|
DEPARTMENT
OF TRADE AND INDUSTRY
UK COAL OPERATING AID SCHEME
CONSULTATION PAPER ISSUED BY IMPORT PARITY PRICE
PANEL
- INTRODUCTION
- On 17 April 2000 the Secretary of State for Trade and
Industry, Stephen Byers, announced, as part of a review of
energy policy, that the Government was discussing with the
European Commission the potential for temporary state aid to the
coal industry. The DTI subsequently issued a paper for
consultation on a Proposed Coal Subsidy Scheme.
- On 26 July the DTI notified the Commission of its intention to
pay operating aid to UK coal producers, and issued a document
"UK Coal Operating Aid Scheme" explaining how the
scheme would be implemented. This Document is available at www.dti.gov.uk/support/coal.htm.
The Commission gave approval to the scheme on 15 November.
- A key objective of the coal subsidy scheme is that it should
not distort competition in the energy market. To achieve this
objective requires that coal purchasers should not be able, as a
result of the subsidy scheme, to purchase coal more cheaply than
they would have been able to do had the scheme not existed.
Amongst the criteria for paying subsidy, therefore, is that the
level of subsidy must not cause the delivered price of coal to
undercut the price of third country coal of an equivalent
quality and sold on equivalent terms. In the document issued on
26 July, the DTI announced its intention to establish an expert
panel (the Import Parity Price Panel or IPP Panel) for the
purpose of calculating an import parity price in respect of
contracts entered into after 1 January 2000 that are to be
fulfilled, or partly fulfilled, by a production unit for which
subsidy is being sought.
- On 1 December 2000 it was announced that the Secretary of
State had appointed members of the IPP Panel. They are Andrew
Horsler (Chairman), David Brewer and John Cousins. The
announcement can be found at www.dti.gov.uk/support/coal.htm
Terms of reference
- For each contract under consideration, the Panel will be asked
to assess, and to advise the Secretary of State:
What cost, in pence per GJ, the buyer of that
UK coal would have had to incur if it had entered fixed price
contracts to secure coal of similar quality and on similar terms
to those in the UK contract but from a non-UK supplier?
- The terms of reference of the Panel, as included in the 26
July notification, are attached at Appendix A.
Consultation
- There are many areas of complexity in determining an Import
Parity Price. The Panel has considered the factors which should
be taken into account in establishing an IPP, and the
methodology it intends to adopt. The Panel recognises that each
contract will need to be considered on a case by case basis, and
its approach is based on practical experience of the UK and
international coal markets, and of custom and practice in
negotiating and managing coal contracts.
- The purpose of this Consultation Document is to set out the
main issues and the underlying methodology, and to invite
comments. The Panel will consider all comments received, and in
the light of these, will issue a further statement.
- It is the Panel's intention also, when a specific contract is
under consideration, to invite the applicant for subsidy and the
purchaser of the coal under that contract to make any
representations that they wish.
- Comments on matters raised in this Document should be sent by
Friday 19 January, in writing, to Arantxa Fernandez either by
electronic mail (preferably in Word 6.0 or text format) to:
E-mail: arantxa.fernandez@dti.gsi.gov.uk
Or to:
Arantxa Fernandez
IPP Panel
Room 295 - Coal Directorate
Department of Trade and Industry
1 Victoria Street
London SW1H 0ET
Fax: 020 7215 2753
It would be helpful if those responding could clearly state who
they are and, where relevant, whom they represent. Should
respondents wish any part (or all) of their comments to be treated
in confidence, this should be made clear in any electronic mail or
papers. In the absence of such an instruction, submissions will be
assumed to be open, and may be shared with others or published by
Ministers, or placed in the Libraries of the Houses of Parliament.
- IMPORT PARITY PRICE PRINCIPLES
- The Terms of Reference of the IPP Panel require the Panel to
set an import parity price (IPP) for each contract signed for
sale of UK coal on or after 1 January 2000 in respect of which
subsidy is being sought. For each contract the Panel will be
asked to assess:
What cost, in pence per GJ, the buyer of that UK coal would
have had to incur if it had entered fixed price contracts to
secure coal of similar quality and on similar terms to those in
the UK contract but from a non-UK supplier?
- The Panel will assess the IPP on the basis of prices in
hypothetical contracts finalised at the same time as the UK
contract which is under consideration was finalised. This will
ensure that the IPP determined by the Panel takes account of
market conditions prevailing at the time the UK contract was
being negotiated. The Panel in establishing the IPP will take
account of all relevant factors including Price Adjustments
discussed in Section 3 of this document, Shipping and Port
issues (Section 4) and Inland Transport Costs (Section 5).
