Prior to examining the fundamental reasons for my rejection, I wish
to state that the service rendered by TTEC to the national community
is less than satisfactory.
A reliable supply of electricity is crucial to the success of any
economy and the Commission’s ability to maintain a regular
supply is questionable.
In fact, there have been continuous and lengthy blackouts throughout
the country.
St. Augustine South has been particularly hard it by blackouts within
recent months.
In all fairness to TTEC, after making representation to the Commission
on behalf of the residents of that area, we have noticed a marked
reduction in the interruption of service.
The Commission did respond to my intervention, however, no date
was given for the completion of maintenance work in an effort to
boost supply to Bamboo Settlement.
The San Juan region has also been hard it with disruption in the
service of electricity.
The area in San Juan that is being referred to is North of the Croisee
along Saddle Road and environs.
Several businessmen and women from this area have complained to
me about these interruptions.
Reference was made to two days in particular where on October 1,
2005, service was interrupted for just over six hours.
I was also told that the situation could have been corrected in
much less time. Another incident occurred on October 20, 2005 when
service was disrupted for practically the entire day.
This, of course, is unacceptable and the Electricity Commission
must be ever mindful of the delivery of service before any request
for a rate increase can be considered.
I am sure that TTEC will argue that in order to provide a better
service, there will be need for upgrades that will cost additional
funding.
This argument is a ruse.
It will depend on more effective management of resources and a penchant
for reducing cost.
I now turn to the fundamentals behind the rejection of a rate increase
for the Trinidad and Tobago Electricity Commission. Electricity
is an extremely important component of all citizens, essentially
a crucial commodity in their public and private lives.
Electricity bills have increased annually reflecting increases in
the fuel (which may rise due to gas price increases and conversion
inefficiencies) and foreign exchange rates, the latter covering
not only conversion cost in US dollars but also on capital acquisition.
The business sector also has several concerns about the proposed
rate increase.
They have narrowed it down to the following six:
1. Initial cash flow requirement, which is based on an assessment
and valuation of the Regulated Asset Base (RAB) and computation
of future demand load.
2. The issue of the role of dividends from PowerGen in the cash
flow computation.
3. The gas supply price and contractual increases and its effect
on pricing.
4. The bulk power supply contracts, the ability of TTEC to police
them and their effect on TTEC costing.
5. The issue of cross sub-sidisation between tariff categories.
6. Productivity and performance measurements.
The following is the private sector’s assessment of the aforementioned
points.
1. Initial Cash Flow Requirement
In attempting to arrive at the quantum of increase for
the initial period, it is being suggested by the RIC’s consultant,
Kenesjay Systems Limited that TTEC uses an Average Incremental Cost
per kWh of electricity for the period 2005 - 2008, which dictates
the projected investments required and the incremental demand expected
for this period.
This will provide an upper limit for TTEC unit revenue.
The lower limit will be established by determining the Required
Cash Flow, which estimates a price level that allows the Company
to sustain its investment programme under realistic financing assumptions
that covers debt service, interest payments, tax liability and contributions
to the investment programme.
It is being suggested that the increase be based on an average figure
between these two benchmarks.
This methodology is being proposed by Kenesjay Systems Limited because
the TTEC asset records are in a chaotic state and have never been
reconciled physically with their accounting records.
As a result, the Regulated Asset Base is unknown and it is expected
that the exercise to correct this will be completed by the end of
2006.
Our serious concern is that improper estimation will result in a
significant initial increase in tariffs.
The more prudent approach would have been to force the utility to
put its house in order, so as to get a true picture of its capital
and investment requirements.
It would also serve to assure the public that the utility has the
managerial capability and efficiency to move forward, since we understand
that this asset accounting exercise has been attempted many times.
2.Exclusion of PowerGen Dividend
The issue of excluding PowerGen dividends in the cash
flow demand computation on the basis that it is dependent on the
performance of another corporate entity, which is not in their control,
is not sound, since it is a long-term contract (renewable in 2009),
has been relatively consistent and accounts for 7 per cent of TTEC
revenues.
In addition, it has greater certainty of being paid than TTEC’s
receivables!
3. Gas Supply Contracts and Effect on Pricing
The gas supply contracts need to be urgently reviewed,
since the annual escalation clause (4 per cent) in the current contract
has the effect of compounding the increases by impacting both TTEC
account payables and debt interest charges.
The government needs to renegotiate another low price gas contract
for electricity, such as the 20-year contract negotiated with AMOCO
in 1974.
The prime minister, at the completion of the LNG Train IV negotiation,
stated that he had negotiated free gas for TTEC, which acknowledged
that electricity is a social commodity.
We need clarification on this, since this must have an impact on
future rate increases, or shall we say decreases?
It must also be stressed that electricity is the only direct benefit
that the general population receives from our gas patrimony.
4. Bulk Power Supply Contracts
The bulk power supply contracts with PowerGen and Trinity
Power must be renegotiated and made public and it is insufficient
for the RIC to merely state that this conversion cost (43 per cent)
is uncontrollable.
It is indeed unfortunate that the government and TTEC missed the
opportunity to purchase both of these enterprises, which have changed
ownership in recent times.
Ownership would have had the effect of correcting the adverse contractual
obligations entered into by TTEC and the government.
The RIC position that the 70 per cent of TTEC cost structure represented
by the gas supply contract and the conversion by PowerGen and Trinity
Power is uncontrollable and outside its purview is untenable, since
both generating companies fall under its ambit.
The rate of return for zero risk investments in other jurisdictions
is approximately five to six per cent.
What returns are these two generators making?
Most power generators have to procure their own fuel source for
conversion, why must this exception continue here?
Notwithstanding, TTEC has been negligent in policing its own interest
as outlined in the RIC document.
The heat transfer rate and conversion efficiency requirements have
not been meticulously monitored under the bulk power supply contracts.
The power generators, already without incentive to operate efficiently
because of their free gas and take or pay contract, have been allowed
to do so with impunity.
It is important that these contracts be presented for public scrutiny,
and full disclosure be made regarding concessions and benefits given
to these two companies.
5. Cross Subsidisation between Tariff
Categories
TTEC has indicated that the commercial and industrial
tariff sectors are making profits, which are being used to subsidise
residential customers.
We fully support the RIC’s position that each tariff segment
must pay for its true efficient cost.
In the residential category, government must recognise that electricity
is a social commodity, any difference in cost of providing it to
households, ought to come from the Treasury and not from other customers,
in a manner similar to the gas subsidisation at National Petroleum.
6. The Productivity and Performance Measurements
Regime
The productivity and performance measurements regime must
be instituted and reported on a regular basis.
The performance indicators suggested by the RIC are comprehensive
and the Private Sector Organisations support their urgent implementation.
CONCLUSION
The Trinidad and Tobago Electricity Commission has made an insufficient
case for a rate increase at this time.
In addition to this, any increase in the rate of electricity will
lead to an escalation in the rate of inflation, which is already
too high.
The population has had to grapple with rising food prices for the
past year and will not be able to absorb any additional cost without
reverting to a reduction in the standard of living.
As mentioned by the private sector, electricity is a social commodity
and should be subsidised as is the case with National Petroleum
and gas prices.
TTEC has not made its case. Let us now hope that the Regulated Industries
Commission will reject the Commission’s petition at this time.
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