MIDDLE EAST AND NORTH AFRICA (MENA) | ENERGY AND EXTRACTIVES GLOBAL PRACTICE | THE WORLD BANK GROUP 93936 M E N A E N E R G Y S E R I E S | R E P O R T N O . 9 3 9 3 6 - E G Transparency and Social Accountability in the Egyptian Power Sector MIDDLE EAST AND NORTH AFRICA ENERGY AND EXTRACTIVES GLOBAL PRACTICE THE WORLD BANK GROUP Transparency and Social Accountability in the Egyptian Power Sector M E N A E N E R G Y S E R I E S | R E P O R T N O . 9 3 9 3 6 - E G MIDDLE EAST AND NORTH AFRICA ENERGY AND EXTRACTIVES GLOBAL PRACTICE THE WORLD BANK GROUP Copyright © January 2015 International Bank for Reconstruction and Development/The World Bank 1818 H Street NW, Washington DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org Some rights reserved This work is a product of the staff of The World Bank with external contributions. 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Araya, ESMAP Designer: Studio Grafik Typesetting: vPrompt eServices Reproduction: AGS Contents Acronyms and Abbreviations 8 Acknowledgments 9 Executive Summary 11 Chapter 1 | Introduction 18 Chapter 2 | Objectives and Methods 19 2.1 Institutional Analysis 19 2.2 Performance Benchmarking 20 2.3 Customer Interface, Transparency, and Public Information Systems 20 2.4 Consumer Surveys 21 Chapter 3 | Current Situation and Key Findings 22 3.1 Institutional Analysis 23 3.1.1 Current Egyptian Power Sector Context 24 3.1.2 Main Challenges and Upcoming Changes 25 3.1.3 Reporting Lines and Responsibilities: EgyptERA’s Mandate 26 3.1.4 Stakeholders’ Reporting Obligations Towards EgyptERA 29 3.1.5 Interfacing Channel Between Licensees and EgyptERA 30 3.1.6 Recommendations on Reporting Lines and Responsibilities 30 3.1.7 Information Transparency and Disclosure Obligations 33 3.1.8 Annual Report Information Benchmarking 34 3.1.9 Public Information and Channelling 36 3.1.10 Channels to Convey Information 36 3.1.11 Communication 40 3.1.12 Conclusion 41 3.2 Performance Benchmarking 42 3.2.1 Benchmarks and Benchmarking Processes Used by Electricity Companies 43 Contents | 5 3.2.2 Benchmarks and Benchmarking Processes Used by EgyptERA 44 3.2.3 Benchmarks and Benchmarking Processes Used by EEHC 45 3.2.4 Normalization of Benchmarking Indicators 48 3.2.5 Communicating Benchmarking Indicators to the Wider Public 48 3.2.6 Conclusion 49 3.3 Customer Interface, Transparency, and Public Information Systems 52 3.3.1 Reporting and Information Flows Between Stakeholders and the Public at Large 52 3.3.2 Reporting Obligations 52 3.3.3 Supply Code 53 3.3.4 Information Flow Between Sector Stakeholders 57 3.3.5 Information Flows Between Distribution Companies and Consumers 58 3.3.6 Communication Channels and Customer Feedback 59 3.3.7 Information on Electricity Bills 60 3.3.8 Customer Charter 62 3.3.9 Information Flows Between EgyptERA and the Consuming Public 62 3.3.10 Public Disclosure Concerning Strategic Sector Plans and Projects 65 3.3.11 Issues 66 3.3.12 Conclusion 66 3.4 Consumer Surveys 71 3.4.1 Findings 73 3.4.2 Recommendations Related to the Methodology of Implementing the Survey 73 3.4.3 Assessment of the World Bank CRC and its Relevance to the Egyptian Case 74 3.4.4 Conclusion 74 Chapter 4 | Recommendations 75 4.1 Incorporating the Consumer Engagement into the Sector’s Goals and Operational Culture 75 4.2 Sector Reform via Organizational, Staffing, and IT Enhancements 78 4.3 Improving Information Flow to Enhance Transparency and Advance Trust Between the Sector and the Public 80 4.4 Categorization of Recommendations 83 6 | Transparency and Social Accountability in the Egyptian Power Sector Annexes 84 Annex A | Governance Arrangements of Egypt’s Power Sector 84 Annex B | Outline of Greece’s RAE Report on Customer Queries and Complaints 86 Annex C1 | Department Level Benchmarks for Distribution Companies Monitored by EgyptERA 88 Annex C2 | Unit Level Benchmarks for Generation Companies Monitored by EgyptERA 89 Annex C3 | Transmission System Operator Benchmarks Monitored by EgyptERA 90 Annex C4 | Financial Performance Benchmarks Monitored by EgyptERA at Company Level 91 Annex D1 | Technical Indicators at Company Level in EEHC’s Quarterly Benchmarking Report 91 Annex D2 | Commercial Indicators at Company Level in EEHC’s Quarterly Benchmarking Report 92 Annex D3 | Financial Indicators at Company Level in EEHC’s Quarterly Benchmarking Report 93 Annex E | Procedure for Providing an Incentive Mechanism 94 Annex F | Point System of an Incentive Mechanism 96 Annex G | Questionnaire (English) 97 Annex H | Questionnaire (Arabic) 102 Annex I | Commercial Quality Indicators in Brazil 110 Annex J1 | Information Items in Annual Data Packages Provided to EgyptERA by Distribution Companies 111 Annex J2 | Information Items in Annual Data Packages Provided to EgyptERA by Generation Companies 113 Annex J3 | Information Items in Annual Data Packages Provided to EgyptERA by Transmission Company 114 Annex K | Indicative Bill Format Proposed by EU 115 Contents | 7 Acronyms and Abbreviations AMR Automatic Meter Reading BoD Board of Directors BOOT Buy, Own, Operate, Transfer CBD Central Business District CEO Consumer and Energy Organization CRC Citizen Report Card CRM Customer Relationship Management DC Distribution Company DOS Distribution Systems Operators EDG Environment & Development Group EEA Egyptian Electricity Authority EEHC Egyptian Electricity Holding Company EETC Egyptian Electricity Transmission Company EgyptERA Egyptian Electric Utility and Consumer Protection Regulatory Agency EHV Extra High Voltage ERGEG European Regulators’ Group for Electricity and Gas EU European Union GIZ German Society for International Cooperation HV High Voltage IPP Independent Power Producer IT Information Technology MIS Management Information System MoEE Ministry of Electricity and Energy NG Natural Gas NGO Non-Governmental Organization NREA New and Renewable Energy Authority RAE Regulator Authority for Energy for Greece RFP Request for Proposal RMT Roundtable Meeting SMS Short Message Service TCI Sanmar Chemical Manufacturer TM Task Manager ToR Terms of Reference TSO Transmission System Operator WB The World Bank 8 | Transparency and Social Accountability in the Egyptian Power Sector Acknowledgments This study was led by Ms. Fowzia Hassan, Energy Specialist, The World Bank Group, and Evangelos Penglis and George N. Seferiadis of Kantor Management Consultants. Marjorie K. Araya of ESMAP assisted in the final production of this Report. The team would like to acknowledge Dr. Hafez El Salmawy, Director EgyptERA and his team for the extended cooperation and valuable contributions, data and information used to enrich this report. The team would also like to extend its gratitude to the many stakeholders with whom several roundtables were held over a period of one year to be able to bring a set of recommendations and conclusions to the table. The financial and technical support by the Energy Sector Management Assistance Program (ESMAP) is gratefully acknowledged. ESMAP—a global knowledge and technical assistance program administered by the World Bank—assists low- and middle-income countries to increase their knowhow and institutional capacity to achieve environmentally sustainable energy solutions for poverty reduction and economic growth. ESMAP is funded by Australia, Austria, Denmark, Finland, France, Germany, Iceland, Lithuania, the Netherlands, Norway, Sweden, the United Kingdom, and the World Bank Group. Acknowledgments | 9 Executive Summary Egypt’s electricity sector has the potential to benefit areas in coordination with the respective stakeholders from better social accountability and transparency. in the sector. The sector is suffering precarious financial situation, shortage in electricity supply, increasing frequent The recommendations are based on the following electricity interruptions, lower quality of electricity description for each of these areas: supply, and increasing consumer discontent and frustration. In order to address these issues, it is • Institutional analysis: Examining the institutional vital to ensure that Egypt’s electricity sector provides and governance arrangements in Egypt’s power quality service, and that the various stakeholders– sector with regards to its transparency and social consumers, investors, and the public at large–are accountability. properly informed and allowed to voice their views • Performance benchmarking: Reviewing the and concerns. operational and financial performance indicators used by EgyptERA and electricity companies to From the perspective of social accountability, gauge the quality and resource efficiency of their the state has to be responsive to the needs of its service, and identifying potential improvements citizens. A prerequisite for that is the transparency based on international practice and certain which entails accessibility of information to citizens, specifics of the Egyptian power sector. communities, and businesses. This study aims to • Customer interface, transparency, and public assess four key areas influencing transparency and information systems: Reviewing and assessing social accountability in the electricity sector, namely: communication and information dissemination institutional analysis; performance benchmarking; between EgyptERA, the regulated companies, customer interface; and consumer surveys. The and the wider public. electricity regulator, the Egyptian Electric Utility and • Consumer surveys: Strengthening the design, Consumer Protection Regulatory Agency (EgyptERA), execution, data analysis, and dissemination of the is taking the lead in addressing shortcomings in these customer survey (“the Citizen Report Cards”), this was initiated by EgyptERA in 2010. Findings This study provided valuable insights on the potential INSTITUTIONAL ANALYSIS for transforming the Egyptian electricity sector into a more transparent and socially accountable sector. EgyptERA’s mandate is consistent in many aspects The following is a highlight of the key findings for with other national electric utilities, conferring many each of the four areas of study. of the same responsibilities, such as issuing licenses Executive Summary | 11 for construction and operation of power generators, indicators. The transparency of Egypt’s electricity ensuring compliance with national laws and sector also suffers for lack of staff dedicated to regulations, publishing reports apprising consumers communications. of their rights and responsibilities, and answering consumer complaints. Shortcomings can be mitigated in the short run by incorporating a more customer-focused outlook In contrast to international practice, however, in the responsibilities of these subsidiaries (as EgyptERA has very limited rule to advise or pass outlined in their Articles of Association); and by opinion on tariff structures to the respective ministries. obliging the EEHC board of Directors to oversee the Nor it is formally involved in approving transfer periodical reports on the commercial and customer pricing between the electricity companies). These satisfaction performance of subsidiary companies. are important limitations to EgyptERA’s mandate, Such amendments can be designed and prepared especially in light of the planned liberalization of under the support of EgyptERA in order to moderate Egypt’s electricity sector. EEHC’s burden of required time and resources. The ability of EgyptERA to oversee the electricity Both EEHC and the regulated licensed companies sector is partly compromised by its limited authority lack the capacity and organization to provide to oversee and regulate licensed regulated EgyptERA with timely, accurate, and comprehensive public companies. Lines of responsibility for the information. This shortcoming can be significantly management and regulation of Egypt’s electricity addressed by revising the existing arrangement at companies are thus blurred, as is their accountability EEHC to strengthen the effectiveness of cooperation to either EgyptERA or the public at large. with EgyptERA. In addition, capacity building as well as revisions of the Supply Code and Articles of Transparency of distribution companies is a broadly Association may be considered to complement the defined obligation whose rules and regulations other efforts to improve the efficiency of information specify only in broad terms the exact information to exchange of licensed companies and EgyptERA. be provided or the mediums through which it is to be conveyed. The draft Supply Code, which has been PERFORMANCE BENCHMARKING recently developed with the aim to govern these obligations in greater detail, is deemed as a positive Performance benchmarking in Egypt currently involves development. three sets of stakeholders: Electricity companies, EEHC, and EgyptERA. Electricity companies monitor Transparency and social accountability in certain performance indicators for internal purposes, Egypt’s electricity sector is also limited due to its while they are also required to provide to EgyptERA underdeveloped communication policy towards and EEHC the underlying benchmark data for consumers and the general public. This partly stems monitoring. Effective monitoring and dissemination from the Egyptian Electric Holding Company (EEHC) of performance indicators in the electricity sector subsidiaries’ lack of legal obligations to oversee or is critically important for ensuring transparency and safeguard its customers’ satisfaction. And while it is social accountability. The following is a summary of standard practice for distribution system operators the role for each of these three stakeholders. and electricity supply companies in the EU (European Union) to monitor and publish their findings on EgyptERA customer services (for example, response times The year-to-year performance of each department for customer claims and complaints), distribution or unit is analysed by EgyptERA by examining companies in Egypt do not currently monitor such historic trends in indicators and benchmarks. The 12 | Transparency and Social Accountability in the Egyptian Power Sector benchmarking analysis is presented and discussed in between companies, it is not uncommon for joint meetings between EgyptERA and the electricity electricity companies to deploy somewhat different companies to validate their results and conclusions, metrics to monitor their own performance. The which are in turn documented by EgyptERA in companies’ absence of uniformity in monitoring annual performance reports for each company and performance could undermine the benefits of are circulated to the Ministry of Electricity and Energy benchmarking and weakens the level of transparency and to EEHC. regarding in reporting their performance. Internal auditing of benchmarking data could thus serve to Despite such thorough benchmarking analysis, ensure that electricity companies adhere uniformly transparency and social accountability are somewhat to the guidelines issued by EgyptERA, and to thwarted by the fact that these reports are not verify consistency among companies in monitoring currently made available to the wider public. performance indicators. International best practice shows that a key to Consistency of performance benchmarking is also monitoring and benchmarking performance resides hindered by the lack of effective data management in the underlying dataset’s accuracy. Many regulators platforms, such as MIS, at EgyptERA and its verify such data via external auditors or comptrollers. regulated companies to unify data and monitor EgyptERA does not yet commission external audits, their benchmarks. Though EEHC has made steps but verifies the validity of data provided by its towards developing such a MIS, it has not yet companies via trend analysis of historical data on 30 been  implemented due to financial constraints. A to 40 indicators recorded in EgyptERA’s database well-functioning MIS would also enable EgyptERA over the past decade. to monitor and the results of the annual consumer- awareness survey. The value of this is to some degree diminished due to the grouping of some benchmarking indicators Load shedding, which interrupts electricity service into units and departments, thus precluding a to customers, is currently a major issue in Egypt’s comparative assessment of performance at company electricity sector. Though significantly affecting the level. The use of a management information quality of service, it is not explicitly monitored, as it is system (MIS) for monitoring benchmarks among aggregated with planned outages due to maintenance different companies is relevant and can be deployed work, for which consumers are informed in advance. to simplify the aggregation and analysis of data by A number of distribution companies have recently EgyptERA and EEHC, while improving the accuracy started to utilize a software system which facilitates of benchmarking indicators. the management of load shedding and aims to distribute the power cuts based on priority or merit. If Electricity Companies such system is fully utilized, it would allow EgyptERA Electricity companies monitor performance indicators to maintain a database of all power cuts and to build against their individual targets in cooperation with a clear accounting on the number and frequency of their holding company, EEHC, without carrying power cuts experienced by each type of consumer. out a benchmarking analysis per se. Performance It will also serve as a valuable tool for monitoring indicators are monitored, discussed, and reported performance in relation to planned power outages monthly within company departments, sectors, and due to load shedding. boards of directors. In contrast to standard international practice, Though EEHC mostly dictates performance distribution companies in Egypt do not currently monitoring requirements for benchmarking analyses monitor certain indicators of customer service such Executive Summary | 13 as response times to complaints or requests for between  the sector’s main stakeholders, in particular new connections. Nor do they conduct customer EgyptERA, electricity companies, and the public. satisfaction surveys that would allow them to gauge their performance in these fields. As mentioned Sector Companies previously, such responsibilities are not embedded in Regulated electricity companies are obliged by their the responsibilities of EEHC subsidiaries. Introducing licenses to provide to EgyptERA and EEHC a variety commercial performance indicators to the distribution of financial, operational, and technical data, along companies’ subsidiaries, and establishing incentive with periodic reports on their past and projected or performance contracts between EgyptERA and performance to ensure that all stakeholders are the distribution companies can significantly improve adequately informed. The most important of these benchmarking of customer service practices. requirements is an annual statement on the quality Nonetheless, distribution companies face a of customer service. In the event that a regulated significant obstacle in monitoring their provision of company does not comply with the requirements, customer services, as they do not currently have EgyptERA has a number of sanctions at its disposal. access to proper customer account management systems, such as customer relation management In practice, however, neither EEHC nor regulated (CRM), to efficiently track and address customer companies have sufficient capacity or organization complaints, queries and feedback. However, Cairo to provide the information required by EgyptERA. South has started the development of a CRM To address this issue, EgyptERA has organized a system in coordination with EgyptERA. When fully number of internal capacity building sessions, and implemented, this system could serve as the practice regularly invites staff from coordination departments for monitoring interfaces with customers throughout to attend but this shortcoming is still unresolved. all distribution companies. Distribution Companies EEHC Distribution companies face an important task in There is limited interaction between EEHC and communicating with their consumers, especially EgyptERA during the benchmarking process. Data is those in rural and remote parts of the country who collected separately, while benchmarking indicators remain largely uninformed of the companies’ roles and are monitored at different institutional levels and functions. This could further hamper the companies’ thus are not directly comparable. The performance attempts to engage the public on important challenges of electricity companies is also being monitored by facing the sector such as power shortages due to lack EEHC which monitors both relative performance of investments, fuel shortages, and subsidies. of companies, and historic performance of each company. Such benchmarking reports and analyses Distribution companies licensed by EgyptERA are carried out by EEHC are not currently made available obliged to provide information to their customers and to the public. to the wider public, either as part of their statutory obligations, or upon their customers’ request. The CUSTOMER INTERFACE, distribution companies’ most important requirements TRANSPARENCY, AND PUBLIC are to inform the wider public and tax payers on their INFORMATION SYSTEMS activities and financial performance, as well as availing them of all application forms, procedures, terms and Transparency and social accountability in Egypt’s conditions for establishing a new connection and a electricity sector relies to a significant extent on supply agreement. The companies are also obliged effective communication and information dissemination to inform their customers on how they can file a 14 | Transparency and Social Accountability in the Egyptian Power Sector query or complaint, as well as how their complaint consumers, with the exception of a few companies will be handled and eventually resolved. that inform priority customers such as hospitals and industries. Adding to the confusion, these Complaints are being tracked by distribution planned outages—for which no warning is given companies as specified in the Distribution Code. to consumers—are not being measured separately The majority of these companies, however, do not from those due to maintenance work—for which have computerized systems (except for Cairo South customers are informed in advance. where a CRM system has been developed). EEHC and EgyptERA rely on each subsidiary to send the EgyptERA information via FAX or email, to be manually analyzed The most significant publication of EgyptERA by and aggregated. Nevertheless, EEHC has made which it communicates with the wider public, steps towards mitigating this issue. It has developed is the Annual Report, which provides extensive a blueprint of an MIS for aggregating data and information on a wide range of pertinent topics for monitoring benchmarks among different companies, Egypt’s electricity sector. Although a consumer- which unfortunately has yet been implemented due protection element is included in the 2010–11 to financial constraints. A well-functioning MIS will Annual Report, EgyptERA does not currently also be required by EgyptERA for monitoring the provide annual reports dedicated to consumer results of the annual consumer-awareness survey service of regulated distribution companies. Such mentioned above. information will be especially important once the market becomes liberalized, whereby consumers Electricity bills can be a particularly effective tool for will need to evaluate for themselves the services distribution companies to disseminate information to offered by each supplier. consumers, given that they reach every consumer. Yet various stakeholders—including consumer groups— EgyptERA’s regulatory mandate is further hindered by find their layout and information confusing and its limited visibility. Consumers and the wider public unclear. Though they all provide identical information, are not aware of its existence and role. EgyptERA, electricity bills issued by each distribution company however, has made significant efforts to address this in Egypt do not adhere to a uniform format. An issue, most recently by helping organize a two-day assessment of Egypt’s electricity bills and addition of public consultation on current challenges in Egypt’s clarifying information may substantially improve the electricity sector. The event will be streamed live over sector’s information flows. the Internet and the audience will be able to pose questions to the panelists. The purpose of the event Meter readers are another important medium of is for the public voice to be heard, and for the sector communication between distribution companies and to be fully transparent concerning the challenges it consumers, with potential to play a significant role is facing. in disseminating information and collecting customer feedback, queries, and complaints. However, Data collection by EgyptERA does not always distribution companies report that meter readers run smoothly, as delays in receiving the required are unable to take on extra responsibilities such as information from regulated companies are common. providing customer information or feedback. Time These delays pose a significant obstacle to the constraints notwithstanding, they lack the training to oversight by EgyptERA. undertake such responsibilities. Since 2010, EgyptERA has been cooperating with Finally, planned power outages due to load the Consumers and Energy Organization (CEO), a shedding  are not being properly communicated to civil society network with nationwide outreach. The Executive Summary | 15 mandate of CEO is to represent energy consumers, Distribution companies face a major hurdle preventing and to raise awareness about consumer rights them from effectively communicating with consumers and responsibilities. It has limited capacity to be and the wider public, stemming from their failure proactive, however, as most of its funding for services to conduct customer satisfaction surveys or to to EgyptERA is provided by the German Society for gauge customer feedback. Consumers can now file International Cooperation and is conditional upon complaints mainly through dedicated call centers EgyptERA’s approval. and service outlets; some are offered the option to file complaints through their respective distribution Finally, EgyptERA has been developing a number companies’ websites. EgyptERA is attempting of communications to improve their visibility and to upgrade these communications by preparing to raise consumer awareness about pertinent templates for distribution companies to undertake issues in the electricity sector. These include a customer satisfaction questionnaires regarding public opinion survey on the quality of electricity their handling of complaints and the quality of services, informative circulars on Egypt’s electricity information they provide. A consumer-awareness sector, and EgyptERA’s website and social media survey conducted by EgyptERA in 2010, derived pages providing videos and messages on energy solely on telephone interviews, was able to reach conservation. only part of the population. To bolster these efforts, the Bank assisted EgyptERA to develop more direct CONSUMER SURVEYS data-collection techniques, as well as more detailed questionnaire forms, which will enable them to more This objective sought to strengthen the design and thoroughly measure the public’s perception on execution, data analysis, and dissemination of the the quality, cost, and evolution of the services they customer survey (“citizen report cards”) that was provide. Finally, EgyptERA is monitoring closely the initiated by EgyptERA in 2010. complaints it received regarding service by distribution companies and publishes them in its annual report. Recommendations It is necessary to establish systems and procedures A. Incorporating the consumer engagement into the that: a) proactively disclose information about the goals/objectives and operational culture of the power sector’s quality of service, operational and electricity sector financial performance, and development plans and policies; b) seek customer and public feedback; 1. Revise goals of EEHC subsidiary to and c) further engage customers in monitoring sector incorporate more responsibilities towards performance. customers. 2. Oblige EEHC to oversee periodical reports of These recommendations, which include comments its subsidiary companies on the satisfaction and actions already taken by EgyptERA, as well as of their customers. comments gathered during a roundtable meeting of 3. Request companies to make explicit reference stakeholders to discuss the findings of this study, fall in their articles of association to obligations under three main actions: arising from their licenses, while EEHC’s responsibility is to verify the companies’ compliance to these obligations. 16 | Transparency and Social Accountability in the Egyptian Power Sector 4. Urge EgyptERA to adopt more advanced 15. Distribution companies to disclose their data collection techniques for their Consumer reporting. Awareness Survey, and revise the licensing 16. Distribution companies should produce obligations of electricity companies to detailed job descriptions and required skill undertake regular consumer satisfaction sets for the personnel that staff the liaison surveys and devise action plans based on offices. feedback. 5. Include in the licenses of each distribution C. Improving communications to enhance company an explicit obligation to draw up transparency and promote trust between the and publicize a customer charter. sector and the public 6. Edit the new supply code to include effective information exchange between distribution 17. Update EgyptERA’s mandate to reflect the companies and consumers. new Electricity Law and upcoming reforms in 7. Represent consumers and civil society the electricity market. in the companies’ boards and in regional 18. Consider implementing a unified CRM system committees of electricity consumers. for logging and tracking complaints. 8. EgyptERA should develop a Code of Conduct 19. Revise benchmarking reports produced by that will define more clearly its responsibilities, EgyptERA and EEHC to be more reader and highlight commitment to transparency friendly, and publish them on company and social accountability. websites and service outlets. 20. EgyptERA and EEHC should establish a B. Sector Reform Via Organizational, Staffing, and new benchmark separating planned power Information Technology (IT) Enhancements outages due to maintenance, from power outages due to load shedding. 9. Distribution companies should set up 21. Distribution companies, EEHC and EgyptERA departments dedicated to communications, should adopt commercial indicators related to staffed with qualified personnel to develop customer satisfaction and ensure all relevant appropriate communication policies. metrics are unified. 10. Create a single, appropriately staffed EEHC 22. Distribution companies should timely submit liaison department. to EgyptERA their network rehabilitation 11. EgyptERA, EEHC and electricity companies plans. should undertake periodic internal audits of 23. Distribution companies should inform electricity companies to validate performance consumers of planned power outages due to benchmarking data. load shedding. 12. EEHC and EgyptERA should combine 24. EgyptERA should implement a communication efforts to produce a unified annual company strategy to raise awareness about its role and performance report, and to set a system for activities. incentives and penalties. 25. Distribution companies should adopt EU 13. Consider implementing a unified MIS for recommendations in reformatting their monitoring benchmarks among different electricity bills. companies. 26. EgyptERA should provide annual reports 14. Increase distribution companies’ investment tailored to consumer service. in handheld Automatic Meter Reading (AMR) devices and smart meters. Executive Summary | 17 CHAPTER ONE: Introduction The World Bank’s initiatives of Social Accountability To achieve this objective, the World Bank and and Transparency over the past two decades are EgyptERA—in consultation with Kantor Management increasingly founded on the notion that transparency Consultants—finds it necessary to establish systems and social accountability of public institutions are and procedures for: a) proactively disclosing essential for stimulating economic growth. information about the power sector’s quality of service, operational and financial performance, and Social accountability refers to the responsiveness of development plans and policies; b) seeking customer the state to the needs of its citizens, and encompasses and public feedback; and c) engaging customers a broad range of actions and mechanisms such as in monitoring sector performance. Such a system, tracking of public expenditures, monitoring of public by helping to improve both the performance of the service delivery, and working with citizen advisory sector and the public acceptance of its policies and boards. These citizen-driven measures complement plans, ultimately can raise the sector’s efficiency, and reinforce conventional mechanisms of quality, and sustainability. accountability such as political checks and balances, accounting and auditing systems, and administrative rules and legal procedures. Transparency is closely linked to, and is in fact a prerequisite for, social accountability. Transparency entails access to and effective use of information by citizens, civil society organizations, non-governmental organizations (NGOs), local communities, and the private sector. It is exemplified by such activities as disclosure and dissemination of information, participation and consultation with beneficiaries and users, and effective handling of complaints. In line with this approach, EgyptERA considers it vital to ensure that Egypt’s electricity sector provides quality service, and that the various stakeholders– consumers, investors, and the public at large–are properly informed and allowed to voice their views and concerns. 18 | Transparency and Social Accountability in the Egyptian Power Sector 2 CHAPTER TWO: Objectives and Methods This study covers four interlocking areas (institutional recommendations reflect a complete picture for analysis; performance benchmarking; customer correcting the sector’s weaknesses in transparency interface-transparency and public information systems; and social accountability. and consumer surveys). After analyzing and identifying weaknesses in each area separately, The delegates of the RTM ultimately accepted the corrections are then suggested that encompass the findings and recommendations of the study. The interlocking whole. delegates particularly emphasized the problem of subsidies and the public perception that electricity The key findings and recommendations of this is something that should be provided for free. analysis were presented to a Roundtable Meeting Educating the public on the problems of the (RTM), inviting all the stakeholders from the Scoping sector—and how everyone could help with simple Workshop at the beginning of the project. behavioral changes—is paramount to tackling power outages. The main objective was to include the opinions and comments of all stakeholders to ensure that our 2.1 Institutional Analysis The objective was to examine the existing institutional the content and effectiveness of public information; and governance arrangements  in Egypt’s power and to enhance the public’s involvement in making sector with regards to its transparency and decisions. social accountability. This entailed reviewing the institutional mandates of EgyptERA, EEHC, the This can be done through the following steps: Egyptian Electric Transmission Company (EETC), and distribution companies, and identifying 1. Analyzing and comparing EgyptERA’s mandate shortcomings and opportunities to enhance service to that of other international peers so as to set delivery, customer feedback, public information the limits of obligations and authority. dissemination and civil society participation. 2. Identifying the reporting requirements, both Recommendations are made for specific changes in towards EgyptERA and the public domain. the institutional and governance framework, aiming 3. Identifying the type of information that is made for several outcomes: To reinforce the obligation of available in Europe or other identified countries electricity companies to deliver a standard level of via the regulators and the electricity sector service; to develop further mechanisms for receiving companies (focusing only on the ones that have and utilizing feedback from customers; to improve a direct impact with the consumer such as Chapter 2 | Objectives and Methods | 19 distribution and supply); and the case in Egypt, 5. Recommending a set of actions and interventions and how this information is channeled to the end that could improve institutional reporting and consumer. transparency. These recommendations are 4. Finalizing the findings and comparisons with provisional, given that there are two more reports a paragraph on consumer participation in the on benchmarking and customer satisfaction that sector and how this is implemented in the United work in a complimentary fashion to this report. Kingdom (which is probably the best example of participatory mechanics in Europe). 