- The international market for coal is characterised by
producers or traders selling either Free on Board (FOB)
cargoes of suitable size contracted by the purchaser, or on a
Carriage, Insurance and Freight (CIF) basis with the seller
arranging the ocean sea freight. In either case, coal and
shipping costs are usually denominated in US dollars ($).
Contracts for overseas coal seldom extend beyond one year, or
if of longer duration they normally contain annual price
reviews. This will present the Panel with difficult decisions
in assessing IPPs for medium and long-term UK contracts that
have annual indexation formulae.
- The Panel would welcome advice on the availability and
nature of longer-term contracts in the international market
for coal. If such contracts are not available, the Panel will
have to form a view as to the price that would have applied
had they existed. Normally, one would expect the overall price
to represent a discount to the current price when prices are
high and expected to fall, and a premium to the current price
when prices are low. Forward markets have recently started to
emerge, which may provide some guidance. If any party can
demonstrate that a longer-term international price was
available or an international contract containing an
indexation formula, at the time when the UK contract was being
finalised, then the Panel will take this information into
account in determining the relevant IPP. The Panel seeks
the views of respondents to this issue.
- A feature of UK coal purchase contracts is optionality, and
the level of optional tonnage in a contract can be valuable to
a buyer, particularly in a rising market. The Panel
would welcome views as to how to value options in UK coal
supply contracts compared with international contracts.
- The starting point for establishing the IPP will be the
Sterling price of imported coal at an appropriate port or
ports delivered on a CIF basis. The Panel has considered ways
of establishing this CIF price, and in the absence of a liquid
and transparent market for world coal, a recognised, well
established and independent index or price indicator appears
to be the most logical solution. The lack of transparency in
the world market for coal makes the auditing of any price
indicator extremely difficult, and the Panel acknowledges that
a formal audit trail of any chosen index will be impossible to
establish. The Panel has considered the following
international coal price indicators.
McCloskey Coal Information Services (MCIS)
NWE Steam Coal Marker Price
- The MCIS NWE Steam Coal Marker is a long established price
indicator, first quoted in January 1991, and produced on a
monthly basis until earlier this year when the frequency was
changed to weekly postings. For historical comparison and
indexation purposes, the monthly price is taken from the first
price quoted each month. The monitored price is a spot price
delivered CIF to NorthWest European ports, in $/te for 6,000
kcal/kg (25.13 GJ/te) coal, with 1% or below sulphur content,
on a Net as Received (NAR) basis. The marker is prepared
through regular communication with key market participants.
Input for the marker is collected up to 3pm (Central European
Time) on the last business day of each week for publication on
that day. To maintain balance and consistency and to ensure
that no one business sector is dominant in the survey, a wide
variety of major buyers, sellers, traders and brokers are
contacted each time the index is produced. Prices that are
quoted on a FOB basis are converted to CIF using freight rates
supplied by the London ship-broking community servicing the
relevant routes for delivery within the appropriate time
frame. The origin prices are then weighted against the volume
of coal imports into NW Europe as reported by the European
Commission (the method of weighting is currently under
review).
- The coals monitored are all steam coals for power station
and general industrial use for delivery within 90 days. Spot
prices are defined as one off purchases from single barge
cargoes to large cape size vessel cargoes. NorthWest Europe is
defined as shipments, of the most economical vessel size, into
ARA, France, Belgium, North Sea Germany, Ireland and the UK.
The index captures the majority of traded coals, but excludes
higher sulphur coals on the basis that these require much
lower sulphur material to blend with them to ensure an
acceptable power station fuel. All coals are converted to a
standard value of 6,000kcal/kg NAR.
- The Panel has certain concerns about the way the information
for the MCIS marker is collated and would have been more
confident if the information gathered had been independently
audited. The MCIS steam coal marker is however widely used and
has become respected throughout the coal community.
European Union Power Station Contract Index
- The European Union’s (EU) power station contract index
reports delivered prices of coal to utilities throughout the
Union. The index is produced on a quarterly basis, but the
time delay in the reporting of trades and deliveries extends
the elapsed time of delivery to the time it is reported to at
least six months. Analysis of the movement of the EU index
shows reasonable correlation with the MCIS index, but the
delayed nature of the information is apparent.
Energy Argus International Index
- COAL Daily, a Washington, USA publication launched the
International Index in December 1998 to track the price of
coal shipments to NorthWest Europe. Sources are asked to give
their best price estimates for the spot shipments on a CIF
basis to ports of Amsterdam, Rotterdam and Antwerp with 6,000
kcal/kg coal at 1% sulphur for delivery within 90 days. The
Index reflects the current price of both direct and
"over-the-counter" (OTC) spot coal market
transactions, though transactions completed since the previous
published index are considered. Input is collected up to 3pm
on the last business day prior to publication from contacts
with most or all of the major buyers, sellers, traders and
brokers. To prevent any chances of "gaming" or
attempts to sway the index, the top and bottom 10% of
responses are discounted.
