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Towards Introducing Uniform Energy Accounting: The Rationale and Way Forward Jamaluddin Ahmed PhD FCA Member Council The Institute of Chartered Accountants of Bangladesh Objectives of the Paper 1. 2. 3. 4. 5. 6. Economics of Regulation Specific need of Uniform Energy Accounting Core issues in Uniform Energy Accounting Scope of uniform Energy Accounting Development of Uniform Energy Accounting in Bangladesh Summary and conclusion Milestones in Infrastructure Reforms United States of America United Kingdom EU Liberalization 1984:British Telecom 1986:British Gas 1987:British Airways 1987:British Airport Authority 1989:Water and Sewerage Companies 1990:Electricity Companies 1995:British Rail 1996:British Energy-Nuclear 1990:Telecomm unications 1991:Railway 1996:Electricity 1996:Gas Financial Change Management Power Sector Reform in Chronology Creation of Rural Electricity Board Establishment of Dhaka Electricity Supply Authority Private sector participation allowed National Energy Policy and Proposal for Regulatory Commission Creation of Power Cell Private Sector Power Generation Policy Corporatization of Ashugonj Power Station Corporatization of West Zone Power Distribution Corporatization of North West Zone Power Distribution Formation of Strategic Business Unit Creation of Power Grid Company of Bangladesh Establishment of Energy Regulatory Commission Post Reform Change Management Paradigm Shift From Command to Market Government to Business Organization Government to Commercial Business Rules Government to own Financing Welfare to Business Concept Loss Making to reasonable Return on Investment Cash Based to Accrual Accounting Effective Utilization of Resources Politicization to Performance Based Management Politicization to Performance Goal Orientation Fixed bonus to performance bonus Bureaucrats to Business Manager Towards value addition and customer satisfaction Addressing Post Reform Issues Finalize terms and conditions of vendor agreement Independent valuation of assets and liabilities Hand and take over of assets & liabilities Prepare strategic business plan Finalizing win win power purchase agreement Prepare and approve functional organization Negotiate per unit power price Design Appropriate Organization Fix up effective tariff Addressing Post Reform Issues Shift from Cash to Accrual accounting system Customize Charts of Accounts in with commercial principles Harmonized Charts of Accounts for Corporatized unit Harmonization of Accounting Policies for Holding and subsidiary Companies Financial Statements in line with IAS and best practice Effective MIS Sustainable financial management system Point of difference Financial Accounting Regulatory Accounting Focus Firm Regulated activities Accounting Within a firm Regulated activities of more firms Activities considered Both regulated and un-regulated Separation of regulated and un-regulated activities Yardstick competition Can not provide Can provide Degree of homogeneity Difficult Easier Basis of cost Temporal cost imputation rule Not included in asset base until in Service Allocation of common cost Inadequate allocation Between regulated and Un-regulated activities A regulated firm would have strong Incentive to allocate common cost to its regulatory activities rather to any Of its competitive activities Objectives Collect information for Sustainability, Allocative Efficiency, Productive Efficiency, Equity or Distributive Efficiency Addressing Human Resources Issues Staff Audit is the First step to Bring Personnel Records up to date Identify and eliminate ghost workers Basis for severance and early retirement options Ensure accuracy of subsequent workforce analysis Establish effective record-keeping procedures to regain control over payroll Provide an accurate basis for review of job positions Addressing Human Resources Issues Benchmarking Internal benchmark Sector benchmark Functional benchmark Generic workforce Benchmarks Gross or net revenue per employee Total payroll cost per employee Ratio of headcounts by function:Management/operation, customer service/maintenance Salary levels by function Average weekly hours per employee Units produced per work hour Product/service line per staff-hour/full-time equivalent employee Training in person-days per year Addressing Human Resources Issues Workforce Analysis General Principles of Regulatory Accounting Causality Revenues, costs, assets, and financial obligations should be allocated according to each activity Objectivity The allocation should be based on objective principles and should not imply any undue benefit to any organization or individual Transparency The methodology of assignation should be clear. The accounts should be clearly distinguishable Coherence The allocation criteria should be constant from one year to another; however, in case of changes in accounting methods, the company should provide the necessary revisions and explanations for such modifications Materiality An accounting departure is considered material if its omission and misrepresentation has the potential to alter the financial position or the nature of company’s regulated and unregulated services Neutrality Internal transferences of costs and revenues should be transparent and in accordance with standard cost Sufficiency The information should comply with the requirements established according to the norm The costs imputed to services should be previously assigned to each Disaggregation Information Requirements for