2.2 Performance Benchmarking The objective was to review the operational and against proposed indicators; and d) the way by which financial performance indicators used by EgyptERA performance indicators are communicated to the and electricity companies to benchmark the quality public (in terms of presentation, content, channels and resource efficiency of their service. These and frequency). The current benchmarking regime in indicators include the generation, transmission, Egypt’s power sector was mapped and examined to and distribution of electricity, as well as customer reveal how EgyptERA is collecting and composing services. Potential improvements were identified the sector indicators. The findings are contrasted vis- based on international practice and certain specifics à-vis with what is currently the status in the EU1 and of the Egyptian power sector, including the following: recommendations are made on the specifics and a) The range of indicators being monitored by limitations of the local context. Limitations are mostly electricity companies and EgyptERA; b) the technical centered on the capacity of the licensed companies and organizational capacity of electricity companies to accurately collect the necessary data as well as to effectively monitor and report their performance; the communication of the performance to the wider c) mechanisms utilized by EgyptERA to audit and public. EgyptERA is making significant efforts to monitor the performance of regulated companies mitigate these problems. 2.3 Customer Interface, Transparency, and Public Information Systems This objective reviewed and assessed communication was the dissemination of consumer charters and information dissemination between EgyptERA, and other information through electricity bills. the regulated companies, and the wider public. The Recommendations are made for potential changes tasks included examining the content of information in the processes, communications, and IT or other provided, the governing framework of regulations, systems and operations of regulated companies and rules and procedures, and the information technology of EgyptERA to improve the flow and quality of the (IT) tools that are used for this purpose. In addition, information provided. this review examined the handling of consumer requests, feedback, and complaints, as well as the effectiveness of citizen participation. Also considered 1 In consultations with EgyptERA, it was decided to use EU as the benchmark. 20 | Transparency and Social Accountability in the Egyptian Power Sector 2.4 Consumer Surveys This objective sought to strengthen the design and execution, data analysis, and dissemination of the customer survey (“citizen report cards”), which was initiated by EgyptERA in 2010. In particular, our immediate goals were as follows: a) to redraft the customer survey form, to better classify data by gender and regions, and to better target relevant policies; b)  to implement a workshop to build the  capacity of EgyptERA’s consumer protection team, on how to use the new survey, covering its content, methodology, implementation, analysis, and policy formulation; and c) to support EgyptERA in drafting the request for proposal (RFP) for conducting the annual customer survey. Chapter 2 | Objectives and Methods | 21 3 CHAPTER THREE: Current Situation and Key Findings Egypt has a largely monopolistic electricity market, The sector is overseen by the Egyptian Electricity with EEHC owning the transmission system and almost Utility and Consumer Protection Regulatory Agency all of its distribution. EEHC comprises 16  affiliated (EgyptERA), which was established by Presidential electricity companies, including six generation Decree 329 in the year 2000 as independent companies, one transmission company (Egyptian from the Ministry of Electricity and Energy and the Electricity Transmission Company (EETC)) and nine service providers. EgyptERA is responsible for distribution companies. EEHC is the successor of granting licenses for generating, transmitting and the Egyptian Electricity Authority (EEA), which in distributing electricity, and for overseeing the sector’s 2000 was restructured as a shareholder cooperative. compliance to its rules and regulations. EgyptERA is EETC, which is the only company licensed for extra currently redrafting its licensing agreements, which high voltage (EHV) and high voltage (HV) electricity are expected to be effective early in 2014. transmission, purchases electrical energy from all generation companies and in turn sells the electrical Egypt’s electricity sector is now facing serious energy to the nine distribution companies and eleven shortfalls of cash, created in part by billing tariffs private distribution companies. EETC also directly that do not accurately reflect the costs to produce, contracts approximately 100 consumers connected transmit, and distribute electricity. It suffers as well to the EHV and HV networks. Furthermore, EETC is from problems of bill collection and consumer theft. responsible  for power exchanges with neighboring These shortfalls in turn hinder payments for fuel, countries over the present interconnections. The further increasing the sector’s debt and lowering majority of Egypt’s electricity is provided by the its credit and attractiveness to potential private EEHC’s nine distribution companies, whereas private investors. distribution companies provide no more than 1 percent of the market. The current single buyer model will The system also operates under a huge subsidy. In perhaps be gradually replaced by a competitive 2011 the subsidy reached about 30 billion Egyptian market based on bilateral contracts together with pounds (EGP) (19 billion EGP in fuel consumed by the spot, balancing and ancillary services markets. power plants in addition to 11 billion EGP in electricity bills). The resulting lack of cash has hindered attempts The electrification level is almost universal, covering 99 to finance new projects and to pay for the fuel and percent of the country’s populated area and serving repay debt. Moreover, electricity generation is also the following numbers and types of consumers: hampered for lack of available natural gas, stemming in part from congestions in the gas network. These • 24 million residential consumers fuel shortages are exacerbated by shortfalls in • 2.5 million shops generation capacity during peak demand, making the • 165 thousand small and medium enterprises need for investments in generation and transmission • 100 large industries capacities crucial. This situation, compounded by • 27 thousand public lights (municipalities and limited public awareness of energy management districts) and conservation, has led to electricity shortages 22 | Transparency and Social Accountability in the Egyptian Power Sector during the peak demand times (especially during the residential customers and serious loss of productivity summer months), causing great inconvenience to and efficiency for large industrial consumers. 3.1 Institutional Analysis As specified in Presidential Decree 329, EgyptERA’s to oversee and regulate licensed regulated public mandate is consistent in many aspects with what is companies, which are in many aspects otherwise observed in other national electric utilities, conferring managed by the holding company, EEHC. Lines of the following main responsibilities: responsibility for the management and regulation of Egypt’s electricity companies are thus blurred, as is • Issuing licenses for constructing, managing, their accountability to either EgyptERA or the public operating and maintaining electric power at large. generation, transmission, distribution, and sales • Ensuring compliance with national laws and Transparency of distribution companies towards regulations EgyptERA, consumers, and the wider public is • Reviewing plans for power consumption, a broadly defined obligation whose rules and production, transmission and distribution, including regulations are outlined in several documents, necessary investments related to such plans namely the Distribution Code, Distribution • Verifying that electric utilities receive a fair return, Licenses and Distribution Companies’ Commercial sufficient to ensure their financial viability Regulations. Although these rules and regulations • Safeguarding the quality of the technical and obligate distribution companies to be transparent administrative services provided by the electric on a wide range of topics, they specify only in broad utilities to consumers terms the exact information that should be provided • Publishing such information, reports, and or the means and procedures through which this recommendations that assist the electric utilities should be done. The draft Supply Code, which has and consumers to be fully aware of their rights been recently developed with the aim to govern the and responsibilities, and of the role played by obligations of electricity suppliers, traders, distribution EgyptERA companies and customers vis-à-vis each other, • Investigating consumer’s complaints to protect specifies in greater detail the type of information their interests and to settle any disputes that may that distribution companies are obliged to provide to arise consumers and to the wider public. It also explicitly names the means through which this should be In contrast to international practice, however, done and bestows more authority upon EgyptERA EgyptERA has very limited rule to advise or pass to regulate oversight. This is deemed as a positive opinion on tariff structures to the respective development, in contrast to de-regulated markets ministries. Nor is it formally involved in approving wherein distribution and supply companies compete or commenting on transfer pricing between the to attract customers; and govern themselves with electricity companies, which is instead set by the state regard to such matters as informing their consumers. monopoly EEHC. These are important limitations In markets lacking competition, regulations often to EgyptERA’s mandate, especially in light of the need more detail to prevent loose interpretation and planned liberalization of Egypt’s electricity sector. ineffective implementation. The authority of EgyptERA to oversee the electricity Transparency and social accountability in Egypt’s sector is partly compromised by its limited authority electricity sector is also limited due to the sector’s Chapter 3 | Current Situation and Key Findings | 23 underdeveloped communication policy towards consumers and the general public, which partly Figure 3.1 | Structure of EEHC and stems from the fact that EEHC subsidiaries are Affiliated Companies not legally obliged to oversee or safeguard the Ministry of Electricity and Energy satisfaction of its customers. In contrast to standard practice of distribution system operators (DSOs) and EEHC electricity supply companies in the EU, which provide publicly available data and indicators monitoring their Production Egyptian Electricity Distribution customer services (for example, response times Companies Transmission Companies for customer claims and complaints), distribution Company (EETC) Cairo North Cairo companies in Egypt do not currently monitor such East Delta South Cairo indicators. Another factor in the sector’s limited transparency is its distribution companies’ lack of Middle Delta Alexandria staff dedicated to marketing or communications. West Delta Canal Upper Egypt North Delta 3.1.1 CURRENT EGYPTIAN POWER Hydro Plants South Delta SECTOR CONTEXT EI-Behera Middle Egypt Egypt has legally unbundled its former vertically Upper Egypt integrated EEA in phases. The major phase was in 2000, when EEA was restructured in the form Source: Authors. of a shareholder cooperative, according to law 159/1981, thus becoming the Egyptian Electricity only company licensed for EHV and HV electricity Holding Company (EEHC). In turn, EEHC established transmission, purchases electrical energy from 16 affiliated electricity companies, including six all generation companies. EETC in turn sells the generation companies, one transmission company electrical energy to the nine distribution companies, (EETC) and nine distribution companies. All electricity and other 11 private distribution companies companies are owned by EEHC, which remains (Figure  3.2). EETC also directly contracts with state-owned (Figure 3.1). At present, EEHC owns approximately 100 consumers connected to the EHV 90 percent of the installed generation capacity in and HV networks. Furthermore, EETC is responsible Egypt, 100 percent of transmission (EETC) and for power exchanges with neighboring countries over approximately 99 percent of distribution. the present interconnections. The electrical energy is sold to more than 23 million consumers on both the There are also three private companies, which were medium and low voltages by distribution companies established based on buy, own, operate and transfer and with Egypt having successfully managed to (BOOT) contracts, comprising nine percent of the provide electrification to 99 percent of the country’s installed generation capacity. These companies are population. At present, the majority of the sales are contracted by EETC as a sole off taker for their full accounted for by the nine EEHC owned distribution dependable capacity, through power purchasing companies, whereas the share of the private agreements for 20 years. Currently, around half of distribution companies does not exceed 1 percent the agreements’ lifespan has elapsed. The remaining of the market. one percent of installed capacity is accounted for by wind farms. The sector is overseen by a regulator, the Egyptian Electricity Utility and Consumer Protection Regulatory The electricity market in Egypt is organized along Agency (EgyptERA) established by Presidential the single buyer model. The EETC, which is the Decree 329 in the year 2000 as an independent legal 24 | Transparency and Social Accountability in the Egyptian Power Sector Figure 3.2 | Egypt’s Power Sector Operation Imports 6 Generation Plants Boot Plants & RES Transmission (EETC) Exports Distribution Large Customers Companies Power Flow Money Flow Residential Customers Source: Authors. entity from the Ministry of Electricity and Energy and credit, and hampering its attractiveness to private the service providers. investors. • Fuel generation shortages stem not only from 3.1.2 MAIN CHALLENGES AND non-payment of fuel but also from lack of natural UPCOMING CHANGES gas (NG) and congestions in the gas network. • Shortfalls of installed gross maximum capacity The electricity sector in Egypt is facing great make the need for generation investment a challenges, with most issues having to do with priority. The preceding situation has led to forced heavily subsidized tariffs. load shedding during the year’s peak demand days, which greatly inconveniences residential • Given that billing tariffs do not reflect the customers and causes serious productivity true costs incurred to produce, transmit and and efficiency issues for the large industrial distribute electricity to customers (compounded consumers. by collection and theft problems), serious cash • Limited energy-saving practices exacerbate the flow deficits have been created due to reduced aforementioned problem. It has proven difficult revenues. This in turn makes payments for fuel to convince the consuming public to reduce difficult, increasing sector debt, lowering its consumption when their tariffs are low and Chapter 3 | Current Situation and Key Findings | 25 their knowledge of the sector’s main issues is • Making sure that the costs of power production, apparently lacking. transmission, and distribution guarantee the interests of all parties involved. Considering these problems, the Arab Republic • Ensuring a fair return for electric utilities to ensure of Egypt needs to bring significant changes and their financial viability. interventions to its electricity sector. • Reviewing the policies and procedures of the National Electricity Control Center to ensure their These changes become even more pressing compliance with the optimum operation standards considering the need for private investment in and technical performance levels in coordination the sector, particularly with regard to electricity with the Egyptian Electricity Holding Company generation, as well as to the planned change from a and in the best interest of all parties. monopolistic electricity market to a more competitive, • Following up on the availability of technical, financial, liberalized market. EETC has already taken steps in and economic resources for the electric utilities. this direction, asking for EgyptERA’s assistance to • Ensuring the quality of the technical and promote third party access with the first such effort administrative services provided by the electric to be launched soon. utilities. • Publishing information and recommendations Removing the aforementioned subsidies goes hand that raise awareness for electric utilities and in hand with developing an intense communication consumers of their rights and responsibilities, as campaign and an elaborate social safety net for the well as the role played by EgyptERA. large number of vulnerable customers. • Investigating consumer’s complaints to ensure protection of their interests and to settle disputes. 3.1.3 REPORTING LINES AND • Issuing licenses for the construction, management, RESPONSIBILITIES: EGYPTERA’S operation, and maintenance of electric power MANDATE generation, transmission, distribution, and sales projects. EgyptERA—the power sector regulator—was established by Presidential Decree 329 in the year EgyptERA’s board of directors is chaired by 2000 as a legal entity independent from the Ministry the Minister of Electricity and Energy and has of Electricity and Energy and the service providers. 10  members (three represent the electric utilities, The agency has been given the following mandate: three from other public sector companies, four representing consumers). The Minister of Electricity • Ensuring that all activities of electric power and Energy (MoEE) recommends board members to generation, transmission, distribution, and supply the Prime Minister, and the board is established by comply with the laws and regulations of the Arab Prime Minister’s Decree. Republic of Egypt, especially those relating to environmental protection. The overall mandate of EgyptERA resembles in many • Reviewing regularly the plans and investments aspects the mandates of other national regulators, necessary for the production, transmission, with some noticeable differences. Those differences distribution, and consumption of electric power relate not only with the mandate itself, but also with for various usages in conformity with government its enforcement by EgyptERA. policy. • Setting regulations that ensure lawful competition The mandates of European regulators are driven in the field of electric power production and by Directive 2009/72/EC, whereby the duties and distribution in the best interests of the consumer. obligations are detailed and specified concerning the 26 | Transparency and Social Accountability in the Egyptian Power Sector domestic as well as the whole EU electricity market. are responsible to advise and pass opinion on tariff The duties of each regulator are very much linked to structures to their respective ministries. Their role market maturity and hence it would be unrealistic to is that of an honest broker balancing on one hand expect a full reflection of the Directive on markets the need for cost reflective tariffs that guarantee a like Egypt’s, which is still more or less a state owned sustainable energy market, and on the other hand monopoly. However, given the drive to liberalize the the need for affordable prices for the greater public. regime, the mandate of EgyptERA will need to be Tariff-setting is missing from EgyptERA’s mandate. enhanced. This is an important difference hindering EgyptERA’s move towards a more liberalized market. Part of this study compared EgyptERA mandates to those of two EU countries regulatory agencies Additionally, EgyptERA is not formally involved in (Greece’s RAE and France’s CRE), based on the approving or even commenting on transfer pricing criterion that they operate in market structures that are between the electricity companies, which is otherwise not highly competitive and still dominated by ex-state set by EEHC. This links to the next difference, monopolies. EgyptERA’s mandate was compared as which is the approval of accounts unbundling and well to those of the regulatory agency AERS of Serbia transparency between sectors. (Serbia being a country under accession to the EU, a member of the Energy Community Treaty and hence Despite such differences, the overall mandate of in a more transitional state during the process of EgyptERA is relatively similar to that which applies in harmonizing with EU Aquis). the aforementioned countries. Issues remain, however, as to how effectively this mandate is exercised given The mandates of EgyptERA and those of regulators the current structure of the Egyptian electricity market in the selected countries, differ mainly concerning and the direction in which it is desired to go. Figure 3.4 tariff setting and monitoring practices (Figure 3.3). outlines the mandate of EgyptERA and the degree to which it is implementing that mandate. In all cases except EgyptERA, the regulator is responsible for both the electricity as well as the The general governance rules of the Egyptian gas sectors. More importantly, RAE, CRE and AERS power sector largely determine the level of effective leverage and power that EgyptERA can exercise. Since transmission and the distribution companies Figure 3.3 | Mandated Responsibilities are under the control of EEHC, these affiliates (which of EgyptERA versus European Regulators are also the licensed regulated companies) do not have control to manage many aspects of their EERA RAE CRE AERS operations that should be reported to EgyptERA. EEHC subsidiary companies have some interesting Electricity & Gas No Yes Yes Yes characteristic limitations concerning their Board of Directors’ (BoD) responsibilities. Their mandate includes the following responsibilities: Tariffs No Yes Yes Yes • Ratify the organizational chart of the company • Set the internal organizing regulations, except Monitoring of Separation & Accounting Practices No Yes Yes Yes for those of the Personnel and Purchasing regulations, which must be approved by the Board Source: Authors. of Directors of EEHC and issued by a resolution of the Head of the General Assembly Chapter 3 | Current Situation and Key Findings | 27 Figure 3.4 | EgyptERA’s Mandated Responsibilities and Degree of Implementation Implementation Mandate Level Ensuring that all activities of electric power generation, Fully exercised transmission, distribution, and supply are carried out in compliance with the laws and regulations in effect in the Arab Republic of Egypt, especially those relating Partially exercised to environmental protection Not exercised Reviewing regularly the plans prepared for electric power consumption, production, transmission and distribution, including the investments necessary for such plans, in order to ensure availability of power for various usages in conformity with government policy Setting regulation that ensures lawful competition in the field of electric power production and distribution in the best interests of the consumer Making sure that the costs of power production, transmission and distribution guarantee the interests of all parties involved in these activities. Ensuring the realization of a fair return for electric utilities to ensure the continuity of their activities and sound financial position thereof Reviewing the policies and procedures of the National Electricity Control Centre to ensure compliance with the optimum operation standards and technical performance levels in coordination with the Egyptian Electricity Holding Company and in the best interest of all parties Following up on the availability of technical, financial and economic capabilities for the Electric utilities Ensuring the quality of the technical and administrative services provided by the Electric utilities to consumers Publishing such information, reports, and recommendations that assist the Electric Utilities and consumers to be aware of their rights and responsibilities and of the role played by EGYPTERA with full transparency Investigating consumer's complaints to ensure protection of their interests and settlements of any disputes that may arise among the parties involved the activity Issuing licenses for the construction, management, operation and maintenance of electric power generation, transmission, distribution, and sales projects Source: Authors. 28 | Transparency and Social Accountability in the Egyptian Power Sector • Propose the ratification of loan agreements, obligations, in terms of reporting to EgyptERA, stem financing, and mortgage deeds (the exceptional from their licensing conditions and from the Distribution General Assembly (EEHC) approving the decisions Code. A number of reporting requirements imposed of the Board concerning these matters) on licensees include: • Propose and participate in the establishment of companies that have a related activity, or to share • Annual report, including the audited financial in the capital of such companies whether they statement and data are inside or outside the country (the General • Semi-annual environmental report Assembly (EEHC) approving the decision) • Human resource development plan • Set a system for control and for performance • Annual load forecasts monitoring and evaluation in accordance with the • Annual total cost of service report technical, financial and economic measures • A total quality management plan and associated • Oversee the periodical reports, connected with annual progress reporting the operation and the financial position of the • Reporting on electricity supply quality and company customer service including complaints • Accept gifts, donations, and awards provided to the company but without opposing its goals EgyptERA can penalize the licensee (producer, transmitter, and distributor) for failing to submit the The above illustrates that, according to this structure, required data and reports. There are three levels the governance of the electricity companies in of penalties: Warning, suspension of license, and planning, tariffs, cash management, and policies are revocation or cancellation of license. Such is clearly under the control of EEHC. The companies have no stated in Circular 1 for the year 2006, “Concerning independence on their financing and budgets. Penalties Due To Delay in Licensees Application for Renewing Licenses Validity.” Furthermore, and relevant to the scope of our project, are the following points: The licensee is obliged to submit to the Egyptian Electric Utility and Consumer Protection Regulatory • The consumers or the civil society are not Agency all the data and information stated in the represented in any form in the regulated General Conditions for Licenses and the required companies’ boards data to accomplish all the procedures required • Customer satisfaction is not written clearly as part for renewing licenses validity, no later than three of the purpose of the distribution companies and months by the end of the licensee’s fiscal year the board (June 30 and December 31 for public and private • The company’s purpose does not mention that companies of each year). All the financial statements the company operates in accordance with the and the financial data to be excluded as it should license issued by EgyptERA, and the board has be submitted to The Egyptian Electric Utility and to assure that the company is fulfilling its license Consumer Protection Regulatory Agency no later requirement than one month from the date of ratification of the Company’s General Assembly of it. In case the 3.1.4 STAKEHOLDERS’ REPORTING licensee trespassed any of the aforementioned time OBLIGATIONS TOWARDS frames the licensee shall bear 1% increase over EGYPTERA the total fees for renewing the licenses validity for each overdue month or part of it. The Egyptian As part of its mandate, EgyptERA is responsible Electric Utility and Consumer Protection Regulatory for  issuing licenses for generation, transmission, Agency has to inform the licensee before the end of and distribution. The regulated licensed companies’ this grace period in writing by minimally one week, Chapter 3 | Current Situation and Key Findings | 29 this article shall be applied starting from the upcoming Figures 3.5 and 3.6 show the responsibilities of fiscal year starting July 1, 2007.” the interfacing that all sector companies have with EgyptERA. Interviews revealed that the companies Two warning notices are scheduled to follow this are mostly staffed with engineers (who are also circular. The first is issued one month after the heads of such departments), while only three public ratification of the financial statement the second DC’s are headed by accountants. Private companies is issued one month later, after which the penalty also have lawyers as department heads. Staff from applies. The penalties that have been applied so far other backgrounds, such as economists or financial for a delay of about two months have been levied on analysts that possess skills necessary for such the New and Renewable Energy Authority (NREA), reporting are lacking. the West Delta Production Company, and two private companies licensed for distribution and generation. Three departments in EEHC are mandated to liaise The penalty was also assessed two years ago to with EgyptERA. Two of them are referred to as EETC for a three-month delay, but then cancelled. general departments of cooperation with EgyptERA but report to the Sector Head of the electricity This year the penalty will be applied on EETC for the companies performance monitoring and to the period of four to five months, and for one year on TCI Executive Director for Electricity Company Affairs, Sanmar, a private distribution company. Additionally, respectively. The third department is referred to as a construction license has recently been suspended the general department for economic studies and for one private generation company for failure to cooperation with EgyptERA, and reports directly to progress as planned towards the construction of the the Executive Director for Strategic Planning and power plant. Power Plant Projects. None of the three departments is fully liaising at the moment with EgyptERA. From international experience, license suspension and revocation should be assessed only for serious The planning, tariff structure, and transfer pricing violations that raise concerns as to the licensee’s between the companies are the sole responsibilities of suitability, technical or financial capacity, or ethics the holding company, and since the three departments to lawfully and adequately perform their licensed within the holding company are not active with activities. EgyptERA, their activities are not coordinated. A recent example of this has been the revocation of 3.1.6 RECOMMENDATIONS ON the licenses of two private electricity supply companies REPORTING LINES AND in Greece charged with financial mismanagement. RESPONSIBILITIES They were clearly in breach of their licensing. EgyptERA 3.1.5 INTERFACING CHANNEL 1. EgyptERA’s mandate has limited or no authority BETWEEN LICENSEES AND concerning tariffs and tariff setting. This is EGYPTERA probably the most important difference from other regulators in Europe. The new electricity law, The main interfacing channels between licensed which has not yet passed through parliament, companies and EgyptERA are the EgyptERA focuses on six main actions: coordination departments. The main role of the a. Establishing a competitive electricity market departments is to prepare and provide the necessary that is based on bilateral contracts and information required by the regulator. adoption of the concept of eligible customers b. Third Party Access 30 | Transparency and Social Accountability in the Egyptian Power Sector Figure 3.5 | Responsibilities of EgyptERA Coordination Departments Responsibilities Company According to the Job Description of EgyptERA Coordination Departments • Prepairing all studies requested by EgyptERA in relation to tariff and cost of service. • Oversee the implementation of Egypt Era’s recommendations by the Electricity Companies in all areas relating to technical, economic, social and environmental. Egyptian Electricity • Coordinating with the ECs for Customer complaints and any clarifications requested by EgyptERA. Holding Company • Coordinating with the electricity companies in preparing all studies, reports and any clarifications (EEHC) requested by the EgyptERA and foresee the companies to implement EgyptERA recommendations. • Coordinating the implementation of the Tariff by the ECs. • Coordinating the implementation of the performance measures set by the EgyptERA. • Prepare all documents required for license renewal. • Follow up the implementation of the regulations set by EgyptERA. Egyptian Electricity • Supervise the reparation of all studies requested by the EgyptERA. Generation Companies • Especially cost of service studies. • Oversee that the power plants comply with environmental and Industrial safty and health regulations. • Ensure fair competition in the electricity market and prevent any monopoly act according to current laws and regulations. • Coordinating with EgyptERA for dispute resolution of large consumers. Egyptian Electricity • Coordinating with EgyptERA for setting the necessary regulations, follow up and monitoring all Transmission Company activities related to electric utilities. • Coordinating with EgyptERA in setting the transmission access charges. • Coordinating with EgyptERA to ensure high quality of service. • Coordinating with EgyptERA to review the operating procedure of the NCC. • Prepare in cooperation with EgyptERA a joint working plan renewed annually. • Follow up the implementation of the approved tariffs and any modifications. • Supervise the preparation of all studies requested by the EgyptERA. Egyptian Electricity • Especially cost of service studies. Distribution Companies • Supervise the replies to customer complaint clarifications requested by the EgyptERA. • Oversee the implementation of EgyptERA regulation concerning the sale of electricity on different voltage level. • Coordinate with other DPTs to fulfill any requests by the EgyptERA. Source: Authors. c. Establishing a Transmission System mandate and its enforcement. It will become a Operator (TSO) and providing assurances more important issue if and when Egypt moves for its independence and full unbundling into a more liberalized electricity market. from other sector participants d. Ratifying tariffs by the regulatory agency Sector Companies e. Supporting renewable energies, cogeneration, 2. EEHC should incorporate into the responsibilities and power generated from secondary of their subsidiaries a more customer focused resources outlook (as dictated by the Law 164 and Law 195 f. Supporting energy efficiency and demand- and the Articles of Association of EEHC and the side management Electricity Companies concerning governance structures for the Power Sector (Annex A)). This Given that the new law will address this issue, it means that they should ask for the companies seems more appropriate to focus on the existing to put as part of their purpose to set targets Chapter 3 | Current Situation and Key Findings | 31 Figure 3.6 | Assessment of EgyptERA Coordination Departments Company Department Head Reporting Line Level of Engagement Under the supervision of the Sector Head of EC's Egyptian Electricity • The person in charge Performance monitoring, Just started to be Holding Company (EEHC) is Engineer the sector head reports involved directly to the EEHC Chairman Egyptian Electricity • The person in charge is Reporting directly to the Fully Active Generation Companies Engineer Chairman The sector head reports Egyptian Electricity • The person in charge is directly to the EETC Fully Active Transmission Company Engineer Chairman • The persons in charge are 7 Engineers in (Delta North and South, Alexandria, Egyptian Electricity Reporting directly to the Beheira, Canal and Upper Fully Active Distribution Companies Chairman Egypt) and 3 Accountants in (Cairo North and South and Middle Egypt) Source: Authors. and measure their performance towards the consolidated under a single department. As it consumer’s satisfaction and needs. stands one is not active at all and the other two only 3. The Board of EEHC itself should add to its partially carry out their mandate. Their isolation responsibilities, to oversee the periodical reports serves to fragment their information. A detailed connected with the commercial and customer diagnostic concerning the responsibilities of the satisfaction performance of the company. department and the skills of its staff to realize 4. The Article of Association for the licensed those responsibilities (especially when it comes companies should mention in its purpose that “It to studies preparation and reporting) is the will operate within the licensing obligations as set first step to understanding of the department’s and agreed with the Regulator.” needs and limitations. The next step involves 5. The Board of EEHC for their subsidiaries should an organizational restructuring that will link skills also mention that “The company operates in and individual responsibilities to specific job accordance with the license issued by EgyptERA descriptions. Finally, the department’s proper and the board has to assure that the company is functioning will need new internal processes and fulfilling its license requirement.” procedures. 