Tradition Financial Services API#1 and API#2
Indices
- Tradition Financial Services (TFS) is a leading broker of
over-the-counter physical and derivative products established
in 1985. It has developed hedging and risk management
transactions in coal from offices in London, Stamford USA,
Frankfurt, Singapore and Sydney. The first TFS API#1 index was
launched in February 1998 as a monthly basket index for the
Amsterdam/Rotterdam/Antwerp (ARA) coal price.
- The prices used to compile the API#1 index are the FOB barge
quotes published by Coal Week International (CWI) and South
African Coal Report (SACR) along with the MCIS Steam Coal
Marker as published in International Coal Report. The CWI and
SACR prices are adjusted to the MCIS basis of 6,000 kcal/kg
CIF, NAR and by a flat $2 to adjust barge quotes to a full
cargo basis. The three prices are then averaged with no
weighting to arrive at the TFS API#1 index.
- The TFS API#2 is a basket index for the ARA coal price found
to be more reliable than the TFS API#1 index, and has become a
benchmark against which all CIF ARA financial transactions
have been marked to the market. It was first produced as a
monthly index in December 1998, but from 6 November 2000 has
been published weekly and from 17 November issued on a daily
basis. The prices used to compile the index are the simple
average of the weekly MCIS Steam Coal Marker numbers published
in the International Coal Report and Energy Argus’
International Index published in COAL Daily. The basis of
API#2 is 6,000 kcal/kg, ARA, CIF, NAR. The TFS API#2 Monthly
index is the average of the weekly API#2 numbers for those
Fridays falling within that calendar month.
WEFA Monthly Spot Coal Price Monitor
- WEFA Energy based in London and Boston USA are a team of
consultants and analysts who provide a wide range of economic
and market consultancy and research services on coal and other
energy industries. The WEFA Monthly Spot Steam Coal Monitor
available to their clients, provides indices for South
African, Colombian and Australian coal on an FOB basis. It is
produced using steam coal prices provided by the European
buyers of imported steam coal. They are canvassed for the
price they would pay for a spot capesize cargo of coal for
delivery within the next three months for coal from the three
regions and based on the following qualities: South Africa
6,000 kcal/kg NAR, Colombia 11,600 Btu/lb GAR, Australia 6,000
kcal/kg NAR. Prices are quoted in US$/GJ and are tracked for
each country of origin, together with freight rates sourced
from London based shipbrokers to produce delivered prices on a
Carriage and Freight (C&F)basis
- WEFA also produce an index comprising 60% South African, 30%
Colombian, and 10% Australian coals and plan to publish a
rolling two-year record of price movements every month. The
WEFA monthly indices have been used as a benchmark index for
derivative trades and also for physical coal transactions.
Standard European Coal Agreement (SECA)
- The SECA contract was launched in late 1999 and in recent
months has gained substantially in both credibility and usage.
It is a standardised FOB barge ARA contract for 5,000 tonnes
with a quality specification of 6,000 kcal/kg NAR which
reflects the average steam coal grade used in Europe. It can
be fine tuned by agreeing premia and discounts for individual
specifications. The contract is for physical delivery with
payment due in five days. However, it is also used for
financial transactions and total physical and financial trade
in the on-line and OTC markets has exceeded 2m tonnes in a
single week. There is therefore sufficient liquidity in the
market to enable the entrance of financial traders. Whilst
there may be some concerns about the applicability of a
standard European barge sized contract to UK circumstances,
the value is derived from actual market transactions and it is
traded in blocks. It is also traded forward for up to a year.
Tracking the contract's value may therefore provide valuable
information on the NW European market in general.
The Panel’s Use of Coal Price Marker
Indices
- In considering the available indices and marker prices, the
Panel has examined imported prices of coal over periods to
look for potential areas of divergence, and the timely
presentation of information. The EU Index was considered to
lag the market. The TFS marker prices are both averages of the
MCIS marker with other indices in an attempt to temper any
sudden movement. The SECA index has become widely used in
recent months. It is apparent that the MCIS marker and the
WEFA C&F, the API#2, and the SECA indices all provide
reasonably consistent information on which actual trades by
market participants have been based. The Panel will be
undertaking further close analysis of the bases of, and the
recent trends shown by, all of these indices to determine
which, or an average of which, is the most appropriate for its
purposes. In the meantime, the Panel invites the views
of respondents on these indices. At the end of the
consultation period the Panel will decide which basis to use,
and will make this known in the final statement describing its
approach.
