to deviations

from target levels, as outlined in CER/18/087 – CRU’s decision on reporting and incentives

under PR4. It should be noted that CER/18/087 redistributed 2016 and 2017 pots to the 2018,

2019 and 2020. This had the effect of increasing the upper and lower bounds of the incentive

payments.

In addition to the €4.04m, the CRU will recoup an additional €8.13m (2019 prices). This is

because in the PR4 decision paper, the CRU included an €8m (2014 prices) incentive

placeholder in the allowed revenues for 2019.

Therefore, the total amount to be recouped from the 2021 allowed revenues is -€12.17m.


12

Incentive Target/Forecast Actual Difference Payment/Penalty(€m)

Customer Minutes Lost (CML)10

77.20 (CML) 87.47 (CML) -10.27 (CML)

-€2.79m

Customer Interruptions (CI)11

102.20 (CI) 122.78 (CI) -20.58 (CI) -€4.42m

Customer Satisfaction 90% 91.2% 1.2% €0.87m

Customer satisfaction Survey (redC poll)

81% 80.8% -0.2% -€0.14m

one-meter reading per year

98% 97.8% -0.2% €0m

Avoiding back to back block estimates (meters)

99% 99.94% 0.94% €0.86m

Stakeholder Engagement (Score from 1-10)

10 7.512 -2.5 €0.56m

Delivering New Connections (ECP-1)13

N/A N/A N/A €0.51m

Smart Metering 10k meters installed by 31

December

15k units 5k units

€0.51m

Total -€4.04m

Table 5: Incentive values.

3.3.5. The Strategic Innovation Fund (€10.16m)

The revenue mechanism for the SIF established in PR4 is that the full payment of €20m is

awarded ex-ante, performance is then measured ex-post. The CRU has scored the ESB

Networks’ performance over 2019 as strong, allowing the DSO to keep the €20m relating to

2019 that were already included in the PR4 decision. The CRU welcomes the significant

improvements that were made by ESB Networks on last year; however, the CRU will be seeking

for further improvements next year.

10 Average number of minutes without supply per customer connected in the year (CML). 11 Average number of interruptions per 100 customers connected in the year (CI). 12 Score provided by the Networks Stakeholder Engagement Evaluation Panel (NSEE) Panel, set out by the CRU and made up by stakeholders. 13 The ECP-1 incentive payment, i.e. €1.5m between 2018 and 2020, will be based on the DSO’s performance in issuing connection offers to all applicants processed under the ECP-1 batch. The target to get 100% of the incentive available is “all offers being delivered” by the 31st of May 2020. Performance will be assessed by the CRU when a close-out report is submitted from the DSO, i.e. by the end of October 2020. An amount of 0,51m was included in the 2019 outturn as a placeholder (note that an amount of €0,51m was included in the 2018 outturn as a placeholder), this will be corrected in future years through the k-factor mechanism.


13

The CRU has also decided that €10.16m (2019 prices) will be made available to ESB Networks.

This amount was withheld last year, as some issues were identified in the 2018 SIF submission.

The issues, which were explained in the CRU’s information paper of last year (CRU/19/102),

have been addressed by ESB Networks in the 2019 SIF submission.

3.3.6. CRU Safe Electric Campaign (€0.32m)

A figure of €0.46m has been included to cover the costs associated with the 2020 safe electric

advertising campaign. The underspend on the previous year’s allowance of €0.14m has been

netted off the requirement for the following year. Therefore, a total amount of €0.32m has been

included in the k-factor adjustments.

3.3.7. Miscellaneous Income (-€7.65m)

ESB Networks has proposed a credit of €7.65m to reflect miscellaneous incomes earned by

ESB Networks. Miscellaneous incomes typically include revenue from categories such as sale

of scrap and profit on sale of assets. A reduction of €7.65m has been applied to the k-factor

adjustments.

3.3.8. Electronic Certification, RECI (-€0.15m)

In 2014, the CRU decided to introduce a requirement that electronic certification be put in place

and maintained by the Electrical Safety Supervisory Body (SSB) from 2016. In 2017 the CRU

agreed that funding could be claimed as pass through costs via the network tariff process.