6. The three departments of EEHC that have been set up to cooperate with EgyptERA have to be 32 | Transparency and Social Accountability in the Egyptian Power Sector 3.1.7 INFORMATION TRANSPARENCY prices or tariffs. Hence, some of the requirements AND DISCLOSURE OBLIGATIONS for transparency in more liberalized markets are not applicable in Egypt. Additionally, the ease on Of course, no market is alike and it takes great effort switching suppliers is another issue that is more to standardize them. It has taken over 17  years relevant to markets where a choice is available. of continuous efforts in Europe to harmonize the electricity market and yet significant differences A More Detailed Understanding remain, especially on implementation of certain rules The next step is to move from the “headline” reports and regulations. Therefore whatever comparisons are that the licensees are obliged to submit, into the made here between Egypt’s and certain international actual content of the reports as depicted in the license practices has always to take into account very agreement. The main documents that specify the different market structures, market dynamics and content of the reports are the country’s distribution societies as a whole. license and draft supply code. The supply code is still in draft format and not yet active. Transparency is at the heart of market operation. A pillar prerequisite for a properly functioning market is As mentioned, the distribution licensing obligations to make information available to all market participants, and the draft supply code to be adopted by EgyptERA including potential and prospective entrants. Lack are very alike indeed. The main shortcomings seem of transparency can lead to unfair pricing and the to involve the enforcement of obligations, the subsequent decay of public confidence. capacity of licensees to honour their obligations, and the quality of the data provided. Transparency of information and reporting obligations cascades the full value chain of the electricity sector, A good example involves the reporting on customer from generation to transmission to distribution to service and quality by various electricity stakeholders. supply. A great part of information transparency All EU members and their NRA’s try to conform to in developed competitive markets has to do with the main axes of the European Regulators’ Group reporting detailed financial information so that sector for Electricity and Gas (ERGEG) on the classification stakeholders understand the profitability of the different of complaints and analysis. The adoption of this components of the gas and electricity markets. The classification system has been optional but highly same conditions are not necessarily transferable to a recommended by the European Commission, market that is still under development, or dominated which had set a target of adoption (70 percent of by a single electricity company. Additionally, annual recommendations) until the end of 2011 for each reports of listed companies are require by law member state. to provide different sets of data, something that doesn’t apply in Egypt’s case, given that none of the Under this framework, the regulator collects companies involved in the Egyptian sector are listed. complaints data under a structured format from the sector stakeholders as well as from consumers that However, given Egypt’s outlook for developing a more contacted the regulator directly. These data underlie open and competitive market, elements of reporting an annual comparative report. The structure and requirements in liberalized markets can be relevant. main elements of such a report can be seen under Annex B. Additionally, a significant element of reporting in liberalized markets relates to tariffs on natural EgyptERA states that such reporting is not possible monopoly structures, such as the transmission and given current limitations on the capacities of licensed distribution networks. EgyptERA has no authority on companies. In this respect, although the draft supply Chapter 3 | Current Situation and Key Findings | 33 code is very specific as to the data and handling area outside the mandate and scope of EgyptERA. of complaints required by the supplier, there is no However, there are elements such as monitoring mention of the supplier needing the proper resources and transparency, as well as consumer protection, to fulfill its task. which should be considered for incorporation in the EgyptERA annual report. The fact that the market is In most EU supply codes, as well as Greece’s, there not liberalized yet reduces some of the monitored is an explicit obligation stipulated for the licensee to indicators, but others remain relevant, given the “have the appropriate financial and human resources partial liberalization now envisioned for the Egyptian for the effective handling of consumer complaints.” electricity market. Article 32 of the Greek Supply Code on the Principle Monitoring and transparency focus mostly on issues of Complaints Handling reads as follows: of bad practices that can affect the consumer, and what the regulator did to amend them. For example The Supplier shall have the appropriate organization in Greece’s RAE of 2011, there were four categories and the necessary resources (financial, human, of transparency and market monitoring addressed by technical) to manage the requests and customer the agency: complaints. For this purpose, the supplier establishes a “Code of requests handling for 1. Monitoring of electricity supplier practices: the customer complaints” which describes the regulators describe the obligations of the suppliers process and resolution timing of the request. to him to provide detailed information concerning practices, activities and financial data. The report In Egypt, there is an opportunity to include in the draft mentions what actions the regulator undertook supply code such an explicit obligation as this. in the period regarding the specific area. For example, in 2011, RAE sent letters to the 3.1.8 ANNUAL REPORT INFORMATION three largest suppliers recommending specific BENCHMARKING changes to the terms offered, to the benefit of the final consumer, as well as to fully comply with The annual report published every year by the the Energy Law and the Supply Code. country’s regulator is an important piece of 2. Price comparison tool: the regulator describes information. A comparative analysis between on  its website the tool it has developed that the annual reports published by EgyptERA and provides pricing information to all types of Regulator Authority for Energy for Greece (RAE) were consumers and makes comparisons between made. Much of the content for the latter is dictated different suppliers. by EU directives and the domestic Energy Law that 3. Removal of barriers for supplier switching: the incorporates the directives of the third liberalization regulator describes the main barriers that existed package. Also included in the comparisons are the or appeared concerning the normal operation annual reports prepared by the UK regulator Ofgem, of the supply market and how it intervened to as they are probably the benchmark in terms of EU tackle them. information transparency. Figure 3.7 illustrates some 4. Practices of the DSO that did not support the messages as to the potential enhancements that are market: main complaints by suppliers against the required by EgyptERA toward obliging their licensees DSO are presented, as well as the subsequent to report certain information. actions taken by the regulator. In 2011, RAE penalized the DSO with a €900,000 penalty for A lot of information in the annual reports of European partial compliance with the relevant Distribution regulators has to do with regulating tariffs, which is an Code and Manuals. 34 | Transparency and Social Accountability in the Egyptian Power Sector Figure 3.7 | Annual Reports of EgyptERA and Greece’s RAE Annual Report Contents EERA AE/OFGEM/EU • Main developments in the electricity sector • Detailed information on allowed revenue, depreciation of regulated assets and allowed rate of return for the regulated entities (networks) • Tariff structure and calculation methodology for regulated entities • Quality of service (Customer Interruptions (CI) Throughout the document and per chapter there were the targets set by the and Customer Minutes Lost (CML)) • Cross boarder issues, imports/exports regulator and achievements towards these targets • Description of market operation & price monitoring • Retail/Supply Market Analysis (main players, customers and categorization, consumption/ volumes per player etc.) • Monitoring of Transparency (reviewing od contractual practices by suppliers, publicly available price comparison tools, removal of supplier switching barriers practices of distribution companies that inhibited the operations of suppliers • Consumer protection (Legislative Framework, definition of vulnerable customers, PSOs, connections and disconnections, consumer complaints • Security of Supply (consumption, peak load, type & share of fuel mix used etc.) • Contact information of all licensed electricity suppliers and traders Not part of the EERA annual report Part of the EERA annual report Partially part of the EERA annual report Source: Authors. Chapter 3 | Current Situation and Key Findings | 35 EgyptERA includes a “Consumer Protection” element but the foundation rests on regulations requiring in its 2010–11 Annual Report. However, the reported information to be published. data could be expanded to include statistics and results related to complaints per supplier, and categorization Information that Should be Made Public of complaints and performance indicators such as Throughout the EU and Australia, the licensees are response times and resolution. This is particularly obliged to provide information to the regulator on important given that when the market is liberalized, all the aspects mentioned earlier. EU regulators, the consumer will be able to better evaluate the value suppliers, and stakeholders are obliged to publicize each supplier provides, which in part includes the their data on their website. The UK regulator Ofgem type and level of services they offer. However, even in has gone to the extent of demanding that suppliers’ situations where there is no option to choose different data be no more than two clicks away from the home suppliers, the consumers have to know how their page and easily searchable. supplier fairs in respect to its sector peers. Table 3.1 summarizes the data that should be easily Below are indicators for comparing the levels of accessible for consumers in the website of each service: regulated company. These data have been compiled from reviews of regulatory regimes in Greece, France, • Types of customer groups served and the UK, although slight differences might exist • Total number of complaints submitted to the between countries. Regulators require the information supplier per customer group listed below to be available to customers in paper • Total number of complaints that were responded format as well, accompanied by all the standardized to in one day documentation, in the regulated companies’ service • Total number of complaints that were responded outlets. to between one and 10 days • Total number of complaints that were responded The published information is required to be updated to beyond 10 days when changes occur, unless otherwise specified, as • Total number of complaints that were resolved in is the case with financial and consumption data. Of less than two working days course in the case of Egypt, information concerning • Total number of complaints that were resolved the switching of supplier is irrelevant. between two and 5 working days • Total number of complaints that were resolved All of the information shown in Table 3.1 (except for after five working days supplier switching) should be made available to the public. Table 3.2 shows which of this information A more detailed analysis of the actual indicators to be is made available by the licensees. Though some used and the structure of a relevant report on customer of this information might be indeed available in complaints and handling are to be described in this the service outlets, a detailed description of the project’s analyses of benchmarking indicators and information offered through the service outlets will be customer interface and information transparency. highlighted in the customer interface and information transparency analysis. 3.1.9 PUBLIC INFORMATION AND CHANNELLING 3.1.10 CHANNELS TO CONVEY INFORMATION Public information tops this project’s priority list as the first step in improving transparency and Although a large part of this specified information accountability. Quality and content are also important, is available in service outlets, most distribution 36 | Transparency and Social Accountability in the Egyptian Power Sector Table 3.1 | Public Reporting Requirements Set by European Regulators Public Reporting Requirements Company Profile Descriptions of processes for the consumer that should be both on the website but also part of the information documentation provided • Number of customers to the customers prior to signing a contract • Contact details and customer complaint references telephone number • Services offered and coverage • Description of services offered • Payment methods in place • Role of networks and generators in the provision • Annual Reports and financial statements as of the service and their liability towards demanded by the local legislation the consumers • Services offered • Description of the criteria requirements to have a supply contract • The process of renewal and or stoppage of the Tariffs contract • The way the consumer will be informed on potential service changes • Description of customer groups and the • Process if the consumer wants to change supplier categorization criteria • Detailed process for the consumer to file complaints • Tariffs per customer group and special groups and the process thereafter for resolution • Detailed and simplified examples of tariff • Code of Conduct calculation separating different charges • Process if the consumer wants and qualifies to embedded in the bill as well as seperating change category (entering a special category) the regulated from the non-regulated charges • Detailed explanation of the charging periods and the calculation of the final charge Ex post information data (annually) • Annual report on activity including customer base Standardized documentation to download and energy consumption • Information on the fuel consumed for the energy sold (oil, gas, lignite, RES etc.) • Application form to supplier for supply • Complaints Report that included: of electricity • Total number of applications/complaints • General terms and conditions submitted to the supplier per category • 3rd party authorization form • # of applications/complaints that were • Service complaints form responded to in a day • Disconnection application form • # of applications/complaints that were • Form to file billing complaints responded to within 10 days • # of applications/complaints that were resolved successfully Source: Authors. companies use their websites to channel such information is also available in the service outlets information (Table 3.3). and could also be requested to be sent as hard copy via mail. This is of particular importance given According to the information collected on-site and that large parts of the Egyptian population have no through documentation provided to the Consultant, access to the internet. licensed companies in Egypt (as is the case in most European countries) dispense information and collect Meter readers constitute an additional channel feedback via websites and service outlets. between consumers and the Egyptian electricity sector. Over most of the EU, meter readers have no Websites should not be the only channel for interaction with the consumers. In Egypt, however, providing information. As in most EU countries this they are employed to collect the payments. Their Chapter 3 | Current Situation and Key Findings | 37 Table 3.2 | Assessment of Reporting by Licensed Regulated Companies Company Profile • Number of customers • Contact details and customer complaint references • Financial statements telephone number • Services offered and coverage Tariffs • Description of customer groups and the categorization criteria • Detailed and simplified examples of tariff calculation separating different charges embedded in the bill • Tariffs per customer group and special groups as well as separating the regulated from the non-regulated charges • Detailed explanation of the charging periods and the calculation of the final charge Descriptions of processes for the consumer that should be both on the website but also part of the information documentation provided to the customers prior to signing a contract • Role of networks and generators in the provision of the service and their liability towards the consumers • Description of the criteria requirements to have a supply contract • Detailed process for the consumer to file complaints • The process of renewal and or stoppage of the and the process thereafter for resolution contract • The way the consumer will be informed on potential service changes • Process if the consumer wants to change supplier • Code of Conduct • Process if the consumer wants and qualifies to change category (entering a special category) Standardized documentation to download • General terms and conditions • Service complaints form • Application form to supplier for supply of electricity • 3rd party authorization form • Disconnection application form Ex post information data (annually) • Information on the fuel consumed for the energy sold (oil, gas, lignite, RES etc.) • Complaints Report that included: • Total number of applications/complaints submitted to the supplier per category • Annual report on activity including customer base • # of applications/complaints that were and energy consumption responded to in a day • # of applications/complaints that were responded to within 10 days • # of applications/complaints that were resolved successfully Information reported on websites or other channels Information not reported on websites or other channels Source: Authors. 38 | Transparency and Social Accountability in the Egyptian Power Sector Table 3.3 | Use of Websites to Convey Information by Distribution Companies Distribution Company Website • North Cairo Electricity Distribution Company • No • South Cairo Electricity Distribution Company • Yes • Alexandria Electricity Distribution Company • Yes • EI-Behera Electricity Distribution Company • No • North Delta Electricity Distribution Company • Yes (doesn't work March 2013) • South Delta Electricity Distribution Company • Yes • Canal Egypt Electricity Distribution Company • Yes • Middle Egypt Electricity Distribution Company • Yes • Upper Egypt Electricity Distribution Company • Yes (doesn't work March 2013) Source: Authors. interaction with consumers is an untapped potential can be found with UK suppliers, who display their for both collecting and providing information. For performance in detail. For example, the British gas such potential to be realized, special training will electricity supply business offers extensive information be needed on specialty subjects such as billing on their customer service, including the number calculations, complaints processing, energy-and bill- and speed of calls and emails answered, homes saving techniques, and so forth. visited for service, and customer contacts resolved.2 Distributors, on the other hand, focus on details of As it stands, distribution companies are not obliged their engineering activities and projects, calculations to publicize this information. Most distribution of their required revenue, operational performance, companies focus on providing information on their customer performance, sustainability performance, websites that is limited to: shareholders information and financials. EDF in France is a good example of information provision • Summaries of the services provided and transparency, both through its website but also • Contact information through its annual report.3 • Engineering activities • Consumer actions to reduce energy consumption Details on the indicators that they use to benchmark • Safety guidelines supply and distribution performance is the main • Surveys on services provided engagement topic of this project’s performance • Contact numbers for electricity supply problems benchmarking, which analyses the indices used in Egypt, their international practice, and how In Europe, where the market is liberalized, suppliers information transparency towards consumers and focus mostly on pricing and price comparisons, investors can be improved. product sales, safety, and energy-saving techniques. Almost all suppliers mention that the distribution In conclusion, EgyptERA has been at the forefront companies are responsible for running the network utilizing the Internet, with a renovated website, and hence any power quality issues. A true social media interventions and reports. However, benchmark of information transparency on websites the information it provides is very much dictated by 2 (http://www.britishgas.co.uk/about-us/about-British-Gas/customer-service-performance.html?bglink_id=imm10097). 3 (http://www.edfenergy.com/sustainability/performance-report/2009/files/publication.pdf). Chapter 3 | Current Situation and Key Findings | 39 its licensees. Thus there is limited opportunity for with promoting the company’s image, and marketing. improving content without the support of the licensed Communication departments are also responsible for companies. interacting with consumer groups and peer pressure groups, and consulting on issues of great importance It is important that EgyptERA has a Cooperation to the consumers. They are mandated with designing Agreement with the Consumers and Energy and executing the long-term communication strategy Organization (CEO). CEO is an umbrella organization and feeding information to the decision makers of representing an extensive network of 40 NGOs the company, as well as ensuring that customer targeting mostly SME’s throughout Egypt, including service is always up to date with the messages that rural areas where providing or receiving information the company wants to convey to their customers. can be particularly hard. See Box 3.1 for a model example of a communication campaign by a European utility. 3.1.11 COMMUNICATION In Egypt, the only communication department Communication is usually driven by marketing currently active is one represented by the spokesman departments, especially those in distribution and of the Ministry. In most distribution companies, there supply companies that have a direct interaction with is no marketing and communications department, the majority of consumers. There is a clear distinction but rather a public relations department which between customer service and communications. reports directly to the company chairman. Such Customer service catalogues and deals with consumer departments deal mostly with administrative and queries and issues, whereas communications deals logistical issues concerning receptions, board Box 3.1 | Indicative Communication Campaign by ScottishPower Creating campaigns to connect with new and existing customers At ScottishPower there’s more to marketing than meets the eye. We’re involved in everything from creating high profile national TV campaigns to developing our consumer website www.scottishpower. co.uk and devising activities to ensure that our most valuable customers stay loyal. Responsible for delivering consistent, interesting, innovative and relevant communications, we work across all customer touch points and channels, including TV, radio, outdoor, PR, Direct Marketing and online. No two days are ever the same as we also maintain our competitive edge by delivering pricing strategies and developing new energy products and propositions to meet changing customer needs and market conditions. Our responsibilities As well as promoting our many benefits and an engaging corporate brand, we also keep a very close eye on the activities of our competitors and facilitate customer surveys to tell us how customers rate their ScottishPower experience. This includes commissioning, interpreting and communicating “Voice of the Customer,” “Voice of the Business” and competitor research. These activities enable us to drive improvements and develop strategies to maximize customer value, drive the retention of high value customers and set the pace in a constantly-changing market. Major challenges In a world where energy costs fluctuate and there are strong regulatory and political pressures, against the backdrop of today’s unstable economic climate—the need for effective campaign planning, reporting and analysis is more important than ever. It will enable us to continue to innovate, target the right audience with the right message and develop new energy products and propositions to meet changing customer needs. 40 | Transparency and Social Accountability in the Egyptian Power Sector meetings, workshops, and so forth. The distribution • Publishing awareness flyers companies of Alexandria and Cairo South provide • Publishing ERA Annual Report and periodicals information on their websites that describes the • Establishing rules for connecting the power supply company’s activities and news. However, these to the residential facilities in the villages and cities departments are not staffed with people possessing • Developing ERA website and social media skills in marketing and communications. presence with videos and messages on energy saving Although the Egyptian market is not yet competitive, • Form a cooperation agreement between the the thrust is to become so in the future. Hence, Egyptian Electric Utility and Consumer Protection people with skills relating to market analytics, media, Regulatory Agency and the Consumers and communications, public relations, and IT will be Energy Organization. needed to staff communication departments of distribution companies. 3.1.12 CONCLUSION Note, however, that unlike the sector companies, In light of the above, it is recommended that EgyptERA’s EgyptERA has been very active in terms of developing mandate is updated ahead of the enactment of the communications. EgyptERA has a constant dialogue New Electricity Law and the upcoming reforms in the with the Investment Authority, the Ministry of Electricity, electricity market. Such amendment to EgyptERA’s and the Ministry of Social Solidarity, with whom it mandate, in order to be effective, will need to be comprises a working group. Through the signing accompanied by structural changes in Egypt’s of memoranda of understanding, this institutional electricity sector, to include the financial unbundling coordination lays grounds for further collaboration of companies, the definition of a clear structure and cooperation in the process of market reform and for sector governance, and the development of communications. There is also communication and a sector-strategic plan and a tariff reform plan. meetings with a number of agencies and entities and These institutional changes will need some time to civil society, particularly with the CEO. be agreed upon, designed, and implemented, and can only take place in the medium-term via close As it stands, EgyptERA staff working on cooperation of all stakeholders including EgyptERA, communication consists of a team of seven EEHC, EETC, and distribution companies. experienced professionals in the Awareness and Consumer Protection Department. Their strategy Transparency and accountability in Egypt’s is to set communication priorities, since the market electricity sector is limited from the fact that EEHC reform will lead to an escalation of complaints and subsidiaries are not held responsible–as specified renewed media pressure. in the companies’ Articles of Association and their licensing agreements–to focus on their customers. Some useful communication activities that have Nor is it the EEHC’s Board’s responsibilities to already been implemented by EgyptERA are: oversee the periodical reports connected with the commercial and customer satisfaction performance • Assessing public opinion on the quality of of the companies. As a result of this institutional electricity services gap, the communication policy of distribution • Issuing circulars by the Egyptian Electric Utilities companies towards consumers and the wider public and Consumer Protection Agency is underdeveloped. For example, despite their daily • Applying an automated system for assessing the interactions with thousands customers, distribution quality of service in distribution companies (as in companies do not currently have marketing and the Cairo South Electricity Distribution Company) communication departments, nor a mandate to Chapter 3 | Current Situation and Key Findings | 41 include them. This situation is further manifested in the only partially fulfill their mandate. This issue is further limited emphasis on commercial indicators, which are exacerbated by the lack of monitoring of the technical marked as customer satisfaction benchmarks (e.g., and financial capacity of the licensed companies to response time to customer complaints or requests for collect, aggregate, and disseminate information. Even new connections) are not currently being monitored in the draft Supply Code, which mitigates several by distribution companies. These shortcomings regulatory limitations (and is yet to be adopted), no can be significantly mitigated in the short term by specification is made for the resources (financial, incorporating a more customer-focused outlook in human, technical) that the regulated companies need the responsibilities of EEHC subsidiaries, as outlined to fulfil their reporting obligations. For lack of such in their Articles of Association; and by obliging resources, regulated electricity companies and EEHC EEHC’s Board of Directors to oversee the periodical are often unable to meet their reporting obligations, reports on the commercial and customer satisfaction thereby precluding EgyptERA from exercising its of subsidiary companies. Such amendments can mandate of overseeing the sector. The above can be be designed and prepared under the support of significantly mitigated by consolidation three existing EgyptERA to moderate EEHC’s burden of required departments of EEHC to create a single department time and resources. In addition, in order to maximize dedicated to cooperating with EgyptERA. EgyptERA the effects of such amendments, it is recommended can assist in this task by helping to attract qualified that EEHC coordinate with EgyptERA to set personnel, and by arranging training courses, commercial and customer performance indices of including twinning activities. In addition, an explicit subsidiary companies, and against which they can remark can be added in the Supply Code, stating that be held accountable by EEHC. suppliers are required to have the capacity needed to fulfil their reporting obligations. This change will Neither EEHC nor regulated companies (generation, need to be accompanied by training courses and transmission, and distribution) have sufficient meetings with distribution companies, to be held by capacity, resources or the organization to effectively EgyptERA, to highlight the importance of the Supply provide EgyptERA with timely, accurate, and Code. In addition, given the licensees’ somewhat comprehensive information and data. Dedicated loose observance of reporting obligations arising coordination departments have been established in from the limited sanctioning authority of EgyptERA, regulated companies to liaise with EgyptERA. They the Articles of Association of licensed companies are, however, often staffed by personnel who lack can be amended to make explicit reference to suitable training and qualifications. Similarly, three these obligations. EEHC can further complement departments of EEHC are dedicated to cooperating EgyptERA’s oversight by verifying the compliance of with EgyptERA, yet one is inactive and the other two licensed companies with these obligations. 3.2 Performance Benchmarking Performance benchmarking in Egypt currently There is limited interaction between EEHC and involves three sets of stakeholders: Electricity EgyptERA during the benchmarking process. Data is companies, EEHC, and EgyptERA (Figure 3.8). collected separately, while benchmarking indicators Electricity companies monitor certain performance are monitored at different levels: EEHC monitors indicators for internal purposes, while they are performance benchmarks only at the company also required to provide to EgyptERA and EEHC level, while EgyptERA monitors benchmarks at the the underlying data for monitoring performance department level. The two sets of benchmarks are benchmarks. not directly comparable. 42 | Transparency and Social Accountability in the Egyptian Power Sector Figure 3.8 | Main Stakeholders in Performance Benchmarking of Egypt’s Electricity Sector EERA • Processes data and derives benchmarks Data at unit/department level • Does not impose regulatory penalties Electricity Companies a rks or incentives Benchm • Generation Companies • Transmission System Operator • Distribution System Operators/ Suppliers Data EEHC Benc • Processes data and derives benchmarks hma rks at company level • Penalizes/rewards performance only via indirect channels Source: Authors. 3.2.1 BENCHMARKS AND shedding–for which no prior warning is given to BENCHMARKING PROCESSES consumers. Therefore this benchmark evidently USED BY ELECTRICITY underestimates the number and frequency of COMPANIES unplanned power cuts experienced by consumers. However, EgyptERA is currently developing and Electricity companies monitor a number of different testing a new process, to be employed by all indicators. As to the indicators monitored by distribution companies in the future, by which distribution companies, there are uniformity issues. customers will be informed by SMS a day in advance For example, the minimum duration of power cuts of planned power cuts due to load shedding. or interruptions that is recorded ranges from two minutes in Alexandria to five minutes in Upper Egypt Limited emphasis is placed on commercial indicators. and Middle Egypt. This inconsistency of indicators Customer satisfaction benchmarks (through surveys complicates any comparison of interruptions. or other means) are not currently monitored by distribution companies. This is a significant limitation In addition, distribution companies seem to be of the benchmarking system in the sector. using different methods to estimate the number of affected customers by each power interruption. For Nevertheless, all distribution companies seem to example, the distribution company of Alexandria have a classification system that categorizes broadly uses differences in the load between elements of the the complaints and tracks the time taken to resolve network to estimate which areas—and hence, how them. In addition, they all produce daily reports. many consumers—are affected. Upper Egypt and However, Cairo South is the only distribution company Middle Egypt use the geographic information of phone currently using a CRM system for logging and tracking calls they receive reporting interruptions to estimate complaints. All other distribution companies do not areas and populations affected. Again, the absence of have computerised systems. This makes the tracking uniformity of methods between distribution companies of complaint-handling benchmarks burdensome and poses problems in comparing benchmarks. prone to errors. Moreover, note that planned outages include those The process by which distribution companies due to maintenance work–for which consumers collect all the benchmarking data is shown below are informed in advance–as well those due to load in Figure  3.9. Departments report to sectors and Chapter 3 | Current Situation and Key Findings | 43 EgyptERA issues a request for data from all companies Figure 3.9 | Information Flow at the fiscal year end (June). Companies are allowed and Reporting Lines in Egypt’s approximately one month to provide technical data Distribution Companies and three months to provide financial data. A penalty BoD can be issued (and has been issued in the past) in the event of delays. Distribution companies have liaison offices dedicated to dealing with such requests for Sector data and information. EgyptERA reports, however, that liaison offices are often staffed by personnel who lack suitable training and qualifications, a problem that Department was mentioned in the Institutional Analysis as well. Source: Authors. EgyptERA processes these data and drafts an annual benchmarking report for each company. sectors report to higher management and their EgyptERA then holds meetings with all electricity respective Board of Directors. Each department is companies to receive and discuss their feedback, obligated by their license to collect all necessary data before finalizing the report and sending it to the and to compose a monthly report that is given to the Ministry of Electricity and Energy and to EEHC. sector head. At sector level, data is aggregated from Note, however, that EgyptERA tracks benchmarks each department and a report is presented monthly only at the department and unit level of distribution to the Board of each company. and generation companies, respectively, without aggregating at the company level. Before submission of each report, departments and sectors have monthly meetings to discuss any Annexes C1-C4 outline all performance benchmarks gaps or other problems with the data. The validity currently monitored and categorized by EgyptERA. and accuracy of the data is tested against historical deviations. If a set of data is significantly divergent As mentioned above, benchmarking for generation from the previous measurement, a re-check is and distribution companies takes place at the unit and requested of the company. As it stands–and unlike department levels, respectively. Units are categorized practices employed in the EU–no third-party audit is in groups according to their type and size, while taking place to validate the accuracy of these data. departments are categorized according to function. For each group the weighted average of the indicator In a recent development, distribution companies are is calculated and each unit or department is graded establishing new departments dedicated to monitoring with reference to the weighted average value of the their quality of service in terms of technical specifications, group, to the best performance in the group, and to e.g., voltage fluctuations, frequency, harmonics. the standard deviation from the weighted average. 