Operators The concession must supply to the regulator the following documents Regulatory Accounting Additional Documents Income Statement Balance Sheet Cash Flow Statement Statement of Changes in Equity Notes to the Accounts Report of accounting procedures used to prepare the financial statements, with detail breakdown of the cost drivers Report of detailed transactions with related parties Report containing a detailed explanation of current results and any deviation from the budgetary figures Report of the use of assets and investment plans Sources of financing of current and future investments Operational statistics Methodology used to set unregulated prices Auditors report Declaration of directors’ responsibility Other valuable information for understanding of information Basis of Allocation of Central Overhead Costs which are not identifiable in line with Generation Transmission & Distribution function Example Interest on foreign loan of miscellaneous projects and Forex loss General & Admin Expenses of Service Departments, Directorates of Accounts, Finance, Personnel Tariff Setting: Getting the Price Right Cover Operating Costs Meet Past and Future Investment Needs Provide Investors Rate of Return on Investment Operate Without Subsidies Cover Operating Costs Full Cost of Energy Repairs and Maintenance Labor Customer Service Taxes Interest on Debt Procedure for Electricity Rate Calculations Projections Calculation of overall costs Depreciation costs Demand Projection Lighting Low-voltage power Repair costs High-voltage power Operation Plan Taxes Business returns Principles of the tariff system Fixed lighting Low-voltage Power Night Power Fuel costs Funding plan Determination of electricity rates Usage-Based Power Operation costs Labor costs Facility Plan Calculation of individual costs High-Voltage Power Commercial Power Ultra-high-voltage power Ultra-high-Voltage Power Commercial Power Fixed rate system Usage-based charge system Basic charge system Time Table for Resetting a Price Control Request for Information 2 years ahead Assess and amend Information 18 months ahead Operating Costs Demand forecasts Assets Base Determine form of Cap 15 months ahead Investment Determine Rate of Return15 months ahead Select candidate Price Cap 12 months ahead Predict Resulting Revenue Calculate Revenue Needs Compare with Revenue Needs Check cash flows etc If Appropriate If not Propose Price Cap At least 9 months ahead Company Accepts Company Rejects Appeal mechanism: 9-3 months Implement Price Cap At least 1 month ahead Source:Green R and Pardina M R (1999), Resetting Price Control for Priv atized Utilities: A manual for Regulation (p 3), EDI Development Studies Single Buyer Model for Electricity Generators Transmission and Dispatch Distribution Customers Ioannis N Kessides (2004):Reforming Infrastructure: Privatization, Regulation, and Competition. A Compilation of World Bank and Oxford University Press The Wholesale Competition Model for Electricity Generators Transmission and Dispatch Distributors Customers Ioannis N Kessides (2004):Reforming Infrastructure: Privatization, Regulation, and Competition. A Compilation of World Bank and Oxford University Press Purpose of Uniform System of Accounts (USoAC) USoAC are important for systematic and efficient functioning of the regulated utilities financial system It allow regulators, creditors, auditors, and others to rely on creditable, transparent, and comparable financial accounting & Reporting information Current BERC Regulated Utilities subject to Uniform System of Accounts BERC DPDC DESCO WZDC NZDC PDB REB PGCB EGCB . Current Accounting System Each regulated utility under BERC jurisdiction records their accounting books in a non-consistent forms Utilities have different aggregated Chart of Accounts The adaptation of Accounting Practices varies from utility to utility Revenue recognition Asset recognition Expense recognition Submission of Reports to BERC on the basis of aggregated accounting practice Uniform System of Accounts All Utilities will provide their financial statements to BERC in the same format All the records will follow a uniform system of accounts Guidelines for proper booking and accounting of utility operation Establishment of Guidelines for all accounts & sub-accounts Establishment of reliable financial and accounts information for regulators, creditors and other interveners. Allow transparency in the Sector’s financial system Advantages of Uniform Accounting System Necessary: for BERC to carry out its regulatory functions under the Act. Uniform Reporting System: to BERC for rate setting by auditing utilities’ books and records and establishing fair and reasonable rate of return Cost Allocation: provides needed accounting information for cost of service study Transparency: Provides the regulators and the public transparency in the regulated utilities accounting recording system Completeness: Provide consistent financial and accounting information to the Regulators and the public Flexibility: Provide a platform that can be modified and enhanced as needed Continuity: In accordance with the existing practice in the companies Limitations of Existing Accounting System Lack of proper financial and accounting recording system for the regulators and the public to investigate rate case applications. Non-Compliance for auditing by the regulators and the independent auditors Non-Compliance of International Accounting Standards (IAS) Non-Comparability between utilities within the Sector Examples of Current