Inclusion of this cost was approved by the CRU in its decision on the 2019 DSO’s Revenues

and 2018/10 DUoS Tariffs14. It was decided that the on-going operation of this process will not

be funded through DUoS, this arrangement is confined to the project costs.

The forecast cost approved relating to 2019 was €0.16m. The actual cost incurred in 2019 by

ESB Networks was negligible as the CRU has now taken on the tendering for this project and

ESB Networks resources were not required. This results in a decrease of €0.15m accounted for

in the k-factor adjustments.

3.3.9. Smart Metering Opex (-€0.27m)

The CRU’s decision on the 2020 DSO’s Revenues and 2019/20 DUoS Tariffs decision15

included an amount of €4.1m in respect of the customer engagement and awareness activities.

ESB Networks’ current expectation of total operating costs for the project to the end of 2020 is

circa €3.8m; and therefore, a reduction of €0,27m has been included in the k-factor adjustments.

14 The Electricity Distribution Network Allowed Revenue 2019 and the DUoS Tariffs & DLAFs 2018/2019. 15 The Electricity Distribution Networks Allowed Revenue 2020 and the DUoS Tariffs & DLAFs 2019/20.

https://www.cru.ie/wp-content/uploads/2019/08/CRU19102-Electricity-Distributution-Tariffs-2019-2020-DLAFs.pdf

https://www.cru.ie/wp-content/uploads/2018/08/CRU18146-Electricity-Distributioution-Tariffs-2018-2019-DLAF.pdf

https://www.cru.ie/wp-content/uploads/2019/08/CRU19102-Electricity-Distributution-Tariffs-2019-2020-DLAFs.pdf


14

3.3.10. Secure Solution of Supplier of Last Resort, non-capitalised (€0.08m)

The CRU approved the secure metering solution for the Supplier of Last Resort (SoLR) and

associated costs in January 2020 i.e. €165,000 capex and €34,000 annual opex. The project

will ensure the ease of transfer of prepayment customers to the electricity SoLR’s Secure profile

and ensure continuity of supply for these customers. The costs will be incurred from 2020 to

2025 in alignment with the Smart metering roll out. The opex input has been calculated by ESB

Networks as the €34,000 approved annual opex and an estimated 10% in overhead costs from

ESB Networks’ resourcing requirement:

The CRU has included an amount of €0.04m in both years, 2019 and 2020 (a total amount of

€0.08m), and therefore these amounts are reflected in the k2019 and k2020 factors. The

amounts represent the expenditure that will be incurred by ESB Networks in 2020 and 2021.

Inclusion of the costs in the k2019 and k2020 factors will allow ESB Networks start recovery of

the costs through the 2020/21 DUoS tariffs.

3.3.11. Secure Solution of Supplier of Last Resort, capitalised (€0.09m)

The capex input has been calculated as the €165,000 approved capex with an estimated 10%

in overhead costs from ESB Networks’ resourcing requirement. The revenue requirement is

calculated by reference to the annual depreciation of a five-year life and a required return on the

PR4 WACC of 4.95%. The calculations are included in the revenues model published alongside

this paper.

The CRU has included an amount of €0.02m for 2019 and an amount of €0.07m for 2020 (a

total amount of €0.09m), and therefore these amounts are reflected in the k2019 and k2020

factors. The amounts represent the expenditure that will be incurred by ESB Networks in 2020

and 2021. Inclusion of the costs in the k2019 and k2020 factors will allow ESB Networks start

recovery of the costs through the 2020/21 DUoS tariffs.

3.3.12. Smart Metering Capex (€0.27m)

This was based on a CRU’s decision made in CER/16/249 , in which the CRU deferred the 2016

€100m placeholder, pertaining to the Smart Metering programme because ESB Networks did

not progress the Smart Metering programme as had been envisaged under the PR4 decision

paper. Smart capex adjustments were made to the allowed revenues from 2017 to 2020,

inclusive. ESB Networks has indicated that due to the commencement of PR5, this is no longer

a required adjustment and therefore no adjustment to the 2021 revenues is necessary. The

amount of €0.27m is to correct for inflation rates applied to the Smart Metering Capex related

adjustments made in 2019 and 2020.

