Pipes & Wires

INSIGHT AND ANALYSIS OF TOPICAL ENERGY & INFRASTRUCTURE ISSUES

Issue 135 – July 2014

 

From the editor’s desk…

 

Welcome to Pipes & Wires #135 … we start this month with an extensive review of regulatory and policy decisions in New Zealand. We then look at changing energy policies in Canada and the United States, and then look at a competition law approval and a policy shift in Australia. This issue closes with a review of possible large gas finds in South Africa. Please also reply to the pop quiz below.

 

Pop quiz #135

 

Which asset investment decision would you have more confidence in (pick one of the links below) ??

 

·     A decision that was high in engineering judgment but with possibly inaccurate data.

 

·     A decision with weak engineering judgment but with totally accurate data.

 

Recent client projects

 

Here’s a sample of work done for clients over the last few years that demonstrate the breadth of skills, insight and experience that is available from Utility Consultants....

 

·     Assessing a large EDB’s asset management practices against ISO 55000:2014.

 

·     Advising an investor on the investment characteristics and regulatory constraints of small hydro development and grid connection.

 

·     Reviewing the engineering aspects of an EDB’s lines pricing methodology.

 

·     Advising a major global consultancy on specific features of emerging electricity transmission and distribution regulatory regimes, including period length, potential for re-opening determinations, caps & collars, total expenditure levels and incentive mechanisms.

 

·     Examining the economic efficiencies of an EDB’s pricing methodologies.

 

·     Advised on the wider philosophical and potential tax issues of the way consumer discounts are paid by EDB’s.

 

·     Prepared an independent engineer’s report to justify proposed alternative asset lives.

 

·     Advised an electricity business on the regulatory implications of bringing externally contracted field services back in-house.

 

·     Identified economic and regulatory arguments to support inclusion of transmission interconnection charge risk into network tariffs.

 

·     Advised lines businesses on a regulator’s proposed treatment of CapEx and OpEx.

 

·     Advised an international investor on gas distribution policy and regulatory trends.

 

·     Identified national energy policy implications for lines businesses.

 

·     Assisted a lines business to identify the burden of proof implied by regulatory determinations.

 

·     Suggested amendments to a gas transmission AMP to strengthen the economic arguments.

 

·     Identified electricity network investment characteristics as part of an acquisition study.

 

·     Developed an AM framework for a gas distribution business to link AM to regulatory requirements.

 

·     Identified OpEx – CapEx tradeoffs for an electricity lines business.

 

·     Performed various substation growth and reinforcement assessments.

 

·     Performed network physical and business risk studies.

 

·     Compiled disaster recovery and business continuity plans.

 

Pick here to download a profile of recent projects, or here to contact Phil.

 

Matters for attention in NZ

 

Readers’ attention is drawn to the following matters…

 

·     Revised standard NZS7901:2014 for Safety Management Systems.

 

·     Likely increased obligations for worker safety.

 

New Zealand

 

NZ – resetting the electricity Default Price Path

 

Introduction

 

The Commerce Commission recently released its Draft Determination of the Default Price Path (DPP) that will apply to the 16 non-exempt electricity distribution businesses (EDB’s) for the 5 period commencing on 1st April 2015 (and to Orion when its Customised Price Path expires). This article examines the key features of the Draft Determination.

 

Legal framework

 

The legal framework for the DPP is as follows…

 

·     Part 4 of the Commerce Act 1986 provides the broad framework for regulated goods or services.

 

·     Subpart 6 of Part 4 specifically addresses the Default and Customised Price-Quality Regulation, with ss 52O and 52P setting out the specific features that a DPP must include.

 

 

·     s54D(1) defines the criteria that an EDB must meet to be exempt from the DPP.

 

 

The Commission’s previous work

 

The Commission’s previous work has included extensive deliberation on information forecasts, on quality and performance incentives, treatment of risk, and how claw back should be applied. Pipes & Wires #127, #129 and #132 discuss these issues.