- Having selected one or more indices, the Panel proposes to
use as the starting point in deriving a relevant IPP, the
average over the three-month period immediately prior to the
finalisation the UK contract in respect of which subsidy is
being sought. The Panel considers that three months is an
appropriate period within which the UK contract would be
negotiated, and it would therefore seem reasonable to average
the import marker price over a similar period. Whilst the
Panel thinks that this is the most appropriate method of
assessing the IPP, the Panel will look at any other
information that is brought to its attention. The Panel
invites comments on the appropriateness of this approach to
establishing the starting point for determining an IPP.
Sterling/US Dollar Exchange Rates
- The price of international coal is usually negotiated in US
Dollars and the Panel has discussed various methods of
handling the Sterling/US Dollar exchange rate risk. The Panel
considers that traditionally, UK generators handled exchange
rate risk by forward purchase of US Dollars at the time that
the contract to purchase imported fuel was finalised. The
method of financial risk management was essentially a matter
for the treasury department of UK companies who might modify
this approach following consideration of forward currency
exchange rates. Most UK coal generators are now either
subsidiary companies of US based corporations or have
substantial assets that are US based and the traditional
methods of financial risk management may not be appropriate in
the current climate. Because this is a matter for individual
companies and can be managed, the Panel does not propose to
ascribe a specific value to exchange rate risk.
- The Panel must however fix the time of the currency exchange
in an appropriate manner to derive the IPP. The Panel
therefore proposes to use the forward Sterling/US Dollar
exchange rate for the midpoint of the duration of the coal
contract in respect of which subsidy is being sought. To allow
for the period over which the UK contract is negotiated, the
average of this daily forward rate as published in the
Financial Times over the three month period prior to the
finalisation of the UK contract, will be taken to fix the
exchange rate. The Panel invites comments on the
appropriateness of this approach.
- PRICE ADJUSTMENTS
- The Panel is required under its Terms of Reference (Appendix
A) to assess the price of imported coal which is of similar
quality and sold on similar terms to those in the UK contract
which is under consideration.
- Many UK coals are of different quality to most coals traded on
the world market. Furthermore, the terms under which coals are
sold within the UK tend to be significantly different to those
for international coals. A key consideration for the IPP Panel
is what adjustment should be made to an international price
prevailing at the time a contract was entered into, to equate on
quality and other contract terms with a UK coal. The basic
philosophy of the panel is to assess the impact on price from a
basis of custom and practice within the industry, rather than to
adopt a more academic approach.
- The factors that the Panel has identified as likely to be most
significant are as follows:
- Calorific value
- Ash, moisture, sulphur, chlorine and heavy metal content
- Ash characteristics
- Consistency
- Payment terms
- Differential loss of heat content
- Delivery terms and penalties
- The Panel believes that some of these factors can be
quantified, others are more difficult, and some can only be
assessed from a qualitative point of view.
Calorific Value
- The most important parameter in valuing a coal is its
calorific value. To take account of this factor, coals will
normally be valued on a p/GJ NAR basis rather than a £/tonne
basis. Power stations are capable of burning coals within a
reasonable range of calorific value. In the case of power
station contracts, the Panel does not propose to make any
secondary adjustments to an international price where the heat
content of the UK coals fall within a range of 22.5 to 27.5 GJ/te.
If any UK coals are considered that have calorific values
outside this range or have other unusual characteristics, as
is possible for example in South Wales, the Panel will
consider them on a case by case basis, taking account of any
information that the receiving customer is willing to provide.
With coals for specialised industrial use, the Panel will need
to examine each case individually and modify its approach
where appropriate.
Ash
- The ash content of a coal is primarily taken into account in
the calorific value of the coal. The higher the mineral matter
content, the lower is the calorific value. However, it has to
be acknowledged that UK coals tend to be of a higher ash
content than international coals. Typical deepmined UK ash
contents are around 15% compared to a typical 10% on the world
market. Power stations and some other customers do incur
additional costs in the handling of ash through the their
systems. The value or cost of the furnace bottom ash and
pulverised fuel ash is very much customer specific depending
on the arrangements for ash disposal and opportunities for
sale of ash. In assessing a contract for an IPP, the Panel
would be pleased to receive advice on this point from the
customer receiving the UK coal. In the absence of specific
advice, the Panel does not propose to make an adjustment to
the international price to take account of different ash
levels unless the ash content of the UK coal is particularly
high or low.
Moisture
- The moisture content of a coal is primarily taken into
account in the calorific value of the coal since calorific
values will be taken on a net, not gross, basis. The Panel is
not aware of price adjustment provisions for moisture content
in UK coal supply contracts over recent years, and does not
propose to make such an adjustment to international prices.
