DBCT Declaration Review – Addendum and Disclosure of Data
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18 June 2018 Mr Ravi Prasad Queensland Competition Authority Dear Ravi DBCT Declaration Review – addendum and disclosure of data DBCTM's submission of 30 May 2018 in respect of the DBCT declaration review which was redacted for publication (the DBCTM submission) contained the following appendices: • Appendix 10 - HoustonKemp expert report on criterion (b) (HoustonKemp Report on (b)); and • Appendix 12 - AME Coal Industry Report (AME Report). HoustonKemp Report on (b) was redacted for confidential data of AME and Wood Mackenzie contained in the tables in Appendices A1 and A3 to that report. The AME Report did not contain confidential information of AME in Figures 14, 15 and 16 of that report. DBCTM has now obtained the consent of AME and Wood Mackenzie for the disclosure of that information. Accordingly, please find attached for publication: • A copy of the AME Report which includes Figures 14, 15 and 16. • A copy of the HoustonKemp Report on (b) with the data in tables in Appendices A1 and A3 unredacted. Note that some information on pages 14, 15, 23, 24, and 28 of the report remains redacted as it is confidential information of particular users of DBCTM. We note that the source of the data in table A1.1 of Appendix A and tables A3.1, A3.4, A3.5 and A3.6 of Appendix A3 to the HoustonKemp Report on (b) is AME, March 2018. The disclaimers set out at start of the AME Report also apply to that data. The source of the data in tables A3.2 and A3.3 of Appendix A3 to the HoustonKemp Report on (b) is Wood Mackenzie, October 2017. In respect of that data, Wood Mackenzie has noted that: The data does not include, nor shall it be construed as including, advice, guidance or recommendations from Wood Mackenzie to take, or not to take, any actions or decisions in relation to any matter, including without limitation relating to investments or the purchase or sale of any securities, shares or other assets of any kind. Should members of the public take any such action or decision based on information in this report, you do so entirely at your own risk and Wood Mackenzie shall have no liability whatsoever for any loss, damage, costs or expenses incurred or suffered by you as a result. The data may contain forward looking statements including statements regarding Wood Mackenzie’s intent, belief or current expectations. Members of the public are cautioned not to place undue reliance on these forward looking statements. Wood Mackenzie does not undertake any obligation to publicly release the result of any revisions to these forward looking statements to reflect events or circumstances after the date hereof. While due care has been used in the preparation of forecast information, actual results may vary in a materially positive or negative manner. Forecasts and hypothetical examples are subject to uncertainty and contingencies outside Wood Mackenzie’s control. Past performance is not a reliable indication of future performance. DBCT Management (07) 3002 3100 PO Box 7823, Waterfront Place QLD 4001 www.dbctm.com.au DBCT Management In addition, we attach for publication an addendum which corrects certain AME figures referred to in the DBCTM submission, and provides clarifying notes on some of the tables in Appendix A3 to the HoustonKemp Report on (b). Accordingly, the confidentiality claim issued to the QCA in respect of the DBCTM submission should be considered amended to the extent noted in this letter. Note that the reference to Appendix 15 in the confidentiality claim template should instead be Appendix 16. Please contact me if you have any related queries. Yours sincerely Jonathan Blakey General Manager — Commercial & Regulation DBCT Management Attachment 1: Addendum to DBCTM submission DBCT Declaration Review – addendum and disclosure of data Page 2 of 4 DBCT Management Attachment 1 Addendum to DBCTM Submission 1 DBCTM provides this addendum to its submission on the DBCT declaration review dated 30 May 2018 to correct for some figures set out in that submission (DBCTM Submission) and provide explanatory notes on some of the tables in Appendix A3 to the HoustonKemp Report on criterion (b) (Appendix 10 to the DBCTM Submission). 