From the
editor’s desk…
Welcome
to Pipes & Wires #142. This month we cover a couple of regulatory decisions
in New Zealand and in the UK, and then take a short historical interlude which
marks the start of another series of articles about people in power. We then
update the Exelon-Pepco merger in the US, and examine some solar trends in the
US and in Germany. This issue then concludes with some regulatory and
competition policy issues in Australia and New Zealand.
Matters for attention in NZ
Readers’
attention is drawn to the following matters…
· Changes to operating procedures for
Long & Crawford Manchester (later rebadged as GEC-Alsthom) oil-insulated
combined fuse switches after an explosion in Perth, Australia.
· Changes to the
requirements for connecting embedded generation to
distribution.
· Increasing interest in ISO 55000:2014 in regard to asset management practices and systems, and
the associated withdrawal of BSI PAS 55:2008.
· Revised standard NZS 7901:2014 for Safety Management
Systems.
· Increased obligations for worker safety.
· The Electricity Authority’s intention to “improve
distribution efficiency”.
· Increasing interest in ISO 37120:2014 in regard to sustainable community development.
Cool stuff
Good use for hydro
This
is a great plug for renewable energy … a hydro power rotisserie. Guess a few readers will be spending the weekend in their
sheds building one !!!
Newly published book – “Keeping The Lights On”
Well-known
electricity historian and author Helen Reilly has recently published her latest
book “Keeping The Lights On – The History Of System Operations In New Zealand
1939 – 2013”. Pick here to order your copy for only $46.50 from Grid Heritage. It’s
a thoroughly good read, and complements Helen’s previous book “Connecting The
Country”.
Regulatory decisions
NZ – amending the pipes & wires information disclosure
requirements
Introduction
This short
article notes the Commerce Commission’s recent amendments to the respective
determinations. There are a wide range of additions, amendments and deletions,
so interested users should refer to the respective Amendments (links below) for
the marked-up versions.
Regulatory frameworks
Electricity
distribution, gas distribution and gas transmission services are subject to
information disclosure pursuant to s54F and s55C of Part 4 of the Commerce Act 1986.
Electricity distribution
The Electricity Distribution Information Disclosure Determination 2012
(consolidated in 2015) has now been consolidated to include the 2015 Amendments.
Gas distribution
The Gas Distribution Information Disclosure Determination 2012 (consolidated
in 2015) has now been consolidated to include the 2015 Amendments.
Gas transmission
The Gas Transmission Information Disclosure Determination 2012 (consolidated
in 2015) has now been consolidated to include the 2015 Amendments.
UK – reporting back on the first year of RIIO-T1
Introduction
Electricity
and gas transmission has been subject to the RIIO-T1 revenue control since 1st
April 2013. This article examines the recent Ofgem report on RIIO-T1’s first year.
The RIIO-T1 price control
RIIO-T1 (and the associated RIIO-ED1 and RIIO-GD1) represented a
significant shift in the way Ofgem regulated pipes & wires in the UK, from
a prescriptive model to a model based more on incentivising performance derived from customer consultation. RIIO-T1 began on 1st
April 2013, and will run for an 8 year period until 31st March 2021.
Key features of the report
Key
features of the report include…
· The cost of electricity transmission services increased from
Ł21.78 to Ł22.59 per (average) customer.
· The cost of gas transmission services decreased from Ł16.63
to Ł13.68 per (average) customer.
· Performance in regard to energy not supplied has exceeded
target for all transmission operators.
· All transmission operators have exceeded their customer
satisfaction targets.
· All transmission operators have underspend their TotEx
allowances, however this mainly due to a reduced volume of new connections.
Hence the allowances will be scaled back to reflect lower volumes.
· All transmission operators expect to exceed the expected ROI
set out in the RIIO-T1 Final Proposals.
· Regulatory reporting by National Grid (both electricity and
gas) was not up to Ofgem’s expectations and had to be re-submitted.
NZ – gas under pressure
Introduction
The
Commerce Commission recently released its cost of capital determination for any CPP proposed by Powerco for its
gas distribution services for the 2015/16 year. This article examines the key
features of that determination.
Regulatory framework
The
regulatory framework for setting the gas distribution WACC’s is set out in Subpart 3 of Part 5 of the Gas Distribution Services Input Methodologies
Determination 2012.