3.2.2 BENCHMARKS AND In addition, yearly improvements or deteriorations BENCHMARKING PROCESSES in the performance of the unit or department are USED BY EGYPTERA monitored to analyze trends. Benchmarking is analyzed using an automated technique that has As part of their annual renewal of licenses, electricity been developed by EgyptERA to ensure accuracy. companies are required to provide to EgyptERA a set of data, which it uses for benchmarking and EgyptERA does not commission audits. Data quality monitoring the performance of the companies. is validated by EgyptERA, based mostly on trend 44 | Transparency and Social Accountability in the Egyptian Power Sector analysis of historical data stored in EgyptERA’s are followed or presented only in absolute values, not database (which contains data since 2002 on thirty to in per unit values (for example, arrears per customer). 40 indicators). EgyptERA believes that the companies have limited capacity to provide accurate data, so its Performance by EEHC is benchmarked between and objective has been to focus on a small number of within companies over time to monitor the change in simple indicators that can be readily cross-checked. company performance and analyze trends. When EgyptERA spots gaps or outliers in the data, it requests explanations from the companies. Although EEHC, in cooperation with subsidiary companies, companies are formally allowed a period of five to sets annual performance targets. As part of the 10 working days to address the query, rarely do they yearly budgeting, electricity companies draft specific adhere to this. EgyptERA staff is typically required to performance targets (for example, on commercial follow up the initial query several times until obtaining and technical losses) which are subsequently a response. approved by EEHC. If EEHC does not approve the targets, the subsidiaries have to accept the targets EgyptERA stressed that the quality of higher set by the holding company. management in electricity companies is pivotal towards ensuring the punctuality and accuracy of EEHC has not set up automatic incentives or the data it receives. Licensees with very competent sanctions to reward or penalise performance. and active management are shown to be much more However, in the annual meetings of EEHC’s Board, responsive and cooperative in liaising with EgyptERA. the subsidiary companies’ attainment of the previous year’s targets is discussed in detail, and EgyptERA does not currently publicize the annual explanations are requested for poor performance. If benchmarking reports, but they expect that that they companies consistently under perform, EEHC may will be able to do this in about a year, following the take appropriate actions to replace personnel at key publication of the “Cost-of-service/supply” report. management positions. 3.2.3 BENCHMARKS AND EEHC and subsidiary companies might also address BENCHMARKING PROCESSES poor performance by setting up working teams USED BY EEHC to analyze and address the problems and draft an action plan for review by EEHC’s BoD. The BoD could EEHC collects data from all companies (generation, assess the action plan and subsequently assign a transmission, and distribution) each month, through manager to monitor the timing and implementation templates provided by EEHC. EEHC processes the of the plan. A more detailed roadmap of such actions data and produces monthly, quarterly, and yearly can be seen in Annex E. benchmarking reports at company level. An indicative quarterly benchmarking report includes information Based on these indicators, regulation of commercial at company level as shown in annexes D1-D3. quality, as currently practiced by European regulators can take either of four forms. The following two are From this information, two main observations emerge. most commonly used: Most importantly, very limited attention is paid to quality-of-service indicators (for example, response • Guaranteed Standards (GS): service quality time to customer complaints, enquiries, and orders levels must be met in each individual case. If for new connections), especially as these could be the company fails to provide the level of service applied to distribution companies, which are directly required by the GS, it must compensate the dealing with consumers. Secondly, most indicators customer affected, subject to certain exemptions. Chapter 3 | Current Situation and Key Findings | 45 • Other Available Requirements (OAR): regulator • OS: 15 sets service quality requirements either at the • OM: 6 individual or aggregate level and imposes sanctions (e.g., financial penalties) for those not met. EU regulators also tend to make greater use of pro-active regulatory mechanisms to promote In addition, the following two indicators are used less improvements in commercial quality. For example, often: Ofgem in Great Britain has in place a Discretionary Reward Scheme, which is designed to acknowledge • Overall Standards (OS): minimum performance outstanding customer service of companies and in terms of service quality levels (usually a can award up to £1m annually. This encourages percentage) must be met on aggregate over a companies to identify customer priorities and shape defined period (e.g., 90 percent of cases over their company strategy accordingly. a  one-year period should be connected within 20 working days). Moreover, in areas where Ofgem has concerns • Only Monitoring (OM): regulators monitor only regarding distribution companies’ performance, it the performance of electricity companies and may explore stakeholder feedback. Companies are publish the actual data on services provided to then monitored closely to ensure that service issues the customers for informative purposes, without put forward by stakeholders are addressed. setting explicit service quality requirements/levels. Indicative benchmarks of financial and operational The percent frequency by which each type of performance for DSO’s and distribution companies requirement is used for commercial quality standards are listed in Table 3.4. by European regulators in 17 European countries4 is as follows: The main difference between benchmarking in Egypt and  in the EU is in their respective coverage of • GS: 38 commercial quality indicators. DSO’s and suppliers • OAR: 37 in the EU provide detailed data on quality-of-service Table 3.4 | Benchmarks of Financial and Operational Performance for DSO’s and Distribution Companies INDICATOR DEFINITION Cost recovery index Operating revenues/Costs (excluding capital expenses) Capital reinvestment rate Average annual capital expenditure/net book value of transmission assets Transmission cost per GWh Costs/total GWh of transmitted power Employees per km of transmission line Total no. of employees/total length of distribution line (km) Labor cost per km of transmission line Total labor cost/total length of distribution line (km) Source: Authors. 4 The countries are: Austria, Czech Republic, Estonia, Finland, France, Great Britain, Greece, Hungary, Ireland, Italy, The Netherlands, Norway, Portugal, Slovak Republic, Slovenia, Spain, and Sweden. 46 | Transparency and Social Accountability in the Egyptian Power Sector indicators to energy regulatory authorities, which monitor Electricity companies seem to be transparent and them closely and publicize detailed benchmarking efficient in providing information top both EEHC reports. In addition, EU regulatory authorities have and EgyptERA, regularly providing detailed technical mechanisms that penalize and reward DSO’s and and financial data and thus allowing both EEHC and suppliers for their quality of service. (However, such EgyptERA to monitor their performance through mechanisms are more likely to be effective in markets appropriate indicators. EEHC holds the electricity where the management of companies is accountable companies accountable for these indicators, through to shareholders, who ultimately stand to gain or lose informal sanctions to their management. on their dividends or share value due to regulatory rewards and penalties). There is, however, limited transparency afforded consumers, especially with regards to indicators Figure 3.10 illustrates the degree to which Egyptian service quality. In the absence of such standards, benchmarking contributes towards transparency consumers are not in position to accurately judge the and accountability, as compared to such practices performance of the sector’s companies. in the EU. Figure 3.10 | Benchmarks and Benchmarking System in Egypt’s Electricity Sector – How They Contribute to Transparency and Accountability ELECTRICITY SECTOR EEHC ACCOUNTABILITY TRANSPARENCY ACCOUNTABILITY Electricity companies EERA TRANSPARENCY ACCOUNTABILITY TRANSPARENCY Consumers Not transparent/accountable Transparent/accountable Source: Authors. Chapter 3 | Current Situation and Key Findings | 47 Figure 3.11 | Forecast Operating and Maintenance Expenditure in Australia – Electricity Distribution Networks 2008–09 Forecast operating and maintenance expenditure—electricity distribution networks, 2008–09 12 000 Urban Rural Mixed 10 000 $ per Customer 8 000 $ per km 6 000 4 000 2 000 0 United City Jemena Actew Ergon Country Powercor SP ENERGEX Energy Integral ETSA Western Aurora Energy Power (Vic) AGL Energy Energy (Vic) AusNet (Qld) Australia Energy Utilities Power Energy (Vic) (Vic) (ACT) (Qld) (NSW) (Vic) (NSW) (NSW) (SA) (WA) (Tas) $ per km $ per Customer Source: Authors. 3.2.4 NORMALIZATION OF of a regulatory agency from a country with wide BENCHMARKING INDICATORS variations between rural and urban population is ANEEL, The Brazilian Electricity Regulatory Agency. There is a noticeable difference between the way an When they set Commercial Quality indicators, they urban network operates versus a rural network, in clearly distinguish between rural and urban networks terms of capital needs, staffing, response times, and as shown in Annex I. so forth. In Australia for example a higher reliability standard is usually required for a central business 3.2.5 COMMUNICATING district (CBD) network with a large customer base BENCHMARKING INDICATORS and a concentrated load density than for a highly TO THE WIDER PUBLIC dispersed rural network with a small customer base and a low load density. While the unit costs A number of technical terminologies might seem of improving reliability in a dispersed rural network alien to the average consumer making whatever are relatively high, an outage is likely to affect few information is publicized irrelevant. Therefore an customers. Conversely, the unit costs of improving analysis should take place in order to identify the reliability in a high density urban network are relatively information that is directly relevant to the consumer low, and an outage is likely to affect many customers. and decide how to communicate it with the simplest This is therefore reflected in the regulatory allowances and most effective way. for each network to cover efficient operating and maintenance expenditure. As shown in Figure 3.11 The main principles behind how to communicate below from the State of the Energy Market 2009 complex information and passing the message in Australia on Distribution Networks, Australians across are: cluster and benchmark the distribution companies based on the areas they serve (urban, rural or mixed) 1. Clarity by using clear wording and examples so as to ensure a “fairer” comparison. 2. Associate the information provided with everyday “common” experience Under this mindset, the same principle of clustering 3. Use of stories or analogies that link to everyday should take place in Egypt as well. Another example experience since messages conveyed through 48 | Transparency and Social Accountability in the Egyptian Power Sector Figure 3.12 | Illustration of Performance Benchmarks Perfomance Indicator Distribution Company 1 Distribution Company 2 Distribution Company 3 Each car Time for response to represents customer claim for 3 working days network connection to respond Each electrician Punctuality of represents 30 appointments with minutes deviation customers from the agreed appointment time Response time to Each telephone customer complaints represents and enquiries 5 minutes of waiting time Source: Authors. stories tend to be understood and remembered This information should be presented in a contrasting for longer compared to facts and statistics manner with the less possible facts and statistics and 4. Do not underestimate the intelligence of the the maximum possible illustrative demonstrations as audience shown in Figure 3.12. Although a communications strategy and design Only selective information from the benchmarking of communications material is outside the scope of report should be referred to the annual report this work, it demonstrates an indicative table in the of EEHC. There is no need for EEHC to make following page of how benchmarking information and their annual report too focused on benchmarking metrics could be easily communicated without using subsidiaries. Whoever is interested to find out in many numbers of facts. detail the technical, operational and commercial relative performance of the subsidiary companies Information communicated to the wider public should could review the annual benchmarking report which be the one that relates to their everyday lives and will also be publicized on EEHC’s website. business. Indicatively (not exhaustively): 3.2.6 CONCLUSION • Time for response to customer claim for network connection Electricity companies, EEHC, and EgyptERA monitor • Time for connecting new customers to the network and disseminate the operational and financial • Time for disconnection upon customer’s request performance indicators used to benchmark the quality • Punctuality of appointments with customers and efficiency of electricity generation, transmission • Response time to customer complaints and and distribution in Egypt. These indicators are enquiries critically important for ensuring transparency and • Time between the date of the answer to the social accountability. complaint and the elimination of the problem • Time for giving information in advance of a EgyptERA planned interruption EgyptERA, as part of its annual renewal of licenses, • Time until the restoration of supply in case of collects an extensive set of data, mainly of technical unplanned interruption and financial nature, which form the core of the dataset • Time from notice to pay until disconnection it uses to monitor and benchmark the performance of • Time for restoration of power supply following regulated licensed companies. Companies renewing disconnection due to non-payment their licenses are allowed a specific period of time Chapter 3 | Current Situation and Key Findings | 49 to provide such data (approximately. one month for companies. This limits the transparency of each technical data and three months for financial data) company’s aggregate performance and the degree following a request by EgyptERA at the fiscal year to which company management can be held end. EgyptERA is authorised to issue a financial accountable. It also complicates comparisons of penalty to companies that fail to comply with this performance indicators produced by EgyptERA with requirement. those carried out internally by licensed regulated companies and EEHC, as these takes place at the Performance of generation companies is monitored company level only. The use of an MIS system for and benchmarked at the organizational level of logging and monitoring company benchmarks “units,” which are grouped according to their type would greatly simplify the analysis and aggregation and size. The performance of distribution companies, of data by EgyptERA and EEHC. It would also however, is measure at the organizational level of reduce the resource burden of data processing “departments,” which are in turn grouped according and would improve the accuracy of benchmarking. to function. For each unit or department, EgyptERA EgyptERA will also require an efficient MIS system calculates the weighted average of each indicator for monitoring and logging the results of the annual and grades it in reference to the weighted average “consumer awareness survey,” which aims to track value of the group, the best performance in the and extract public perception trends on quality, cost, group, and the standard deviation from the weighted and evolution of services provided in the electricity average, in order to rank each unit’s or department’s sector. performance relative to its peer group. The year- to-year performance of each department or unit is International best practice shows that a key to analysed by EgyptERA by examining historic trends monitoring and benchmarking performance resides in indicators and benchmarks. The benchmarking in the underlying dataset’s accuracy. Many regulators analysis is presented and discussed in joint meetings verify such data via external auditors or comptrollers. between EgyptERA and the electricity companies to EgyptERA does not yet commission external audits, validate their results and conclusions, which are in turn but verifies the validity of data provided by its documented by EgyptERA in annual performance companies via trend analysis of historical data on 30 reports for each company and are circulated to the to 40 indicators recorded in EgyptERA’s database Ministry of Electricity and Energy and to EEHC. over the past decade. To rectify errors in the data, EgyptERA requests clarifications from the companies, Despite such thorough benchmarking analysis, which are allowed five to 10 days to address the transparency and social accountability are somewhat query. This procedure is commonly hindered by thwarted by the fact that these reports are not companies ignoring this requirement, and responding currently made available to the wider public. It is only after several follow ups by EgyptERA. To recommended that EgyptERA publicizes these mitigate this issue, EgyptERA, EEHC, and electricity benchmarking reports on its website and on companies can undertake periodic internal audits service outlets of electricity companies, and that it at electricity companies to improve accuracy and coordinates with electricity companies to review and validate data. One prerequisite to implementing this re-design report templates and presentation formats recommendation requires personnel who now lack to make them accessible to the wider public. the qualifications required for undertaking audits and data validation receive appropriate training. The value of the analysis is also to some degree diminished due to the fact that monitoring and Electricity Companies benchmarking are restricted to units and departments, Electricity companies monitor performance indicators thus preventing comparisons of performance to against their individual targets as set in cooperation 50 | Transparency and Social Accountability in the Egyptian Power Sector with holding company EEHC, without carrying cuts based on a priority or merit sequence. Full roll- out a benchmarking analysis per se. Performance out of the software will allow EgyptERA to maintain indicators are monitored, discussed and reported on a database and build a clear picture on the number monthly within company departments, sectors, and and frequency of power cuts experienced by each boards of directors. type of consumer. It will also serve as a valuable tool for monitoring performance related to planned power Though performance monitoring requirements outages due to load shedding. are mostly dictated by the holding company for benchmarking between companies, it is not Distribution System Operators and electricity uncommon for electricity companies to deploy supply companies in the EU typically monitor their somewhat different metrics to monitor their performance against specific targets concerning performance. Internal auditing of benchmarking data, the provision of customer services, e.g., response as discussed above, could thus serve to ensure that times to customer complaints and claims for new electricity companies adhere uniformly to EgyptERA connections). In contrast, distribution companies in guidelines, and to standardize measurements of Egypt do not currently monitor such indicators and company performance. do not conduct customer satisfaction surveys that would provide them valuable feedback to gauge their Performance comparisons are also hindered by performance in this field. As mentioned previously, the lack of MIS available to either EgyptERA or the distribution companies’ limited emphasis on electricity companies to unify their monitoring data. commercial indicators could be addressed by adding EEHC and EgyptERA rely on each subsidiary to such responsibilities to their licensing agreements. send the information via FAX or email, and the These responsibilities could be further enforced subsequently aggregate and analyze the data by establishing performance incentive contracts manually. Nevertheless, EEHC has made steps between EgyptERA and the distribution companies. towards mitigating this issue, developing a blueprint Nonetheless, distribution companies face a for an MIS system which, however, has not yet significant obstacle in monitoring their provision of been implemented due to financing constraints. customer services, as they do not currently have A  well-functioning MIS system will be also required available CRM systems for logging and tracking by EgyptERA for logging and monitoring the results customer complaints, queries, and feedback. of the annual consumer awareness survey, to track Such systems would enable them to monitor such and  extract public perception trends on issues benchmarks in an effective and cost-efficient manner. concerning quality, cost, and evolution of services The exception is Cairo South, where a CRM system provided in the electricity sector. has been developed in coordination with EgyptERA. When fully developed and implemented, such a Load shedding, which interrupts electricity service system will centralize complaints and enquiries from to customers, is currently a major issue in Egypt. It all distribution companies. This recommendation affects significantly the quality of service yet is not will first require that distribution companies and being explicitly monitored, as it is aggregated with EgyptERA secure required funding. planned outages due to maintenance work, for which consumers are informed in advance. EgyptERA EEHC and EEHC can thus establish a new benchmark The performance of electricity companies is also being for monitoring planned power outages due to load monitored by the EEHC, which collects data by all shedding. A number of distribution companies have companies and analyzes benchmarks on a monthly, recently started to use a software system that helps quarterly and yearly basis at company level. As part manage load shedding and distributes the power of their yearly budgeting, each subsidiary electricity Chapter 3 | Current Situation and Key Findings | 51 company, in cooperation with EEHC, sets annual publicizes these benchmarking reports on its website performance targets against which their performance and on the service outlets of subsidiary companies. is evaluated and discussed in annual meetings between EEHC’s Board of Directors and electricity EEHC does not commission external audits to company managers. Although formal incentives validate the accuracy of data provided by subsidiary or sanctions are not in place, each company’s companies, and verifies only the quality of this data performance is scrutinized in these meetings, and via trend analysis of historical data. As in the case where systematically poor performance may lead to of EgyptERA, in order to rectify any inaccuracies the replacement of its management. Transparency identified in the data, EEHC requests clarifications and social accountability with regards to the from the companies. To mitigate this issue, EgyptERA, performance of electricity companies is again, as EEHC, and electricity companies can undertake with EgyptERA, hindered by the failure of EEHC to periodic internal audits at electricity companies and make its benchmarking reports available to the wider require that personnel receive training appropriate to public. It is thus recommended again that EEHC the task. 3.3 Customer Interface, Transparency, and Public Information Systems Transparency and social accountability in approximately 16 percent of total consumption. Egypt’s electricity sector relies significantly on Figure 3.13 illustrates the bilateral flow of information effective communication between the sector’s between each set of stakeholders. main stakeholders, namely EgyptERA, electricity companies, and the wider public. 3.3.2 REPORTING OBLIGATIONS 3.3.1 REPORTING AND INFORMATION As previously discussed, in the Institutional Analysis, FLOWS BETWEEN STAKEHOLDERS the main obligations of licensed regulated companies AND THE PUBLIC AT LARGE to provide information and data to EgyptERA stem from their licenses and the distribution code The main stakeholders involved in exchange of (Table 3.5). information and feedback in Egypt’s electricity sector are the regulated companies (generation, Licenses and the distribution code oblige electricity transmission, and distribution), EgyptERA, and companies to provide EgyptERA with financial consumers, including the general public. All and operational data and reports on the previous regulated companies are obliged by their licenses– year’s performance, as well as projections for future and the distributors’ distribution code–to provide performance. certain information to EgyptERA. EgyptERA in turn– in accordance with its mandate–informs consumers However, not all of the reporting obligations are and allows them to provide feedback through specific fulfilled. With regards to future performance, each channels (e.g., service outlets, telephones, emails). In company is supposed to submit to EgyptERA their addition, distribution companies also communicate estimated budget for every fiscal year as well as directly with consumers, providing information and their development plans for generation units, the receiving feedback from them. The same applies for transmission network, and the distribution network. the approximately one hundred very large consumers In addition, upon renewal of their licenses, these powered directly from the TSO, who account for companies submit to EgyptERA annual reports, 52 | Transparency and Social Accountability in the Egyptian Power Sector Figure 3.13 | Flows of Information in Egypt’s Electricity Sector EERA Information Information Feedback Generation Transmission Distribution Companies Company Companies tion Feedback rma Info Feedback Consumers 100 Very large Consumers / tion Industrials rma Info • Wider public • Consumer representative bodies (NGOs, etc.) Source: Authors. detailing their plans for meeting performance criteria and to the wider public. It is explicit in terms of the approved by EgyptERA, and for attaining specific mediums through which this should be done, and goals on quality standards. However, this practice is bestows more authority upon EgyptERA in order to rarely followed. Hence it is impossible for EgyptERA oversee regulations. to either review or monitor any of the plans. The distribution license already specifies that A major document that has a significant impact on distribution companies are obliged to develop a the reporting obligations concerning all distribution customer service system providing a complete companies, including those in Egypt, is the Supply description of the services available, as well as Code. efficient procedures for answering inquiries and for dealing with  requests. These need to be 3.3.3 SUPPLY CODE submitted to EgyptERA for approval. However, this specification seems to lack precision, as it bundles The draft Supply Code–whose aim is to govern a number of obligations and leaves significant room the obligations of electricity suppliers, traders, for interpretation and variation of standards and distributors and customers vis-à-vis each other–will obligations between regulated distribution companies. be able to mitigate some of the current regulatory issues, as it specifies the information that distribution The Supply Code obliges distribution companies companies are obliged to provide to consumers to draft and submit to EgyptERA a manual on the Chapter 3 | Current Situation and Key Findings | 53 Table 3.5 | Reporting Obligations of Regulated Companies Towards EgyptERA OBLIGATION APPLIES TO: INFORMATION ITEM DISTRIBUTION GENERATION TRANSMISSION COMPANIES COMPANIES COMPANY Certified financial statements for each fiscal year • • • Including the certified account comptroller’s report and his remarks on such accounts. Estimated budget for each successive fiscal year Including targeted revenues, expected expenses in the light of expected demand, • • • price of sale, expected cost and the regulated company’s investment and cash flow (capital and operating) budgets. Quarterly reports on the Licensee’s • • • commercial and financial performance Detailed annual study cost of service study Provided that such study includes elements • • • of the cost and revenues according to the approved annual budget. Annual environmental report Including all relevant environmental information regarding operations, according • to applicable environmental laws. The report should also include corrective measures taken in regard to complaints in this matter. Studies of power and load forecasts5 For short term (one year), medium term (three years) and long term (ten years) classified • • • according to indications of energy demand and future loads increase Annual report detailing its licensed activities The report shall encompass all financial, • • • technical and commercial aspects as well as consumer service. Annual human resources development plan To be submitted to the Agency along with his • • • annual report. Contracts concluded with other Licensees and consumers contract forms and templates • • • All for review and approval by EgyptERA Report detailing his plan to meet performance criteria and indicators approved by the Agency • • • Provided within 90 days of the date of issuing the license. (Continued) 5 See Annex 1 describing the main elements of information item. 54 | Transparency and Social Accountability in the Egyptian Power Sector Table 3.5 | Continued OBLIGATION APPLIES TO: INFORMATION ITEM DISTRIBUTION GENERATION TRANSMISSION COMPANIES COMPANIES COMPANY Plan to achieve total quality management pertaining to the activities set forth in the license. Provided within 90 days of the date of issuing • • • the license. It shall incorporate specific goals for developing quality standards and methods to follow up on these goals. Annual report on implementation of plan should also be provided. Report on planning the distribution network Plan for at least three years which should address ways to support the rehabilitation/ renewal, maintenance and operation of the • DCs’ distribution network. The report should also include demand projections as well as an evaluation of alternative options for supplying this expected demand. Quarterly report on electrical supply approvals6 Provided no later than one month after the • • end of period. It should include objectives and plans for the following fiscal year with regard to improving approvals of electrical supply. Studies, expansion and development plans For generation units, transmission network and distribution network as applicable. Provided • • • two months prior to the beginning of each year for review and approval by EgyptERA. Annual statement on the Quality of Customer Service The Statement indicatively includes the following: • Number of consumers categorized by various criteria • Number of connections categorized by consumer class • Number of meter outages categorized by • • consumer class • Number of disconnection’s according to consumer class • Complaints categorized by consumer class. • Outages during the last five years either forced or planned • Voltage quality data by consumer class. Source: Authors. 