 

Key features of the Draft Determination

 

Key features of the Draft Determination include…

 

·     The following starting prices (MAR) and annual rates of change shall apply…

 

Company

Maximum Allowable Revenue ($m)

Annual rate of change

Alpine Energy

$30.913

10.0%

Aurora Energy

$56.590

0.0%

Centralines

$10.084

6.0%

Eastland Networks

$22.681

3.5%

Electricity Ashburton

$32.846

2.0%

Electricity Invercargill

$14.556

0.5%

Horizon Energy

$22.047

0.5%

Nelson Electricity

$6.093

0.0%

Network Tasman

$28.729

0.0%

OtagoNet

$23.742

0.0%

Powerco

$256.527

0.0%

The Lines Company

$35.816

0.0%

Top Energy

$35.020

7.0%

Vector

$396.831

0.0%

Wellington Electricity

$100.482

0.0%

 

·     The following SAIDI targets, collars and caps shall apply (revenue at risk from the collar & cap approach is 1%)…

 

Company

SAIDI collar

SAIDI target

SAIDI cap

Alpine Energy

78.77

147.60

216.44

Aurora Energy

61.41

86.80

112.20

Centralines

100.94

137.19

173.44

Eastland Networks

206.03

246.60

287.16

Electricity Ashburton

109.27

139.55

169.83

Electricity Invercargill

17.51

29.16

40.80

Horizon Energy

124.54

170.64

216.73

Nelson Electricity

5.55

15.13

24.7

Network Tasman

102.54

126.03

149.52

OtagoNet

171.51

233.61

295.70

Powerco

166.19

222.32

278.44

The Lines Company

201.33

238.81

276.30

Top Energy

364.24

445.99

527.75

Vector

81.52

106.64

131.77

Wellington Electricity

24.92

37.12

49.31

 

Next steps

 

The Commission will receive submissions on this Draft until 29th August 2014, and will release its Final Decision by 30th November 2014.

 

NZ – reviewing the WACC Input Methodology

 

Introduction

 

The Commerce Commission has been re-considering the use of the 75th percentile of the WACC range for regulated infrastructure in response to comments made by the High Court in a recent legal case. This article examines the details of this matter that have emerged to date.

 

Legal framework for the Input Methodologies

 

The legal framework for Input Methodologies (IM’s) is set out in Subpart 3 of Part 4 of the Commerce Act 1986 and has the stated purpose of “promoting certainty for supplies and consumers in relation to the rules, requirements and processes applying to the regulations or proposed regulations…”. Specific sections include…

 

·     s52T(1)(a)(i) requires an IM to be compiled for to address the cost of capital.

 

·     s52U requires the IM’s to be determined no later than 30th June 2010.

 

·     s52Y requires the Commission to review each IM no later than 7 years after its date of publication.

 

Surrounding issues

 

There are several surrounding issues that must also be considered…

 

·     The High Court’s remark about the suitability of the 75th percentile appears to have prompted inquiries from major infrastructure users.

 

·     There is the need to provide certainty for the resetting of the electricity distribution default price path (DPP) prior to November 2014, and also to provide certainty for the Transpower individual price path (IPP).

 

·     The over-arching requirement for the regulatory framework to encourage investment.

 

Events to date

 

S52X of the Commerce Act 1986 requires a material change to an IM to be treated as if it were a new IM, which invokes the procedural requirements set out in s52V. Understandably, regulated infrastructure companies were concerned about the possibility of a significant decrease in WACC, and took the opportunity to make submissions to the Commission.

 

The Commission has also sought advice from a range of experts (although the Commission has made it clear that those reports do not represent the Commission’s official view).

 

The Commission’s Draft Decision

 

The Commission’s Draft Decision was released in late July 2014 and comprises two components…

 

·     Energy companies should be subject to a 67th percentile WACC instead of the 75th percentile currently used. The Commission recognises that it is appropriate to use a WACC significantly above the mid-point because the cost of under-investment outweighs the costs of over-investment.

 

·     A range from the 33rd to the 67th percentile of the WACC distribution should be used for Information Disclosure instead of the currently used 25th to 75th percentile.

 

The WACC percentile for airports will be addressed separately.

 

Next steps

 

The Commission will receive submissions on its Draft Decision until Friday 29th August 2014, and expects to release a Final Determination during November 2014.

 

NZ – improving distribution efficiency

 

Introduction

 

Those overseeing the infrastructure sectors have a general concern about the sector’s efficiency. This article examines the Electricity Authority’s (EA) recently released Statement Of Intent for 1st July 2014 to 30th June 2018 to see what might be around the corner for the distribution segment of the electricity supply chain.