Accounting System Current practices as observed by Statutory Auditors performing recent independent audit of the following firms: Qualifications Bangladesh Power Development Board Only maintains Cash Book & Bank Book Gratuity & Pension Expenses not correctly shown in Financial Statements Accrued Fixed Deposit Receipts (FDR) income not recognised Customer Security Deposit could not be identified correctly Clearing A/Cs not reconciled with Regional Accounting Office (RAO) A/Cs Foreign & Govt. grants not properly recognized Qualifications (cont.) Bangladesh Power Development Board Deposit work fund created but no adjustment made after the construction/installation of Assets Correct status of slow moving/obsolete inventory could not be verified (applies to all utilities) Qualifications Power Grid Company of Bangladesh Ltd. No physical count of fixed assets conducted and no fixed asset register maintained No physical inventory count No recognition obtained from NBR for “Unfunded Gratuity Scheme” Concerns Power Grid Company of Bangladesh Ltd. Inadequate Insurance Coverage of FA Absence of FA Addition & Disposal Policy Item-wise Inventory List not Available GMD reported Inventory differs from Physical Counting of Inventory No Financial & Accounting Policy Developed Inadequate Internal Audit Coverage and Consolidation of Financial Statements Concerns (cont.) Power Grid Company of Bangladesh Ltd. Transmission charge not Independently Verified Cash Transaction amount Notable Opportunity Lost in FDR Interest Bank Reconciliation Statements incorrectly prepared Long Outstanding cheques in Reconcilation Tax at Source deducted inadequately Concerns (cont.) Power Grid Company of Bangladesh Ltd. Overtime Register for employees not found Log-book of Sub-Station not Updated Long Pending of Unadjusted Advance Qualifications REB: 70 PBSs Theft, burn or damage to Electricity/ Equipment in Service was not recognized correctly in the Financial Statements Interest on Long Term Loan recognized in the wrong period. Cash flow Statement had not been prepared Compensation received Electrical Equipment Damaged/Destroyed was not included in the P & L A/C. Concerns REB: 70 PBSs Company is operating below BEP PBS could not utilise a line bought from PBS causing loss System loss percentage prescribed by REB has been fluctuating over last 5 years Obsolete items in PBS store Significant amount of Consumer bills lie outstanding Concerns (cont.) REB: 70 PBSs PBS required to invest in Asset Replacement Fund but there is a shortfall PBS required to invest in Donation Reserve Fund but there is a shortfall Significant amount of money lies with the Cashier which is not covered by insurance No inventors of materials in shops Concerns Non-regulated Independent Power Producers (IPP) (Current problems which may benefit from USoAC) Detailed break down of FA valuation as not available for which ascertaining FA value for future insurance claim might be difficult 2 Generation Plants inactive, and there is a risk of penalty by BPDB if the 3rd plant closes Depreciation treatment are not provided properly in accounting system Correct status of slow moving/obsolete inventory could not be verified Tax on dividend to shareholders not correctly done Tax on ‘off-shore’ technical service also not correctly adjusted Observed Issues to be Addressed No asset valuation in any Utility No current fixed asset register No current Depreciation Study after the transfer of assets No Uniformity in depreciation application across the Utility In a Nutshell Implementation of the Uniform System of Accounts allows BERC to carry out the provisions of the Act and provide transparency & reduce the information asymmetry and to improve the quality of regulation For Bangladesh USoAC is one of the key regulatory elements for effective regulations of utilities and is important for systematic functioning of the regulated utilities financial system recording within the sector. What is the USoAC?? USoAC or the Uniform System of Accounts is a Prescribed System of Accounts Designed to segregate each account type of the Utilities according to Assets, Liabilities, Income and Expense The USoAC has been successfully implemented and practiced in the United States for more than 100 years It is operated by the Federal Energy Regulatory Commission (FERC) in USA Purpose of the USoAC USoAC is important for systematic and efficient functioning of the regulated utilities financial system It allow regulators, creditors, auditors, and others to rely on creditable, transparent, and comparable financial accounting & Reporting information How the USoAC will Function? Advantages of the USoAC Current Accounting Practice Limitations of Current Accounting Practice Collaborative Workshops 1st Collaborative Workshops 2nd Collaborative Workshops 3rd Collaborative Workshops 4th Collaborative Workshops 4th Collaborative Workshops (contd.) No. of Participants Organization Designation 2 DPDC DGM (Finance), Deputy Manager (F) 1 WZPDCL Manager (F) 1 United Power Gen. & Dist. Co. Ltd. Deputy Manager (A & F) 1 RPCL Deputy Manager (A & F) 1 DESCO Deputy Manager (F) 1 BPDB Additional Director (Finance) 2 EGCB Ltd. Manager (F & A), Manager (F) 1 REL Chief Accountant, Manager (A/cs & Tax) 2 REB Controller (F & A), Director (Finance) 2 PGCB Deputy Manager (A), Manager (A) 1 APSCL Asst. Manager (F), 1 Summit Power Manager (Internal Audit) 2 NWZPDCL Deputy Director (F), Director (F Power Cell Deputy Director (F) Features of the Workshops Following the Workshops Thank You