Ausgrid S Revised Regulatory Proposal for the Period 1 July 2014 to 30 June 2019

Ausgrid’s Revised Regulatory Proposal for the period 1 July 2014 to 30 June 2019 - Confidentiality Template Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential. Attachment 1.02 Curriculum Viate of Not specific to Personal The attached Curriculum Viate The attached Curriculum There is no perceived public Statement of Trevor Trevor Armstrong, any one part Information of Trevor Armstrong is Viate about the author benefit from disclosing this Armstrong, Chief Chief Operating of Ausgrid’s considered to be confidential discloses details about the information which is personal in Operating Officer – Officer - Ausgrid revised as it contains information author that the author does nature. Ausgrid proposal. This which is personal in nature not want to be in the public information such as addresses, contact domain. Confidentiality is relates to information and education claimed on the whole personal views details. of Annexure 2: and Curriculum Viate experience.

Attachment 1.11– Confidential credit Overall Market sensitive Standard & Poor’s stand- Standard & Poor’s The potential detriments that Standard and Poors assessment by Revenue, credit assessment alone credit assessments are confidential credit could be caused by publishing – Ausgrid’s stand- Standard & Poor’s capex, opex always confidential, due to the assessment are likely to the information in the Standard alone credit profile and WACC market sensitivity of S&P’s materially impact Ausgrid’s & Poor’s confidential credit opinions regarding actual debt costs and assessment outweigh any Confidentiality is businesses’ creditworthiness. equity valuation. potential benefit. These claimed over potential detriments would information on: extend across both Ausgrid and the covering letter Standard & Poor’s as a rating and p 1-4 agency.

Any detriments to Ausgrid’s actual debt costs and equity valuation would not be in the best interest of customers.

Attachment 1.12 Analysis of Overall Market sensitive UBS assessment of the UBS’ analysis of the There is no benefit obtained by Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential. UBS section on implications of Revenue, information impact of Standard & Poor’s implications of Standard & customers from the information implied credit ratings Standard & Poor’s capex, opex regarding credit confidential credit assessment Poor’s confidential credit in UBS report regarding Confidential credit and WACC assessments and on market pricing of Ausgrid’s assessment could Standard & Poor’s confidential Confidentiality is assessment for Strategic debt could impact the terms materially worsen credit assessment. It will help claimed on material Ausgrid. Information on which it negotiates debt Ausgrid’s actual debt costs inform the AER about the contained on pages: contract terms and pricing. and equity valuation. financial detriment that could - p10 paragraph 6 be caused from its draft - p11 paragraphs In addition to this, all Standard decision revenue allowances 1,3, 4 and 5 & Poor’s stand-alone credit and would inform its final - p13 paragraphs 4 assessments are required to decision accordingly. However, and 5 be kept confidential due to the if it was released prior to a final - p14 paragraph 8 market sensitivity of S&P’s decision, there could be - p15 paragraphs 5- opinions regarding unwarranted detriment to 7. businesses’ creditworthiness. Ausgrid’s actual financial sustainability, which would not be in the best interest of customers.