 

Legal basis for the SOI

 

The legal requirements for preparing a SOI are set out in the Crown Entities Act 2004 as follows…

 

·     s139 requires a Crown Entity to prepare a SOI covering at least the 3 following years.

 

·     s141 defines what the SOI must include, especially the outcomes that the entity is expected to achieve or contribute to.

 

Overall direction of the EA’s work

 

Following on from the statutory objectives in s15 of the Electricity Industry Act 2010, the overall direction of the EA’s work is to address the following questions (Source – SOI 2014 – 2018)…

 

·     Are prices reasonable ? Do prices reflect the efficient costs of supplying customers ?

 

·     Will the lights stay on ? Do market arrangements ensure continuity of supply even in dry years and during foreseeable short-term emergencies ?

 

·     Do consumers have choices ? Do consumers face any unnecessary barriers to switch to get the best deal for them ? Can large customers participate appropriately in the market ?

 

·     Is innovation occurring ? Do suppliers develop new services and pricing plans to deliver greater value to customers ?

 

The likely impacts on the distribution segment of the electricity supply chain

 

Table 5 of the SOI sets out the EA’s strategies and impact measures, and at first glance embodies a lot of high-level phrases like…

 

·     more level playing field.

 

·     reduced set up costs.

 

·     reduced instances of inefficient prices.

 

However a more detailed read under the heading of “Providing efficient price signals” reveals two areas of focus that are likely to impact on distribution…

 

·     more efficient price signals for residential and SME consumers.

 

·     improved efficiency in transmission and distribution networks.

 

More efficient price signals

 

The EA has been undertaking a major work stream around the efficiency of distribution pricing methodologies, and in particular ensuring that individual EDB’s pricing methodologies comply with a range of economic efficiency principles. However the pursuit of economic efficiency must be balanced against (i) a range of practical factors such as billing simplicity and minimsing the number of distribution tariffs to a workable level, and (ii) wider industry regulations and expectations such as the use of variable tariffs to recover fixed costs, low-user tariffs, and the repackaging of distribution charges by retailers.

 

Improving network efficiency

 

The focus on productive efficiency lies principally with the Commerce Commission’s price control role under Part 4 of the Commerce Act 1986, however the EA presumably does have a role in contributing to allocative and dynamic efficiency which in practice appears to mean encouraging allocation of resources to supply continuity and restoration at about the current prices, and ensuring that EDB’s are incentivised to smoothly transition into the future (of which a large part will be leveraging the smart meter data to further refine investment levels and pricing).

 

NZ – amending the electricity distribution services Input Methodology

 

Introduction

 

The Commerce Commission recently released a consultation paper on proposed amendments to the Input Methodologies (IM) for electricity distribution services. This article examines what those proposed amendments are.

 

Legal framework for the IM

 

The legal framework for the IM’s is Subpart 3 of Part 4 of the Commerce Act 1986. This subpart inter alia sets out the purpose of the IM’s, what issues they must address, and the process for establishing and amending IM’s.

 

Proposed changes

 

The Commission proposes to amend the IM as follows…

 

·     Adopt a mid-year timing assumption for the definitions of notional deductible interest for tax treatment, rather than the year-end payments assumed by the current model.

 

·     Correct for the incorrectly allowed double deduction of the term credit spread differential allowance for the regulatory tax allowance.

 

·     Correct the amortisation of initial differences in asset values.

 

Interested readers should read the consultation paper and the associated documents before forming a view.

 

Next steps

 

At the time of writing the Commission is consulting on the proposed amendments, and received submissions until 5pm on Friday 18th July 2014. The Commission expects to make its final decisions by 30th September 2014.

 

NZ – amending the electricity Information Disclosure Requirements

 

Introduction

 

The Commerce Commission recently published a Process Paper in regard to amending the Information Disclosure requirements for electricity distribution and gas pipelines for the 2015 disclosures. This article examines those proposed amendments.

 

Legal framework

 

The legal framework for information disclosure includes the following aspects…

 

·     Subpart 4 of Part 4 of the Commerce Act 1986 which defines the purpose of information disclosure, and provides for a Determination made under s52P to define the types of information to be disclosed.

 

·     s54F which makes all electricity lines services subject to information disclosure.

 

·     s55C which similar makes all gas pipeline services subject to information disclosure.

 

The Commission’s process

 

The Commission has been operating an issues register for electric and gas companies to record issues and concerns with the existing disclosure requirements, and expects to prioritise these issues on the basis that high impact, low complexity issues will receive high priority.

