This submission is made in relation to the annual Performance-Based Rate-Making (PBRM) tariff adjustment filing for 2015, in accordance with the All Island Electric Licence 2001 (the Licence), Schedule 3, section 4, which states:
“The Licensee shall make annual filings to the Office at least sixty (60) days prior to the Adjustment Date. These filings shall include the support for the performance indices, the CPI indices, and the proposed Non-Fuel Base Rates for electricity, and other information as may be necessary to support such filings….”
In accordance with the Licence, the OUR’s January 7, 2014 Determination Notice and Determination Notice Addendum 1, the 2015 annual non-fuel tariff adjustment will incorporate changes in relation to the annual inflation adjustment, the resetting of the base foreign exchange rate and the X factor adjustment, however, it will not include any adjustments for either the Q factor or the Z factor.
For the 2015 annual tariff submission, we wish to note that system losses continues to be one of the primary challenges facing JPS and it presents a threat to the Company’s viability and to energy security for Jamaica. JPS remains steadfast in its belief that the reduction of electricity theft is a national problem that must be tackled jointly by the Government through legislation and targeted social intervention, the Regulator through supportive and proactive regulation and the utility through effective loss reduction initiatives. Based on the proximity of this filing to the OUR’s Determination notice of January 7, 2015 in which the target was adjusted and the fact that the Determination is under appeal, JPS is not requesting a review of the system losses target at this annual adjustment. The Company however reiterates and maintains the view that the target is unreasonable and bears no relation to the reality of the losses experience in Jamaica.