3.4 Comparing the 2021 with the 2020 revenues

The 2021 calendar year revenue of €920.74m (2021 nominal) has led to an increase of €81.4m

or c.10% compared to the 2020 calendar year revenue of €839.3m (2020 nominal). The DUoS

tariffs are not set on a calendar year basis, and therefore interested parties may find it more

useful to compare the AUPs between tariff periods as discussed within the next section.


15

4. The DUoS tariffs for the 1 Oct 2020 to 30 Sept 2021 period

This section provides detail on how portions of calendar year revenue are allocated for recovery

within the DUoS tariffs that are implemented from 1 October to 30 September.

4.1 Revenue for recovery during Oct 2020 to Sept 2021

The approved methodology sees 26.7% of the 2020 calendar year revenue (26.7% of €839.3m

= €224.09m) and 73.3% of the 2021 calendar year revenue (73.3% of €920.74m = €674.90m)

being allocated to the tariff period from 1 October 2020 to 30 September 2021. Therefore, a

total of €899m is to be recovered during the 1 October 2020 to 30 September 2021 tariff period.

This represents a c.8% increase relative to the €836.1m that was approved for recovery during

the equivalent period for the previous tariff year (1 October 2019 to 30 September 2020).

4.2 The DUoS tariffs for Oct 2020 to Sept 2021

The DUoS tariffs for the 1 October 2020 to September 2021 period have been calculated by the

DSO to allow recovery of the revenue €899m as detailed in this paper.

While the DSO does not collect its revenue on a per kWh basis, it is useful to compare the

Average Unit Price (AUP). The CRU’s AUP is calculated by dividing the total allowed revenue

by the total forecast units of electricity sold for 2020/2021 (measured in kWh), which is available

in the CRU’s revenues model. This is a very simplistic way of comparing average unit prices

when moving from one “tariff period” (12-month period, starting each October) to the next. This

is very different to the DSO’s tariff calculation. The DSO’s calculation includes forecasts of the

number of electricity customers, and customers’ contracted electricity demand capacity, as well

as electricity units sold. The DUoS tariffs calculation is also influenced by Large Energy User

(LEU) rebalancing, as per CER/10/198. The CRU will shortly start considering whether the

application of the LEU rebalancing remains necessary for future tariff years.

Given the AUP and DUoS tariffs are calculated in different ways, and represent slightly different

things, the DSO’s customer impact analysis will always vary from the CRU’s AUP. It happens

that in the 2020/21 tariff year, both the AUP and the DUoS tariffs are increasing similarly i.e.

c.12% on the previous tariff year.

Based on the DUoS revenues and the estimated tariff period demand, the AUP for the 1 October

2020 to 30 September 2021 tariff period is estimated to be approximately 3.75c/kWh. This is an

increase of c.12% relative to the 3.36c/kWh AUP for the previous tariff period. The percentage

change in the DUoS tariffs for 2020/21, as calculated by ESB Networks, is an increase of

approximately 11.62%.



16







The DUoS tariffs for previous years are published on the CRU website18. For convenience, there

is a customer impact analysis showing the amount of DUoS paid by an average customer

(broken down by category) under the current and new tariffs provided in Appendix 1 of this

paper.

It should be noted that a flat DUoS rate will apply to the three time bands (day/night/peak) of the

new Time of Use (ToU) tariffs in 2021 as an interim solution. This is indicated in the DSO’s

schedule of the DUoS charges, published alongside this information paper. The CRU plans to

start a full review of the tariffs structure in 2020 with the aim of ensuring that network tariffs are

fit for purpose.

16 DG1, standard 24h tariff. 17 The Electricity and Gas Retail Markets Monitoring Report 2019 will be published on the CRU’s website shortly. 18 The tariffs that are currently in place (covering the period 1 October 2019 to 30 September 2020) are available here.

https://www.cru.ie/wp-content/uploads/2019/08/CRU19102a-Schedule-of-Distribuber-2019-%E2%80%93-30th-September-2020.pdf


17

5. Distribution Loss Adjustment Factors The CRU has approved the Distribution Loss Adjustment Factors (DLAFs) for implementation

from 1 October 2020 to 30 September 2021. DLAFs are applied to the metered consumption of

relevant customers to apportion distribution losses to energy consumption or production

metered at end user sites. In the electricity market, electricity suppliers must pay for energy

(kWh) measured at the customer meter and the losses (DLAFs). For example, if a customer

consumes 3,000kWh of energy the supplier is responsible for the associated losses in addition

to the customer’s energy consumed. In order to determine the total kWh, we must multiply the

customer’s energy consumption by the relevant DLAF, which is 1.087. Therefore, the supplier

is responsible for 3,261kWh19. DLAFs are also applied to distribution connected generation.