Attachment 1.14 Details of General Opex Market Sensitive Insurance premiums, nature of If other NSPs became There is no perceived public AON: Insurance Liability insurance cost inputs coverage and capacity are aware of our ‘preferred’ benefit to the release of this Advice Report: program including market sensitive. The global coverage and raised the information. Release could Insurance costs and premiums, nature of market is highly competitive. issue with insurers there is result in higher insurance coverage impacts coverage and In particular Ausgrid receives a real risk that the nature premiums and less coverage arising from cuts in insurers participating coverage under the program of the cover could be (increased opex), which adds vegetation on the program. not generally available to withdrawn by insurers on to the price of electricity. management other market participants the program. Insurers expenditure for the (non-aggregated limits for could use premium and 2014-19 regulatory bushfire).Also NNSW’s nature of coverage period. insurance market negotiation information to their position to negotiate a fair and advantage and jeopardise Confidentiality is competitive premium would be NNSW’s appropriate claimed over adversely impacted. negotiating advantage to information on negotiate competitive pages: insurance renewal - p 4 paragraph 8, premiums. Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential. -p 5 paragraph s1-3, -p 9 points 6 and 9, - p11 paragraphs 2-4 - p16 paragraph 1 - p17paragraphs 2- 4 - p 18 table - p 19 paragraph 7 point 1 - p 21 - p 22 first four paragraphs. Attachment 5.05 Industrial relations Ausgrid’s Other and Other The disclosure of this Ausgrid considers that any The plan details potential information may adversely Strategic Deliver and and workforce future Strategic future workforce size and impact on employees public benefit would be Workforce Plans planning information. intentions with Information. composition based on itsthe relations and productivity outweighed by the potential 2015-19. its workforce forecasts included in the as well as Ausgrid’s detriment to Ausgrid arising and its goals Revised Regulatory Proposal. position in current 2014 from the disclosure which could Confidentiality is in current and future EBA extend to negative financial sought for material Strategic Information negotiations. Enterprise impacts and a reduced ability to on pages: The release of this information Bargaining could result in unfavourable improve enterprise agreements - p7 table Agreement labour cost outcomes which and current operating - p8 both tables negotiations could materially impact the environment. -p 9 paragraphs 3 taking place. value of the business if there and 4 were to be a change in -p10 both graphs ownership structure or to its -p11 paragraphs 2-5 current owner. -p13 paragraph 1 -p26 graph -p27paragraph 3 -p30 paragraph 4 -p31 paragraphs 1 and 3 -p41 table and paragraph 3 Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential. -p44 paragraphs 2, 4, 5 and table - p45 second paragraph 2nd dot point, fourth paragraph dot points 1-3 -p46 first paragraph and table -p50 paragraph 4 -p54 table and last two paragraphs -p55 table and last sentence -p56 table and sentence below -p63 table -p64 paragraphs 2-7 and table -p65 table -p67 paragraphs 6-9 -p68 table -p69 table -p71 both tables -p72 three tables -p73 both tables -p74 paragraphs 3,6, 7 and table -p75 both tables -p76 three tables -p78 one row in table -p 81numbers in both tables -p82 paragraph 1 -p85 both tables Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential. -p86-109 numbers in the tables

Attachment 5.15 This is a model Cost Other Model contains proprietary It is believed that The consultant is entitled to CEG Escalation belong to an external Escalation modelling functions which is disclosing this information protect their intellectual Factors Ausgrid 20 Dec 2013. consultant engaged (Opex & an intellectual property of the will adversely impact the property and is not obliged to by Ausgrid. It Capex) consultant. consultant given that they make this information available Confidentiality is contains proprietary have invested in publicly. All assumptions claimed for the whole modelling techniques techniques developed. contained in the methodology model to protect and formulae. document, which is not against the confidential. The Public benefit disclosure of is served by making the functionality of the methodology and assumptions model. A public transparent, not by making the version of this model modelling techniques available (in PDF) format has publicly. been provided.

Attachment 5.17 Personal Information. Witness Personal Personal information Disclosure of personal There is no perceived public Statement prepared by Group Executive Curriculum Viate of qualifications information contained within the document information. benefit from releasing Network Strategy – John Hardwick. and information which is personal in John Hardwick experience nature.

Confidentiality is claimed on the Curriculum Viate of John Hardwick (pages 18-23 of the Witness statement)

Attachment 6.01 Industrial relations Ausgrid’s Other and Other The disclosure of this Ausgrid considers that the Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential.

ARUP - Ausgrid and workforce future and Strategic The plan details potential information may adversely disclosure of this report may future workforce size and impact on employee Labour Analysis planning information. past intentions Information composition based on the relations and productivity constrain its ability to improve Report. with its . forecasts included in the as well as Ausgrid’s its enterprise agreements and workforce, and Revised Regulatory Proposal. position in current 2014 respond to is current operating Confidentiality is its goals in and future EBA environment. The negative sought for the entire current Strategic Information negotiations. financial impacts to Ausgrid report (75 of 75 The release of this information Enterprise and customers from this would pages) could undermine Ausgrid’s Bargaining current EBA negotiations, far outweigh the public benefit Agreement particularly where there has from disclosing this information. negotiations been a shift in approach from In addition, the report is an taking place. Ausgrid’s historical position on workforce planning. This could equivalent report to the Deloitte materially impact the value of ‘Labour Analysis Report’ which the business if there were to was commissioned by the AER be a change in ownership as part of its Draft structure or to its current owner Determination. This report on Ausgrid’s past workforce management decisions was kept in confidence by the AER to avoid any detriment to Ausgrid arising from the author’s view of Ausgrid’s labour practices. We believe that the same considerations dictate confidentiality being afforded to the Arup report given the identical subject matter. Attachment 6.02 Calculation of labour Opex and Market sensitive The report relates to directly to Release of a report The release of this information Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential. CEG: Labour unit cost by employee capex (labour cost inputs labour costs. commissioned by the would result in a disruption in cost - review of category and costs) business on labour costs current and future negotiations, Deloitte report comparison to other would disrupt current and directly increasing labour costs DNSPs future negotiations. to the long run detriment of Confidentiality is consumers. The sensitivity of claimed for the entire this information was recognised document. in the AER's decision to make the Deloitte report confidential.