6 See Annex 1 describing the main elements of information item. Chapter 3 | Current Situation and Key Findings | 55 Table 3.6 | Supply Code Specification of Information to be Included in Supply Agreements Information to be Included in Agreements with Non-eligible Consumers The duration of the contract and its amendment or renewal procedures The terms on the termination of the Agreement by each party The means of calculating the amount to be paid The rules applicable on the terms of metering and information on how the customer access them The terms on disconnection of supply and interruption whether scheduled or not The guaranteed and other customer service standards The standard quality of electricity The method of initiating procedures for settlement of disputes Information relating to consumer rights, including complaint handling Information relating EERA's authorities for consumer protection Specific rights of Vulnerable Customers Source: Authors. detailed procedure for new connections and transfer • Distribution companies shall prominently of connections and the conclusion of an agreement display at all offices where applications for new for the supply of electricity. The manual should be connections are received and on their websites, made available through the company’s website and the manual application forms for the conclusion the distribution company’s offices or service outlets. of an agreement for the supply of electricity and The manual shall refer to: the connection of the customer. In order for the tariff and other charges for the electricity to take • the complete list of documents required, along effect, the distribution company shall announce with an application for the supply of electricity and them after they are approved by EgyptERA, the connection to the network and shall published them in at least two daily • the documentation required for the classification newspapers having wide circulation in the area or reclassification of a customer as vulnerable, of supply. Immediately after EgyptERA’ approval, including the criteria applicable for such (re) the distribution company shall publish the tariff classification schedule on its web site and make it available to • the amount of security to be deposited by the consumers free of charge. In addition, EgyptERA is applicant for the supply of electricity given the authority to oblige regulated companies to maintain a waiting list of applicants seeking new The draft Supply Code also specifies the contents connections and area-wide information about of supply agreements with eligible and non- new connections released. An update of the eligible consumers. These shall include at least the waiting list shall be displayed on the distribution information presented in Table 3.6. company’s website. The distribution company 56 | Transparency and Social Accountability in the Egyptian Power Sector shall inform the customer on the billing period, Detailed information on technical performance of date of meter reading, and due date for payment. electricity companies is collected by EgyptERA in a Any subsequent change in the schedule shall be less direct way through the obligation of companies brought to the notice of the customer sufficiently to provide a specific data package prior to the annual in advance. Several provisions are also made renewal of their licenses. The contents of these for communicating with customers with visual packages are shown in Annex J1, Annex J2, and and hearing impairments, as well as “vulnerable” Annex J3-K. customers. Finally, the Supply Code specifies that each distribution company shall handle complaints Overall, all companies are required (via the license, via mechanisms for facilities that: a) operate the distribution code, and license renewal obligations) continuously to receive notice of urgent faults and to periodically provide comprehensive information to difficulties with the electricity supply; and b) that EgyptERA on financial, technical, and operational operate during business hours to receive queries performance. Such institutionally established and give information concerning the customer’s obligations are certainly important for ensuring electricity accounts and connection services. adequate flow of information from regulated licensed companies to EgyptERA. The draft Supply Code, when implemented, will significantly upgrade the quality of information flows In addition, EgyptERA is authorized to penalise between distribution companies and consumers and companies if they do not provide the above the wider public as it will provide a clearer framework requirements. In the event of non-compliance, for exchanging information by specifying the EgyptERA can Issue a warning, or suspend or revoke information to be provided by distribution companies the company’s license. EgyptERA has yet to exercise as well as the mediums and procedures through either of the latter options. Even in mature markets, which this should be done. when there is a monopolist in the market or when it is deemed that the impact would be significant, it 3.3.4 INFORMATION FLOW BETWEEN is rare for the regulator to revoke a license. Or, as SECTOR STAKEHOLDERS recently happened in Greece, where two suppliers had their licenses revoked, the market was designed EEHC demands to be informed each quarter about to accommodate for such eventuality by having a their financial performance, in addition to an annual third supplier “of last resort.” report validated and audited by certified comptrollers. Both EEHC and EgyptERA can view the operational Data collection by EgyptERA does not always costs of each licensee, who is required to submit an run smoothly, as delays in receiving the required annual cost-of-service study. Such data are depicted information from regulated companies are common. in annual reports of each company, which include These delays pose a significant obstacle to the financial, technical, and commercial aspects of their oversight by EgyptERA. performance. These obligations are common to all regulated licensed companies, but a small number of In particular, EgyptERA feels that the dedicated requirements pertain only to distribution companies. liaison offices, or coordination departments, of The most important of these requires submitting an regulated companies, whose role is to prepare and annual statement on the quality of customer service, provide the information required by the regulator, which should include information on voltage quality are often staffed by personnel who lack suitable data categorized by consumer class and the number training and qualifications. As the role of coordination of outages (forced or planned) during the last five departments is pivotal in liaising with EgyptERA, years. this not only causes delays in the data collection Chapter 3 | Current Situation and Key Findings | 57 procedure but may also affect the quality of provided The obligations of distribution companies to provide data. For example, a period of five to ten working days information to consumers and to the wider public is formally allowed the companies when addressing address a comprehensive range of issues. an EgyptERA request for clarification. However, in most cases EgyptERA staff has to follow up the initial Distribution companies are required to inform query several times until a response is obtained. the wider public and tax payers on their financial performance and activities, while also providing them EgyptERA has stressed that the quality of higher all application forms, procedures and terms and management is equally critical towards improving the conditions for establishing a new connection and a punctuality and accuracy of received data and other supply agreement. In addition, distribution companies materials. Licensees with competent and active are required to be transparent in calculating their management have been much more cooperative in tariffs and consumer categories. liaising with EgyptERA. Distribution companies inform their customers on Despite the significant breadth and depth of how they can reach the company to file a query or obligations placed on regulated companies for a complaint. Upon customer request, distribution providing information to EgyptERA, the quality and companies provide detailed information on the flow of this information seems very much dependent process by which their complaint will be handled and on the capabilities and commitment of key personnel. eventually resolved. In addition, they inform customers This indicates an organizational problem in the flow of of open meetings with consumer representatives, in information from regulated companies to EgyptERA. which they can provide feedback. Customers can obtain information on meter reading procedures, Finally, EgyptERA has limited capacity to validate as well as energy saving tips and safety guidelines. much of the information as it can not commission Customers can also request and receive information external audits to the regulated companies. The on the quality of supply, and obtain copies of the checking of data quality by EgyptERA is mostly distribution code, commercial regulations, and other based on trend analysis of historical data stored in official documents detailing their rights as well as the EgyptERA’s database. obligations. 3.3.5 INFORMATION FLOWS BETWEEN However, such obligations do not specify in sufficient DISTRIBUTION COMPANIES AND detail either the content or the mediums and CONSUMERS procedures through which the information should be provided. For example, the requirement to publicize Distribution companies are obligated to provide “information on electricity charges and the method information to their customers and to the wider public of calculating tariffs for all consumer categories” either as mandated or upon the customers’ request. specifies neither the detail or the medium through These obligations are specified in their distribution which such information to be published. codes and licenses, and in EEHC’s commercial regulations. As discussed, in de-regulated markets where distribution and supply companies compete Table 3.7 summarizes the sources and types of to attract customers, provisions for sufficiently obligations of distribution companies to provide informing consumers are self-regulated. In non- information to their customers and to the wider competitive markets, however, regulations often public. need to be specified to prevent loose interpretations 58 | Transparency and Social Accountability in the Egyptian Power Sector Table 3.7 | Obligations of Distribution Companies to Provide information to Consumers and Wider Public INFORMATION ITEM SPECIFIED IN: MANDATORY All required documentation related to the provision of Distribution Code commercial services (e.g., meter replacement) and the establishment of new connections Includes application forms, procedures, terms and conditions. Must be made available at service outlets and on DC websites. Company contact details for receiving customer Distribution Code inquiries and complaints DC shall provide telephone number and email address in a suitable medium of their choice (e.g., newspaper and radio broadcasts) Information on electricity charges and the method of Distribution Code calculating tariffs for all consumer categories Annual financial reports Distribution Code Should be published in a “well-known” newspaper and on their website Announcement of periodic meetings with consumer Distribution License representatives The aim of such meetings should be to facilitate exchange of views between stakeholders Commercial regulations as well as systems and Commercial Regulations regulations in place for readings of electric meters Should be published in a “well-known” newspaper Information about the company Distribution License Including activities undertaken, services provided, etc. Guidelines on safety and Electrical Installations in Part of the Egyptian buildings Building Code , referenced in Chap 16 of Distribution Code UPON Copies of the supply code, the company statutes, and Distribution Code REQUEST the commercial regulations Information concerning the quality of electrical supply Distribution Code Including explanation for any incident/failure Detailed process for filing and resolving complaints At the back of the bill, on the company’s web sites, and on the outlets Source: Authors. and ineffective implementations. For example, 3.3.6 COMMUNICATION CHANNELS most of the companies’ information is not required AND CUSTOMER FEEDBACK to be on their websites. Hence the Internet is not yet utilized by all distribution companies. (Even as In practice, the most common medium through of March 2013, four companies did not have an which distribution companies channel the above operating website). information is service outlets (though several Chapter 3 | Current Situation and Key Findings | 59 distribution companies do use their websites, to address EgyptERA directly about their distributions and occasionally also broadcast through local TV company’s decision. Distribution companies track channels and through flyers inside the bill. all complaints and related information as specified in the distribution code, but most of them (except Distribution companies do not currently have Cairo South) lack computerised systems. When departments dedicated to marketing and fully developed and implemented by all distribution communications. Their public relations departments companies, such a system will centralize complaints report directly to the company chairmen, focused and enquiries with a universal call-in number. The mostly on administrative and logistical issues system will also handle payments and receive meter concerning receptions, board meetings, workshops, readings from mobile phones. and so forth. Consumer representatives or other civil society Distribution companies do, however, see a need to organizations—which are few in Egypt—are not create a separate department of communications providing feedback to distribution companies. (The tailored to consumers. This is especially important companies report that it is rare for them to receive in light of the public’s difficulties in comprehending complaints from their consumers). This disconnect concepts such as fuel shortages and subsidies. is further exacerbated by the absence of consumers In addition, distribution companies report that the or civil society on the companies’ boards. Only remoteness and cultural characteristics of certain on EEHC’s board are industry representatives rural areas makes local population suspicious participating. Therefore, although limited participation towards distribution companies. of civil society organizations in Egypt’s electricity sector is partly a cultural trait, their participation Distribution companies further limit their toward should nonetheless be encouraged. consumer communicationsby failing to conduct either customer satisfaction surveys or any organized There was an idea to utilize further Egypt’s meter efforts to gauge their feedback. Nor do they inform readers to also provide information and receive them of planned power outages (outside those feedback, and so on. However, distribution related to planned maintenance) with the exception companies report that meter readers are already of a few distribution companies that inform “priority” overloaded with work, and that they lack the customers such as hospitals and industries. qualifications to undertake such extra responsibilities. However, as mentioned in the benchmarking analysis, At the moment, Upper Egypt is the only distribution EgyptERA is currently developing and testing, along company employing meter readers to also collect with the Cairo South distributor, a new process to be consumer complaints, mostly in remote areas. employed by all distribution companies in the near future, by which an SMS will inform customers of 3.3.7 INFORMATION ON ELECTRICITY planned power cuts due to load shedding a day in BILLS advance. Electricity bills issued by distribution companies in Consumers can now file complaints mainly through Egypt do not adhere to a uniform format, though in dedicated call centers and service outlets. (Some broad terms they all provide identical information. The distribution companies offer the option to file common items include meter readings (in kWh), total complaints through their websites, but as discussed, cost (EGP), and the amount and date to be paid. not all of these websites are now working). However, no regulations yet specify the response time allowed Best international practice for providing information for customer complaints. The complainant is entitled on electricity bills is well captured in the publication 60 | Transparency and Social Accountability in the Egyptian Power Sector Table 3.8 | Information Currently Provided on Electricity Bills versus Information Specified by Egypt’s Supply Code and the EU’s Good Practice Guidance for Billing CURRENT SUPPLY EU INFORMATION ITEM BILL CODE GUIDE Customer account reference number/meter number, and date of the bill Meter readings and consumption (in kWh) during the billing period Amount to be paid, for which billing period, by when Total cost and total consumption (kWh) Meter readings at the beginning and end of the billing period Balance premiums7 Dates of meter readings - - Means of payment - - Supplier’s contact details (including helpline and emergency number) - - Contract duration - - Description of premises supplied with electricity at the point of delivery - - Base price of energy unit (kWh) and breakdown of applicable tariff - - How amount has been calculated (including whether it is based on - - actual meter reading or estimation) Information on how to obtain the bill in alternative formats (e.g., in - - large print) for consumers with disabilities Information on how to get tips on saving energy (e.g., a link to a - - website with tips or the number to call to request a brochure) Information on where the energy comes from, how it is generated, - - how environment friendly it is (“the fuel mix”) Deadline for informing supplier if consumer wants to switch supplier n/a n/a Switching code (needed to switch suppliers) n/a n/a Source: Authors. of  the  European Regulators’ Group for Electricity EU Guidelines also recommend a number of and Gas, Implementation of EC Good Practice additional information items. These could be included Guidance for Billing. This publication was the either in the monthly bill, or they could be provided outcome of extensive consultations between via an extra annual reconciliation bill. Examples of the the European Commission, national consumer recommended information items are the following: organizations, industry representatives, national regulators, and government authorities. Table 3.8 • Total amount paid so far during the year, and the provides a comparison between current practice in history of payments Egypt, EU recommendations, and the provisions of • The debit/credit balance Egypt’s draft Supply Code, which specifies the exact • Clear information on whether the regular (e.g., items that should be included in each bill. monthly) installments need to be recalculated, and, if so, how to change the amount which is paid regularly in installments 7 If there are is Debt/Credit balance, it is added in the rescheduled amount and the balance on the bill. Chapter 3 | Current Situation and Key Findings | 61 • Meter reading details: history of readings during Customer charters should be designed to provide the year information clearly and simply. The consumer • Bill payment methods and facilities for consumers should be able to quickly understand the content experiencing payment difficulties (e.g., a help line) without prior knowledge of the sector or issues of • In the case of second or warning bill, a description electricity distribution. The composer of the charter of late payment or possible disconnection should develop messages that almost anyone can processes comprehend with confidence. • A clear visual presentation of how the annual consumption compares to previous years Given that distribution companies in Egypt do not • A clear visual presentation of energy use over the yet publish customer charters, EgyptERA would year propose an indicative customer charter, drawing from international experience and existing regulations Electricity bills, given that they reach every consumer, in Egypt, for future adoption by distribution are a particularly effective tool for disseminating companies. Below is such a customer charter. Note information to consumers. However, stakeholders in that certain elements from international experience Egypt’s electricity sector report that the layout of bills don’t necessarily fit the Egyptian reality. For example, and information contained therein are confusing and showing the supplier’s profit from the bill doesn’t unclear. An evaluation of current bills and selective apply in Egypt. However, this could be edited to read inclusion of additional information in Egypt’s electricity how much subsidy has been given to the consumer. bills may contribute substantially to improved On the other hand there are special support schemes information flows in the sector. An indicative bill for the vulnerable that are vary by country (not all format as proposed in EU guidelines is provided in countries have the capacity to address the needs of Annex K. the energy poor). 3.3.8 CUSTOMER CHARTER No country or market is alike, and customization that addresses the particular financial and cultural A customer charter is a document composed structure of each country and subsequent market voluntarily by each company, which sets forth the should be taken into account. Figure 3.14 is an commitments and obligations of each company indicative example of a customer charter for other towards their customers and specifies minimum countries. standards of service. These obligations could simply be the collection of various statutory obligations 3.3.9 INFORMATION FLOWS contained in regulatory documents. It could also BETWEEN EGYPTERA AND include self-imposed pledges that highlight a THE CONSUMING PUBLIC company’s commitment to high standards. This is important for prospective customers as it sets clear As discussed in the Institutional Analysis, part expectations of service prior to any agreement. It also of EgyptERA’s mandate is to “publish such acts as a point of reference for existing customers. information, reports, and recommendations that Customer charters are tools through which assist the Electric Utilities and consumers to be companies raise levels of transparency regarding aware of their rights and responsibilities and of the their obligations, while allowing customers to hold role played by EgyptERA with full transparency.” companies accountable for fulfilling them. Customer This is reflected in EgyptERA’s organization, which charters are always part of the supplier’s web site includes two departments dedicated to liaising with as well as in the supplier’s outlets (in the form of consumers, one named the Awareness and Mass information leaflets). Communication Department, which manages various 62 | Transparency and Social Accountability in the Egyptian Power Sector Figure 3.14 | Indicative Customer Charter 1. Sales Commitments • We are committed to making sure our sales process is professional and transparent • We are committed to compensate any resulting financial loss caused if you were given inaccurate or misleading information about our products and services 2. Outline of available channels to contact the company and of customer services provided Telephone service • Our call centers numbers are ..................... and are open between: ....AM and ....PM Internet service • You'll find clear contact details on our website, at .... • There's also a Frequently Asked Questions (FAQ) area to answer your questions. • We're also launching a customer feedback form – where you can tell us when we're doing something right / wrong, and give us your ideas and recommendations where we could improve things Mail service • You can write to us at .... Other service • Our Team (phone ...) can tell you about assistance for vulnerable customer and any government help available • Our Team (phone ...) can help if you're struggling with your energy bills – through special tariffs and applications for funding and grants (this applies to EU countries with special benefits schemes for the most vulnerable) • If you have hearing or speech difficulties you can contact us on textphone at ... 3. Quality of customer service commitments • We will answer your call as quickly as possible – most calls are answered within 20 seconds. • We always aim to respond to letters or emails within 24 hours • If we need to contact you about your letter, we'll call you within five days of receiving it • Dedicated team guarantees to explore the situation fully, and to provide a written response 4. Billing and pricing commitments • We will give you 30 days' notice of a change in the price you pay • We help you understand how much energy you’ve used, how much you need to pay, when you need to pay. • Your bill will clearly show any changes to our prices • If there is a delay in sending you an energy bill we can extend the time available for your prompt payment discount at your request • If you receive a bill which is significantly higher than normal, we will ask you to contact us to carry out a review of your account • We’ll update any changes to your personal details as soon as you let us know • We’ll resolve the majority of billing queries immediately (although some complex queries may take a little longer to reach a solution) • We will send you an annual energy statement • We will provide a clear breakdown on your bills and your annual statement of how your energy costs are calculated, including how much profit/subsidy we have made from your bill • If we have been at fault by significantly underestimating the amount of energy you use or by not sending your bills, we will accept responsibility for this 5. Metering commitments • We will aim to visit your property every month to read your meters or upon request if demanded by you • We will give you a variety of ways to give us up-to-date readings yourself –leaving the reading at the door of your property, by phone or online • If we have to use estimated readings, we will base our estimate on the amount of energy you have used; in the past; on average usage patterns; and on the time of year • If you provide an actual reading within five days of receiving an estimated bill, we can usually send a revised bill the following month • To keep your bills as accurate as possible, you can submit meter readings either online at … (Continued) Chapter 3 | Current Situation and Key Findings | 63 Figure 3.14 | Continued 6. Outline of payment methods and customer service assistance • We give you three ways to pay for your energy: By Direct Debit, Online or by phone when you receive your bill, ‘Pay as you go’ using one of our pre-payment meters. • We will offer you an Annual Energy Review to check you are on the best payment method for your needs. Call … to get your review now. • We’ll tell you all you need to know about the latest government assistance programmes and grants, and give you information on home improvement programmes and support • We will process valid refund requests within fifteen working days. 7. Complaint-handling commitments • If you are logging a complaint, our adviser will give you their name and extension number so you can contact them again if you need to • If the adviser cannot resolve your query, they will pass you to a manager to find a way forward • You can ask to speak to a manager at any point • If we have still not solved your problem you can contact our Head of Customer Services. Call … or email … • If you’re still unhappy, you can contact the Consumer and Energy Organization service which provides free, confidential and impartial advice on … or visit … • You can contact EgyptERA at … for help if our Head of Customer Services hasn’t resolved your complaint within five working days, or if it has been eight weeks since you first contacted us to make a complaint and we haven’t resolved it 8. Commitments to vulnerable customers • We will take your ability to pay into consideration • We will check if you are eligible for any assistance or government benefits • We will never knowingly disconnect the energy supply of a vulnerable customer, except for essential maintenance, safety or criminal reasons. • We will add you to our Priority Services Register at your request, so that the energy network operators in your area are aware that you may be affected by a disruption to supply. It’s especially important that you tell us if you depend on electricity for essential medical equipment. 9. Outline of other commitments • Environment – we’re committed to help our customers reduce their costs and their carbon footprint • New technology – we invest in new technologies to improve our service to our customers • Community investment – we’re dedicated to investing in the communities around us Source: Authors. communication activities, and the other named the • Information on consumer protection (legislative Consumer Protection Department, which receives framework, definition of vulnerable customers, and resolves consumer complaints in cooperation PSOs, connections and disconnections, with the relevant distribution companies. consumer complaints) • Information on security of supply issues EgyptERA undertakes a number of communications, (consumption, peak load, type, percent share of providing substantial information on Egypt’s electricity fuel mix used) sector to consumers and to the wider public. The most significant of these activities is the publication of the The Annual Report is a comprehensive publication Annual Report which includes the following information: on a wide range of pertinent topics. EgyptERA is currently working to make it more accessible to the • Main developments in the electricity sector wider public. • Detailed data on customer interruptions and customer minutes lost 64 | Transparency and Social Accountability in the Egyptian Power Sector EgyptERA has also been very active in organising the services provided to EgyptERA is provided by GIZ and implementing a number of communications and is conditional upon EgyptERA’s approval. The including: CEO is not empowered to be proactive, which means that it reacts to the requests put forth by EgyptERA. • Public opinion survey on quality of electricity This limits the potential role that the CEO could have. services • Dissemination of informative circulars on Egypt’s EgyptERA collects and responds to customer electricity sector queries and complaints through various channels • Development of guidebook for obtaining (on-line, telephone, formal letter, email, and so forth). investment projects and residential consumers Consumers are entitled to file complaints to EgyptERA power supply in cities and villages when a distribution company has failed to properly • Development of EgyptERA website and social respond their requests. The Consumer Protection media pages with videos and messages on General Department within EgyptERA resolves such energy conservation complaints in cooperation with the relevant distribution companies. Following a customer complaint to EgyptERA in cooperation with the Ministry of EgyptERA, a response is requested from the Electricity and Energy plans to organise a two-day company within five to ten days, and two subsequent public consultation on current challenges in Egypt’s warnings are issued in case of delay. In the event that electricity sector. The participants include electricity the distribution company fails to respond to these sector stakeholders, consumer groups, universities, queries, the CEO of the company is invited to the and representatives of industry and women Board of EgyptERA to explain. However, companies associations as well as the electricity and oil sector usually respond at an earlier stage. Detailed data on representatives. The two events will be streamed live complaints are included in EgyptERA’s Annual Report. over the Internet, and people will have the option to pose questions to the panellists. The main objective The main barrier EgyptERA is facing in communicating of the event is for the public to be heard and for the information to the greater public is its own brand sector be fully transparent concerning the significant and role, which are mostly unknown to the average challenges it faces. consumer. Limited awareness makes it difficult to reach people and to convey messages effectively. For Since 2010, EgyptERA has cooperated with the example, when asked about their sources of information Consumers and Energy Organization (CEO), a on the electricity sector, none of the interviewed national civil society network of 200 NGOs. CEO’s stakeholders reported ever referring to EgyptERA’s mandate is to represent energy consumers, and website, in spite of its clear and comprehensive to raise awareness about consumer rights and presentation of information. To this end, EgyptERA responsibilities. In effect, CEO acts as EgyptERA’s is currently developing a detailed communication partner for public outreach. CEO organizes strategy promoting its role and activities. capacity building events for civil organization groups concerning the rules and regulations that govern the 3.3.10 PUBLIC DISCLOSURE electricity sector in Egypt. It also organizes public CONCERNING STRATEGIC hearings and consultations with energy sector SECTOR PLANS AND PROJECTS stakeholders, and awareness-raising campaigns to inform the public on issues such as energy efficiency The Supreme Energy Council (SEC) is a ministerial and demand-side management. However, although committee guiding and overseeing the energy sector CEO does not rely on license fees (as is the case with in Egypt. The SEC was established by decree of the some EU consumer groups), most of its funding for Prime Minister in 1979 and amended in 2006. The Chapter 3 | Current Situation and Key Findings | 65 SEC’s main charter is to develop energy strategies energy, and issuing certificates for energy labelling of in support of Egypt’s economic, social development, electric appliances. and energy efficiency policies. Strategies cover management of energy resources and patterns of The NREA issues an excellent annual report that energy production and consumption patterns, as covers renewable energy statistics, its national well as providing guidance to energy reform activities, strategy and R&D programs and projects, training and handling market emerging issues. and other activities. It has a well-developed website at www.nrea.gov.eg. The SEC is headed by the Prime Minister and has 12 ministers as members specializing in 3.3.11 ISSUES defence, finance, petroleum, electricity, economic, development, environment, housing, trade and As part of this investigation into the electricity industry, and foreign affairs. The decisions of the SEC sector’s processes, operations, and information are distributed to the relevant ministerial offices. flows—as well as the problems that hamper them–a comprehensive questionnaire was provided to Some of the decisions are issued by Prime Minister all distribution companies, EETC, and generation decrees, which are announced on the press, companies throughout Egypt (Annexes G and H). newspapers and the official paper, ElWakaa, for This was deemed necessary given the complexity example. There is no official public website for SEC of relationships, as well as the potential differences or EEU. in viewpoints and understanding of the situation between different regions in the country (urban The MoEE was established in 1964 to oversee all the versus rural). electricity activities and strategies in Egypt. The MoEE ultimately decides nearly all aspects of the electricity The questionnaires, in conjunction with the sector. Information disclosure usually covers main information collected in interviews with sector sector events such as the opening of a new project, stakeholders, revealed four categories of issues the fiscal year activities and changes on the boards of currently preventing a more effective flow of electric companies and EEHC, and so forth. information in Egypt’s electricity sector: Information disclosed to the wider public is published • Processes on the MoEE website (www.moee.gov.eg), and in the • Transparency/Communication press and newspapers nationwide. • IT or other systems • Operations The MoEE has an active communication department, represented by the spokesman of the Ministry. It also Table 3.9 categorically summarizes the main issues includes a unit that deals with complaints in the same and their effects. way as EgyptERA. 3.3.12 CONCLUSION The NREA was established in 1986. Its main charter was to assess renewable energy potential within Transparency and social accountability in Egypt’s Egypt, execute electricity generation projects from electricity sector relies significantly on effective renewable sources, set specifications and codes, communication and information dissemination and consult and training on national and international between the sector’s main stakeholders, namely issues. The NREA’s activity has since expanded to EgyptERA, electricity companies, and the wider include managing R&D laboratories for renewable public. 