The DLAFs for the 1 October 2020 to 30 September 2021 period are published alongside this

paper and are also provided in the table below. The values from the previous period (October

2019 to September 2020) are available on the CRU website20 and for ease of reference have

also been provided in the table below.

Voltage Level Time Period

Composite Day Night

38kV Sales 1.019 1.021 1.017

MV Sales 1.035 1.037 1.030

LV Sales 1.087 1.093 1.075

Table 7: The DLAFs for the 1 October 2020 to 30 September 2021 period.

Voltage Level Time Period

Composite Day Night

38kV Sales 1.020 1.021 1.017

MV Sales 1.035 1.037 1.030

LV Sales 1.087 1.093 1.075

Table 8: The DLAFs for the 1 October 2019 to 30 September 2020 period.

19 (1.087 x 3,000kWh). 20 www.cru.ie

http://www.cru.ie/


18

6. Summary of review This information paper outlines the allowed electricity distribution network revenues for ESB

Networks for the 2021 calendar year. This revenue is to be collected during the 2020/21 tariff

year period and will cover the costs of ESB Networks in its role as the DSO and DAO.

The paper outlines:

• The ESB Networks’ allowed revenues approved for the 2021 calendar year; and,

• the Demand DUoS tariffs approved for implementation during the tariff period from 01

October 2020 to 30 September 2021.

The total distribution allowed revenues for the 2021 calendar year are €920.74m (2021 prices).

This represents an increase of c.10% compared to the €839.3m allowed revenues for 2020.

The total distribution allowed revenues for the DUoS tariff period from 01 October 2020 to 30

September 2021 are €899m. This is an increase of c. 8% relative to the €836.1m that was

approved for recovery for the period from 01 October 2019 to 30 September 2020.

Based on the DUoS tariff period revenues and the estimated tariff period demand, the AUP for

the 1 October 2020 to 30 September 2021 tariff period is estimated to be approximately

3.75c/kWh. This is an increase of c.12% relative to the 3.36c/kWh AUP for the previous tariff

period. The percentage change in the DUoS tariffs for 2020/21 is an increase of approximately

11.62%.










19

Appendix 1: The DUoS payments made by the average customer

The below table gives a customer impact analysis showing the amount of the DUoS paid by an

average customer’s (broken down by category) under the current and new tariffs.

DUoS payments made by average customer

kWh MIC* Oct 19 – Sept 20 tariffs, €

Oct 20 - Sept 21 tariffs, €

Change €

Change %

DG1: Urban Domestic - Standard Meter 3,713 n/a 214.3 239.2 24.9 11.62%

DG1: Urban Domestic - Dual Meter 6,849 n/a 256.8 286.6 29.8 11.62%

DG2: Rural domestic - standard meter 4,136 n/a 261.6 292.0 30.4 11.62%

DG2: Rural domestic - dual meter 13,060 n/a 503.6 562.1 58.5 11.62%

DG3: Unmetered 18,125 n/a 607.7 678.3 70.6 11.62%

DG5 with a standard meter 10,809 n/a 573.3 639.9 66.6 11.62%

DG5 with a dual meter 30,518 n/a 1,178.1 1,315.0 136.9 11.62%

DG6 240,894 120 9,632.7 10,752.0 1,119.3 11.62%

DG7 2,992,100 1,055 23,519.8 26,252.7 2,732.9 11.62%

DG8 17,490,995 5,249 67,820.2 75,700.7 7,880.4 11.62%

DG9 885,818 1,826 18,477.6 20,624.6 2,147.0 11.62%

Table 9: DUoS payments made by average customer.

* The average MIC of customers in DG6 - DG9 excludes DG (a) customers as they do not pay

capacity charges.

the electricity distribution network allowed …...electricity to approximately 2.4 million irish...

Documents