 

Next steps

 

The Commission received submissions on the Process Paper until 5pm on 11th July 2014, and expects to publish its Draft Decision by in September or October 2014 after which a 4 week consultation period will follow. A Final Decision is expected in February 2015.

 

North America

 

Canada – examining Ontario’s energy policy

 

Introduction

 

Last month Ontario’s Liberal premier Kathleen Wynne was returned to office with a majority that no longer relies on the support of the New Democrats. This article examines what that could mean for Ontario’s energy policy against a backdrop of a world in which strongly articulated energy policies are diluted by the practical necessities of coalition politics.

 

The election results

 

The election results were as follows…

 

Party

Prior to the election

After the election

Liberal Party

48 seats (45%)

58 seats (54%)

New Democrats

21 seats (20%)

21 seats (20%)

Progressive Conservative

37 seats (35%)

28 seats (26%)

Vacant

1 seat (1%)

0 seats (0%)

 

It appears that the Liberals gain has come almost totally at the expense of the Progressive Conservatives.

 

How the election might effect the Liberals’ energy policies

 

Given that the New Democrats have been scathing of the Liberals in the past and had a specific policy position of reducing domestic electric bills, it is expected that the Liberal’s increased majority will mean full steam ahead for most of their policies. These include…

 

·     Feed In Tariffs program, which will subsidise renewable generation between 10kW and 500kW.

 

·     Large Renewable Procurement Program, which is a competitive bidding process for the Province to purchase renewable energy projects greater than 500kW.

 

·     Conservation First framework, which will achieve a 7,000 GWh reduction in energy consumption by 31st December 2020.

 

·     Long-Term Energy Storage, which provides for 50 MW of grid storage to be procured by the end of 2014.

 

Where might this lead

 

A quick read of the official publications suggests that there will be a full-on charge into renewables with no obvious concern for costs or security of supply. It is therefore not clear why Ontario won’t end up with the same high prices and declining supply reliability that Germany and the UK are now experiencing.

 

US – rooftop solar, nett metering, fixed tariffs and subsidies

 

Introduction

 

Nett metering has proved to be a dividing line in the battle for rooftop solar. This article tries to get to the bottom of exactly why nett metering seems to be such a sensitive issue.

 

The real issue

 

Firstly we need to understand that nett metering measures … well … uh … the nett kWh entering a customer’s connection. So if a customer generates their own electricity, the nett electricity entering their connection declines so they prima facie pay less to the electric company. A customer that generates lots of electricity may become a nett exporter and in some cases may get paid by the electric company rather than paying them.

 

However the electric company’s costs to own and operate its distribution network are almost totally fixed regardless of the kWh consumed by individual customers, but that of itself is not an issue. The real issue becomes when the electric company must recover those fixed costs on a variable (kWh) basis, because a customer who reduces their nett kWh pays less towards the fixed network costs.

 

So where do subsidies come into this ??

 

In order to recover the fixed costs of owning and operating the distribution network, those costs are divided by an estimated annual kWh throughput to derive a c/kWh charge. So … plain and simple … if the kWh throughput declines, the c/kWh charge must increase.

 

Those customers with generators are likely to try to generate more kWh when they see how much money they can make and how much cost they can avoid, further reducing the kWh throughput. Those without generators are stuck with paying a higher c/kWh charge whilst consuming pretty much the same kWh ie. a subsidy from non-generators to generators occurs.

 

Until recently many policy makers didn’t seem to have a problem with these subsidies … given that it was mainly renewable generators such as rooftop solar that was receiving them. However attention has recently turned to the classes of electric consumers who are paying these subsidies, and not surprisingly large numbers of them are the poor. This appears to have struck a chord in the hearts of some officials who are now searching for a way forward…

 

Recent happenings

 

A few promising happenings in a couple of states are worth examining…

 

·     Massachusetts – provision for electric companies to charge a minimum monthly tariff for those customers with rooftop solar (to contribute to the fixed costs of the distribution network), albeit with the concession that those customers potential earnings will no longer be capped.

 

·     Missouri – as part of the 15% renewables target by 2021 investor-owned electric companies were required to pay rooftop solar customers $2 per Watt of installed capacity. This was phased out in 2013 with the Public Service Commission’s agreement, but progress has been slow due to a law suit to block the phase out.