66 | Transparency and Social Accountability in the Egyptian Power Sector Table 3.9 | Summary of Main Issues and Effects in Relation to Information Flows and Customer Interfacing in Egypt’s Electricity Sector ISSUE EFFECTS PROCESSES Regulatory documents do not sufficiently • In markets lacking specify the information that should be provided competition, this may lead by distribution companies to their customers to loose interpretation and and to the wider public, or the mediums or ineffective implementation procedures through which this should be done. of specifications Planned power outages for maintenance are • Load shedding is a major communicated via local media or even via issue in Egypt’s electricity door to door contact. However, planned power sector, significantly outages due to load shedding are not always affecting the quality of communicated to consumers service (Planned outages include those due to • Poor service; customers maintenance work, for which customers are are unable to plan their informed in advance, as well those due to load commercial and domestic shedding, for which no prior warning is given to activities consumers apart from “priority” customers in certain cases) Limited representation of consumers or the • Poor flow of information and civil society in the sector feedback from consumers (Consumers or the civil society are not towards electricity represented by the regulated companies’ boards; companies and EgyptERA official communication channels are not used) Limited use of surveys or other channels by • Poor flow of information distribution companies to gauge consumer and feedback from satisfaction and feedback consumers towards (Customer satisfaction seems not to be an issue electricity companies and for them and is not currently surveyed) EgyptERA TRANSPERENCY/ Communication policy of distribution • Consumers receive only COMMUNICATION companies is underdeveloped generic information through (DC’s have no departments dedicated to limited channels (mainly marketing and communications. Their public service outlets) relations departments deal mostly with • Communication barriers administrative and logistical issues concerning related to cultural traits and receptions, board meetings, workshops, etc.) geographic isolation are not addressed Consumers and the wider public are not aware • EgyptERA’s mandate and of EgyptERA’s role in the electricity sector pivotal role in raising (EgyptERA is not a recognizable institution; consumers’ awareness of their consumers do not know of the regulator’s rights and responsibilities is existence and mandate) not fully realized Customer Charters are not a common practice • Consumers are poorly in the sector informed of their rights and (DC’s do not publicize any customer charters of distribution companies’ outlining their consumer obligations and obligations, both before minimum standards of service) agreeing to contracts with distribution companies and during the provision of the service • Limited transparency and accountability may lead to poor service (Continued) Chapter 3 | Current Situation and Key Findings | 67 Table 3.9 | Continued ISSUE EFFECTS Information currently provided on the • Poor flow of information electricity bill is limited and feedback between (As compared to EU guidelines, there are consumers and electricity several information items not currently included companies in the electricity bill) IT SYSTEMS CRM systems are unavailable in distribution • Tracking of complaints is companies for logging and tracking complaints significantly burdensome (Only DC Cairo South is currently using a CRM and prone to errors system for logging and tracking complaints. All • Information flows are other DC’s have no computerized systems) slowed • The lack of a unified system by distribution companies also creates uneven service between consumers served by different distribution companies OPERATIONS Personnel of distribution companies’ liaison • Information quality and offices with EgyptERA do not always meet accuracy may suffer their role specifications • Delays may be caused in (DC liaison offices with EgyptERA are not gathering required data and always staffed by personnel with suitable responding to EgyptERA’s training and qualifications) queries Understaffing and overloading of meter • As meter readers often act readers as the only contact point of (Limited number of meter readers with consumers with distribution significant overload and occasionally poor companies, this may lead to qualifications) poor information flow Source: Authors. Sector Companies financial, technical and commercial aspects of their Regulated electricity companies are obliged by performance. These obligations are common to their licenses to provide to EgyptERA and EEHC a all regulated licensed companies but there are a variety of financial, operational and technical data small number of requirements pertaining only to and periodical reports on their past and projected distribution companies. The most important of these performance, to ensure that all stakeholders are is the requirement to submit an annual statement adequately informed about sector performance and on the quality of customer service, which should developments. include among others, information on voltage quality categorized by consumer class and the number of Licensed regulated companies in Egypt inform EEHC outages (either forced or planned) during the previous about their financial performance through quarterly five years. In the event that a regulated company and annual reports, the latter of which are audited does not comply with the requirements, EgyptERA and validated by certified comptrollers. EEHC and has a number of sanctions at its disposal. EgyptERA are informed about the operational costs of electricity companies via annual cost-of-service In practice, however, compliance with the above studies submitted by each licensee. This information requirements is subject to certain barriers, most is also exhibited in annual reports detailing the significantly the fact that neither EEHC nor regulated licensed activities of each company, including companies have sufficient capacity or the organization 68 | Transparency and Social Accountability in the Egyptian Power Sector to provide the timely, accurate and comprehensive coordination with EgyptERA). When fully developed information required by EgyptERA. Although and implemented, this system will log, integrate and regulated companies have dedicated “coordination analyse complaints and inquiries from all distribution departments” to liaise with EgyptERA, they are often companies. In addition, no management information staffed by personnel who lack suitable training and system (MIS) is available to EgyptERA or licensed qualifications. Likewise, although three departments regulated companies to unify data and monitor of EEHC are at the moment dedicated to cooperating benchmarks among different companies. EEHC with EgyptERA, they are hardly able to carry out their and EgyptERA rely on each subsidiary to send the mandate. This issue is further exacerbated by the information via FAX or email, to be manually analyzed fact that the abilities of the companies to collect and and aggregated. Nevertheless, it is important that disseminate information are not being verified at any EEHC has made steps towards mitigating this issue. stage of the licensing process. Due to their limited It has developed a blueprint of an MIS system for resources, regulated electricity companies and EEHC aggregating data and monitoring benchmarks among are often unable to meet their reporting obligations, different companies which unfortunately has not yet hampering EgyptERA’s ability to fully oversee its been implemented due to financing constraints. regulations. To address this issue, EgyptERA has A  well-functioning MIS system will be also required made it a regular practice to invite staff of coordination by EgyptERA for logging and monitoring the results departments to all capacity building events in the of the annual consumer awareness survey mentioned organization, while it has also organized a number of above, aiming to track public perception trends internal capacity building sessions. on issues concerning quality, cost and evolution of services provided in the electricity sector. Distribution Companies (Licensed by EgyptERA) Distribution companies are obliged to provide Distribution companies face an important task in information to their customers and to the wider communicating with their consumers, especially public either as part of their statutory obligations, those in rural and remote parts of the country who or upon the customers’ request. These obligations remain largely uninformed of the companies’ roles are specified in their distribution code and licenses and functions. This disconnect creates uncertainty, and EEHC’s commercial regulations, and address which further hampers the companies’ attempts to a wide range of issues. The distribution companies’ engage the public on important challenges facing most important requirements are to inform the the sector such as power shortages due to lack of wider public and tax payers on their activities and investments, fuel shortages, and subsidies. financial performance, as well as availing them of all application forms, procedures, and terms and Electricity bills can be a particularly effective tool for conditions for establishing a new connection and a distribution companies to disseminate information to supply agreement. The companies are also obliged consumers, given that they reach every consumer. to inform their customers on how they can file a Various stakeholders (including consumer groups), query or complaint, as well as how their complaint report difficulties in understanding electricity bills, will be handled and eventually resolved. finding their layout and information confusing and unclear. Though they all provide identical information, Complaints and all related information (subject of electricity bills issued by each distribution company complaint, procedures of its investigation, decision in Egypt do not adhere to a uniform format. The main taken, and its date) are being tracked by distribution items are meter readings and consumption during companies as specified in the Distribution Code. the billing period (in kWh), total cost (EGP), the The majority of these companies, however, do amount owed (EGP), and date due. Most distribution not have computerised systems (except for Cairo companies also promote the importance of energy South where a CRM system has been developed in conservation and the use of compact fluorescent Chapter 3 | Current Situation and Key Findings | 69 lamps (CFLs) through messages at the back of the EgyptERA’s regulatory mandate is further hindered by bill. An assessment of Egypt’s electricity bills and its limited visibility. Consumers and the wider public addition of clarifying information may substantially are not aware of its existence and role. EgyptERA, improve the sector’s information flows. however, has made significant efforts to address this issue, most recently by organizing in cooperation Meter readers are another important medium of with the Ministry of Electricity and Energy, energy- communication between distribution companies sector stakeholders, and civil society organizations–a and consumers. They are responsible for monitoring two-day public consultation on current challenges in and logging electricity meters and for collecting Egypt’s electricity sector. The event will be streamed payments. Meter readers often act as the single live over the Internet and the audience will be able pose point of contact between consumers and their questions to the panellists. The purpose of the event is distribution company, and can play a significant for the public to be heard, and for the sector to be fully role in disseminating information and collecting transparent concerning the challenges it is facing. customer feedback, queries and complaints. However, distribution companies report that meter It should also be noted that since 2010 EgyptERA has readers are already overloaded with work and unable been in a cooperation agreement with the Consumers to take on extra responsibilities such as providing and Energy Organization (CEO), a civil society network customer information or feedback. Time constraints with nationwide outreach. (As of December 2012, the notwithstanding, they lack the training to undertake network included 40 NGOs, with a target to expand its such responsibilities. membership to 5000 NGOs by the end of 2013). The mandate of CEO is to represent energy consumers, Finally, planned power outages (due to load and to raise awareness about consumer rights and shedding) are not being properly communicated to responsibilities. CEO acts as EgyptERA’s partner for consumers (with the exception of a few companies reaching out to the public and organizing capacity- that inform priority customers such as hospitals and building events for civil organization groups to learn the industries). Adding to the confusion, these planned regulations governing the electricity sector in Egypt. outages (for which no warning is given to consumers) It also organizes public hearings with energy-sector are not being measured separately from those due to stakeholders and awareness-raising campaigns to maintenance work (for which customers are informed inform the public on issues such as energy efficiency in advance). and demand-side management. In contrast to some EU consumer representation groups, CEO does EgyptERA not rely on license fees. It has limited capacity to be The most significant publication of EgyptERA, by which pro-active, however, due to the fact that most of its it communicates with the wider public, is the Annual funding for services to EgyptERA is provided by the Report, which provides extensive information on a German Society for International Cooperation (GIZ) wide range of pertinent topics for Egypt’s electricity and is conditional upon EgyptERA’s approval. sector. Although a “Consumer Protection” element is included in the 2010–11 Annual Report, EgyptERA— Finally, EgyptERA has been developing a number in contrast to many European regulators—does not of communications to improve their visibility and to currently provide any annual reports dedicated to raise consumer awareness about pertinent issues consumer service of regulated distribution companies. in the electricity sector. These include a public Such information will be especially important to opinion survey on the quality of electricity services, provide once the market becomes liberalized, whereby informative circulars on Egypt’s electricity sector, and consumers will need to evaluate for themselves the EgyptERA’s website and social media pages with services offered by each supplier. videos and messages on energy conservation. 70 | Transparency and Social Accountability in the Egyptian Power Sector 3.4 Consumer Surveys An analysis was done on the following perspectives: The suggested solution for the above challenges focused on reforming tariffs and subsidies, and • The challenges facing the electricity sector. encouraging private investment in the sector. These • The role of EgyptERA and its challenges in reforms could be addressed as follows: assessing the performance of the electricity service from the consumer’s perspective. Business Clients: trials to take big customers to free • EgyptERA’s method for testing consumer market practices, by fully releasing the subsidy. awareness with regards to the role of the organization as regulator of the electricity sector. Household Clients: tariff reform, especially the huge • Consumers’ awareness of the electricity subsidies middle tranche. and the extent of their equity. • Comments from the first survey commissioned in Wholesale Public Trader System: studying the 2010 (designed and conducted by the Information introduction of such a system, coupled with a safety and Decision Support Center (IDSC)), identifying net targeting the poorest of the poor. strengths and weaknesses from the survey and gaps to be addressed. Increasing Private Investment in the Sector: by liberalizing the market and relying on a competitive The main challenges facing the sector: market environment—especially with the potential rise in demand and expected profits—the entire • Damaged financial structures of the licensed sector’s performance and customer satisfaction companies, and the related cash problem they will be enhanced. In addition to improving the are suffering, hindering their ability to invest performance of the existing distribution companies, in the company’s performance or to spread it is imperative that the government work towards awareness. creating an attractive investment environment for the • The lack of investment in the companies also private sector. has led to inefficiency and waste that burden the consumer. • Client segmentation and monitoring tools: • The need for increased client awareness to household clients (40 percent) divided into three enhance energy efficiency and to make them tranches, with the middle tranche representing aware of the amount of subsidy currently the largest bulk. provided. • Business, services, and government clients • Cost of production is also higher than international (60 percent), with the 100 large clients representing averages, and is expected to rise further due to: 20 percent of consumption. 1) declining credit worthiness of the government • Client satisfaction monitoring tools should differ in (used to give sovereign guarantee for currently both content and channels between the two main used soft loans); 2) higher interest rates (in case segments. financing needs give rise to seeking commercial • The survey can serve to enhance awareness loans as opposed to currently used soft loans); tool, as well as monitor client satisfaction. The 3) higher wages (according to social justice survey could easily include questions on energy demands of the revolution); and 4) expected rise conservation. It can also be used to assess or in subsidized input prices of natural gas and oil predict client reactions to certain policies—such (due to removal of the subsidy). as price hikes—before announcing them. Chapter 3 | Current Situation and Key Findings | 71 Awareness: Data Collection: Face-to-face interviews are recommended, as opposed to data collection through • The main challenge assessed by EgyptERA is the phone, as the former will allow respondents a financing the awareness campaigns. better understanding of the various questions, while • Reference was also made to the white paper also including those segments of the population not assessing effectiveness of communication reached through telephone calls. channels. • Simple, low-cost awareness tools were Workshop suggested, such as TV interviews of EgyptERA senior staff explaining to the general public how The objective of this workshop was to present the much electricity is subsidized, and how they can amendments introduced to the survey form, and practice more efficient energy consumption. discuss the suggested methods for implementing it, and using it as a tool for making policy decisions. Survey: Usage: the survey can be used as a tool to assess • Form and content: needs to include some fixed the level of awareness among the target population questions for monitoring and benchmarking from (relying on the sample results), in order to design year to year, as well as certain questions reflecting responsive awareness campaigns. However, the on the new/conditions in the market. Content survey tool cannot be used as an awareness raising should also match the characteristics of each mechanism, as it only reaches a sample of the client segment (household/business). population. • Methods: sampling needs to reflect all of Egypt (urban, rural, upper, lower), and either a specialist Awareness: the backside of the bill might be used as in sample design or CAPMAS should design the an awareness raising platform, as well as for sending sample. Data also needs to be collected via face- positive messages and incentives to save energy. to-face interviews, rather than phone calls. Thus, redesigning the electricity bill, which reaches • An independent survey is recommended for the largest customer base, is highly recommended. the 100 large business clients, and could be administered by hosting a one-day event to Implementation: EgyptERA’s communication team capture their feedback and test their knowledge does not have the capacity (human or financial) to of the energy sector. carry out this task. Thus the implementation will • The need was also discussed for a comprehensive need to be outsourced. EgyptERA asked for help plan to annually administer the survey and in assessing the budget, drafting the scope of benchmark feedback. work for outsourcing this task, and recommending • The issue of checking the relevance of the World a list of public and private organizations capable of Bank Consumer Card system, to the Egyptian undertaking the survey. case, was also discussed. Methodology: the sampling needs to be carried out Design of the Survey by a sampling expert to reflect the entire society (urban and rural). The proper sample size would Sampling Methodology: the need for a sampling range between 1500 and 2500 households. It is expert to draw a random, nationally representative recommended that the form be filled out in full, via sample (based on CAPMAS latest population face-to -face interviews (which should not take more census), of the entire Egyptian population. than twenty minutes each). The survey should be conducted annually or biannually. 72 | Transparency and Social Accountability in the Egyptian Power Sector The main elements of any survey are as follows: 2. The survey needs a new sample designed by a sampling expert and drawn from the Population • Setting the objective and main policy issues to be Census 2006 (CAPMAS). addressed 3. The survey needs to be conducted through face- • Defining the target group to-face interviews. • Phrasing the questions 4. Several indicators could be derived from • Developing the methodology the questions and the data available. These • Deciding on the sampling approach indicators will be useful for implementing the • Determining the data collection means (i.e., surveys, as they will answer several relevant questionnaire or interview guide) questions on the quality of electricity service, • Implementation consumer satisfaction and their use of electricity • Analysis of the results saving techniques, and the general quality of • Recommendations and suggested policy actions the service. Below are several examples of such indicators: To develop an index for comparing subsequent surveys, the sample should be divided into segments • Index of household wealth (which could be according to wealth level, and then the correlation linked to electricity usage, public awareness between this index and awareness level (for example) with Egypt Era, public acceptance of the can be compared between various rounds of the electricity bill as a value of service, etc.); survey. • Index of total household expenditures (which could be linked to electricity usage, public 3.4.1 FINDINGS awareness with EgyptERA, public acceptance of the electricity bill as a value of service, etc); 1. EgyptERA conducted a consumer’s awareness • Trend of public acceptance of electricity bill; survey in 2010. • Trends of electricity cuts over time; 2. The survey was telephone-based and thus could • Trends of efficiency in solving electricity not reach the different segments of the society. problems; and 3. Discussions took place on the objectives of • Trends in using electricity saving techniques. EgyptERA, from conducting the survey, its degree of regularity, and its sample frame and 3.4.2 RECOMMENDATIONS RELATED implementation possibilities. TO THE METHODOLOGY OF 4. The questionnaire form needed re-drafting to IMPLEMENTING THE SURVEY include new questions and variables, and to exclude irrelevant questions or issues. The primary objective of the Egypt-ERA survey 5. The sample frame has to be changed to is to provide estimates on the national scale and accommodate EgyptERA requirements. four major administrative regions: Metropolitan areas, Lower Egypt, Upper Egypt and Borders Steps Taken governorates. Two governorates could randomly be selected to represent each of these regions. The 1. Through lengthy discussions, the questionnaire randomly selected primary sampling units (PSUs) form was twice amended and restructured should include shiakha/towns in urban areas and before reaching the final version. A copy of the villages in rural areas. updated new survey is attached. (Annexes G and H). A stratified random sample of 1500 to 2500 households will be selected. The strata could include Chapter 3 | Current Situation and Key Findings | 73 representation of the regions as well as the areas’ 4.4.4 CONCLUSION household incomes. Distribution companies face a major hurdle preventing Several procedures have to be undertaken for the them from effectively communicating with consumers accurate completion of the survey: The training and the wider public, stemming from their failure to of data collectors; the pilot study to fine tune the conduct customer satisfaction surveys or to gauge survey; the conduction of the survey; entry, cleaning, customer feedback. As it stands, consumers can validation, and tabulation of the data; and final report file complaints mainly through dedicated call centres preparation. and service outlets; some are offered the option to file complaints through their respective distribution Regular surveys will enable EgyptERA to monitor and companies’ websites. Nevertheless, EgyptERA evaluate trends, and thus help in recommending the is attempting to address this issue by preparing appropriate policies. templates for distribution companies to undertake customer satisfaction questionnaires regarding their 3.4.3 ASSESSMENT OF THE WORLD handling of complaints and the quality of information BANK CRC AND ITS RELEVANCE they provide. A consumer-awareness survey was TO THE EGYPTIAN CASE also conducted by EgyptERA in 2010, though being derived solely on telephone interviews was able to In discussions of the assessment techniques of reach only part of the population. To bolster these public awareness and satisfaction, the Citizen Report efforts, the Bank assisted EgyptERA to develop more Cards (CRCs) widely used by the World Bank were direct data-collection techniques, as well as more mentioned. detailed questionnaire forms, which will enable them to more thoroughly measure the public’s perception The EDG Consultant reviewed the CRC and on the quality, cost and evolution of the services suggested that there is a substantial difference they provide. Finally, EgyptERA is monitoring closely between a nationally representative survey and a CRC. the complaints addressed directly to it regarding While the former provides an overall assessment of service by distribution companies and preparing and electricity service quality and cost, and response to publicizing annual reports. various consumer problems, the CRC could serve as a means of assessing service of certain distribution companies on the local level, either over time, or in comparison to other public services such as water, sewage, and garbage collection. If the objective of assessing the performance of distribution companies is a target in itself, each assessment technique complements the other. 74 | Transparency and Social Accountability in the Egyptian Power Sector 4 CHAPTER FOUR: Recommendations Our recommendations, which include comments the need to reform, (2) addressing underlying and actions already taken by EgyptERA, as well as weaknesses, and, (3) introducing a new culture and comments by the delegates, fall under three main capacity towards achieving the targeted goals. actions, as follows main actions: Note that culture is a key parameter influencing 1. Incorporating the consumer into the goals and people’s willingness to change. The implementation operational culture of the electricity sector. of almost all of the recommendations and changes 2. Adding staff and enhancing information assumes acceptance and a sense of ownership by technologies to achieve reform objectives. the main players. This acceptance should come 3. Improving communications to enhance from the top management, along with proper transparency and advance trust between the training, education, effective process, and practice. sector and the consuming public. EgyptERA has shown the willingness to drive change, having already started to tackle a number of these There is a logical sequence between those three recommendations. categories, namely: (1) accepting and endorsing 4.1 Incorporating the Consumer Engagement into the Sector’s Goals and Operational Culture The following set of recommendations touches all 1. Revise Goals of EEHC subsidiaries to aspects and necessary interventions for the electricity incorporate more responsibilities towards sector to become more consumer oriented. These customers recommendations range from instituting changes in formal documentation (articles of association, Transparency and social accountability in Egypt’s performance reports, annual reports, and so on), electricity sector is limited due to its underdeveloped to adopting benchmarking metrics that measure communication policy towards consumers and the consumer satisfaction, to better representing wider public in general. The customer focus is in fact consumers in the electricity sector’s decisions. absent from the articles of association and licensing agreements of EEHC subsidiaries. Such an omission could be corrected by simply adding an article to the companies’ goals and objectives, as per the following example: “The goals and objectives of the Company are to operate with a customer-focused Chapter 4 | Recommendations | 75 approach, strengthen corporate governance, the licensing obligations of electricity pursue stable and sustainable development, and companies to undertake regular consumer provide high-quality services.” satisfaction surveys and devise action plans based on feedback 2. Oblige EEHC to oversee periodical reports of its subsidiary companies on the satisfaction Distribution companies do not conduct customer of their customers satisfaction surveys nor undertake any organized efforts to gauge customer feedback, creating a Overseeing customer satisfaction of subsidiary major obstacle for achieving effective communication companies is not at the moment embedded in the with consumers and the wider public. It is thus responsibilities of the EEHC. Such responsibilities recommended that EgyptERA includes in the licensing could be added to those of the EEHC’s board of terms of the electricity distribution companies the director’s. Implementing this recommendation would stipulation that the distribution company is obliged first require EEHC to coordinate with EgyptERA to to undertake regular customer surveys and to devise set indices that reflect the performance of subsidiary action plans based on the feedback.” companies toward satisfying their customers–indices currently lacking for such companies in Egypt. By enhancing the flow of information and feedback, these steps would improve the responsiveness of 3. Request companies to make explicit electricity companies to consumer needs and improve reference in their articles of association their social accountability, enabling consumers to to obligations arising from their licenses, hold electricity companies accountable against while assigning EEHC the responsibility to measurable targets. verify the companies’ compliance to these obligations To implement recommendation, EgyptERA will first need to secure sufficient funds for periodically The authority of EgyptERA to oversee and regulate executing the survey, as well as for developing the electricity sector is hindered by the authority the software systems necessary for logging and of the EEHC, which maintains significant control over monitoring survey results. EgyptERA will also need to the operations of licensed companies. With lines of provide training to data collectors and launch a pilot responsibility thus blurred, public companies remain program to fine-tune the survey. unaccountable for their operations by EgyptERA or the public at large. To correct this flaw it is 5. Include in the licenses of each distribution recommend that EEHC secures the time and human company an explicit obligation to draw up resources to review and amend relevant parts of the and publicize a customer charter electricity companies’ and its subsidiaries’ articles of association. Electricity companies should explicitly A customer charter is a tool used internationally— add to the written purpose of the companies: “The though not yet a standard practice in Egypt—through Company operates in accordance with the license which supply companies elevate trust between issued by EgyptERA, and the company board is supplier and consumer. Such charters increase responsible for assuring that its license requirements transparency regarding the supplier’s obligations, are fulfilled.” and allow customers to hold companies accountable. Following a request by EgyptERA, and based on 4. Urge EgyptERA to adopt more advanced international experience and existing regulations in data collection techniques for their Egypt, an indicative customer charter was drawn Consumer Awareness Survey, and revise up. The licenses of distribution companies should 76 | Transparency and Social Accountability in the Egyptian Power Sector include an obligation specifying the channels through committees represent the public for each regional which the customer’s charter will be provided, such distribution company. However, every country, as web sites and service outlets. EgyptERA already market and culture is different, and no one size supports distribution companies in such an initiative fits all. Hence, for Egypt it was recommended by providing to them a draft consumer charter and that EgyptERA, in association with the distribution holding meetings with consumer representatives to companies, establishes a pilot representation collect feedback. model in the form of regional electricity consumers’ committees (ECCs), to be housed under EgyptERA, 6. Edit the new supply code to include effective in one or two areas mirroring the boundaries of information exchange between distribution the distribution companies. In advance of the companies and consumers pilot, EgyptERA should: a) set criteria for selecting consumer representatives by reviewing international The draft supply code, when implemented, could experience and practice; b) specify internal significantly upgrade the quality of information mechanics of ECCs and high-level communications flowing between distribution companies and with distribution companies; c)  secure adequate consumers. The supply code could contain a clear- financing (perhaps via license fees); and d) ensure cut framework for specifying in detail the content of access of information to all parties to raises public the information and the procedures through which awareness of ECCs. The pilot should be reviewed the distribution companies should provide it to and adjusted after at least two years of operation consumers. To achieve this, it was recommended to inform a nation-wide roll-out plan. If the pilot is that EgyptERA and each distribution company set deemed successful, it can be extended over the up working teams to discuss the details of the draft longer term by adjusting the companies’ licensing supply code and agree on the provisions for such obligations. information exchange, followed by a roundtable meeting with sector stakeholders to convey the 8. EgyptERA should develop a Code of importance of implementing it. It is especially Conduct that will define more clearly their encouraging that EgyptERA’s board of directors is responsibilities, and highlight commitment already in the process of the ratifying their supply to transparency and social accountability code. As specified in Presidential Decree 329, EgyptERA’s 7. Represent consumers and civil society mandate is consistent in many aspects with other in the companies’ boards and in regional nation utilities, assuming a number of responsibilities committees of electricity consumers including “publishing such information, reports, and recommendations that assist the Electric Utilities Consumer and other civil society organizations are and consumers to be aware of their rights and relatively few in Egypt, and not particularly powerful in responsibilities and of the role played by EgyptERA shaping public policy, or active in providing feedback with full transparency.” However, the mandate to distribution companies. Consumers are thus does not adequately articulate the EgyptERA’s unrepresented in the companies’ decisions (except obligations toward consumer rights or commitments in EEHC’s board of directors, where a large-industry to transparency and social accountability. It was consumer representative is participating. thus recommended that EgyptERA’s mandate be supplemented by a Code of Conduct which will clearly Many other countries have addressed this issue state such obligations and commitments. EgyptERA by developing public engagement models. has already drafted such a Code of Conduct, and For example, in the UK, electricity consumers’ intends to ratify it soon. Chapter 4 | Recommendations | 77 4.2 Sector Reform via Organizational, Staffing, and IT Enhancements The following set of recommendations focuses on These departments are thus limited in their ability improving the sector’s service to consumers via to carry out their mandate. It is recommended to information technology, systems, processes, and create a single department in EEHC with the proper organizational structures. capacity to liaise with EgyptERA. To implement these recommendations, the following actions were 1. Distribution companies should set-up suggested: departments dedicated to communications, staffed with qualified personnel to develop • Conduct a study diagnosing the responsibilities of appropriate communication policies the department and the required skills of the staff • Add specific skills to job descriptions and Distribution companies, despite serving as the responsibilities sector’s direct interface with consumers and the • Draft new processes and procedures concerning wider public, lack staff dedicated to marketing or the department’s functioning and cooperation communications. Distribution companies would with EgyptERA thus be well served by adding such staff, focused • Design a program to build capacity and to train on improving the quality of customer information EEHC staff and tailoring it to specific consumer categories. To address these needs, EgyptERA intends to hold a 3. EgyptERA, EEHC and electricity companies roundtable discussion with distribution companies should undertake periodic internal audits and consumer groups. It is recommended that of electricity companies to validate EgyptERA further this goal by introducing a section performance benchmarking data in its annual report comparing companies in terms of their public information and their customer- International best practice shows that the quality of service performance. To better assess companies’ performance monitoring and benchmarking largely performances, EgyptERA could also propose certain depends on the accuracy of the underlying data. minimum standards against which the companies Such accuracy is commonly validated by external would be evaluated, and sharing these comparisons auditors and comptrollers. At the moment, neither with consumers through websites, reports, leaflets EgyptERA nor EEHC commission external audits and other forms of media. The distribution companies of Egypt’s electricity companies. Rather they verify should also ensure proper staffing of their marketing the companies’ data via historical trend analysis, or and communications departments by providing request clarifications from the companies themselves, appropriate training and tools for the tasks. which unfortunately lack the qualifications for undertaking such audits. 