Key features of the Determination
The key feature of the Determination is the
mid-point and 67th percentile WACC’s…
|
Vanilla WACC period |
Mid-point |
67th
percentile |
|
3 years |
6.72% |
7.25% |
|
4 years |
6.70% |
7.23% |
|
5 years |
6.72% |
7.25% |
Previous WACC decisions
Some
of the Commissions’ previous WACC decisions are as follows.
|
WACC
decision applies to |
Approx
date |
Mid-point
WACC |
75th
(or 67th) percentile WACC |
|
Powerco
gas CPP application before April 2016. |
March
2015 |
Vanilla
6.70% to 6.72% |
Vanilla
7.23% to 7.25% |
|
Maui
Developments for 2016 disclosure year |
January
2015 |
Vanilla
7.08% |
Vanilla
7.89% |
|
Vector,
GasNet CPP application before December 2015. |
December
2014 |
Vanilla
7.11%, 7.14%, 7.22% |
|
|
All
electricity CPP applications after 30th September 2014. |
September
2014 |
Vanilla
6.58%, 6.64%, 6.72% |
|
|
Auckland,
Christchurch Airports for 2015 disclosure year. |
July
2014 |
Vanilla
7.64% |
Vanilla
8.63% |
|
Vector,
GasNet for 2015 disclosure year. |
July
2014 |
Vanilla
7.54% |
Vanilla
8.35% |
|
Transpower
for 2015 disclosure year. |
July
2014 |
Vanilla
6.83% |
Vanilla
7.55% |
|
Wellington
Airport for 2015 disclosure year. |
April
2014 |
Vanilla
7.70% |
|
|
EDB’s
for 2015 disclosure year. |
April
2014 |
Vanilla
6.89% |
|
|
Powerco
gas CPP applications before March 2015. |
March
2014 |
Vanilla
5-year 7.54% |
Vanilla
5-year 8.35% |
|
Maui
pipeline (gas transmission). |
January
2014 |
Vanilla
7.64%, post-tax 6.85% |
|
|
Vector,
GasNet CPP applications before December 2014. |
December
2013 |
Vanilla
7.56% |
|
|
All
CPP applications before 30th September 2014 |
September
2013 |
Vanilla
from 6.26% to 6.69% |
Vanilla
from 6.97% to 7.41% |
|
Transpower |
July
2013 |
|
Vanilla
6.85% , post-tax 6.17% |
|
Vector
gas distribution, GasNet |
July
2013 |
|
Vanilla
7.65%, post-tax 6.97% |
|
Auckland
& Christchurch airports |
July
2013 |
|
Vanilla
8.00%, post-tax 7.75% |
|
All
electricity distribution |
April
2013 |
|
Vanilla
6.83%, post-tax 6.14% |
|
Maui
pipeline (gas transmission) |
February
2013 |
|
Vanilla
7.46%, post-tax 6.80% |
|
All
gas distribution and gas transmission DPP’s |
December
2012 |
|
Vanilla
6.63% |
|
Vector,
GasNet CPP’s |
December
2012 |
Vanilla
6.39% (5 years) |
|
|
Powerco
gas distribution |
October
2012 |
Vanilla
6.83%, post-tax 6.12% |
|
People in power
This
series of historical interest articles follows on from a similar series a few
years ago, and examines the lives and achievements of electrical pioneers that
were born in the last few decades of the 1800’s.
Fred Wheadon wires up the city of Adelaide
Birth, early years & education
Fred
Wheadon was born in Ilminster, England in 1872. A broad-based education in
civil, mechanical and electrical engineering and in surveying at various
colleges around London was followed by a few jobs in municipal electricity
supply with the Bath Electric Supply Company and then as engineer-in-charge for
the City of London Electric Lighting Company’s Bankside Power Station. In 1897 Fred went to work for renowned boiler makers Babcock & Wilcox where he oversaw the erection of one of the first
superheater boilers in Spain.
The move to South Australia
Soon
after returning from Spain, a telegram arrived offering young Fred a 3 year
contract as chief engineer to the Adelaide Electric Supply Company (AESCO).
Fred accepted the offer on 4th April 1899 and arrived at Largs Bay
near Adelaide on 31st July 1899. History records that AESCO’s
company secretary was somewhat taken aback by Fred’s youth and reported to the
Board that “they have sent me a mere boy”.
Achievements at AdESCO
Fred quickly
proved to be a diligent operator who promptly found favor with the Mayor by
improving the reliability of the city’s electric supply. The remaining 46 years
of Fred’s career at AESCO saw the consolidation of coal-fired generation
including various ideological battles between public and private power and various
running disputes with the government over the development and use of Leigh
Creek coal, which culminated in the Electricity Trust of South Australia Act 1946 which nationalised AESCO into ETSA.
Retirement & later years
Fred
retired from AESCO at the end of 1946 at the age of 74, just after AESCO was
nationalized. Sadly, no records of Fred’s life after AESCO could be found.