Sulphur
- The sulphur contents of UK coals vary significantly. Sulphur
levels in English coals can be over 1.5% compared to a typical
maximum of 1% for international coals purchased by UK
customers, although generators have used some higher sulphur
international coals. In some circumstances higher sulphur
levels may be helpful to power station operation, especially
precipitator performance. However, the main importance of the
sulphur content of a coal lies in its impact on plant and
company SO2 emissions. This is very plant specific
and is dependent upon whether the plant has flue gas
desulphurisation (FGD) equipment or other sulphur dioxide
abatement technology installed.
- As a general principle, the Panel believes that higher
sulphur coals have a lower value. In purchasing a high sulphur
coal, a customer may be constraining his flexibility to
operate, or may limit his options by having to purchase a much
lower sulphur international coal within his overall portfolio.
In addition, for power stations with FGD, the higher the
sulphur the higher the limestone supply, works power and
gypsum production. The Panel will consider evidence in the
public domain on the additional costs of running FGD equipment
at higher sulphur levels, including evidence presented to the
Environment Agency. The Panel would particularly welcome
evidence from generators on this issue.
- The Panel does not believe that it is possible to make a
universally applicable monetary adjustment on grounds of
sulphur to equate an international coal to a UK coal. However,
the Panel recognises the increasing importance of the sulphur
content of coal and will assess on a case by case basis
whether there is a material incremental cost in burning higher
sulphur UK coal compared with lower sulphur imported coal. In
examining individual contracts, the Panel will be pleased to
receive advice on this point from the customer receiving the
coal.
Chlorine
- The chlorine content of UK coals varies considerably. Most
deepmined coals have higher chlorine contents than opencast
coals, which are close to international chlorine levels. Most
UK power stations have been designed and maintained to be able
to take the higher chlorine content of a blend of high and
lower chlorine UK coals. Historically UK generators set
chlorine limits on a plant by plant and company wide basis.
The plant by plant limits ensured chlorine would be below
levels that would cause enforced outage from corrosion and
tube leaks. The company wide limits ensured that sufficient
flexibility existed in managing a portfolio of coals to a
number of stations. With the plant divestments in recent years
the company wide limits are less relevant.
- Contracts between UK suppliers and electricity generators
have historically included downward price adjustments for
chlorine contents above certain base levels, but have not in
general included upward adjustments for chlorine contents
below this base. The costs to generators of plant outages
outweigh the level of historic chlorine adjustment provisions.
The Panel is of the view that generators will buy a portfolio
of coals that will not cause major operating problems. It is
not proposed that any adjustment will be applied to take
account of chlorine levels in UK coals unless these are
particularly high, say above 0.5%.
Heavy Metals
- The Environment Agency is progressively tightening limits on
the heavy metal content of fuels for generation, and
generating companies have to take account of heavy metal
contents in their procurement decisions. However, this is not
a pricing issue. A coal is either acceptable or not. The Panel
does not propose to make any price adjustments in respect of
heavy metal contents.
Ash Characteristics
- The propensity of individual coals to cause slagging or
fouling is very difficult to quantify or value. Typically
individual power stations or other customers would look to
test burn individual coals before making major contract
commitments. A coal therefore is either acceptable or not to
an individual customer. There is no basis for applying any
price adjustment for coals with a propensity to slagging or
fouling.
Consistency
- International coals, due to their reduced mining variability
and blending at the port of loading, tend to be of a high
consistency. UK coals are generally more variable and the
difference in quality between individual train deliveries can
be greater. However, provided that deliveries are within a
reasonable band, this should not impose additional costs on
the generator. Unless purchasers come forward with evidence on
this point, the Panel will not include any consistency
adjustment in the conversion of international prices to UK
terms.
Payment Terms
- There is a significant difference in payment terms between
international and UK coals. International coals (unless bought
through a UK trader) are generally sold on a FOB basis and
payment is due up to 2 weeks after the vessel is loaded. In
some cases, this can result in payment even before the coal
reaches the UK, let alone before it is delivered to the
customer. Typically imported coals may be held in stock at the
ports for anything up to 60 days. The time between payment and
delivery of an international coal to a UK customer can
therefore be significant. UK coals are typically invoiced
after delivery to the power station with payment made in the
middle of the month following delivery. The difference between
these payment terms will have some impact on customers'
working capital, albeit in most cases small. The Panel will
look at the payment terms in any contract put before it and
assess the difference between these and typical international
contract terms at LIBOR plus 1%. In general, the magnitude of
this difference will probably not be material, and the Panel
would not normally expect to make any adjustment to the IPP in
respect of payment terms.
Differential Loss of Heat Content
- For international coals the determination of quantity and
quality is usually undertaken at the load port. Quantity and
quality are also measured at the receiving power station. It
is not unusual for there to be a shortfall in heat delivered
to the final customer of over 1%. The actual level of
shortfall will depend upon the period of stockholding and the
amount of double handling. The more that these take place, the
higher the heat shortfall will be. For UK coals, the quantity
and quality is usually determined at the power station or
colliery/loading point. It is not known whether customers take
account of differential loss of heat content in comparing UK
and international prices, and the Panel will be pleased
to receive advice on this point.