 

·     Maine – Central Maine Power has proposed adding $3 per month to the average customer’s bill to contribute to the cost of maintaining the distribution network.

 

The fact that electric companies have had to fight tooth and nail against advocacy groups, and in some case policy makers, to obtain the smallest of gains whilst also having to make concessions suggests that the core issue of free-riding is still not well understood.

 

Possible ways forward

 

So … a couple of possible ways forward include…

 

·     Meter all premises on a gross basis rather than a nett basis. Whilst this won’t eliminate the economic inefficiency of recovering a fixed cost with variable charges it will minimise the subsidies.

 

·     Establish a fixed monthly charge based on fuse capacity for connecting to the distribution network, regardless of the direction and amount of kWh throughput. It seems that Massachusetts and Maine are heading this way.

 

The fixed monthly charge will be a big leap across the comfort gap for those who insist that customers should be “charged for what they use”, but it also provides a great opportunity to educate those people that what they are actually using is network capacity and availability. Throw in the possibility of the monthly charge being less because the volume-risk premium could be eliminated and it might get some traction…

 

Australia

 

NSW – AGL cleared to acquire Macquarie Generation

 

Introduction

 

Recent issues of Pipes & Wires have followed the unfolding saga of AGL’s proposed acquisition of Macquarie Generation (MacGen). This article examines the Australian Competition Tribunal’s (ACT) decision to allow the acquisition.

 

Sequence of events

 

The following sequence of events has occurred…

 

·     AGL offers to buy MacGen from the NSW Government for $1.7b (the only acceptable offer).

 

·     The ACCC refuses to allow the acquisition on the basis that it would be likely to lessen competition in the NSW retail market.

 

·     The ACT overturns the ACCC ruling, allowing the acquisition to proceed.

 

AGL’s proposed acquisition of MacGen

 

AGL Energy proposed to pay the NSW government $1.7b for assets that include …

 

·     Bayswater, a 4 x 660 MW hard-coal fired station.

 

·     Liddell, a 4 x 500 MW hard-coal fired station.

 

·     The 50 MW Hunter Valley gas turbines.

 

·     The Liddell solar farm.

 

The ACCC’s refusal to allow the acquisition

 

On the 4th March 2014 the ACCC announced that it opposed the proposed acquisition on the basis that it would be likely to substantially lessen competition in the NSW retail electricity supply market. The proposed acquisition would result in the state’s largest generators being owned by 1 of the 3 largest retailers, which the ACCC claims would both raise barriers to entry and expansion for other retailers and reduce hedge liquidity.

 

The ACT’s overturning the ACCC refusal

 

On the 25th June 2014 the ACT overturned the ACCC’s refusal on the following grounds…

 

·     That “substantial public benefits” would arise from the acquisition.

 

·     That the public detriments identified by the ACCC were “unlikely to arise”.

 

·     That there would still be active competition in the NSW retail electricity market, including access to an adequate hedge market for small retailers.

 

It is noted that the ACCC does have some limited grounds for appealing the ACT’s decision, but otherwise the acquisition is expected to be completed by June 2015.

 

Aus – repealing the carbon tax

 

Introduction

 

Pipes & Wires #132 examined the Abbot Government’s plans to scrap Australia’s Carbon Tax which was blocked in the Senate by 33 votes to 29. This article examines the vote to scrap the Carbon Tax by the newly configured Senate.

 

Abbot’s legislative package

 

Abbott’s legislative package includes the Clean Energy Legislation (Carbon Tax Repeal) Bill 2013 and comprises 7 Bills to inter alia repeal the 6 Acts that established the carbon pricing mechanism.

 

Recent happenings

 

The following events have recently occurred…

 

·         On 23rd June the Abbott Government reintroduced the Repeal Bills.

 

·         During the week of the 7th July, the Senate (the Upper House) rejected the Repeal Bills after the Palmer United Party withdrew its support.

 

·         On 14th July the House Of Representatives (the Lower House) passed the Repeal Bill after making some amendments demanded by Palmer to ensure that savings would be passed to consumers. This passing of the Bill allows it to pass to the Senate for another vote.

 

·         On 17th July the Senate voted 39 to 32 to pass the Repeal Bills. The Abbot Government was supported by 7 new cross-bench Senators

 

Political responses

 

Not surprisingly, the political responses have been hugely divergent with the political right claiming a huge victory for common sense whilst the political left are understandably disgusted.