2 The following table corrects the figures in respect of AME estimates of foreseeable demand in Figure 9 at paragraph 217 of the DBCTM Submission.1 No corrections have been made to the HoustonKemp estimates of foreseeable demand in the table.2 Figure 9: Comparison of estimates of total foreseeable demand from HoustonKemp and AME (throughput basis) Year Foreseeable demand including all Foreseeable demand excluding BMA and BMC production (Mtpa) HPCT (Mtpa)3 HoustonKemp AME HoustonKemp AME 2021 150.9 151.0 91.1 96.0 2022 156.1 155.6 95.2 100.6 2023 164.8 161.5 102.7 106.5 2024 172.7 172.1 109.6 117.1 2025 182.4 178.4 117.8 123.4 2026 186.7 190.2 120.6 135.2 2027 179.0 191.8 111.3 136.8 2028 181.9 181.8 112.7 126.8 2029 181.6 182.7 112.5 127.7 2030 182.1 182.0 113.0 127.0 3 Having regard to the figures in that table, DBCTM also corrects: 3.1 The figures in paragraph 219 of the submission to read: "The table shows that on a throughput basis AME's peak forecast demand figures are 191.8Mtpa (including all BMA and BMC forecast production) and 136.8Mtpa (excluding 55Mtpa of BMA forecast production). Converted to a demand for coal handling contract capacity basis, those figures become 213Mtpa (including all BMA and BMC forecast production) and 152Mtpa (excluding 55Mtpa of BMA forecast production)." 1 As noted in the DBCTM Submission, the AME foreseeable demand figures in this table come from the AME Report, pages 18 to 19. Note that Figures 14 and 15 in AME's report specify totals for DBCT, Gladstone, Abbot Point and Hay Point (which reflect AME's view of which terminals the coal might be railed to in those years). This is because as noted in paragraph 215 of the DBCTM Submission, AME is forecasting throughput at DBCT rather than total foreseeable demand in the market in which the DBCT service is supplied. DBCTM has included the overall totals from those Figures in the table in order to specify total foreseeable demand in the market in which the DBCT service is supplied, which can include demand from mines proximate to DBCT which is served by other terminals. 2 As noted in the DBCTM Submission, the HoustonKemp foreseeable demand figures come from Table 5.1 of the HoustonKemp Report on (b). 3 HoustonKemp's figures exclude all BMC and BMA forecast production whereas AME's figures exclude 55Mtpa of BMA forecast production. DBCT Declaration Review – addendum and disclosure of data Page 3 of 4 DBCT Management 3.2 The references in paragraphs 63.1, 191.3, 203.2 and 223 of the DBCTM Submission of 218 Mtpa to read 213 Mtpa.4 4 DBCTM provides the following explanatory notes on the tables in Appendix A3 to the HoustonKemp Report on criterion (b): 4.1 Table A3.1 – Coal handling charges at each terminal (A$ per tonne) – AME provided the "port handling charges" data covering terminal access and handling charges in US$, which was converted to A$ in HoustonKemp’s model using an exchange rate of US$1.00 = A$1.30 (provided by AME). 4.2 Table A3.4 – Seaborne coal price assumptions ($US per tonne) – AME provided a price series in US$/t for benchmark coal types, to which was applied the relevant discount or premium due to the specific quality of coal at the respective mines (supplied by AME), to calculate the specific price for each product of each mine. 4.3 Table A3.5 – Production cost assumptions for each mine ($US per tonne) – the figures in the table are actually $A per tonne including maintenance capex. AME provided the production cost data in US$, which was converted to A$ in HoustonKemp’s model using an exchange rate of US$1.00 = A$1.30 (provided by AME). 4 Note this correction is made because on a demand for coal handling contract capacity basis, AME's estimate of maximum total foreseeable demand over the period 2021 to 2030 is approximately 213Mtpa (including all BMA and BMC forecast production). DBCT Declaration Review – addendum and disclosure of data Page 4 of 4 Does DBCT’s coal handling service satisfy criterion (b)? A report for DLA Piper 28 May 2018 HoustonKemp.com Report Authors Greg Houston Daniel Young Sam Forrest Luke Wainscoat Stuart Morrison Contact Us Sydney Singapore Level 40 8 Marina View 161 Castlereagh Street #15-10 Asia Square Tower 1 Sydney NSW 2000 Singapore 018960 Phone: +61 2 8880 4800 Phone: +65 6817 5010 Disclaimer This report is for the exclusive use of the HoustonKemp client named herein. There are no third party beneficiaries with respect to this report, and HoustonKemp does not accept any liability to any third party. Information furnished by others, upon which all or portions of this report are based, is believed to be reliable but has not been independently verified, unless otherwise expressly indicated. Public information and industry and statistical data are from sources we deem to be reliable; however, we make no representation as to the accuracy or completeness of such information. The opinions expressed in this report are valid only for the purpose stated herein and as of the date of this report. No obligation is assumed to revise this report to reflect changes, events or conditions, which occur subsequent to the date hereof.