Delivery and Penalty Terms
- The Panel recognises that the rate of delivery and penalty
clauses in smaller UK contracts may be such that there is no
realistic import equivalent. The Panel will consider each such
case on its merits.
Other Adjustments
- Some other factors have been raised that could impact upon
the value of an IPP, in particular:
- UK coals have traditionally attracted a premium over
international prices in the UK market. Should any premium be
attached to UK coals?
- Will the UK subsidy scheme have any impact on the world
market price of coal?
UK Premium
- There is little doubt that, over recent years, power
generators have been prepared to pay a premium for coal
supplies from the UK. The premium covered issues such as
security of supply, short supply lines and ease of
communication, flexibility of deliveries, known quality
parameters, longer-term security considerations as well as the
national and local public relations value of supporting UK
production. However, the level of premium has never been
quantified, and it has been wrapped up in the conclusions of
coal contract negotiations. Recent developments in the
generation market, with the divestment of coal fired plants
and the construction of new ports, suggest that any UK premium
going forward, if any, would be small and the Panel does not
propose to make any specific adjustment for this factor.
Impact On World Market Prices
- In 1999 world seaborne trade of steam coal amounted to 302
Mt. UK imports of steam coal totalled 12 Mt in 1999, i.e. only
4% of the international market. Whilst the total tonnage of
coal that is likely to seek support under the UK subsidy
scheme is not known at present, and will vary from year to
year, the Panel is of the opinion that the impact of the
subsidy arrangements on world market prices will be small. The
impact of state aids elsewhere in Europe, in Germany, France
and Spain, is far more likely to be having an impact on world
market prices than the arrangements in the UK. The Panel will
not take this factor into account in assessing an IPP.
Conclusions
- It is apparent from the above analysis that there are
several factors which add or detract from the value of an
international coal compared with a UK coal of equivalent
calorific value.
- Generally speaking, the lower ash, sulphur and chlorine
levels, and consistency of international coals enhance their
value, therefore it might be appropriate to adjust
international prices downwards to equate with UK coals in
calculating an IPP. On the other hand, different payment
terms, differential loss of heat content, and some of the
factors underlying the historic "UK premium" such as
short supply lines, easier communications, flexibility of
deliveries, and known qualities enhance the value of UK coals.
Many of these factors are specific to the customer concerned
and his plant, many are unquantifiable, and it would not be
possible to calculate a set of universally applicable
adjustments.
- With the exception of reflecting the impact of higher UK
sulphur and chlorine levels in specific cases, and possibly an
adjustment for differential loss of heat content, the Panel
does not propose as a general rule to make adjustments to the
international price in calculating an IPP. However, the Panel
will examine each contract individually to see whether there
are any other particular features of the coal or the contract
which merit specific consideration, and will be pleased to
receive views from the UK supplier and his customer.
The Panel invites comments on the proposed
approach to price adjustments set out above.
- SHIPPING AND PORT ISSUES
- To determine an IPP for each contract being considered by the
Panel it will be necessary to consider the costs and feasibility
of using the various coal importing facilities through which
purchases of imported coal would have been handled.
- The Panel considers that the ports available for importing
coal on a large scale to the main consumers of coal are
Hunterston, Redcar, Immingham Bulk Terminal, Humber
International Terminal, Bristol and Liverpool. Other ports such
as Hull and Newport could be used for limited volumes,
specialised qualities or in particular circumstances.
- The Panel will be establishing for its own use a database of
information on each port. Some of the information required is in
the public domain, such as the maximum annual throughput, the
maximum size of ship that can be handled, speed of unloading,
stocking capacity and rail loading capacity. The Panel will also
be seeking other information, which it will hold in confidence,
such as typical port charges.
- The location of each port and the maximum size of vessel that
can be handled will influence the CIF cost of coal delivered at
any port. As indicated in Section 3 of this document, the Panel
proposes to use certain well-established price indices as
primary reference prices, checked against or supplemented by
other sources of information. Such price information principally
reflects the price of international coal at ARA, and will need
adjustment if it is to be used to assess a comparable price at
the various UK ports. The Panel will be seeking expert advice on
differential CIF costs at different ports, and on certain other
matters relating to UK ports.
- HM Customs & Excise now produce more reliable figures of
import volumes and CIF prices at different ports. While these
are historic in that they reflect deliveries against contracts
signed earlier, they may provide useful additional information
to that gained elsewhere as they represent actual transactions.