Attachment 6.03 Information and Opex and Market sensitive The report relates to Release of a report The release of this information K&L Gates: analysis on the capex (labour cost inputs enterprise bargaining commissioned by the would result in a disruption in Comparison and elements of costs) agreements which relate to business on the merits of current and future negotiations, Analysis of Enterprise Bargaining the cost of labour. EBA provisions would directly increasing labour costs Enterprise Agreements (EBA) for disrupt current and future to the long run detriment of Bargaining NNSW businesses negotiations. consumers. The sensitivity of Agreements for this information was recognised Distribution Networks in the AER's decision to make the Deloitte report confidential. Confidentiality is claimed for the entire document. Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential.

Attachment 7.09 Details of confidential Rate of Return Market Sensitive The document contains Information about the There is no perceived public Statement of Justin credit rating and - Cost of Debt cost inputs. market sensitive information timing and amount of debt benefit to the release of this De Lorenzo Group credit rating rationale Personal about the debt management placement is market information. Chief Financial and details of debt information strategy including, the timing sensitive for large debt Officer, Networks management strategy and amount of debt maturities, financings of the type NSW and debt interest rate forecasts and contemplated by the management policies. confidential financial Networks NSW Confidentiality is Confidential financial information. The Statement businesses. Information claimed for the entire information. also contains confidential about debt management document. stand alone credit rating strategies could impact the Personal information information for the business. approach debt markets about the Statement The statement also includes take to the cost of debt Author. personal information about the refinancing and new debt provider of the statement. draw downs. The credit rating outcome and credit The attached CV about the rating rationale information author discloses details about including confidential the author that the author financial information about does not want to be in the the Networks NSW public domain. businesses is subject to strict confidentiality requirements agreed with the rating agency Moody’s. Information about the Networks NSW Businesses mark to market position on debt which is not disclosed in public annual report documents. This information could be misinterpreted by the market, potential investors and ratings agencies. Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential.

File A ‘Post June This model calculates Capex Market sensitive Contractor tender prices for There is no specific The 2010 version of the annuity 2009 Annuity the annuity prices for cost inputs materials and services. detriment to Ausgrid model has been published on Prices.xls’ of all assets installed arising from the disclosure Ausgrid’s website with all The output of this model is a Attachment 8.02 post June 2009. The of the information. Any sensitive material removed so published price list and can be model contains potential detriment from that the functionality of the Confidentiality is found in the public version of contractor tender the disclosure would arise model can be tested. claimed for the whole the public lighting price list. All prices for materials for contractors and model to protect inputs to the model are However even with sensitive which are used as suppliers. against the ‘back- documented in the Investment information removed it is inputs into the solving’ of the plan summary and opex possible that material prices calculation of post- confidential forecast attachment. can be calculated by goal seek. June 2009 annuity information. A public This potentially could be used prices. These prices version of this model as a tool for calculating are publicly disclosed (in PDF) format has Ausgrid’s supplier pricing and in Attachment 8.14. been provided. in particular LED luminaire pricing which is a particularly competitive market. It is for this reason we are not publishing a public version of the 2014 annuity model Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential.