2. Create a single, appropriately staffed EEHC liaison department Implementing this recommendation first requires that all parties agree on a particular set of indicators, EEHC is neither properly organized nor staffed and a common method for measuring them. They to provide EgyptERA with timely, accurate and also need to ensure sufficient staff, with appropriate comprehensive information and data. Three training and background, dedicated to auditing these dedicated “coordination” departments in EEHC specific sets of data. As an alternative, EgyptERA is have been set up to liaise with EgyptERA, staffed by considering the services of external auditors as part personnel lacking suitable training or qualifications. of their annual renewal of licenses. 78 | Transparency and Social Accountability in the Egyptian Power Sector 4. EEHC and EgyptERA should combine Before implementing this recommendation, EEHC efforts to produce a unified annual company and EgyptERA must secure funding to implement the performance report and to set a system for MIS blueprint already developed by EEHC. incentives and penalties 6. Increase distribution companies’ investment EgyptERA monitors and benchmarks the in handheld Automatic Meter Reading (AMR) performance of generation companies in groups, devices and smart meters or “units,” according to their type and size, while the performance of distribution companies are Meter readers are an important medium of organized as “departments” which are in turn communication between distribution companies grouped according to function. The performance and consumers. They are responsible for monitoring of electricity companies is also being monitored and logging electricity meters and for collecting by the EEHC, which collects monthly data and payments. However, distribution companies report analyzes benchmarking data at the company level. that meter readers are already overloaded with work Such inconsistencies in the metrics used to monitor and unable to take on extra responsibilities such as performance of companies complicate comparisons providing customer service or feedback. In response, and obstructs transparency. To implement this certain distribution companies have already taken recommendation, working groups from each party steps to invest in handheld Automatic Meter need to map their respective reporting differences, Reading (AMR) devices that not only read meters, design their unified performance report, along with but also produce meter-reading statistics and log a roadmap for implementing new report guidelines. customer complaints. Such devices could allow Performance could be measured at different levels, meter readers the time to gather customer feedback, ranging from systems to individual customers (for thus becoming front-line customer service agents example, the number of unplanned interruptions, that facilitate transparency between consumers or the response time per complaint). There could and the electricity companies. To implement this be a financial reward or penalty for performance, recommendation, distribution companies would first based on a percentage of the company’s revenue need to secure funding. or profit, similarly to the framework already in place in the UK. 7. Distribution companies to disclose reporting 5. Consider implementing a unified MIS for Distribution companies are hindered in complying monitoring benchmarks among different with their reporting requirements to EgyptERA, in that companies neither they nor the EEHC have sufficient capacity, resources, or organization to provide timely, accurate An MIS system would significantly simplify the and comprehensive information. The companies’ task of EgyptERA and EEHC to accurately log technical and financial capacity to collect, aggregate and monitor company benchmarks. EEHC and and disseminate information is not being verified at EgyptERA currently rely on each subsidiary to send any stage of the licensing process. Lacking such the information via FAX or email, to be manually information, EgyptERA is unable to properly oversee analyzed and aggregated. An efficient MIS system and regulate the companies. In order to begin will be also required by EgyptERA for logging and closing this information gap, EgyptERA could hold monitoring the results of the annual “consumer meetings with distribution companies to highlight awareness survey,” with its aim to closely track and the importance of the Supply Code in general, and extract public perception trends on quality, cost and to stress specifications for accurately reporting and evolution of services provided in the electricity sector. validating data. Chapter 4 | Recommendations | 79 8. Distribution companies should produce training and qualifications. Recognizing that distribution detailed job descriptions and required skill companies may have limited capacity to restructure sets for the personnel that staff the liaison their liaison offices, EgyptERA can help by cooperating offices with their personnel managers to prepare detailed mandates for change. For example, EgyptERA has Although distribution companies now have dedicated already commenced drafting organization charts, job “coordination departments” to liaise with EgyptERA, descriptions and minimum qualification requirements they are often staffed by personnel who lack suitable for the personnel that staff the liaison offices. 4.3 Improving Information Flow to Enhance Transparency and Advance Trust Between the Sector and the Public 1. Update EgyptERA’s mandate to reflect the progress in this direction. It has published a “Cost new Electricity Law and upcoming reforms of Service” report on its website, plans to publish a in the electricity market comprehensive report on electricity subsidies within the first quarter of 2014, and intends to hold a series The overall mandate of EgyptERA confers them limited of public hearings concerning a planned tariff reform. authority to advise or pass opinion on tariff structures to the respective ministries. Regulators in other 2. Consider implementing a unified CRM countries have mandates for setting, monitoring, and system for logging and tracking complaints regulating prices, and for approving tariffs. To ensure a more balanced protection of regulated companies Most distribution companies do not have and consumer interests, EgyptERA’s authority should computerized systems (except for Cairo South) be strengthened, especially in the unbundling and developed in coordination with EgyptERA to track reform of the electricity sector. complaints. It is recommended that developing a customer relation management system, which, when For any proposed amendment to EgyptERA’s fully implemented by all Distribution Companies, will mandate to be effective, it will have to be centralize complaints and enquiries. A pre-requisite accompanied by wider structural changes in Egypt’s to the implementation of this recommendation is electricity sector as a whole, including financial that Distribution Companies and EgyptERA secure unbundling of companies, defining a clear structure required funding. for sector governance, and developing strategic plans for sector and tariff reform. These institutional 3. Revise benchmarking reports produced changes will need time to be agreed upon, designed, by EgyptERA and EEHC to be more reader and implemented, requiring close cooperation of all friendly, and publish them on company stakeholders including EgyptERA, EEHC, EETC and websites and service outlets distribution companies. It is also recommended that these mandates are communicated by EgyptERA Despite the thorough benchmarking analyses carried to the public via a comprehensive communication out and reported by EgyptERA and EEHC (focusing strategy aiming to raise awareness about the mostly on technical, financial and operational regulator’s role and activities. Despite its limited indicators), their contributions to transparency and authority, EgyptERA has already made significant social accountability are somewhat thwarted by their 80 | Transparency and Social Accountability in the Egyptian Power Sector lack of public availability. To correct this shortcoming, is currently developing and testing a new process it is recommended that EEHC allocates sufficient time to be employed by all distribution companies in the and human resources to re-design and publish these future, by which Short Message Service (SMS) will reports, and that EgyptERA cooperates with electricity inform customers of planned power cuts due to companies to complete their design of report templates load shedding a day in advance. To implement this that are “accessible” to the wider public. EgyptERA scheme, mobile phone companies will have to give has already communicated to electricity companies their consent for such a service, and agree to provide the need to activate and update their websites, and EgyptERA their customers’ contact details. has started developing a benchmarking system to assess the functionality and content of each website. 6. EgyptERA should implement a communication strategy to raise awareness about its role and 4. EgyptERA and EEHC should establish a activities new benchmark separating planned power outages due to maintenance, from power EgyptERA’s mandate can be facilitated by raising their outages due to load shedding visibility among their consumers and the wider public. Awareness of EgyptERA’s existence and regulatory Load shedding is a major issue in Egypt’s electricity role is low, thus hindering efforts to inform and educate sector. It affects significantly the quality of service, yet the public on important challenges facing the sector, is not being explicitly monitored as it is aggregated such as shortages due to lack of investments, fuel, together with planned outages due to maintenance and subsidies. Implementing this recommendation work, for which consumers are informed in advance. A would require either that EgyptERA increase staff and number of distribution companies have recently started training focused on communications, or that the task to utilize a software system that helps manage load is outsourced to specialized companies. EgyptERA shedding and aims to distribute the power cuts based intends to take immediate actions to intensify its use of on priority and merit. Full roll-out of the software will new communication tools such as its new website, and allow EgyptERA to maintain a database of all power social media (Facebook, Twitter, YouTube channel) and cuts, and thereby build a clear picture of the number to expand the distribution of its newsletter (EgyptERA and frequency of power cuts experienced by each type Magazine). Mass media (TV, radio, newspapers, and of consumer. The software will also serve as a valuable so on) is also critical, for reaching the majority of tool for monitoring and reporting performance on consumers that do not have access to the Internet. benchmarks in relation to planned power outages due to load shedding. A pre-requisite to the implementation 7. Distribution companies should adopt EU of this recommendation is that distribution companies recommendations in reformatting their and EgyptERA secure the required funding. electricity bills 5. Distribution companies should inform Electricity bills can be a particularly effective tool for consumers of planned power outages due distribution companies to disseminate information to load shedding to every consumer. Various stakeholders in Egypt report difficulties in understanding their electricity The consuming public is concerned over their electric bills, citing their lack of information and confusing companies’ failure to warn them of planned power layouts. An assessment of current bills and inclusion outages due to load shedding. A few Distribution of additional information may substantially improve Companies do, however, inform priority customers communications while fostering greater transparency such as hospitals and industries. To address these and social accountability of the sector. EgyptERA concerns, EgyptERA—along with Cairo South DC— is designing a provisional template for a new bill Chapter 4 | Recommendations | 81 Table 4.1 | Recommendations for Improving Transparency and Social Accountability in the Egyptian Power Sector Recommendation Time of Orientation Financing Capacity Primary implementation (strategic requirement building responsibility (short/long) vs action) (Yes/No) requirement (Yes/No) Incorporating the Consumer Engagement into the Sector’s Goals and Operational Culture 1. Revise Goals of EEHC subsidiaries to incorporate more Short Action No No EEHC responsibilities towards customers 2. Oblige EEHC to oversee periodical reports of its subsidiary Short Strategic No Yes EEHC companies on the satisfaction of their customers 3. Request companies to make explicit reference in their Short Action No No EEHC articles of association to obligations arising from their licenses, while assigning EEHC the responsibility to verify the companies’ compliance to these obligations 4. Urge EgyptERA to adopt more advanced data collection Short Strategic Yes Yes EgyptERA techniques for their Consumer Awareness Survey, and revise the licensing obligations of electricity companies to undertake regular consumer satisfaction surveys and devise action plans based on feedback 5. Include in the licenses of each distribution company an Short Action No No EgyptERA explicit obligation to draw up and publicize a customer charter 6. Edit the new supply code to include effective information Short Strategic No No EgyptERA exchange between distribution companies and consumers 7. Represent consumers and civil society in the companies’ Long Strategic Yes No EgyptERA boards and in regional committees of electricity consumers 8. EgyptERA should develop a Code of Conduct that will Short Action No No EgyptERA define more clearly their responsibilities, and highlight commitment to transparency and social accountability Sector Reform Via Organizational, Staffing, and IT Enhancements 1. Distribution companies should set-up departments Long Strategic Yes Yes Electricity dedicated to communications, staffed with qualified companies personnel to develop appropriate communication policies 2. Create a single, appropriately staffed EEHC liaison Long Strategic No Yes EEHC department 3. EgyptERA, EEHC and electricity companies should Short Strategic Yes Yes EgyptERA & undertake periodic internal audits of electricity companies EEHC to validate performance benchmarking data 4. EEHC and EgyptERA should combine efforts to produce a Short Strategic No No EgyptERA & unified annual company performance report and to set a EEHC system for incentives and penalties 5. Consider implementing a unified MIS for monitoring Long Action Yes Yes EEHC benchmarks among different companies 6. Increase distribution companies’ investment in handheld Long Action Yes No Electricity Automatic Meter Reading (AMR) devices and smart companies meters 7. Distribution companies to disclose reporting Long Strategic No No EgyptERA 8. Distribution companies should produce detailed job Short Action No No EgyptERA descriptions and required skill sets for the personnel that staff the liaison offices Improving Information Flow to Enhance Transparency and Advance Trust Between the Sector and the Public 1. Update EgyptERA’s mandate to reflect the new Electricity Long Strategic No Yes EgyptERA Law and upcoming reforms in the electricity market 2. Consider implementing a unified CRM system for logging Long Action Yes Yes Electricity and tracking complaints companies (Continued) 82 | Transparency and Social Accountability in the Egyptian Power Sector Table 4.1 | Continued Recommendation Time of Orientation Financing Capacity Primary implementation (strategic requirement building responsibility (short/long) vs action) (Yes/No) requirement (Yes/No) 3. Revise benchmarking reports produced by EgyptERA and Short Action No No EgyptERA EEHC to be more reader friendly, and publish them on company websites and service outlets 4. EgyptERA and EEHC should establish a new benchmark Short Action Yes No EgyptERA separating planned power outages due to maintenance, from power outages due to load shedding 5. Distribution companies should inform consumers of Short Action No No Electricity planned power outages due to load shedding companies 6. EgyptERA should implement a communication strategy to Short Action No No EgyptERA raise awareness about its role and activities 7. Distribution companies should adopt EU recommendations Long Action Yes No Electricity in reformatting their electricity bills companies 8. EgyptERA should provide annual reports tailored to Long Strategic Yes Yes EgyptERA consumer service Source: Authors. format, in cooperation with distribution companies sector. In contrast to many European regulators, and consumer representatives. To this end, the Bank EgyptERA does not publish annual reports dedicated assisted EgyptERA in providing best practices on the to its distribution companies’ handling of complaints, format and content of EC countries’ electricity bills. and other consumer services. To implement this The eventual revision and adoption of electricity bills recommendation, electricity companies need to by the distribution companies will require investments devote more time and resources to collecting and in existing software and printing infrastructure. providing EgyptERA with detailed and accurate data on consumer service. As a first step, EgyptERA should 8. EgyptERA should provide annual reports introduce a section in its Annual Report devoted to tailored to consumer service “Transparency and Monitoring,” documenting the information that electricity companies disclose to the The most significant publication of EgyptERA aimed public via their reports and other media. Full roll-out of at communicating with the general public, is the the CRM system under development will significantly Annual Report, which provides extensive information facilitate this recommendation. on a wide range of topics relevant to Egypt’s electricity 4.4 Categorization of Recommendations Table 4.1 shows a grouping of the recommendations higher level and demand a prequel set of action discussed in Section 4.3 according to: in order to be implemented and achieved. On the other hand “action” type recommendations • the sector stakeholder that has the primary are implemented via a single or small number of responsibility for its implementation (EgyptERA, actions EEHC or electricity companies) • financing needs or not to for implementing the • estimated time required for the recommendation recommendation implementation (short/long) • capacity building needs that are required as • orientation of the recommendation (strategic complimentary measure for the implementation vs action), where a strategic recommendation is of the recommendation Chapter 4 | Recommendations | 83 Annexes Annex A | Governance Arrangements of Egypt’s Power Sector Law 164 and Law 195, and the Articles of Association of association include a paragraph under the of EEHC, and the Electricity Companies provide purpose of the company; that the company the following governance structures for the Power is compelled with the rules of the Presidential Sector: Decree No. 339, Year 2000, concerning the establishment of EgyptERA and all other issued • The Holding Company has a General Assembly resolutions.” headed by the Minister of Electricity and appointed by the Prime Minister; a delegate of the General The distribution companies are in charge of both the Association of Egypt Labor Unions is among the wire and supply services. According to its articles of selected members. association, the purpose of the company is: • The Holding Company has a board of directors appointed by the General Assembly, it includes • To sell and distribute the electric power to the vice chairmen and representatives of the customers supplied on medium and low voltage Ministries of Electricity and Power, Finance, which is purchased from Egypt Electricity Planning, Petroleum and the Central Bank. Transmission Company (EETC) and directly from Among the members should also be a number of the Generating Companies. In addition to the experts not more than three and a representative surplus electric power purchased from industrial of the General Association of the labor unions constitution and others and approved by the in Egypt. EEHC Board of Directors. • The board of the Holding Company is the General • To manage, operate and maintain the networks Assembly of all its affiliated companies and of medium and low voltages according to the appoints the board of the Affiliated Companies, instructions of the control centers for the purpose which represents mainly EEHC and could include of economic operation. two experts. • To prepare forecasting studies for loads and • A labor union is represented in Affiliated Company power of the customers of the company and board. forecasting of the financial and economic plans of • Holding companies and affiliated companies the company. prepare budgets and financial statements using • To make studies, research, designs and the Egyptian Accounting Standards. implementing projects of distributing electricity • The accounts of holding companies and affiliated for different usages on low and medium voltage companies are audited by the Central Audit and carrying out all other tasks related or Agency as the independent auditor. The articles supplementing it. 84 | Transparency and Social Accountability in the Egyptian Power Sector • To manage, operate and maintain the generating plants owned by the Company, which are not connected to the unified national grid. • To do any other activities or works connected or related to the goals of the company, in addition to works assigned by EEHC. • To implement works related to the main activity of the Company and are required by outsiders for the purpose of achieving economic revenue. The main responsibilities of the Board are: • To ratify the organizational chart of the company. • To set the internal organizing regulations, except for those of the Personnel and Purchasing regulations, this must be approved by the Board of Directors of EEHC and issued by a resolution of the Head of the General Assembly. • To approve the proposed budget, the balance sheet and the final accounts of the company. • To propose the ratification of loans’ agreements, financing and mortgage deeds. The exceptional General Assembly approves the decisions of the Board concerning these matters. • To propose the establishment or participation in the establishment of companies that have a related activity, or to share in the capital of such companies whether they are inside or outside the country. The exceptional General Assembly approves the decision. • To set a system for control and for performance monitoring and evaluation in accordance with the technical, financial and economic measures. • To oversee the periodical reports, connected with the operation and the financial position of the company. • To accept gifts, donations and awards provided to the company but without apposing its goals. Annexes | 85 Annex B | Outline of Greece’s RAE Report on Customer Queries and Complaints REPORT OF ENERGY REGULATORY AUTHORITY ON CUSTOMER QUERIES AND COMPLAINTS 2011 1. Introduction and contents of the report _____________________________________________________________________________________ 2. Categorization of queries – compliance with European Commission Recommendation – Description of procedure by which queries are monitored and recorded by the Energy Regulatory Authority – Brief outline of recommendations by the European Commission and the ERGEG on the categorization of queries 3. Summary data of written queries and consumer complaints Presentation of statistics and information on recent queries and consumer complaints 3.1.1. General statistics of queries submitted to the Authority in 2011 – Description of data and changes compared to previous year, explanation of data and trends observed 3.1.2. Recipients of queries – Overview of distribution of queries between different organizations (for example, Energy Regulatory Authority, Consumer Ombudsman) – Identity of query/complaint senders 3.1.3. Market segment – Distribution of queries between different sectors (for example, electricity, gas, etc.) 3.1.4. Companies related references queries – Distribution of queries between different companies 86 | Transparency and Social Accountability in the Egyptian Power Sector 3.1.5. Subject matter of queries 3.1.5.a. Sub-categories of queries, 2008–2011 – Categorization of queries in 3 groups: pre-contract, network issues, supply issues 3.1.5.b. Requests for information 2011 – Number of requests for information 3.1.5.c. Complaints 2011 – Number of complaints and outline of content per category: 1. Tariffs and prices (…%) Overview of complaint content 2. Quality of service (…%), Overview of complaint content 3. Billing (…%) Overview of complaint content 4. Network connection (…%). Overview of complaint content 3.1.5.d. Network issues 2011 – Overview of network complaints, requests for information and queries: quantification per subject/category and outline of content 3.1.5.e. Supply issues 2011 – Overview of network complaints, requests for information and queries: quantification per subject/category and outline of content 4. Regulatory actions of RAE for informing and protecting consumers – Overview of regulatory actions (including directions and sanctions) undertaken during the year by the Energy Regulatory Authority Annexes | 87 Annex C1 | Department Level Benchmarks for Distribution Companies Monitored by EgyptERA INDICATOR CALCULATION FORMULA Reliability Indicators System Average Interruption (total no. of electric power supply interruptions/total no. of Frequency Index (SAIFI) customers of different categories) × 1000 System Average Interruption Duration (total duration of interruptions (min.)/total no. of customers Index (SAIDI) of different categories) × 1000 Customer Average Interruption total duration of interruptions (min.)/total no. of electric Duration Index (CAIDI) power supply Interruptions Availability Indicators Average Service Availability Index (8760 × 60 − total time of interruptions (min.))/(8760 × 60) (ASAI) Network Characteristics Indicators LV Underground Cables length of lv underground cables/(length of lv underground cables + length of lv overhead lines) MV Underground Cables length of mv underground cables/(length of mv underground cables + length of mv overhead lines) Operational Indicators Network Utilization Factor [(total quantity of sold electric energy (gwh) × 1000)/(peak load of electric distribution network (mw) × 8760)] × 100 Distribution Equipment Utilization [(total quantity of sold electric energy (gwh) × 1000)/(total Factor capacity of electrical distribution transformer (mva) × 8760)] × 100 Efficiency Indicators Percentage of Technical and [(total quantity of available electric energy (gwh) − total Non-Technical Losses8 quantity of sold electric energy (gwh))/total quantity of available electric energy (gwh)] × 100 Commercial Indicators No. of Complaints9 no. of complaints/total no. of customers of different categories No. of Employees no. of employees/total no. of customers of different categories no. of employees/total quantity of sold energy (gwh) 8 Commercial losses are calculated on the difference between block transformer meter reading and the aggregate of the block’s residential meter readings minus any technical losses. Given this methodology there is a timing constraint (as there is a time lag between different meter readings) but adjustments are made to the data to take that into account. 9 EgyptERA receives a report on the number of complaints by distribution companies, quarterly, and compiles an internal yearly analysis on complaints. This analysis however is not fully published as the accuracy of the data provided is not as yet fully validated. 88 | Transparency and Social Accountability in the Egyptian Power Sector Annex C2 | Unit Level Benchmarks for Generation Companies Monitored by EgyptERA INDICATOR CALCULATION FORMULA Reliability Indicators Starting Reliability (actual unit starts(1)/attempted unit starts(2)) × 100 Availability Factor (available hours(3)/period hours(6)) × 100 Forced outage Rate [forced outage hours(9)/(forced outage hours(9) + service hours(5))] × 100 Scheduled Outage Factor (scheduled outage hours(10)/period hours(6)) × 100 Forced outage Factor (forced outage hours(9)/period hours(6)) × 100 Efficiency Indicators Self-Consumption [(generated electricity − sent electricity)/generated electricity] × 100 Fuel Consumption Rate fuel quantity/generated electricity Operational Indicators Average Run Time service hours(5)/actual unit starts(1) Gross Capacity Factor [gross actual generation(15)/(period hours(6) × gross maximum capacity(14))] × 100 Gross Output Factor [gross actual generation(15)/(service hours(5) × gross maximum capacity(14))] × 100 Service Factor (service hours(5)/period hours(6)) × 100 Load Factor [total mvw generated in the period/(period hours × maximum load)] × 100 Utilization Factor (maximum load/gross capacity factor) × 100 1 Number of times the unit was synchronized. 2 Number of attempts to synchronize the unit after being shut down. Repeated failures to start for the same cause, without attempting corrective action, are considered a single attempt. 3 Sum of all service hours, reserve shutdown hours or period hours – (planned outage hours + forced outage hours + maintenance outages hours). 4 Total number of hours the unit was available for service but not electrically connected to the transmission system for economic reasons. 5 Total number of hours a unit was electrically connected to the transmission system. 6 Sum of all service hours, reserve shutdown hours, planned outage hours, maintenance outages hours and forced outage hours. 7 Sum of all hours experienced during maintenance outages and maintenance outage extensions. 8 The removal of a unit from service to perform work on specific components that can be deferred beyond the end of the next weekend, but requires the unit be removed from service before the next planned outage. Typically, maintenance outages may occur any time during the year, have flexible start dates, and may or may not have predetermined durations. 9 Sum of all hours experienced during forced outages. 10 Sum of all hours experienced during planned outages and planned outage extensions. 11 The removal of a unit from service to perform work on specific components that is scheduled well in advance and has a predetermined start date and duration (for example, annual overhaul, inspections, testing). 12 Sum of all hours experienced during maintenance outages and maintenance outage extensions. 13 The removal of a unit from service to perform work on specific components that can be deferred beyond the end of the next weekend, but requires the unit be removed from service before the next planned outage. Typically, maintenance outages may occur any time during the year, have flexible start dates, and may or may not have predetermined durations. 14 Maximum capacity a unit can sustain over a specified period of time when not restricted by seasonal or other ratings. 15 Actual number of electrical mega-watt-hours generated by the unit during the period being considered. Annexes | 89 Annex C3 | Transmission System Operator Benchmarks Monitored by EgyptERA INDICATOR CALCULATION FORMULA Reliability Indicators Transformer Average Interruption Frequency Index (T-AIFI) T-AIFI at X kv Level Σ no. of forced outages for transformers at X kv level in a zone/Σ no. of in a zone transformers at X kv level in a zone T-AIFI for a zone Σ no. of forced outages for transformers at all voltage level in a zone/Σ no. of transformers at all voltage levels in a zone T-AIFI for a company Σ no. of forced outages for transformers at all voltage levels in all zone/Σ no. of transformers at all voltage levels in all zones Transformer Average Interruption Duration Index (T-AIDI) T-AIDI at X kv Level Σ duration of forced outages for transformers at X kv level in a zone/Σ no. of in a zone transformers at X kV level in a zone T-AIDI for a zone Σ duration of forced outages for transformers at all voltage level in a zone/Σ no. of transformers at all voltage levels in a zone T-AIDI for a company Σ duration of forced outages for transformers at all voltage levels in all zones/Σ no. of transformers at all voltage levels in all zones Transformer Availability (T-A) T-A at X kv Level in a (Σ service hours for transformers at X kv level in a zone/Σ Period hours zone × no. of transformers at X kv level in a zone) × 100 T-A for a zone (Σ service hours for transformers at all voltage level in a zone/Σ Period hours × no. of transformers at all voltage levels in a zone) × 100 T-A for a company (Σ service hours for transformers at all voltage levels in all zones/Σ Period hours × no. of transformers at all voltage levels in all zones) × 100 Transformer Forced Unavailability (T-FU) T-FU at X kv Level in (Σ forced outages hours for all transformers at X kv level in a zone/Σ Period a zone hours × no. of transformers at X kv level in a zone) × 100 T-FU for a zone (Σ forced outages hours for all transformers at all voltage level in a zone/ Σ Period hours × no. of transformers at all voltage levels in a zone) × 100 T-FU for a company (Σ forced outages hours for all transformers at all voltage levels in all zones/ Σ Period hours × no. of transformers at all voltage levels in all zones) × 100 Transformer Scheduled Unavailability (T-SU) T-SU at X kv Level in (Σ scheduled outages hours for all transformers at X kv level in a zone/ a zone Σ Period hours × Number of transformers at X kv level in a zone) × 100 T-SU for a zone (Σ scheduled outages hours for all transformers at all voltage level in a zone/ Σ Period hours × no. of transformers at all voltage levels in a zone) × 100 T-SU for a company (Σ scheduled outages hours for all transformers at all voltage levels in all zones/Σ Period hours × no. of transformers at all voltage levels in all zones) × 100 90 | Transparency and Social Accountability in the Egyptian Power Sector Annex C4 | Financial Performance Benchmarks Monitored by EgyptERA at Company Level INDICATOR CALCULATION FORMULA Liquidity Indicators Quick Ratio (#) net profit/accounts receivable Current Ratio (#) current assets/current liabilities Leverage Indicators Debt to Total Assets (%) total liabilities/total assets Profitability Indicators Return on Equity (%) net profit/total owner’s equity Return on Assets (%) net profit/total assets Gross Profit Margin (%) (net sales – cost of goods sold)/net sales Net Profit Margin (%) net profit/net sales Activity Indicators Average Collection Period (day) 365 × accounts receivable/net sales Annex D1 | Technical Indicators at Company Level in EEHC’s Quarterly Benchmarking Report Generation • Generated electricity (MkWh) • Installed capacity (MW) • Amount of fuel consumed per type of fuel, e.g., NG, HFO, LFO • Self-consumption per source, e.g., auxiliaries, attached buildings, etc. (%) • Load factor (%) • Capacity factor (%) • Availability factor (%) • Usage factor (%) • Average fuel consumption rate (gm/kWh) • Average fuel cost (PT/kWh) Transmission • Network components (substations and length of cables and lines per voltage level) • Forced outages (no. per 100 KM of cable and line and 100 MVA of transformers for HV and VHV) • Maintenance outages (no. per 100KM of cable and line and 100 MVA of transformers) • Forced outages (% for cable and line and transformers for HV and VHV) • Scheduled outages (% for cable and line and transformers for HV and VHV) • Losses (%) • Loading (distribution of transformers’ loading, for HV and VHV) Distribution • Energy purchased and energy sold (MkWh) • Losses (%) • Network components (length of cables and lines for LV and MV; MVA of distribution panels; no. of transformers and kiosks) • Outages per 100 units per DC component (no. per 100 km of cables and lines for LV and MV; no. per 100 distribution panels; no. per 100 transformers) • Disconnected energy due to outages (MkWh) • Disconnected energy per consumed energy (%) • Average disconnected time (min.) Annexes | 91 Annex D2 | Commercial Indicators at Company Level in EEHC’s Quarterly Benchmarking Report ENERGY ENERGY NO. OF ENERGY COLLECTIONS COLLECTIONS COLLECTION SALES SALES PER CUSTOMERS PURCHASED AND ARREARS AND ARREARS RATE Amount TARIFF BAND Amount (MkWh); Arrears YoY; PER SECTOR % (MkWh); Value Amount Value (000 LE); Arrears in Arrears YoY; (000 LE); (MkWh); Av. Price (PT/ months; Arrears in Av. Price (PT/ Value (000 kWh) Collections per months; kWh) LE); category Collections per Av. Price (PT/ category kWh) Generation • • Companies Transmission • • • • Company10 Distribution • • • • • • Companies 92 | Transparency and Social Accountability in the Egyptian Power Sector 10 Indicators are produced per voltage level of customer/distribution company connection and for each voltage level, per type of customer/distribution company (e.g. energy intensive industrial, non-energy intensive industrial, metro, other customers). Annex D3 | Financial Indicators at Company Level in EEHC’s Quarterly Benchmarking Report P AND L EXPENSES INVESTMENTS AVERAGE AVERAGE WAREHOUSE CASH FLOW DEBT NO. OF NO. OF FIGURES PER ITEM (000 LE) AND UNIT COST UNIT COST STOCKS (000 FIGURES OBLIGATIONS STAFF PER EMPLOYEES (000 LE) (000 LE) SOURCES OF AND PRICE PER ITEM LE) AND accounts DISCIPLINE PER UNIT revenue; for example, FINANCE (%) (PT/KWH) (PT/KWH) INVENTORY payable/ for example, for example, expenses; fuel; spare MONTHS receivable; rate engineering, MW; MVA; profit/ parts and of collections accounting/ customer loss; maintenance; to payments finance, etc. other salaries income; Generation • • • • • • • • • • Companies Transmission • • • • • • • • • • Company3 Distribution • • • • • •11 • • Companies 11 Annexes | 93 Does not include inventory months. Figure E1 | Procedure for Providing an Incentive Mechanism 1 Clarify Objective 2 Map the Strategy 3 Map Delivery Chain 4 Design 7 5 Reveiw Measure 6 Apply 8 Implement Annex E | Procedure for Providing an Incentive Mechanism Providing the incentive for big (or even smaller) organization to change is a huge task involving carefully structured steps. Starting from defining a clear objective to be achieved, setting the strategy to achieve it, analyzing the necessary resources and barriers (legal and regulatory, organizational, financial, technological, and so forth), to overcome toward a clear implementation roadmap and subsequent monitoring. 