The Panel would welcome information from coal
users, traders and handlers on the matters set out above.
Port Capacity Limitations
- A key consideration is the extent to which there are
limitations on available capacity at any port, which would
restrict the ability of purchasers to import coal through such
ports in replacement for UK supplies, or lead to additional
costs as a result of congestion. This is likely to be a
particular issue on the East Coast, where there are capacity
limitations at the ports which represent the lowest cost routes
for imports to the power stations in Yorkshire and the East
Midlands.
- It will be necessary to take a view on the available spare
capacity at all the ports. There will be an ongoing level of
steam coal imports into the UK, because the UK coal industry,
even with subsidy, is unable to satisfy total demand. Over the
next two years these imports are likely to be running at much
the same level as in recent years. At Redcar and Immingham the
principal coal imports are of coking coal, which have been
running at a broadly stable level for some years. The Panel will
examine the recent usage of each port, and existing commitments,
in order to assess the availability of spare capacity.
- In determining IPPs for UK coal contracts, the Panel will need
to decide the ports through which hypothetical equivalent import
contracts would have been handled. The Panel has identified two
principal approaches to this issue.
- The first approach can be termed "first come, first
served". The first contract for which an IPP is being
calculated would be assumed to take the first tranche of spare
capacity at the port providing the lowest cost import route.
This would then remove that capacity from consideration for the
next contract, the capacity providing the lowest delivered cost
imports would be progressively taken up, and IPPs for later
contracts would be based on the assumption of using other, more
expensive, import routes. While there is some logic to this
approach, the Panel feel that it would create an increasingly
artificial and unworkable situation. IPPs for hypothetical
import contracts would be being calculated on the assumption
that certain ports were unavailable. In reality not all these
contracts would have been awarded to overseas suppliers, there
would be capacity at these ports, and customers would able to
obtain quotations for using them. There could be some difficulty
in establishing the precise order in which applications for
subsidy should be examined, and the order in which available
port capacity was to be taken up. Later applicants could be
adversely affected purely through accidents of timing of their
contract portfolios. There is also an artificiality in that the
Panel are considering only those contracts entered into from 1
January 2000, and not earlier ones.
- The other approach is based on a pro-rata allocation process.
For each year (or other appropriate period) the Panel would
aggregate the volumes of all the contracts for which IPPs were
being sought, and allocate them in a fair way across the most
appropriate available port capacity taking into account the
ongoing underlying level of imports. This would ensure that each
applicant for subsidy had his IPP assessed using a reasonable
share of the port capacity which provides the lowest delivered
cost imports. A disadvantage of this approach is that in some
cases it may not be possible to determine final IPPs until all
applications for subsidy in a particular period have been
received. This problem was foreshadowed in the DTI consultation
paper issued earlier in the summer. As indicated then, the Panel
would where necessary issue an interim IPP for a contract,
subject to finalisation when all applications for subsidy for a
particular period had been received.
The Panel believes that it is appropriate to
adopt the second of these approaches.
Comments are invited on the most appropriate
approach to the allocation of available port capacity between
hypothetical import contracts.
5. INLAND TRANSPORT COSTS.
- To determine an IPP for each contract considered by the Panel
it will be necessary to have information or to make estimates of
delivery costs between the production unit and the point of
consumption, and the delivery costs of imported coal between
ports and the consumer.
- Contracts for the sale of UK power station coal have usually
been priced at the pithead or opencast rail loading point, with
buyers meeting the cost of transporting the coal. Because the
subsidy is to be given to coal producers, and not to coal buyers
or to rail transporters, there can be no compulsion under the
scheme for coal buyers or railway companies to reveal details of
transport costs. If buyers and/or rail companies choose to make
such details available through statements approved by their
auditors, these costs can be verified and taken into account as
with other coal production costs. In the absence of this
information, the Panel will have to take a view on transport
costs between the point of production and the point of use.
- In general the majority of coal will be conveyed from pit to
power station or from import terminal to power station by rail.
To determine rail haulage rates, the Panel will enter
discussions with rail freight operators who have specialist rail
trucks for conveying coal to UK power stations. English Welsh
and Scottish Railways (EWS) have been established in this market
for several years, and Freightliner Heavyhaul are about to enter
the market. The Panel's principal interests in this regard are
the differential transport rates between conveying UK and
imported coals to the customer. The Panel intends to establish a
confidential database of such rail transport costs for its own
use in order to determine an IPP for each contract under
consideration
- For short journeys from pits to power stations road delivery
may be competitive, and the Panel will be guided by information
contained in the contracts being considered. Usually road
delivered coal would be contracted at a delivered price and the
Producer will be required to provide an audited statement of
road haulage costs as part of the application for subsidy. Where
a contract states a delivered price for coal, the Panel would
expect the transport element of the price to be transparent. For
road delivered contracts where coal is purchased at a mine or
loading point, the road distances, and appropriate road vehicle
carriage rates obtained from the Road Haulage Association might
be applied. The costs of delivery by canal barge to Ferrybridge
Power Station will also be considered where appropriate.