 

Policy responses

 

The major policy responses include immediate removal of the $25.40 per ton tax on CO2 from Australia’s 350 largest emitters. This is expected to reduce tax revenues by $7b over the next 4 years.

 

Africa

 

South Africa – a bright future for shale gas ??

 

Introduction

 

Most of us have a general idea that most of South Africa’s electricity generation is from coal. This article examines recent news that South Africa has heaps of shale gas, and considers what that might mean in terms of cost, supply and shifts in the mix of generation plant.

 

South Africa’s generation mix

 

About 90% of South Africa’s annually generated 240,000 GWh is from coal-fired stations, with the remaining 10% equally split between nuclear and hydro. South Africa does also have about 2,450 MW of gas turbine stations within its national generation capacity of about 44,000 MW, but it appears that their load factor is pretty low.

 

Likely shale gas reserves

 

It appears that that the Karoo Basin (which actually covers about 65% of South Africa’s land area) alone has about 485 trillion cubic feet (TCF) of technically recoverable gas. That is about 3,200x New Zealand’s annual gas consumption.

 

Changing the dynamics of generation

 

So how might heaps of cheap gas change the dynamics of electricity generation ?? A couple of options spring to mind…

 

·     A reasonable starting point could be that the existing gas turbines could be run as base-load stations, which would generate about 21,000 GWh or about 9% of annual generation.

 

·     Construction of combined-cycle gas turbine generation by either Eskom or by IPP’s (or both).

 

·     Conversion of some of the existing coal-fired six-packs to gas-firing. This would obviously require a lot of engineering work to install gas firing, and probably introduce some inefficiencies around the boiler reheat stages.

 

General stuff

 

Guide to NZ electricity laws

 

I’ve compiled a “wall chart” setting out the relationship between various past and present electricity Acts, Regulations, Codes etc in sort of a chronological progression. To request your free copy, pick here. It looks really cool printed in color as an A2 or A1 size.

 

Recently released book “Small Hydroelectric Engineering Practice”

 

Well-known hydroelectric engineer Bryan Leyland has recently published a book entitled “Small Hydroelectric Engineering Practice”. This is a comprehensive reference book covering all aspects of identifying, building and operating hydroelectric schemes between 500kW and 50MW. Pick here for more details.

 

A bit of light-hearted humor

 

What if price control had been around in the 1920’s and 1930’s ? A collection of photo’s with humorous captions looks at some of the salient features of price control. Pick here to download.

 

Conferences & training courses

 

The following conferences and training courses are planned...

 

·     NZ Coatings & Corrosion Conference & Exhibition – Auckland, 29th – 30th July 2014.

 

·     Fundamentals of the NZ Electricity Industry – Wellington, 23rd – 24th September 2014.

 

·     Fundamentals of the NZ Electricity Industry – Auckland, 7th – 8th October 2014.

 

·     Africa Oil & Gas Expo – Johannesburg, 9th – 10th October, 2014.

 

Utility Consultants takes no responsibility for the content of individual courses or conferences, nor for any administrative or travel arrangements.

 

Wanted – old electricity history books

 

If anyone has an old copy of the following books (or any similar books) they no longer want I’d be happy to give them a good home…

 

·     Wonders Of World Engineering (published 1937) – in particular editions 1 to 27.

 

·     Distribution Of Electricity (WT Henley, the cable manufacturer)

 

·     Northwards March The Pylons.

 

·     Two Per Mile.

 

·     Live Lines (the old ESAA journal).

 

·     The Engineering History Of Electric Supply In New Zealand.

 

House-keeping stuff

 

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Disclaimer

 

These articles are of a general nature and are not intended as specific legal, consulting or investment advice, and are correct at the time of writing. In particular Pipes & Wires may make forward looking or speculative statements, projections or estimates of such matters as industry structural changes, merger outcomes or regulatory determinations. These articles also summarise lengthy documents, and it is important that readers refer to those documents in forming opinions or taking action.

 

Utility Consultants Ltd accepts no liability for action or inaction based on the contents of Pipes & Wires including any loss, damage or exposure to offensive material from linking to any websites contained herein, or from any republishing by a third-party whether authorised or not, nor from any comments posted on Linked In, Face Book or similar by other parties.