From:	hha99175@bigpond.net.au
Sent:	Thursday, 31 July 2014 6:54 PM
To:	Web Email Addresses
Subject:	Unite against Unity submission

Dr. Malcolm Roberts
Chairman Queensland Competition Authority G P O  Box 2257 Brisbane Qld 4001 . 
 
Re – SEQ  Long Term Framework – Implementation [ July 2014 ] 
 
Dear Dr. Roberts ,
Unite against Unity is pleased to respond to this invitation for public 
comment on implementation of the proposed “Light Handed “ regulatory regime 
for water service business entities in S E Q .
 
Unite against Unity Summary Comment – 
 
Without QCA’s independent confirmation that the Queensland Governments 
determination of 2008 legacy regulatory assets has correctly used the deprival 
value approach set out in pages 32 – 35 of the Authoritys Statement of 
regulatory Pricing Principles for the Water Sector[ December 2000], adoption 
of the modified C P I indexation methodology proposed in this draft will not 
achieve items – a- b – c and d , the four overarching regulatory objectives 
set out  on page IV for Moretons consumers of Water services . 
 
Discussion - 
 
Unite strongly endorses the four overarching regulatory objectives that are 
consistent with the Statement of Regulatory Pricing Principles for the Water 
Sector [ December 2000].
Unite also reaffirms the Associations rejection of the ‘Light Handed “ 
regulatory regime for Unitywater for reasons set out in the public submission.
The permissible return on regulatory assets constitutes more than 60 % of 
maximum allowable revenue . Given past failures to perform satisfactory prices 
monitoring investigations by accepting restrictive terms of reference set out 
by the Ministers Q C A , it is surprising that the Authority now proposes a 
regulatory prices framework from 2015 which effectively embeds the inflated 
valuations of regulatory assets determined by the Queensland Government  in 
2008 based on flawed advice from K P M G . 
 
Development of this draft implementation proposal makes hollow the Authority’s 
commitment to consider the associations public submission on the Regulatory 
Framework Paper [ Q C A  2014 a ]  dated the 25 th June and represents a waste 
of public resources . 
 
Rodney Hansen – Unite against Unity
www.uniteagainstunity.info