- Similar principles and methodology will be applied in the case
of industrial contracts being considered by the Panel. Where the
contract is on a delivered price basis, the coal company
applying for subsidy will be required to identify the transport
cost.
- In addition to establishing inland transportation costs, the
Panel will also consider rail capacity constraints over various
routes. The Panel will consult EWS, Freightliner and Railtrack
with a view to identifying the constraints on rail transport
between import terminals and power stations. The availability
and constraints on rail loading infrastructure will also be
taken into consideration. Where rail capacity limitations are
identified on particular flows, the Panel will identify and
consider alternative sub-optimal import routes as a basis for
estimating the IPP.
The Panel seeks views from respondents on the
appropriateness of this approach to establishing the transport
cost elements underlying the calculation of an IPP.
- CONCLUSIONS
- The Panel believes that overwhelmingly the most significant
factors in the determination of an IPP are:
- The estimation of a dollar price of imported coal in a
hypothetical contract that the purchaser would have purchased
had he not signed a contract for UK coal
- The selection of the port or ports through which such
hypothetical imports would have been shipped, and the
resultant costs
- The estimation of transport costs between the ports and
points of consumption, and (where this not explicit) between
the UK production or loading points and the points of
consumption.
The Panel's approach to these issues has been
outlined in this paper.
- Against these three factors, most of the other questions
discussed in this paper are likely to be of second-order
importance. Nevertheless the Panel will examine each contract
in detail, to assess whether it is appropriate to make
adjustments for reasons of coal quality or because of the
specific contractual terms in the UK contract.
-
The Panel will welcome comments from interested parties on
all the matters raised, and views on whether there are any
other factors not discussed in this paper which should be
taken into account. The address and deadline for
comments is given in Section 1.
- During the consultation period the Panel will be further
examining and analysing all the available information relevant
to the determination of Import Parity Prices. The Panel's
final views, taking into account responses received to this
consultation, will be made known as soon as possible.
Appendix A
TERMS OF REFERENCE FOR THE IMPORT PARITY PRICING PANEL
A Pricing Panel will be established to set import parity price
(IPP) for each contract signed for sale of UK coal to UK consumers
on or after 1 January 2000 for which subsidy is sought. For each
contract the Panel will be asked to assess:
What cost, in pence per GJ, the buyer of that UK coal would
have had to incur if it had entered fixed price contracts to
secure coal of similar quality and on similar terms to those in
the UK contract but from a non-UK supplier
The IPP would be assessed on the basis of prices in
hypothetical contracts finalised at the same time as the UK
contract in question. This is to ensure that the IPP takes account
of market conditions prevailing at the time the UK contract was
being negotiated.
The Panel will be an independent body, made up of a mix of
experts, at least some of
whom will have direct experience of the industry. The Panel’s
procedures will be open and transparent in so far as that is
consistent with respecting the commercial
confidentiality of parties not applying for aid under the
scheme. The Panel will be free to seek representations from
interested parties in relation to any aspect of their work. Any
IPP recommendation from the Panel to the Secretary of State will
be made public.
In reaching its assessment, the Panel will take account of all
factors it considers relevant. The panel will be asked, in coming
to their decision, to take into account:
- Quality of the coal
Coal of equivalent quality must be of equal value in use to
the purchaser in terms
of:
· Calorific value
· Content of ash, moisture, sulphur, chlorine, heavy metals
· Ash characteristics (fusion, slagging)
· Consistency
and other components of importance to the equipment design.
- Supply terms
Equivalent contract terms on volumes of coal per unit time
(supply rate) and
overall contract duration, including options.
(c.) Transport costs
The cost of delivering the coal to the UK, including port
handling charges, and
from UK ports to the location where the contracted UK coal is
expected to be
consumed;
- Infrastructure limitations
Where transport infrastructure would be insufficient for the
full set of contracts
under consideration a higher price must be estimated to take
account of the costs
which would be incurred in expanding capacity or using
alternative transport
routes.
- Risks
These include the cost of hedging exchange rate risks given
that non-UK
producers are likely to have sought prices denominated in a
foreign currency; and
costs that the overseas supplier might have had to incur in
order to ensure a
comparable degree of security of supply.
- Other
Any other contractual matter which might reasonably be
expected to have a
measurable impact on the price of coal.
The Panel will be free to use any relevant information,
including price indices, in coming to their recommendation on an
IPP.
Back
to coal main page
Last updated 18 December
2000
| index |
|