Mergers & acquisitions
US - New Jersey regulators approve Exelon-Pepco merger
Introduction
Previous
issues of Pipes & Wires have examined Exelon’s proposed acquisition of Pepco. This issue notes the New
Jersey Board Of Public Utilities approval.
Key features of Exelon’s offer
Exelon
has made a $6.8b all-cash offer of $27.25 per Pepco share, which represented a 24.7%
premium to Pepco’s closing price on the announcement day.
Key features of the New Jersey Board of Public Utilities
approval
Key
features of this approval include…
· Achieving a settlement between Exelon, Pepco, the Board and
the Independent Energy Producers of New Jersey that included provisions for
$15m of efficiency gains for customers of Atlantic
City Electric.
· Establishing a fund of $62m to provide rebates to Atlantic
City Electric customers.
Status of the required approvals
The
status of the regulatory approvals is…
|
Regulator |
Current
status of approval |
|
Federal Energy Regulatory Commission. |
Approved
20th November 2014. |
|
District of Columbia Public Service
Commission. |
Application
filed on 18th June 2014. |
|
Delaware Public Service Commission. |
Application
filed on 18th June 2014. As of 8th April 2015, the
proposed benefits to Delaware customers are being increased to include a
greater up-front bill credit and a commitment to improve supply reliability. |
|
Maryland Public Service Commission. |
Application
filed on 19th August 2014, approval may take up to 15 months. As
of 18th March 2015, settlement was achieved in 2 counties to
increase customer benefits including bill credits, funding energy-efficiency
programs and assisting low-income customers. |
|
New
Jersey Board of Public Utilities. |
Approved
on 11th February 2015. |
|
Virginia
State Corporation Commission. |
Approved
8th October 2014. |
Pipes
& Wires will comment further as the last 3 approvals emerge.
Asset strategy & management
Withdrawal of asset management standard PAS 55:2008
Readers
should note that the asset management standard PAS 55:2008 was withdrawn on 1st
February 2015, and effectively superseded by ISO 55000. That doesn’t mean that
all the hard work of achieving PAS 55 certification is now worthless, but
rather that the internationally consistent ISO 55000 is now the preferred
standard. To discuss how your company can move towards ISO 55000 certification,
pick here.
Solar, electric cars & nett metering
US – Georgetown goes solar
Introduction
News
recently emerged that SunEdison will install 150MW of solar panels next year to supply the
city of Georegetown, Texas (a city of 47,000 people on I-35 between Austin and Waco), which along with wind will make
it pretty much 100% renewable. This article examines the technical and
commercial features of the proposal.
The current electric supply arrangements
Georgetown’s
electricity is supplied by its own muni, Georgetown Utility
Systems. GUS is governed by a Board appointed by the Georgetown
City Council, and is managed by the Assistant City Manager (Utility
Operations). GUS buys its electricity through a mixture of short and long-term
wholesale power contracts, and distributes that electricity to about 20,000
customers within a 42 square mile service territory.
GUS
has recognised that solar is likely to provide cheaper electricity going
forward (as well as hedging against the regulatory risk around coal-fired
generation), and emphasises that it has made the decision based on price and
not for environmental reasons.
The scale of the installation
The
installed capacity of the solar panels will be 150MW, and it is expected to
generate about 9,500GWh per year for 25 years (that seems like a capacity
factor of 723%, so maybe the figures quoted in the media are incorrect).
SunEdison’s technology portfolio also includes battery storage, as well as a
recently acquired wind turbine business.
The business model
The
panels will be supplied, installed and initially owned by SunEdison. When
completed, SunEdison will offer to sell it to its associate company TerraForm Power.
Is this the way of the future ??
It
really does seem to be that way ... capital costs are falling, primary energy cost
is zero, operating costs are minimal, security of supply is improving, they
don’t make any noise, and visual intrusion is minimal especially if they are
mounted on large flat roofs.
The
challenge is now for grid-connected solar to beat the cost of customer-owned solar.
Germany – responding to the solar “drought”
Introduction
Most
of us … especially New Zealander’s … are familiar with the effect of droughts
on hydro-dominated generation systems. This article examines the recent solar
eclipse and its effect on Germany’s solar electricity by thinking of it as a
“drought”.
Germany’s solar electricity
Germany’s
approximate solar generation for 2014 was as follows…
|
|
Solar |
Total |
|
Installed
capacity (MW) |
36,000 (21%) |
172,000 |
|
Annual
generation (GWh) |
32,800 (6.2%) |
529,000 |
The
low overall annual GWh might be surprising given the popular media’s fondness
for quoting isolated periods during which solar provided 40% or even 50% of Germany’s
total power demand.