1. Objective: the first step is to clarify what the objective is and make sure it is measurable. For example it could be “to increase collection rates from residential consumer by 3 percent in the next 3 years.” 2. Strategy: it is important to identify the combination of activities and outputs that should help to achieve it. It should be based on evidence/measurable indicators, or at least consensus, on what drives the outcome. It can then be used to identify the actors and/or other stakeholders that will deliver those outputs in the form of a delivery map. In our example this could be a simple sequence of: a) designing of new payment packages where consumers could pay with installments; b)  investment in potential technology to aid the payment options (web, mobile, pre-paid meters, and so forth); c) detailed identification of the main actors involved in the collection (or lack off) which can be operational (for example, inadequately trained meter readers). 94 | Transparency and Social Accountability in the Egyptian Power Sector 3. Delivery Map: the Delivery Map displays how an organization can take an objective and its strategy, and map the relationships between the stakeholders that are involved. It should then detail which are the performance levers and how they are used to influence those stakeholders, and any sanctions or rewards that are attached to them. Coming back to the example, it was identified that the main actor involved are the IT and technical departments of the DC that need to install invest in the necessary technology for the new payment methods as well as the meter readers that will inform the consumer of the options given. The main barriers are (inadequate technological infrastructure, lack of investment capital, lack of training for the meter readers, etc.), the performance levers (new legislation or regulation, investment needs, training program dates, etc.), and their associated sanction or reward mechanisms (financial bonus to departments and individuals that achieve their targets). An indicative mapping layout of stakeholders involved in the process along with the key tabs addressing metrics/performance levers as well as proposed sanctions/rewards and recommendations is shown below. Performance Stakeholder/Actor Proposed Sanctions/Rewards Issues Recommendations Lever Name Level Financial Operational Reputational South Cairo Department Team Individual 4. Designing sanction and reward mechanisms: when designing a penalties/rewards mechanism, the first step is to define the dimensions that are available (financial, reputational, organizational). This may mean a reduced budget for the DC, financial penalties on the company’s higher management, explicit publication of poor performance to the consuming public, or organizational penalties by changing the management. Of course it needs to assess which players have control or significant influence, so as not to penalize individuals or departments that are not part of the loop. When rewards are financial, a balance between the value created and the reward must be ensured. In our example if the target for a 3-percent increase is achieved over three years then the reward should be distributed in a fair way throughout the chain of the involved actors, from higher management down to individual trained meter readers. Finally the assessment of attainment of the objective can only be made by independent parties not by the company (DC) themselves. 5. Measure performance: performance can be measured on the basis of the specific indicators/metrics set during the strategy formation. Data systems and software might be needed to track those metrics. In our example a regular (monthly) progress on collections throughout the implementation of the “changes” programme will be necessary. 6. Apply the sanction or reward: it is important to apply whatever sanction or reward in a timely, consistent and transparent manner, so as to ensure credibility and gain the trust of everybody involved. Bad application is enough to destroy trust and put the whole process and effort into jeopardy. Annexes | 95 7. Review effectiveness: it is important to build regular internal and external reviews of the effectiveness of the sanction or reward mechanism into the programme’s overall performance management cycle. This could be in the form of meetings and appropriate reporting. In our example, the working group from the side of EEHC will liaise closely with the working group of the DC, monitor and report in regular intervals to EEHC’s higher. 8. Implementation: during implementation, it is recommended to phase in the new sanction or reward mechanism gradually, or on a pilot basis, to identify and address any dysfunctional behavior or any strong reservations from the side of the implementing party. Annex F | Point System of an Incentive Mechanism Quality and performance incentive schemes link the only penalty for breaching the standard. In case performance levels of the company to its earnings. (2)  makes the revenue of the regulated company The regulator has to first decide the parameters, on fully depended on performance in a linear fashion, which it wishes to determine the current as well as with both reward in case of better than the standard the optimal level of quality. The performance level can performance and penalty if otherwise. Finally, in case be measured at different levels ranging from system (3) there is a maximum fixed limit for penalty or a level to the performance delivered to the individual reward in addition to case (2). customers (for example, number of unplanned interrupts due to distribution network failure or time Figure F1 | Penalty/Reward Schemes top response per complaint). Based on company performance against this optimal level, there is 1 2 a reward or a penalty. The penalties or rewards financial impact can be given as a percentage from Penalty 3 the company’s allowed/regulated revenue or profit. The exact level of a penalty or reward is a matter of analyzing a multiple of factors and impacts that this could have on the regulated company. It is very much linked to the detailed analysis required as presented in Annex F, where the designing and implementation steps of a reward/penalty scheme are outlined. Reward Figure F1 presents three formats a financial penalty/ Period Under Examination reward scheme could take as is the case in many countries where the distribution networks are regulated. In the case (1) the regulator issues a fixed penalty when a minimum standard is breached. In this case there is no incentive for improvement but 96 | Transparency and Social Accountability in the Egyptian Power Sector Annex G | Questionnaire (English) BASIC DATA OF THE RESPONDENTS: QUESTIONS ABOUT FAMILY AND LIVING CONDITIONS 1. Gender 5. Number of family members • Female • Male • ––––––––––––– 2. Age 6. Number of employed family members • ––––––––––––– • ––––––––––––– 3. Level of education 7. Place of residence • Illiterate • An apartment • Less than primary education • Room(s) • Primary - Preparatory • Urban house • Secondary or equivalent • Rural house • Intermediate education (high institute) • Other, please state: ––––––––––––– • University • Post graduate 8. Durable goods owned by the family 4. Employment status • Stove (natural gas/gas pipes) • Stove (electric) • unemployed • Manual washing machine • Employed • Automatic washing machine • Water heater (gas) ○ Government • Water heater (electric) ○ Public sector • VCR/DVD Player ○ Private sector/Business owner • Computer ○ Retired • Deep Freezer ○ Looking for a job • Air conditioner ○ Unemployed and not looking for a job • Dish washer ○ Student • Electric heater ○ Housewife • Iron ○ Sick/unable to work • Motorcycle ○ Other • Bicycle ○ No answer • Car • Telephone 9. What is the average monthly expenditure of the family? • ––––––––––––– Annexes | 97 CONSUMER AWARENESS OF THE 16. What was the average rate of your electricity bill ROLE OF THE ELECTRIC FACILITY in the past three months? REGULATION AND CONTROL AUTHORITY • ––––––––––––– • No answer 10. Do you know that there is/Have you heard of an authority for electric facility regulation and 17. What is your average electricity consumption consumer protection? during the summer? • Yes • ––––––––––––– • No (explain the idea and go to question 14)* • No answer (explain the idea and go to 18. What is your average electricity consumption question 14)* during the winter? 11. How did you hear about the authority? (More • ––––––––––––– than one choice allowed) 19. Do you think that the amount of money you • Television/Radio/Newspaper pay is suitable for your family’s electricity • Electricity company consumption? • Acquaintances/friends/family • Other, please state: ––––––––––––– • Yes • No 12. Do you know that the there is a website for the • To some extent electricity companies and services? • No answer • Yes 20. If you want to decrease your electricity • No consumption, do you know what the best method would be? 13. Have you ever used the website? • Yes • Yes • No • No (I don’t have a computer) 21. Out of the following methods, which do you QUESTIONS THAT ASSESS THE do choose/follow in order to decrease your QUALITY OF ELECTRICITY SERVICES electricity consumption? (read out the choices, more than one choice allowed) 14. Have you ever issued a complaint? • Using saving lamps/florescent instead of • Yes normal lamps • No ○ Does Plan to do 15. What was your average consumption (per kilowatt) in the past three months? • Using natural gas water heaters/instant instead of an electric heater • ––––––––––––– • No answer ○ Does Plan to do 98 | Transparency and Social Accountability in the Egyptian Power Sector • Using natural gas ovens instead of an electric 25. Have you suffered from electricity cuts in the past oven three months? (Don’t read out the choices, only one choice allowed) ○ Does Plan to do • Yes • Not using electronic devices when it is not • No (go to question 28) necessary • No answer (go to question 28) ○ Does Plan to do 26. How many times have you suffered from electricity cuts in the past three months? (Don’t • Not keeping the lights on when it is not read out the choices, only one choice allowed) necessary • Once ○ Does Plan to do • Twice • Three times • Other, please state: • Four times • Five times ○ Does Plan to do • Six times or more • No answer • No answer 27. How long was the duration of the electricity cuts 22. Do you know your electricity meter’s amperage/ in the past three months? (Don’t read out the number of phases? choices, only one choice allowed) • Yes • Less than 15 minutes • No • Between 15 and 30 minutes • Between 30 and 60 minutes 23. Have you received and kept your electricity • Between an hour and two hours service contract? • Between 2 and 5 hours • More than five hours • Yes • No answer • No 28. Have you experienced a sudden weakening/ 24. Do you agree that your contract with the strengthening in the electricity current in the electricity authority states clearly your rights and past three months, i.e. It’s wasn’t stable? (if the duties? answer is yes, ask again if this happened only once or happens constantly) (Read out the • Yes choices). • No • I haven’t read the contract • Yes, constantly • No answer • Yes, sometimes • No, it doesn’t happen Note: if the answer is no, ask again if they mean that • No answer it doesn’t state the rights and duties or they haven’t read it. Annexes | 99 29. Does this change in current have a negative 34. Does the bill collector come regularly (every impact? month)? • Yes • Yes • No • No • No answer 30. What impacts you most? 35. Is the collector’s attitude acceptable for you? • The need for electronic devices • Water cut • Yes • Elevator problems • No • Other, please state: ––––––––––––– • No answer 31. Does the person who reads the electricity meter 36. Do you accept paying the bill through banks, post come regularly (monthly)? (don’t read out the offices, internet like the telephone bill or through choices, one choice only allowed) a prepaid means like the telephone card? • Every month • Yes • Every two months • No • Every three months • No answer • The meter is outside • No answer 37. Did you face a problem regarding electricity in the past year and reported it? 32. Does the person who reads the meter come in  times that are convenient for you or your • Yes family? • No • No answer • Yes (go to question: 34) • No 38. What was the problem? (Don’t read out the choices, more than one choice allowed) 33. What is the convenient time for you and your family for reading the electricity meter? (don’t • Regular cuts read out the choices, more than one choice • Long duration of cuts allowed) • Instability of the current (sudden weakening/ strengthening) • From 9:00 am to 11:00 am • Unstable bill value • From 11:00 am to 1:00 pm • Very high bill (consistently high) • From 1:00 pm to 3:00 pm • Other, please state: ––––––––––––– • From 3:00 pm to 5:00 pm • From 5:00 pm to 7:00 pm 39. Who did you report the problem to? (Don’t read • From 7:00 pm to 9:00 pm out the choices, more than one choice allowed) • After 9:00 pm • Other, please state: ––––––––––––– • The electricity company • No answer • The regulatory authority for the electric facility and consumer protection 100 | Transparency and Social Accountability in the Egyptian Power Sector • Malfunctions emergency number/unknown ELECTRICITY AND SUBSIDIZING source/number written on the back of the receipt 43. Do you know that the electricity bill is subsidized? • Other, please state: ––––––––––––– • Yes 40. How did you report your complaint? • No • Telephone 44. Do you prefer to have the subsidized fraction • Went to the place stated on the bill? • Fax • Normal mail • Yes • Website or email • No • Other, please state: ––––––––––––– • No answer 45. Do you know that the electricity bill is built on consumption brackets—the higher the 41. Was the problem fixed? consumption, the higher the price? • Yes • Yes • No • No • No answer (go to question 43) 46. Do you agree that the pricing brackets based on 42. How long did it take to fix it? (don’t read out the the level of consumption achieve social justice? choices, more than one choice allowed) • Yes • Same day of complaint • No • Two days • Three days * An authority that regulates and monitors everything that has to do with the electricity’s production, transportation and • Four days distribution and works on customer satisfaction. • Five days • Six days • One week • Other, please state: ––––––––––––– • No answer Annexes | 101 ‫)‪Annex H | Questionnaire (Arabic‬‬ ‫ﺍﺳﺘﻤﺎﺭﺓ ﺍﺳﺘﻄﻼﻉ ﺭﺃﻯ ﺍﻟﻤﻮﺍﻃﻨﻴﻦ‬ ‫ﺣﻮﻝ‬ ‫ﺧﺪﻣﺎﺕ ﺍﻟﻜﻬﺮﺑﺎء ﻭﺗﻘﻴﻴﻤﻬﻢ ﻟﺠﻮﺩﺓ ﺗﻠﻚ ﺍﻟﺨﺪﻣﺎﺕ‬ ‫ﺍﻟﺒﻴﺎﻧﺎﺕ ﺍﻟﻔﺮﺩﻳﺔ ﺳﺮﻳﺔ ﺑﺤﻜﻢ ﺍﻟﻘﺎﻧﻮﻥ ﻭﺗﺴﺘﺨﺪﻡ ﻷﻏﺮﺍﺽ ﺍﻟﺒﺤﺚ ﺍﻟﻌﻠﻤﻲ ﻓﻘﻂ‬ ‫ﺻﺒﺎﺡ ﺍﻟﺨﻴﺮ‪/‬ﻣﺴﺎء ﺍﻟﺨﻴﺮ ﺃﻧﺎ ‪ ..............‬ﺃﻋﻤﻞ ﻓﻰ ﻣﺮﻛﺰ ﺍﺳﺘﻄﻼﻉ ﺍﻟﺮﺃﻯ ﺍﻟﻌﺎﻡ‪،‬‬ ‫‪.‬ﺩﻗﺎﺋﻖ ‪ 5‬ﺃﺣﻨﺎ ﺑﻨﻌﻤﻞ ﺩﺭﺍﺳﺔ ﻋﻦ ﺭﺃﻯ ﺍﻟﻨﺎﺱ ﻭﺗﻘﻴﻴﻤﻬﻢ ﻟﺨﺪﻣﺎﺕ ﺍﻟﻜﻬﺮﺑﺎء‪ ،‬ﻣﻤﻜﻦ ﻧﺄﺧﺬ ﻣﻦ ﻭﻗﺖ ﺣﻀﺮﺗﻚ‬ ‫ﺃﻭﻻً‪ :‬ﺍﻟﺒﻴﺎﻧﺎﺕ ﺍﻷﺳﺎﺳﻴﺔ ﻟﻠﻤﺒﺤﻮﺙ‬ ‫ﺍﻟﻨﻮﻉ‪:‬‬ ‫‪.1‬‬ ‫)‪ (2‬ﺃﻧﺜﻰ‬ ‫)‪ (1‬ﺫﻛﺮ‬ ‫ﺍﻟﺴﻦ‪:‬‬ ‫‪.2‬‬ ‫ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﺘﻌﻠﻴﻤﻰ‪:‬‬ ‫‪.3‬‬ ‫)‪(1‬‬ ‫ﻻ ﻳﻘﺮﺃ ﻭﻻ ﻳﻜﺘﺐ‬ ‫)‪(2‬‬ ‫ﺃﻗﻞ ﻣﻦ ﺍﺑﺘﺪﺍﺋﻰ‬ ‫)‪(3‬‬ ‫ﺍﺑﺘﺪﺍﺋﻰ ‪ -‬ﺇﻋﺪﺍﺩﻯ‬ ‫)‪(4‬‬ ‫ﺛﺎﻧﻮﻯ ﻭﻣﺎ ﻳﻌﺎﺩﻟﻪ‬ ‫)‪(5‬‬ ‫)ﻓﻮﻕ ﻣﺘﻮﺳﻂ )ﻣﻌﻬﺪ ﻋﺎﻟﻰ‬ ‫)‪(6‬‬ ‫ﺟﺎﻣﻌﻰ‬ ‫‪102 | Transparency and Social Accountability in the Egyptian Power Sector‬‬ ‫ﺍﻟﺤﺎﻟﺔ ﺍﻟﻌﻤﻠﻴﺔ‪:‬‬ ‫‪.4‬‬ ‫ﺃ‪ .‬ﻳﻌﻤﻞ‬ ‫ﺏ‪ .‬ﻻ ﻳﻌﻤﻞ‬ ‫)‪(1‬‬ ‫ﺑﺎﻟﺤﻜﻮﻣﺔ‬ ‫)‪(1‬‬ ‫ﻣﺘﻘﺎﻋﺪ ﻋﻠﻰ ﺍﻟﻤﻌﺎﺵ‬ ‫)‪(2‬‬ ‫ﺑﺎﻟﻘﻄﺎﻉ ﺍﻷﻋﻤﺎﻝ ﺍﻟﻌﺎﻡ‬ ‫)‪(2‬‬ ‫ﻳﺒﺤﺚ ﻋﻦ ﻓﺮﺻﺔ ﻋﻤﻞ‬ ‫)‪(3‬‬ ‫ﻟﺤﺴﺎﺑﺔ ﺍﻟﺨﺎﺹ‪/‬ﺻﺎﺣﺐ ﻋﻤﻞ‬ ‫)‪(3‬‬ ‫ﻻ ﻳﻌﻤﻞ ﻭﻻ ﻳﺒﺤﺚ ﻋﻦ ﻋﻤﻞ‬ ‫)‪(4‬‬ ‫ﻃﺎﻟﺐ‬ ‫)‪(5‬‬ ‫ﺭﺑﺔ ﻣﻨﺰﻝ‬ ‫)‪(6‬‬ ‫ﻣﺮﻳﺾ‪/‬ﻏﻴﺮ ﻗﺎﺩﺭ ﻋﻠﻰ ﺍﻟﻌﻤﻞ‬ ‫)‪(7‬‬ ‫ﺃﺧﺮﻯ‬ ‫)‪(8‬‬ ‫ﺭﻓﺾ ﺍﻹﺟﺎﺑﺔ‬ ‫ً‪ :‬ﺑﻴﺎﻧﺎﺕ ﺧﺎ ﺻﺔ ﺑﺎﻷﺳﺮﺓ ﺍﻟﻤﻌﻴﺸﺔ‬ ‫ﺛﺎﻧﻴﺎ‬ ‫ﻋﺪﺩ ﺃﻓﺮﺍﺩ ﺍﻷﺳﺮﺓ ﺍﻟﻤﻌﻴﺸﺔ‬ ‫‪.5‬‬ ‫ﻋﺪﺩ ﺃﻓﺮﺍﺩ ﺍﻷﺳﺮﺓ ﺍﻟﻤﻌﻴﺸﺔ ﺍﻟﺬﻳﻦ ﻳﻌﻤﻠﻮﻥ‬ ‫‪.6‬‬ ‫ﻣﻜﺎﻥ ﺍﻟﺴﻜﻦ‬ ‫‪.7‬‬ ‫)‪ (1‬ﺷﻘﺔ ﻓﻰ ﻣﻨﺰﻝ‬ ‫)‪ (2‬ﺣﺠﺮﺓ ﺃﻭ ﺃﻛﺜﺮ ﻓﻰ ﺷﻘﺔ‬ ‫)‪ (3‬ﻣﻨﺰﻝ ﺭﻳﻔﻰ‬ ‫)‪ (4‬ﻣﻨﺰﻝ ﺧﺎﺹ ﺑﺎﻟﺤﻀﺮ‬ ‫)‪ (5‬ﺃﺧﺮﻯ ﺗﺬﻛﺮ‬ ‫ﺍﻟﺴﻠﻊ ﺍﻟﻤﻌﻤﺮﺓ ﺍﻟﺘﻰ ﺗﻤﻠﻜﻬﺎ ﺍﻷﺳﺮﺓ‬ ‫‪.8‬‬ ‫)‪ (1‬ﺑﻮﺗﺠﺎﺯ ﻳﻌﻤﻞ ﺑﺎﻟﻐﺎﺯ‪/‬ﺍﻷﻧﺒﻮﺑﺔ‬ ‫)‪ (2‬ﺑﻮﺗﺠﺎﺯ ﻳﻌﻤﻞ ﺑﺎﻟﻜﻬﺮﺑﺎء‬ ‫)‪ (3‬ﻏﺴﺎﻟﺔ ﻳﺪﻭﻯ‬ ‫)‪ (4‬ﻏﺴﺎﻟﺔ ﺃﺗﻮﻣﺎﺗﻴﻚ‬ ‫)‪ (5‬ﺳﺨﺎﻥ ﺑﺎﻟﻜﻬﺮﺑﺎء‬ ‫)‪ (6‬ﺳﺨﺎﻥ ﺑﺎﻟﻐﺎﺯ‪/‬ﺍﻟﺒﻮﺗﺠﺎﺯ‬ ‫)‪ (7‬ﻓﻴﺪﻳﻮ‪/‬ﺩﻯ ﻓﻰ ﺩﻯ‬ ‫)‪ (8‬ﻛﻤﺒﻴﻮﺗﺮ‬ ‫)‪ (9‬ﺩﻳﺐ ﻓﺮﻳﺰﺭ‬ ‫)‪ (10‬ﺗﻜﻴﻴﻒ‬ ‫)‪ (11‬ﻏﺴﺎﻟﺔ ﺃﻃﺒﺎﻕ‬ ‫‪Annexes | 103‬‬ ‫)‪ (12‬ﺩﻓﺎﻳﺔ ﻛﻬﺮﺑﺎﺋﻴﺔ‬ ‫)‪ (13‬ﻣﻜﻮﺍﻩ‬ ‫)‪ (14‬ﻣﻮﺗﻮﺳﻴﻜﻞ‬ ‫)‪ (15‬ﻋﺠﻠﺔ‬ ‫)‪ (16‬ﻋﺮﺑﻴﺔ‬ ‫)‪ (17‬ﺗﻠﻴﻔﺰﻳﻮﻥ‬ ‫ﻣﺎ ﻫﻮ ﻣﺘﻮﺳﻂ ﺍﻧﻔﺎﻕ ﺍﻷﺳﺮﺓ ﺍﻟﺸﻬﺮﻯ‬ ‫‪.9‬‬ ‫ً‪ :‬ﻭﻋﻰ ﺍﻟﻤﺴﺘﻬﻠﻚ ﺑﺪﻭﺭ ﺟﻬﺎﺯ ﺗﻨﻈﻴﻢ ﻭﻣﺮﺍﻗﺒﺔ ﻣﺮﻓﻖ ﺍﻟﻜﻬﺮﺑﺎء‬ ‫ﺛﺎﻟﺜﺎ‬ ‫ﺣﻀﺮﺗﻚ ﺗﻌﺮﻑ‪/‬ﺳﻤﻌﺖ ﺇﻥ ﻓﻴﻪ ﺟﻬﺎﺯ ﺗﻨﻈﻴﻢ ﻣﺮﻓﻖ ﺍﻟﻜﻬﺮﺑﺎء ﻭﺣﻤﺎﻳﺔ ﺍﻟﻤﺴﺘﻬﻠﻚ ﺑﺘﻘﻮﻡ ﺑﺘﻨﻈﻴﻢ ﻭﻣﺮﺍﻗﺒﺔ ﻣﺮﻓﻖ ﺍﻟﻜﻬﺮﺑﺎء‪12‬؟‬ ‫‪.10‬‬ ‫ﻟﻢ ﻳﺤﺪﺩ )ﺍﺷﺮﺡ ﺍﻟﻔﻜﺮﺓ ﺛﻢ ﺍﻧﺘﻘﻞ ﺇﻟﻰ ﺱ‪(3‬‬ ‫ﻻ )ﺍﺷﺮﺡ ﺍﻟﻔﻜﺮﺓ ﺛﻢ ﺍﻧﺘﻘﻞ ﺇﻟﻰ ﺱ‪(3‬‬ ‫ﻧﻌﻢ‬ ‫ﺣﻀﺮﺗﻚ ﺳﻤﻌﺖ ﻋﻦ ﺍﻟﺠﻬﺎﺯ ﻣﻨﻴﻦ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ ﻭﻳﺴﻤﺢ ﺑﺎﺧﺘﻴﺎﺭ ﺃﻛﺜﺮ ﻣﻦ ﺇﺟﺎﺑﺔ(‬ ‫‪.11‬‬ ‫ﺍﻟﺘﻠﻴﻔﺰﻳﻮﻥ‪/‬ﺍﻟﺮﺩﺍﻳﻮ‪/‬ﺍﻟﺼﺤﻒ‪.‬‬ ‫)‪(1‬‬ ‫ﺷﺮﻛﺎﺕ ﺍﻟﻜﻬﺮﺑﺎء‪.‬‬ ‫)‪(2‬‬ ‫ﺍﻷﻗﺎﺭﺏ‪/‬ﺍﻟﻤﻌﺎﺭﻑ‪/‬ﺍﻷﺻﺪﻗﺎء‪.‬‬ ‫)‪(3‬‬ ‫ﺃﺧﺮﻯ‪ ) .‬ﺗﺬﻛﺮ ‪( .......................‬‬ ‫)‪(4‬‬ ‫ﺣﻀﺮﺗﻚ ﻋﺎﺭﻑ ﺇﻥ ﻓﻴﻪ ﻣﻮﻗﻊ ﻋﻠﻰ ﺍﻹﻧﺘﺮﻧﺖ ﻟﺸﺮﻛﺎﺕ ﻭﺧﺪﻣﺎﺕ ﺍﻟﻜﻬﺮﺑﺎء؟‬ ‫‪.12‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫‪15‬ﻓﻰ ﺣﺎﻟﺔ ﺍﻻﺟﺎﺑﺔ ﺑﻼ ﺍﻧﺘﻘﻞ ﻟﻠﺴﺆﺍﻝ *‬ ‫ﻋﻤﺮﻙ ﺩﺧﻠﺖ ﻋﻠﻰ ﺍﻟﻤﻮﻗﻊ؟‬ ‫‪.13‬‬ ‫)‪ (2‬ﻻ ﺍﻣﺘﻠﻚ ﻛﻤﺒﻴﻮﺗﺮ )ﺍﻧﺘﻘﻞ ﺇﻟﻰ ﺳﺆﺍﻝ ‪(15‬‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﻋﻤﺮﻙ ﻗﺪﻣﺖ ﺷﻜﻮﻯ؟‬ ‫‪.14‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫‪. .12‬ﺍﻟﺠﻬﺎﺯ‪ :‬ﻫﻮ ﺟﻬﺔ ﺑﺘﻨﻈﻢ ﻭﺗﺮﺍﻗﺐ ﻛﻞ ﻣﺎ ﻳﺘﻌﻠﻖ ﺑﺎﻟﻜﻬﺮﺑﺎء )ﺇﻧﺘﺎﺟﻬﺎ‪/‬ﻧﻘﻠﻬﺎ‪/‬ﺗﻮﺯﻳﻌﻬﺎ( ﻭﻣﺮﺍﻋﺎﺓ ﻣﺼﺎﻟﺢ ﺍﻟﻤﺴﺘﻬﻠﻚ‬ ‫‪104 | Transparency and Social Accountability in the Egyptian Power Sector‬‬ ‫ً‪ :‬ﺃﺳﺌﻠﺔ ﺗﻘﻴﻴﻢ ﺟﻮﺩﺓ ﺧﺪﻣﺎﺕ ﺍﻟﻜﻬﺮﺑﺎء‬ ‫ﺭﺍﺑﻌﺎ‬ ‫ﺧﻼﻝ ﺍﻟـ ‪ 3‬ﺷﻬﻮﺭ ﺍﻟﻠﻰ ﻓﺎﺗﺖ ﻣﻤﻜﻦ ﺃﻋﺮﻑ ﻣﺘﻮﺳﻂ ﻗﺮﺍءﺓ ﺍﻟﻌﺪﺍﺩ ﺑﺘﺒﻘﻰ ﻛﺎﻡ ﻓﻰ ﺍﻟﺸﻬﺮ؟ )ﻋﺪﺩ ﺍﻟﻜﻴﻠﻮ ﻭﺍﺕ ﻓﻰ ﺍﻟﺸﻬﺮ(؟‬ ‫‪.15‬‬ ‫)‪ (2‬ﻻ ﺃﻋﺮﻑ‬ ‫)‪ (1‬ﺍﻻﺳﺘﻬﻼﻙ‪/‬ﺍﻟﻌﺪﺩ‪ ............... :‬ﻛﻴﻠﻮﻭﺍﺕ‬ ‫ﺧﻼﻝ ﺍﻟـ ‪ 3‬ﺷﻬﻮﺭ ﺍﻟﻠﻰ ﻓﺎﺗﺖ ﻣﻤﻜﻦ ﺃﻋﺮﻑ ﻣﺘﻮﺳﻂ ﻗﻴﻤﺔ ﻓﺎﺗﻮﺭﺓ ﺍﻟﻜﻬﺮﺑﺎء ﺍﻟﻠﻰ ﺑﺘﺪﻓﻌﻮﻫﺎ ﺑﺘﺒﻘﻰ ﻛﺎﻡ ﻓﻰ ﺍﻟﺸﻬﺮ؟‬ ‫‪.16‬‬ ‫)‪ (2‬ﻻ ﺃﻋﺮﻑ‬ ‫)‪ (1‬ﺍﻟﻤﺒﻠﻎ‪/‬ﻣﺘﻮﺳﻂ ﺍﻻﺳﺘﻬﻼﻙ‪ .......... :‬ﺟﻨﻴﻪ‬ ‫ﻣﺎ ﻫﻮ ﻣﺘﻮﺳﻂ ﻗﻴﻤﺔ ﻣﺎ ﺗﺪﻓﻌﻪ ﻓﻰ ﺍﻟﺸﻬﺮ ﻟﻠﻜﻬﺮﺑﺎء ﻓﻰ ﻓﺼﻞ ﺍﻟﺼﻴﻒ ؟‬ ‫‪.17‬‬ ‫ﻣﺎ ﻫﻮ ﻣﺘﻮﺳﻂ ﻗﻴﻤﺔ ﻣﺎ ﺗﺪﻓﻌﻪ ﻓﻰ ﺍﻟﺸﻬﺮ ﻟﻠﻜﻬﺮﺑﺎء ﻓﻰ ﻓﺼﻞ ﺍﻟﺸﺘﺎء ؟‬ ‫‪.18‬‬ ‫ﻫﻞ ﺣﻀﺮﺗﻚ ﺷﺎﻳﻒ ﺇﻥ ﺍﺳﺘﻬﻼﻙ ﺃﺳﺮﺗﻚ ﻣﻦ ﺍﻟﻜﻬﺮﺑﺎء ﻣﺘﻨﺎﺳﺐ ﻣﻊ ﺍﻟﻠﻰ ﺑﺘﺪﻓﻌﻮﻩ ﻓﻰ ﺍﻟﺸﻬﺮ؟‬ ‫‪.19‬‬ ‫)‪ (4‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫)‪ (3‬ﻻ‬ ‫)‪ (2‬ﺇﻟﻰ ﺣﺪ ﻣﺎ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﺇﺫﺍ ﻛﻨﺖ ﻋﺎﻳﺰ ﺗﻘﻠﻞ ﺍﺳﺘﻬﻼﻙ ﺍﻟﻜﻬﺮﺑﺎء‪ ،‬ﻫﻞ ﻋﺎﺭﻑ ﺃﻳﻪ ﺃﻓﻀﻞ ﺍﻟﻄﺮﻕ؟‬ ‫‪.20‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﻣﻦ ﺑﻴﻦ ﺍﻟﻄﺮﻕ ﺍﻵﺗﻴﺔ ﺃﻳﻪ ﺍﻟﺬﻯ ﺗﻌﻤﻠﻪ ﺃﻭ ﺗﺨﺘﺎﺭ ﺃﻥ ﺗﻌﻤﻠﻪ ﻋﻠﺸﺎﻥ ﺗﺨﻔﺾ ﺍﺳﺘﻬﻼﻙ ﺍﻟﻜﻬﺮﺑﺎء؟ )ﻣﺘﻌﺪﺩ ﺍﻹﺧﺘﻴﺎﺭﺍﺕ ( )ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺴﻤﺢ ﺑﺎﺧﺘﻴﺎﺭ‬ ‫‪.21‬‬ ‫ﺃﻛﺜﺮ ﻣﻦ ﺇﺟﺎﺑﺔ(‬ ‫ً‬ ‫ﺣﺎﻟﻴﺎ ً‬ ‫ﻣﺴﺘﻘﺒﻼ‬ ‫)‪(1‬‬ ‫ﺍﺳﺘﺨﺪﺍﻡ ﻟﻤﺒﺎﺕ ﻣﻮﻓﺮﺓ ﺃﻭ ﻓﻠﻮﺭﻳﺴﻨﺖ ً‬ ‫ﺑﺪﻻ ﻣﻦ ﺍﻟﻠﻤﺒﺎﺕ ﺍﻟﻌﺎﺩﻳﺔ‬ ‫)‪(2‬‬ ‫ﺑﺪﻻ ﻣﻦ ﺍﺳﺘﺨﺪﺍﻡ ﺳﺨﺎﻥ ﻛﻬﺮﺑﺎء‬ ‫ﺍﺳﺘﺨﺪﺍﻡ ﺳﺨﺎﻥ ﻏﺎﺯ‪/‬ﺳﻢ ﺳﻰ ً‬ ‫)‪(3‬‬ ‫ﺑﺪﻻ ﻣﻦ ﺍﺳﺘﺨﺪﺍﻡ ﺍﻟﻔﺮﻥ ﺍﻟﻜﻬﺮﺑﺎﺋﻰ‬‫ﺍﺳﺘﺨﺪﺍﻡ ﻓﺮﻥ ﻏﺎﺯ ً‬ ‫)‪(4‬‬ ‫ﻋﺪﻡ ﺗﺸﻐﻴﻞ ﺍﻷﺟﻬﺰﺓ ﺍﻟﻜﻬﺮﺑﺎﺋﻴﺔ ﺑﺪﻭﻥ ﺩﺍﻋﻰ‬ ‫)‪(5‬‬ ‫ﻋﺪﻡ ﺗﺮﻙ ﺍﻷﻧﻮﺍﺭ ﻣﻀﺎءﺓ ﻓﻰ ﺍﻷﻣﺎﻛﻦ ﻏﻴﺮ ﻣﺘﻮﺍﺟﺪ ﺑﻬﺎ ﺃﺣﺪ‬ ‫)‪(6‬‬ ‫)‪.......................................‬ﺃﺧﺮﻯ )ﺗﺬﻛﺮ‬ ‫)‪(7‬‬ ‫ﻻ ﺃﻋﺮﻑ‬ ‫ﻫﻞ ﺣﻀﺮﺗﻚ ﻋﺎﺭﻑ ﺍﻟﻌﺪﺍﺩ ﺍﻟﻠﻰ ﻓﻰ ﺍﻟﺒﻴﺖ ﻛﺎﻡ ﺃﻣﺒﻴﺮ‪/‬ﻓﺎﺯ؟‬ ‫‪.22‬‬ ‫ﻻ‬ ‫ﻧﻌﻢ‬ ‫ﻫﻞ ﺍﺳﺘﻠﻤﺖ ﻋﻘﺪ ﺗﻮﺭﻳﺪ ﺍﻟﻜﻬﺮﺑﺎء ﻣﻦ ﺷﺮﻛﺔ ﺍﻟﺘﻮﺯﻳﻊ ﺍﻟﺘﺎﺑﻊ ﻟﻬﺎ ﻭﻣﺤﺘﻔﻆ ﺑﻪ؟‬ ‫‪.23‬‬ ‫ﻻ‬ ‫ﻧﻌﻢ‬ ‫‪Annexes | 105‬‬ ‫ﻫﻞ ﺣﻀﺮﺗﻚ ﺷﺎﻳﻒ ﺇﻥ ﻋﻘﺪﻙ ﻣﻊ ﺷﺮﻛﺔ ﺍﻟﻜﻬﺮﺑﺎء ﺑﻴﻮﺿﺢ ﺣﻘﻮﻗﻚ ﻭﺍﻟﺘﺰﺍﻣﺎﺗﻚ؟‬ ‫‪.24‬‬ ‫)‪ (4‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫)‪ (3‬ﻟﻢ ﺃﻗﺮﺃ ﺍﻟﻌﻘﺪ‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫)ﻣﻠﺤﻮﻇﺔ‪ :‬ﻓﻰ ﺣﺎﻟﺔ ﺇﺟﺎﺑﺔ ﺍﻟﻤﺒﺤﻮﺙ ﺑـ ”ﻻ“ ﻳﺘﻢ ﺍﻟﺘﺄﻛﻴﺪ ﺍﻟﻌﻘﺪ ﺑﻴﻮﺿﺢ ﺣﻘﻮﻗﻚ ﻭﺍﻟﺘﺰﻣﺎﺗﻚ ﻭﻻ ﻟﻢ ﺗﻘﺮﺃ ﺍﻟﻌﻘﺪ(‬ ‫ﺧﻼﻝ ﺍﻟـ‪ 3‬ﺷﻬﻮﺭ ﺍﻟﻠﻰ ﻓﺎﺗﺖ ﻳﺎ ﺗﺮﻯ ﺍﻟﻜﻬﺮﺑﺎء ﻛﺎﻧﺖ ﺑﺘﻨﻘﻄﻊ ﻋﻨﺪﻛﻢ ﻓﻰ ﺍﻟﺒﻴﺖ؟ )ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺠﺐ ﺍﺧﺘﻴﺎﺭ ﺇﺟﺎﺑﺔ ﻭﺍﺣﺪﺓ ﻓﻘﻂ(‬ ‫‪.25‬‬ ‫)‪ (3‬ﻟﻢ ﻳﺤﺪﺩ )ﺍﻧﺘﻘﻞ ﺇﻟﻰ ﺱ ‪( 82‬‬ ‫)‪ (2‬ﻻ )ﺍﻧﺘﻘﻞ ﺇﻟﻰ ﺱ ‪( 82‬‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﺧﻼﻝ ﺍﻟـ‪ 3‬ﺷﻬﻮﺭ ﺍﻟﻠﻰ ﻓﺎﺗﺖ ﻳﺎ ﺗﺮﻯ ﺍﻟﻜﻬﺮﺑﺎء ﻗﻄﻌﺖ ﻛﺎﻡ ﻣﺮﺓ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺠﺐ ﺍﺧﺘﻴﺎﺭ ﺇﺟﺎﺑﺔ ﻭﺍﺣﺪﺓ ﻓﻘﻂ(‬ ‫‪.26‬‬ ‫)‪ (1‬ﻣﺮﺓ ﻭﺍﺣﺪﺓ‬ ‫)‪ (2‬ﻣﺮﺗﻴﻦ‬ ‫)‪ (3‬ﺛﻼﺙ ﻣﺮﺍﺕ‬ ‫)‪ (4‬ﺃﺭﺑﻊ ﻣﺮﺍﺕ‬ ‫)‪ (5‬ﺧﻤﺲ ﻣﺮﺍﺕ‬ ‫)‪ (6‬ﺳﺖ ﻣﺮﺍﺕ ﻓﺄﻛﺜﺮ‬ ‫)‪ (7‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫ﺧﻼﻝ ﺍﻝ ‪ 3‬ﺷﻬﻮﺭ ﺍﻟﻠﻰ ﻓﺎﺗﺖ ﻟﻤﺎ ﺍﻟﻜﻬﺮﺑﺎء ﺑﺘﺘﻘﻄﻊ ﻛﺎﻥ ﻃﻮﻝ ﻓﺘﺮﺓ ﺍﻧﻘﻄﺎﻉ ﺍﻟﺘﻴﺎﺭ ﺍﻟﻜﻬﺮﺑﺎﺋﻰ ﺑﻴﺴﺘﻤﺮ ﻗﺪ ﺍﻳﻪ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺠﺐ ﺍﺧﺘﻴﺎﺭ ﺇﺟﺎﺑﺔ‬ ‫‪.27‬‬ ‫ﻭﺍﺣﺪﺓ ﻓﻘﻂ(‬ ‫)‪ (1‬ﺃﻗﻞ ﻣﻦ ‪ 15‬ﺩﻗﻴﻘﺔ‬ ‫)‪ (2‬ﻣﻦ ‪ 15‬ﺩﻗﻴﻘﺔ ﺇﻟﻰ ﺃﻗﻞ ﻣﻦ ‪ 30‬ﺩﻗﻴﻘﺔ‬ ‫)‪ (3‬ﻣﻦ ‪ 30‬ﺩﻗﻴﻘﺔ ﺇﻟﻰ ﺃﻗﻞ ﻣﻦ ‪ 60‬ﺩﻗﻴﻘﺔ‬ ‫)‪ (4‬ﻣﻦ ﺳﺎﻋﺔ ﺇﻟﻰ ﺃﻗﻞ ﻣﻦ ﺳﺎﻋﺘﻴﻦ‬ ‫)‪ (5‬ﻣﻦ ﺳﺎﻋﺘﻴﻦ ﺇﻟﻰ ﺃﻗﻞ ﻣﻦ ‪ 5‬ﺳﺎﻋﺎﺕ‬ ‫)‪ 5 (6‬ﺳﺎﻋﺎﺕ ﻓﺄﻛﺜﺮ‬ ‫)‪ (7‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫ﺧﻼﻝ ﺍﻟـ ‪ 3‬ﺷﻬﻮﺭ ﺍﻟﻠﻰ ﻓﺎﺗﺖ ﻫﻞ ﺑﻴﺤﺼﻞ ﺇﻥ ﺗﻴﺎﺭ ﺍﻟﻜﻬﺮﺑﺎء ﺑﻴﻜﻮﻥ ﻗﻮﻯ ﻭﻓﺠﺄﺓ ﻳﻀﻌﻒ ﺃﻭ ﺍﻟﻌﻜﺲ ﻳﻌﻨﻰ ﺑﻴﺒﻘﻰ ﻣﺶ ﺛﺎﺑﺖ؟ )ﻣﻠﺤﻮﻇﺔ‪ :‬ﻓﻰ ﺣﺎﻟﺔ ﺇﺟﺎﺑﺔ‬ ‫‪.28‬‬ ‫ً( )ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ(‬ ‫ﺍﻟﻤﺒﺤﻮﺙ ﺑﻨﻌﻢ ﻳﺘﻢ ﺍﻟﺘﺄﻛﻴﺪ ﻭﺩﻩ ﺑﺎﺳﺘﻤﺮﺍﺭ ﻭﻻ ﺍﺣﻴﺎﻧﺎ‬ ‫)‪ (4‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫)‪ (3‬ﻻ ﻳﺤﺪﺙ ﺫﻟﻚ‬ ‫)‪ (2‬ﻧﻌﻢ ﺃﺣﻴﺎﻧﺎ‬ ‫)‪ (1‬ﻧﻌﻢ ﺑﺎﺳﺘﻤﺮﺍﺭ‬ ‫ﻫﻞ ﻫﻨﺎﻙ ﺃﺛﺮ ﺿﺎﺭ ﻟﻬﺬﺍ ﺍﻟﺘﻐﻴﺮ ﻓﻰ ﺍﻟﺘﻴﺎﺭ؟‬ ‫‪.29‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫‪106 | Transparency and Social Accountability in the Egyptian Power Sector‬‬ ‫ﺃﻳﻪ ﺃﻛﺜﺮ ﺍﻷﺿﺮﺍﺭ ﺗﺄﺛﻴﺮﺍ ﻋﻠﻴﻚ ﻓﻰ ﻓﺘﺮﺓ ﺍﻧﻘﻄﺎﻉ ﺍﻟﻜﻬﺮﺑﺎء؟‬ ‫‪.30‬‬ ‫)‪ (1‬ﺗﻠﻒ ﺍﻷﺟﻬﺰﺓ ﺍﻟﻜﻬﺮﺑﺎﺋﻴﺔ‬ ‫)‪ (2‬ﺍﻧﻘﻄﺎﻉ ﺍﻟﻤﻴﺎﻩ‬ ‫)‪ (3‬ﺍﻧﻘﻄﺎﻉ ﺍﻟﻤﺼﻌﺪ‬ ‫)‪ (4‬ﺃﺧﺮﻯ )ﺗﺬﻛﺮ ‪(..............................‬‬ ‫ﻳﺎ ﺗﺮﻯ ﺍﻟﻜﺸﺎﻑ )ﺍﻟﻤﺴﺌﻮﻝ ﻋﻦ ﻗﺮﺍءﺓ ﺍﻟﻌﺪﺍﺩ( ﺑﻴﺠﻰ ﻛﻞ ﺷﻬﺮ ﺑﺎﻧﺘﻈﺎﻡ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺠﺐ ﺍﺧﺘﻴﺎﺭ ﺇﺟﺎﺑﺔ ﻭﺍﺣﺪﺓ ﻓﻘﻂ(‬ ‫‪.31‬‬ ‫)‪ (1‬ﻛﻞ ﺷﻬﺮ‬ ‫)‪ (2‬ﻛﻞ ﺷﻬﺮﻳﻦ‬ ‫)‪ 3 (3‬ﺃﺷﻬﺮ‬ ‫)‪ (4‬ﺍﻟﻌﺪﺍﺩ ﺧﺎﺭﺝ ﺍﻟﻤﻨﺰﻝ‬ ‫)‪ (5‬ﻻ ﺍﻋﺮﻑ‬ ‫ﻫﻞ ﻣﻮﺍﻋﻴﺪ ﺣﻀﻮﺭ ﺍﻟﻜﺸﺎﻑ )ﺍﻟﻤﺴﺌﻮﻝ ﻋﻦ ﻗﺮﺍءﺓ ﺍﻟﻌﺪﺍﺩ( ﻣﻨﺎﺳﺒﺔ ﻟﺤﻀﺮﺗﻚ‪/‬ﻷﺳﺮﺗﻚ؟‬ ‫‪.32‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ )ﺍﻧﺘﻘﻞ ﺇﻟﻰ ﺱ ‪( 34‬‬ ‫ﺇﻳﻪ ﻫﻮ ﺍﻟﻤﻴﻌﺎﺩ ﺍﻟﻤﻨﺎﺳﺐ ﻟﺤﻀﺮﺗﻚ‪/‬ﻷﺳﺮﺗﻚ ﺧﻼﻝ ﺍﻟﻴﻮﻡ ﻟﻘﺮﺍءﺓ ﺍﻟﻌﺪﺍﺩ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺴﻤﺢ ﺑﺎﺧﺘﻴﺎﺭ ﺃﻛﺜﺮ ﻣﻦ ﺇﺟﺎﺑﺔ(‬ ‫‪.33‬‬ ‫)‪ (1‬ﻣﻦ ﺍﻟﺴﺎﻋﺔ ‪ 11 – 9‬ﺻﺒﺎﺣﺎً‬ ‫)‪ (2‬ﻣﻦ ﺍﻟﺴﺎﻋﺔ ‪ 9 – 7‬ﻣﺴﺎءﺍً‬ ‫)‪ (3‬ﻣﻦ ﺍﻟﺴﺎﻋﺔ ‪ 1 – 11‬ﻇﻬﺮ ﺍً‬ ‫)‪ (4‬ﺑﻌﺪ ‪ 9‬ﻣﺴﺎءﺍً‬ ‫)‪ (5‬ﻣﻦ ﺍﻟﺴﺎﻋﺔ ‪ 3 – 1‬ﺑﻌﺪ ﺍﻟﻈﻬﺮ‬ ‫)‪ (6‬ﻃﻮﺍﻝ ﺍﻟﻴﻮﻡ‬ ‫)‪ (7‬ﻣﻦ ﺍﻟﺴﺎﻋﺔ ‪ 5 – 3‬ﻋﺼﺮﺍً‬ ‫)‪ (8‬ﺃﺧﺮﻯ )ﺗﺬﻛﺮ ‪(...............‬‬ ‫)‪ (9‬ﻣﻦ ﺍﻟﺴﺎﻋﺔ ‪ 7 – 5‬ﻣﺴﺎ ءﺍً‬ ‫)‪ (10‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫ﻳﺎ ﺗﺮﻯ ﺍﻟﻤﺤﺼﻞ ﺑﻴﺠﻰ ﻛﻞ ﺷﻬﺮ ﻳﺤﺼﻞ ﻓﺎﺗﻮﺭﺓ ﺍﻟﻜﻬﺮﺑﺎء؟‬ ‫‪.34‬‬ ‫)‪ (3‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﻫﻞ ﻣﻌﺎﻣﻠﺔ ﺍﻟﻤﺤﺼﻞ ﻣﺮﺿﻴﺔ ﺑﺎﻟﻨﺴﺒﺔ ﻟﻚ؟‬ ‫‪.35‬‬ ‫)‪ (3‬ﻣﺶ ﺩﺍﺋﻤﺎً‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﻫﻞ ﻣﻌﺎﻣﻠﺔ ﺍﻟﻜﺸﺎﻑ ﻣﺮﺿﻴﺔ ﺑﺎﻟﻨﺴﺒﺔ ﻟﻚ؟‬ ‫‪.36‬‬ ‫)‪ (3‬ﻣﺶ ﺩﺍﺋﻤﺎً‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﺣﻀﺮﺗﻚ ﺗﻮﺍﻓﻖ ﻋﻠﻰ ﺳﺪﺍﺩ ﺍﻟﻔﺎﺗﻮﺭﺓ ﻣﻦ ﺧﻼﻝ ﺍﻟﺒﻨﻮﻙ ﺃﻭ ﻣﻜﺎﺗﺐ ﺍﻟﺒﺮﻳﺪ ﺃﻭ ﺍﻹﻧﺘﺮﻧﺖ ﺯﻯ ﻓﺎﺗﻮﺭﺓ ﺍﻟﺘﻠﻴﻔﻮﻥ ﺃﻭ ﻣﻦ ﺧﻼﻝ ﻋﺪﺍﺩﺍﺕ ﻣﺴﺒﻮﻗﺔ ﺍﻟﺪﻓﻊ ﺫﻯ‬ ‫‪.37‬‬ ‫ﻓﺎﺗﻮﺭﺓ ﺍﻟﺘﻠﻴﻔﻮﻥ؟‬ ‫)‪ (4‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫)‪ (3‬ﻏﻴﺮ ﻣﻮﺍﻓﻖ‬ ‫)‪ (1‬ﻣﻮﺍﻓﻖ‬ ‫‪Annexes | 107‬‬ ‫ﺧﻼﻝ ﺍﻟﺴﻨﻪ ﺍﻟﻠﻰ ﻓﺎﺗﺖ ﻫﻞ ﻗﺎﺑﻠﺘﻚ ﻣﺸﻜﻠﺔ ﺑﺨﺼﻮﺹ ﺍﻟﻜﻬﺮﺑﺎء ﻭﺑﻠﻐﺖ ﻋﻨﻬﺎ؟‬ ‫‪.38‬‬ ‫)‪ (3‬ﻟﻢ ﻳﺤﺪﺩ‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﻭﻛﺎﻧﺖ ﺍﻟﺸﻜﻮﻯ ﻣﻦ ﺃﻳﻪ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺴﻤﺢ ﺑﺎﺧﺘﻴﺎﺭ ﺃﻛﺜﺮ ﻣﻦ ﺇﺟﺎﺑﺔ(‬ ‫‪.39‬‬ ‫ﺗﻜﺮﺍﺭ ﻣﺮﺍﺕ ﺍﻧﻘﻄﺎﻉ ﺍﻟﻜﻬﺮﺑﺎء‬ ‫)‪(1‬‬ ‫ﻃﻮﻝ ﻓﺘﺮﺍﺕ ﺍﻧﻘﻄﺎﻉ ﺍﻟﻜﻬﺮﺑﺎء‬ ‫)‪(2‬‬ ‫)ﺗﺬﺑﺬﺏ ﺍﻟﺘﻴﺎﺭ ﺍﻟﻜﻬﺮﺏ ﺍﺋﻰ )ﻳﻌﻨﻰ ﻣﺜﻼً ﻳﻜﻮﻥ ﻗﻮﻯ ﻭﻓﺠﺄﺓ ﻳﻀﻌﻒ ﺃﻭ ﺍﻟﻌﻜﺲ‬ ‫)‪(3‬‬ ‫ﺗﻔﺎﻭﺕ ﻗﻴﻤﺔ ﻓﺎﺗﻮﺭﺓ ﺍﻟﻜﻬﺮﺑﺎء‬ ‫)‪(4‬‬ ‫)ﺍﺭﺗﻔﺎﻉ ﻗﻴﻤﺔ ﻓﺎﺗﻮﺭﺓ ﺍﻟﻜﻬﺮﺑﺎء )ﺑﺎﺳﺘﻤﺮﺍﺭ‬ ‫)‪(5‬‬ ‫)‪........................................................‬ﺃﺧﺮﻯ )ﺗﺬﻛﺮ‬ ‫)‪(6‬‬ ‫ﺇﻳﻪ ﻫﻰ ﺍﻟﺠﻬﺔ ﺍﻟﻠﻰ ﺑﻠﻐﺖ ﻟﻬﺎ ﺍﻟﺸﻜﻮﻯ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺴﻤﺢ ﺑﺎﺧﺘﻴﺎﺭ ﺃﻛﺜﺮ ﻣﻦ ﺇﺟﺎﺑﺔ(‬ ‫‪.40‬‬ ‫ﺷﺮﻛﺔ ﺍﻟﻜﻬﺮﺑﺎء ﺍﻟﺘﺎﺑﻊ ﻟﻬﺎ‪/‬ﺷﺒﻜﺔ ﺍﻟﻜﻬﺮﺑﺎء‪/‬ﻓﺮﻉ ﺍﻟﻜﻬﺮﺑﺎء‬ ‫)‪(1‬‬ ‫ﺟﻬﺎﺯ ﺗﻨﻈﻴﻢ ﻣﺮﻓﻖ ﺍﻟﻜﻬﺮﺑﺎء ﻭﺣﻤﺎﻳﺔ ﺍﻟﻤﺴﺘﻬﻠﻚ‬ ‫)‪(2‬‬ ‫ﺭﻗﻢ ﺃﻋﻄﺎﻝ‪/‬ﻃﻮﺍﺭﺉ‪/‬ﻻ ﺃﻋﺮﻑ ﺗﺎﺑﻊ ﻷﻯ ﺟﻬﺔ‪/‬ﺍﻟﺮﻗﻢ ﺍﻟﻤﻮﺟﻮﺩ ﻋﻠﻰ ﻇﻬﺮ ﺍﻹﻳﺼﺎﻝ‬ ‫)‪(3‬‬ ‫)‪........................................................‬ﺃﺧﺮﻯ )ﺗﺬﻛﺮ‬ ‫)‪(4‬‬ ‫ﺍﻳﻪ ﺍﻟﻄﺮﻳﻘﺔ‪/‬ﺍﻟﻮﺳﻴﻠﺔ ﺍﻟﻠﻰ ﺑﻠﻐﺖ ﺑﻬﺎ ﺷﻜﻮﺗﻚ ؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺴﻤﺢ ﺑﺎﺧﺘﻴﺎﺭ ﺃﻛﺜﺮ ﻣﻦ ﺇﺟﺎﺑﺔ(‬ ‫‪.41‬‬ ‫ﺍﻟﺘﻠﻴﻔﻮﻥ‬ ‫)‪(1‬‬ ‫ﺍﻟﺬﻫﺎﺏ ﺇﻟﻰ ﺍﻟﺠﻬﺔ‬ ‫)‪(2‬‬ ‫ﺇﺭﺳﺎﻝ ﻓﺎﻛﺲ ﻟﻠﺠﻬﺔ‬ ‫)‪(3‬‬ ‫ﺑﺎﺳﺘﺨﺪﺍﻡ ﺍﻟﺒﺮﻳﺪ ﺍﻟﻌﺎﺩﻯ‬ ‫)‪(4‬‬ ‫ﻣﻦ ﺧﻼﻝ ﺍﻟﻤﻮﻗﻊ ﺃﻭ ﺍﻟﺒﺮﻳﺪ ﺍﻻﻟﻜﺘﺮﻭﻧﻰ‬ ‫)‪(5‬‬ ‫)‪........................................................‬ﺃﺧﺮﻯ )ﺗﺬﻛﺮ‬ ‫)‪(6‬‬ ‫ﻟﻢ ﻳﺤﺪﺩ‬ ‫)‪(7‬‬ ‫ﺍﻟﻤﺸﻜﻠﺔ ﺍﺗﺤﻠﺖ؟‬ ‫‪.42‬‬ ‫)‪ (3‬ﻟﻢ ﻳﺤﺪﺩ )ﺍﻧﺘﻘﻞ ﺇﻟﻰ ﺳﺆﺍﻝ ‪(44‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﻭﻳﺎ ﺗﺮﻯ ﺍﻟﻤﺸﻜﻠﺔ ﺍﺗﺤﻠﺖ ﻓﻰ ﺃﺩ ﺃﻳﻪ ﺗﻘﺮﻳﺒﺎً؟ )ﻻ ﺗﻘﺮﺃ ﺍﻟﺒﺪﺍﺋﻞ‪ ،‬ﻭﻳﺴﻤﺢ ﺑﺎﺧﺘﻴﺎﺭ ﺃﻛﺜﺮ ﻣﻦ ﺇﺟﺎﺑﺔ(‬ ‫‪.43‬‬ ‫ﺧﻼﻝ ﻧﻔﺲ ﻳﻮﻡ ﺗﻘﺪﻳﻢ ﺍﻟﺸﻜﻮﻯ‬ ‫)‪(1‬‬ ‫ﺧﻼﻝ ﻳﻮﻣﻴﻦ‬ ‫)‪(2‬‬ ‫ﺧﻼﻝ ‪ 3‬ﺃﻳﺎﻡ‬ ‫)‪(3‬‬ ‫ﺧﻼﻝ ‪ 4‬ﺃﻳﺎﻡ‬ ‫)‪(4‬‬ ‫ﺧﻼﻝ ‪ 5‬ﺃﻳﺎﻡ‬ ‫)‪(5‬‬ ‫ﺧﻼﻝ ‪ 6‬ﺃﻳﺎﻡ‬ ‫)‪(6‬‬ ‫ﺧﻼﻝ ﺃﺳﺒﻮﻉ‬ ‫)‪(7‬‬ ‫)‪........................................................‬ﺃﺧﺮﻯ )ﺗﺬﻛﺮ‬ ‫)‪(8‬‬ ‫ﻻ ﻳﺤﺪﺩ‬ ‫)‪(9‬‬ ‫‪108 | Transparency and Social Accountability in the Egyptian Power Sector‬‬ ‫ﺧﺎﻣﺴﺎ‪ :‬ﺍﻟﻜﻬﺮﺑﺎء ﻭﺍﻟﺪﻋﻢ‬ ‫ﻫﻞ ﺗﻌﻠﻢ ﺍﻥ ﻫﻨﺎﻙ ﺩﻋﻢ ﻋﻠﻲ ﻓﺎﺗﻮﺭﺓ ﺍﻟﻜﻬﺮﺑﺎء؟‬ ‫‪.44‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﻓﻰ ﺣﺎﻟﺔ ﺍﻹﺟﺎﺑﺔ ﺑﻨﻌﻢ ﻧﺴﺄﻝ ﻫﻞ ﻓﻰ ﺃﻋﺘﻘﺎﺩﻙ ﺍﻥ ﻫﺬﺍ ﺍﻟﺪﻋﻢ ﻗﻠﻴﻞ ﺃﻡ ﻛﺜﻴﺮ؟*‬ ‫ﻫﻞ ﺗﻔﻀﻞ ﺍﻥ ﻳﺬﻛﺮ ﺣﺠﻢ ﺍﻟﺠﺰء ﺍﻟﻤﺪﻋﻮﻡ ﻣﻦ ﺍﻟﻜﻬﺮﺑﺎء ﻋﻠﻲ ﺍﻟﻔﺎﺗﻮﺭﺓ؟‬ ‫‪.45‬‬ ‫)‪ (2‬ﻻ‬ ‫)‪ (1‬ﻧﻌﻢ‬ ‫ﺣﻀﺮﺗﻚ ﻋﺎﺭﻑ ﺇﻥ ﺣﺴﺎﺏ ﻓﻮﺍﺗﻴﺮ ﺍﻟﻜﻬﺮﺑﺎء ﺑﻴﻜﻮﻥ ﻣﻦ ﺧﻼﻝ ﺷﺮﺍﺋﺢ ﺑﺘﺘﻘﺴﻢ ﺣﺴﺐ ﺍﻻﺳﺘﻬﻼﻙ ﺍﻟﺸﺮﻳﺤﺔ ﺍﻷﻋﻠﻰ ﺃﻏﻠﻰ ﻭﺍﻷﻗﻞ ﺃﺭﺧﺺ؟‬ ‫‪.46‬‬ ‫ﻻ‬ ‫ﻧﻌﻢ‬ ‫ﻫﻞ ﺗﺮﻯ ﺃﻥ ﺍﻟﺘﺪﺭﺝ ﻓﻲ ﺗﺴﻌﻴﺮ ﺷﺮﺍﺋﺢ ﺍﻟﻜﻬﺮﺑﺎء ﺑﺤﺴﺐ ﺷﺮﻳﺤﺔ ﺍﻻﺳﺘﻬﻼﻙ ﻳﺤﻘﻖ ﺍﻟﻌﺪﺍﻟﺔ ﺍﻻﺟﺘﻤﺎﻋﻴﺔ؟‬ ‫‪.47‬‬ ‫ﻻ‬ ‫ﻧﻌﻢ‬ ‫ﺍﺷﻜﺮ ﺍﻟﻤﺒﺤﻮﺙ ﻭﺍﻧﻬﻲ ﺍﻟﻤﻘﺎﺑﻠﺔ‬ ‫‪Annexes | 109‬‬ Annex I | Commercial Quality Indicators in Brazil Commercial standards defined in ANEEL Resolution n° 414/2010 (group A refers to consumers connected in voltage equal or above 2.3 kV or by underground circuit, and group B refers to other consumers connected in voltage bellow 2.3 kV) Maximum period for inspection of a consumer unit, located in an urban area, after a 3 working connection request. days Maximum period for inspection of a consumer unit, located in a rural area, after a 5 working connection request. days Maximum period for connection of a group B consumer, located in an urban area, from 2 working the date of approval of installations. days Maximum period for connection of a group B consumer, located in a rural area, from the 5 working date of approval of installations. days Maximum period for connection of a group A consumer from the date of approval of 7 working installations. days Maximum period to prepare studies, projects and budgets and to inform the consumer 30 days when there is a need for improvement in network to allow the connection. Maximum period to begin the improvements when the conditions set out in legislation 45 days and regulations are fulfilled by the consumer. Maximum period to inform consumer the result of the analysis of her/his project, when 30 days the improvement of network is due to consumer and it is directly made by her/him (counted after its presentation). Maximum period to review the project when there is failure or lack of information from 10 days the distribution company in the previous analysis. Maximum period for attending requests for the inspection of meters and other 30 days measurement equipment. Maximum period for reconnection when found improper suspension of supply (with 4 hours company expenses). Maximum period for attending requests of reconnection to a consumer unit located in 24 hours an urban area, when ceased the reason for suspension. Maximum period for attending requests of reconnection to a consumer unit located in a 48 hours rural area, when ceased the reason for suspension. Maximum period for attending urgent requests of reconnection in an urban area, when 4 hours ceased the reason for suspension. Maximum period for attending urgent requests of reconnection in a rural area, when 8 hours ceased the reason for suspension. Maximum period to send a written notice to the consumer with a list of all companies’ 30 days local offices (upon request). Maximum period for inspection of a consumer’s equipment when there is a complaint 10 days about electrical damage (only consumers with nominal voltage below 2.3 kV). Maximum period for inspection of a consumer’s equipment used to store perishable 1 working foods or medicines when there is a complaint about electrical damage. day Maximum period to send a written notice to the consumer with the result of the request 15 days for reimbursement from electrical damage, counted from the date of the inspection or, in the absence of that, from the date of the request for reimbursement. Maximum period to compensate from electrical damage the consumer through payment 20 days in cash, or the repair or replacement of damaged equipment, after informing the consumer the result of the request for reimbursement from electrical damage. 110 | Transparency and Social Accountability in the Egyptian Power Sector Annex J1 | Information Items in Annual Data Packages Provided to EgyptERA by Distribution Companies Information Items – Distribution Companies 1. Contracts with customers and other licensees 2. Feasibility study of any project the applicant is planning to implement during the licensed year 3. Expansion studies, plans and the expected developments of the distribution facilities during the licensed year attached the program 4. Distribution license attachments which include the following: Attachment 1 • Operational Information on the distribution network • Total components of the transmission network in the fiscal year 2011–2012 • Quantities of energy exchanged in the distribution network (MWh) • Values of energy exchanged in the distribution network (EGP) • Number and nominal capacities of distributed generation units owned by the distribution company (isolated generation units) • Quantities and values of energy sold from distributed generation units • Malfunctions rates of the distribution network components • Information about the continuity of supply in MV network • Information about the quality of supply in MV network • Reports on replacement and rehabilitation of distribution facilities • Reports on technical losses • Reports on measurements of the quality of supply and the power factor improvement studies Attachment 2 • Number of residential consumers • Quantities of energy sold to residential sector • Values of energy sold to residential sector • Number of commercial consumers • Quantities of energy sold to commercial sector • Values of energy sold to commercial sector • Quantities and values of energy sold to housing companies • Number of consumers with capacity more than 500 kW • Quantities of energy sold to consumers with capacity more than 500 kW • Values of energy sold to consumers with capacity more than 500 kW • Number of consumers with capacity up to 500 kW • Quantities of energy sold to consumers with capacity up to 500 kW • Values of energy sold to consumers with capacity up to 500 kW • Number of consumers and quantities and values and of energy sold to public lighting • Information about collection and arrears Annexes | 111 Attachment 3 • Information about level of the service • Information about collection and arrears • Distribution of employment on the functional disciplines 7. Financial statements are required to renew the license and distribution include the following: • Final Financial Statements for the fiscal year after the approval of the General Assembly • Attachments and disclosures to the financial statements adopted on an annual basis • The auditor’s report on the financial statements and response to it • Approved planning budget • Financial planning model (soft copy + hard copy) • Technical and financial performance indicator used in the production companies 8. A detailed study on the cost of electricity distribution 9. Future plan to achieve the technical and financial performance indicators 10. Future plan to achieve total quality management 11. Receipt indicating the payment of the license fee 112 | Transparency and Social Accountability in the Egyptian Power Sector Annex J2 | Information Items in Annual Data Packages Provided to EgyptERA by Generation Companies Information Items – Generation Companies 1. Contracts with Customers and Other Licensees 2. Feasibility Study of any Project the Applicant is planning to implement 3. Expansion plans and studies of Generation facilities and implementation programs 4. Environment Agency Approval 5. Generation License Attachments which include the Following Attachment 1 • Generation Station Basic Information • Production, Consumption Capacity of the Generation Station, Power Connectors and Units • Performance and Operation Indicators • The value and the quantity of consumed fuel • Sold energy distributed on various voltages • Distribution of employment on the functional disciplines • Heat transfer diagram • Environmental Information 6. Other Financial Attachments • The final financial statements for the fiscal year is approved by the General Assembly on 06/30/each year • Attachments and disclosures to the financial statements adopted on 06/30 • The auditor’s report on the financial statements and respond to it • Approved planning budget • Financial planning model (soft copy + hard copy) • Depreciation Data 7. Annual report on the activity of the company and includes data on what has been achieved compared to the target and plan includes the following • The development of human resources • Periodic and preventive maintenance for the production facilities • Replacement and rehabilitation of the production facilities • Technical and financial performance indicator used in the production companies 8. A detailed study on the cost of electricity generation 9. Future Plan to achieve the technical and financial performance indicators 10. Future Plan to achieve total quality management 11. Receipt indicating the payment of the license fee Annexes | 113 Annex J3 | Information Items in Annual Data Packages Provided to EgyptERA by Transmission Company Information Items – Transmission Company 1. Contracts with customers and other licensees 2. Feasibility study of any project the applicant is planning to implement during the licensed year 3. Expansion studies, plans and the expected developments of the transmission facilities during the licensed year attached the program 4. Transmission license attachments which include the following Attachment 1 • Operational Information on the transmission network • Total components of the transmission network in the fiscal year 2011/2012 Malfunctions rates of the transmission network components during the fiscal year 2011–2012 • Information about transformers of the transmission network for each region • Information about transmission lines and cables of the transmission network • For each region • Information about delivery points of the transmission network for each region • Purchased energy from generation companies • Quantities of energy purchased from industrial companies on the ultra, high, and medium voltages • Energy sold to the distribution companies • Detailed statement of energy sales to customers • Distribution of employment on the functional disciplines Attachment 2 Final balance sheet for the year 2011–2012, after the approval of the general assembly on 30/6/2012 • Attachments and disclosures to the approved financial statements on 306/2012 • Proposed profit distribution • Cash flow table • Table of changes in equity share 5. Other financial attachments • Table of expenditures and revenues • Depreciation table • Gains and losses 6. feasibility study of any project the applicant is planning to implement 7. Environment agency approval 8. Previous experience in this field and management 9. Description of land and buildings upon which he shall perform the activity with copies of owner ship documents or his right to use those premises (original documents might be requested for comparisons) 10. Receipt indicating the payment of license fees 114 | Transparency and Social Accountability in the Egyptian Power Sector Annex K | Indicative Bill Format Proposed by EU Annexes | 115 116 | Transparency and Social Accountability in the Egyptian Power Sector MIDDLE EAST AND NORTH AFRICA ENERGY AND EXTRACTIVES GLOBAL PRACTICE THE WORLD BANK GROUP MENA ENERGY SERIES | REPORT NO. 93936-EG http://www.worldbank.org/en/region/mena | www.esmap.org | http://www.worldbank.org/en/country/egypt