C Pre 2009 'Fixed This model calculates Capex Market sensitive Contractor tender prices for There is no specific There is no identifiable public Charge' model.xls the allocation of the cost inputs materials and customer bills. detriment to Ausgrid benefit in disclosing tender (CONFIDENTIAL) of RAB to each arising from the disclosure prices for material and The output of this model is Attachment 8.02 customer and the of the information. Any services. It must be noted that fixed charge for each return on and return potential detriment from this model has been supplied to Report - Charges' customer. This is confidential of capital the disclosure would arise our customers and the AER B4:H107 as it discloses each of the for contractors and with all sensitive material 'Input - Customer customers bills. This price list suppliers who have removed so that the Inventory FY15' can be found in the expressed their wishes for functionality of the model can Column B confidential version of the Ausgrid not to publicly be tested. It was published on 'Input - Component public lighting price list. disclose their prices which the Ausgrid website April 2014 Costs FY13' Column then could be obtained by D & E their competitors. 'Input - Actual Residual Value' Column B 'Calc - FY15 RAB allocation' Columns B,K,L 'Calc - RAB 2015-19' Column A 'Calc - RAB 2015-19' Column A 'Calc - RAB 2015-19' Column B Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential.

File D Opex Cost This model calculates Opex Market sensitive Contractor tender prices for There is no specific There is no identifiable public Build up Model.xls the revenue cost inputs materials and services. detriment to Ausgrid benefit in disclosing tender (CONFIDENTIAL)’ of requirements for arising from the disclosure prices for material and The output of this model is Attachment 8.02 Ausgrid's public of the information. Any services. It must be noted that published price list for each lighting operational potential detriment from this model has been supplied to lamp type which can be found Input - Inventory' the disclosure would arise our customers and the AER and total revenue which can for contractors and with all sensitive material found in the public version of Column U - AA suppliers removed so that the the public lighting price list. functionality of the model can The total revenues that it be tested. It was published on calculates can be found in the Ausgrid website April 2014 attachment Operational Expenditure and associated cost build-up model.doc.

Attachment 8.03 Public lighting: Customer Other – third party These prices have been kept No detriment to Ausgrid in No detriment to Ausgrid, ‘Public lighting price customer specific specific prices pricing confidential during the 2009- disclosure of these prices. however, there may be list’ Pre-2009 capital pre-2009 capital information 14 period. For the transitional Any potential detriment detriment to its customers from charges’ pages 11- charges year, these prices are to be from the disclosure would disclosing their pricing 13 escalated by CPI and it would arise for the customers information. therefore be appropriate for through the disclosure of these escalated prices to their pricing information. remain confidential for the Title, page and Description of the Topic the Identify the Provide a brief explanation Specify reasons Provide any reasons paragraph number confidential confidential recognised of why the information falls supporting how and why supporting why the identified of document information. information confidentiality into the selected category. detriment may be caused detriment is not outweighed containing relates to category that the from disclosing the by the public benefit If information falls within confidential (e.g. capex, information falls identified information. (especially public benefits ‘other’ please provide information. opex, WACC within. such as the effect on the further details on why the etc.) long term interests of information should be consumers). treated as confidential. transitional year.

Appendix B to Confidential Appendix Approved Other –third party The approval by the ACCC of There is no specific Attachment 9.02 B to Ausgrid’s current discount in pricing the discount was given on 6 detriment to Ausgrid ‘Ausgrid’s proposed Transmission Pricing transmission information June 2002 and the terms of arising from the disclosure Transmission pricing Methodology which charges for an that prudent discount have of the information. Any methodology’’, page sets out the Ausgrid been kept confidential since potential detriment from 29 (1 page) conditions of approval (transmission that time, including as the the disclosure would arise of a discount in connected) Confidential Annexure B to the for the customer through transmission charges customer. Transmission Pricing the disclosure of their for a customer which Methodology. pricing information. was approved by the ACCC in 2002, expiring in 30 June 2017. Ausgrid’s Revised Regulatory Proposal for the period 1 July 2014 to 30 June 2019 - Proportion of confidential material notice

Submission Title Number of pages of Number of Total number of Percentage of pages of Percentage of pages of submission that pages of pages of submission that include submission that do not include information submission submission information subject to a claim include information subject subject to a claim of that do not of confidentiality to a claim of confidentiality confidentiality include information subject to a claim of confidentiality

Ausgrid revised regulatory proposal for 313 5191 5504 5.7% 94.3% 2009-14 (inclusive of attachments)