The eclipse and Germany’s response
Friday
20th March 2015 was a bright sunny day in Germany … perfect for
seeing the eclipse, and also perfect for stress testing an electric grid with a
high solar penetration. The Erneuerbare Energien Gesetz (Renewable Energy Sources
Act) prioritises the “dispatch” of renewable generation, so it’s reasonable to
assume that pretty much all solar panels were actually supplying the grid.
Careful planning by the 4 grid operators (50 Hertz, TenneT, Amprion and EnBW Transportnetze) enabled the “drought” to
be filled by gas turbines and pumped storage which were then ramped down as the
eclipse ended. The almost insignificant 500MW of wind generation that morning
reportedly made the balancing task much easier.
Who pays for the response ??
Responding
to the solar “drought” obviously required dispatchable generation to be
available, so we need to ask the very pointed question of “who paid for that”.
Readers might recall that Pipes & Wires #119 examined the issue of how stand-by generation might be paid
for buffering wind generation … there seemed to be this vague, unstated
expectation that stand-by generation such as Knapsack would be available to buffer wind, but would only be paid
for the MWh it actually generated. Knapsack’s owner, Statkraft, called for standing capacity payments of €1,500 per kW per
year to maintain such plant (and good on them). So at this stage it’s not clear
whether all the dispatchable generation will actually get paid for anything
more than the MWh they actually generated.
US – facilitating third-party ownership of rooftop solar
Introduction
Although
the cost and hence price of solar panels is falling, they still seem to be a
bit beyond the reach of most domestic electric customers. This article examines
recent legislation in the US state of Georgia that will facilitate third-part
ownership of rooftop solar.
The issues around solar ownership
The
key issue is simply the up-front cost (price) of the panels. The most common
funding model to emerge was a feed-in tariff (FIT) set at greater than 1 which
was effectively a time-payment subsidy for customers with rooftop solar owners
(and paid by customers without rooftop solar).
Now
that FIT’s are being ramped down for various reasons, potential rooftop solar
owners have to pay the full price for the panels and associated kit. This has
opened the way for third-party ownership (TPO) of rooftop solar in which a
party other than the building owner or the electric company own the panels …
TPO’s might include installers or investors. Some commentators reckon that the ever-declining
price of solar panels will actually make TPO redundant.
The Georgia legislation
House Bill #57 proposes to amend Article 1, Chapter 3, Title 46 of the Official Code of Georgia Annotated to provide for third-party financing and ownership of
rooftop solar. Progress through the corridors of power is as follows…
· Three readings in the House during January 2015, followed by
House adoption on 9th February 2015.
· Introduced into the Senate on 10th February 2015.
· Three readings in the Senate during March 2015, followed by
Senate adoption on 27th March 2015.
· At the time of writing, HB57 is now awaiting the Governor’s approval.
The role of Big Electric in all this
Big
Electric has agreed to support HB57 in exchange for including provisions to…
· Limiting the capacity of domestic solar panels to 10kW.
· Limiting commercial solar panels from generating more than
125% of their own energy consumption.
The editor comments
Advocates
of rooftop solar claim that Big Electric simply wants to prevent rooftop solar.
A more balanced view might be that Big Electric simply insists that all
connected customers pay the true long-run economic cost of connection without
subsidy. This strikes right to the heart of the regulatory compact … electric
companies upside gains are limited in return for limiting the downside losses through
what was understood to be a predictable recovery of costs over the long-term.
Rooftop solar is almost certain to significantly skew the business model towards
downside losses, however corresponding moves to relieve the limits on upside
gains seem to be slow in coming.
Regulatory & competition policy
Aus – ramping up retail competition in Western Australia
Introduction
As
part of Western Australia’s on-going energy reforms, Energy Minister Dr Mike Nahan recently announced that competition would be introduced to
the domestic and small commercial retail electricity market segments. This
article examines that announcement and considers the likely outcomes.
Specific plans for retail electricity competition
It
appears that full retail contestability will be introduced over a 4 year
period, during which time the incumbent state-owned retailer Synergy will also lose all its subsidies which are forecast to cost
the government about $500m for the 2014/15 year. It is expected that Synergy
will be to also retail gas, in competition with existing gas retailers (who in
turn are expected to begin retailing electricity).
Views on structural reform and asset sales
Nahan
has indicated that introducing further competition will be the focus, rather
than structural changes to the existing state-owned electricity supply chain,
or sale of assets. This is almost certainly a recognition that asset sales in
particular are politically difficult.
Expected results
Understandably,
new entrants are welcoming the announcement with 1 established commercial
retailer already claiming that it could shave 5% to 10% off of residential
electric bills. Experience in other states suggests this is certainly possible.
NZ – managing extended reserves
Introduction
Being
able to shed a specified amount of (electrical) load during a major grid
frequency excursion is a fundamental aspect of a secure transmission grid
operation. This article examines recent changes to the way that this load
shedding will be managed.
The legacy load shedding mechanisms
The
New Zealand electricity grid broadly has 3 load shedding mechanisms…
· Ripple control, which injected an audio-frequency tone into
the distribution network to control tuned relays for switching specific loads
such as hot water cylinders and streetlights. The legacy ripple injection
plants usually take a few minutes to operate, so they aren’t of any use in a
sudden frequency excursion (more modern devices that often also embody smart
meters could be switched off within seconds).
· Interruptible load that is offered into both the Fast
Instantaneous Reserve (FIR) and the Sustained Instantaneous Reserve (SIR)
markets.
· Relays at substations that trip circuits corresponding to
specific percentages of connected load at specific frequencies, known as
automatic under-frequency load shedding (AUFLS). The 1st
block of AUFLS will trip 16% of load at 47.8Hz, and the 2nd block of
AUFLS will trip a further 16% at either 47.5Hz or if the grid frequency stays
below 47.8Hz for more than 15s. AUFLS will operate within a few hundred
milliseconds in response to a detected frequency drop. These requirements are
set out in Schedule
8.3 of the Electricity Industry Participation Code.
The concerns
In
2012 the Electricity Authority commenced a stream of work on the belief that procuring
extended reserve could be done more efficiently than the current AUFLS
arrangement, and proposed a more market-based approach rather than the current
obligations on participants. One of the specific concerns was the difficulty of
arming load to 2 blocks of 16% whilst ensuring that critical loads like
hospitals and sewage pumping stations were not tripped and that loads with a
relatively high interruption cost weren’t included.
The proposal
The
Authority’s preferred approach was to have an optimised process for selecting
load for extended reserves and having an extended reserves manager (ERM) run
the selection process.
Appointing the Extended Reserves Manager
By
early 2015 the Electricity Authority’s work had progressed to the point of
selecting the NZ Stock Exchange (NZX) as the preferred supplier for the role of
extended reserves manager. Pipes & Wires will comment further as the ERM
announces its preferred loads.
Aus – transferring regulation of Western Power to the AER
Introduction
In
conjunction with announcing the introduction of domestic and small commercial
retail electricity competition, Energy Minister Dr Mike Nahan also announced
that jurisdiction for regulating Western Power’s transmission and distribution
networks would be transferred from the (WA) Economic
Regulatory Authority to the Australian Energy Regulatory (AER). Long-time readers might recall that a similar
transfer occurred in Victoria on 1st January 2009.
The current regulatory arrangement
Western
Power’s 2 wires businesses are subject to revenue control in a similar manner to most other revenue controls. Key
legislation includes…
· The ERAWA was established by the Economic Regulation Authority Act 2003, which inter alia
establishes an economic regulator (Part 2) and defines its functions (Part 4).
· The Electricity Corporations Act 2005 which inter alia provides for the establishment of the
various supply chain entities as bodies corporate with perpetual succession.
The proposed regulatory arrangement
It is
proposed to transfer jurisdiction of the 2 Western Power wires businesses from
the ERAWA to the AER, so that those 2 businesses will be treated on a national
basis the same as the wires businesses in the eastern states. This will require
an amendment to the Economic Regulation Authority Act 2003 to transfer
jurisdictional authority.
What might the advantages be ??
At
face value, bringing all Australian wires businesses under a common regulator
that has a nationally consistent approach would appear to be a good idea.
Perhaps a more compelling argument would be the removal of important regulatory
and economic decisions from a state-based agency that could be influenced by
its political masters.
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....
· Advising a major global investment bank on the revenue and
capital cost characteristics of the New Zealand generation industry.
· Assessing the investment characteristics of proposed CapEx
increases to an investor-owned electric network.
· Assessing three EDB’s asset management practices against ISO
55000:2014.
· Assessing an EDB’s compliance with the lines – generation
separation requirements of the Electricity Industry Act 2010.
· Assessing an EDB’s compliance with the Electricity Industry
Participation Code.
· Compiling safe operating procedures for a wide range of
distribution switches.
· 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.
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.
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...
· Fundamentals of the NZ electricity industry, 7th – 8th September 2015,
Wellington.
· Fundamentals of the NZ electricity industry, 19th – 20th October 2015,
Auckland.
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…
· Economic Operation Of Power Systems (Kirchmayer).
· 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.
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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
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