FERC Accounting and Reporting Issues

Transcription

1 Background At the Spring Accounting Conference, we have scheduled a panel discussion on FERC Accounting and Reporting Issues. This agenda item is part of a larger effort to respond to an invitation from the FERC Chief Accountant regarding accounting and reporting matters that are of greatest concern to FERCjurisdictional companies. This is a unique opportunity to work collaboratively with a key regulator in addressing areas of concern to the industry. Each year, the EEI-FERC Liaison Group (representatives of EEI member companies who often also have natural gas operations) meets with the FERC Chief Accountant and various members of his staff to discuss accounting, reporting, and audit matters affecting FERC-jurisdictional companies. These discussions are interactive, informal, open, and increasingly productive in building our relationship with this key group. At the 2013 meeting, the group raised a number of areas in which our members were having increasing difficulty interpreting or applying the directions in the system of accounts and other FERC guidance. At that time, the FERC representatives noted that the process for amending the system of accounts is rather involved, occurs infrequently, and generally requires some type of more significant event to warrant undertaking the effort. Therefore, it was considered unlikely that ad hoc amendments would be forthcoming soon. However, the Chief Accountant asked the EEI-FERC Liaison Group to identify top areas of concern for our members where changes to the system of accounts or additional/revised guidance would be helpful. Once we have done so, he stated a willingness to consider other administrative means, such as accounting orders, by which some of those might be able to be addressed. The focus of these issues is areas where there is ambiguity or lack of guidance in how to apply the system of accounts. In some cases, this occurs because changes in the business since the system of accounts was issued do not clearly fall under any one area of the rules. We are not necessarily seeking to resolve all diversity or eliminate the need for each company to exercise judgment in applying the FERC requirements. Rather, we are seeking to identify broad areas where there is consensus that additional guidance is necessary for the reasons indicated above. A cross-section of EEI and AGA members has been working for several months to identify, understand, and prioritize our list of issues. Based upon their work to date, the group is providing the attached list for your review prior to the conference. The panel participants for the FERC issues agenda session will discuss selected issues, but they also are interested in your input. After the meeting, the group expects to finalize the list and provide it to the FERC Chief Accountant and his staff for consideration at our meeting later in Action Requested Please review the attached list of issues prior to the conference and come to the Tuesday FERC issues panel discussion prepared to provide any input that your company may have with respect to these issues, including agreement with the list, recommendations to add or remove items, or views about the priority of the issues. Spr i n g A c c o u n t i n g C o n f e r e n c e P a g e 1

2 Items focusing on Accounting and Reporting Guidance General Plant Considerations New types of communication equipment exist that send signals from functional plant equipment back to the office, such as meter readings, pressure readings, remote operation of equipment via radio, satellite, smart phone, etc. Member companies would like to know whether it is more appropriate to classify this equipment as account 397-Communication Equipment or in the functional 300 account. If the equipment should be assigned to the function, which account is most appropriate for each function? Ex.) Steam Production account 316-miscellaneous power plant equipment exists, but there is no such account for Distribution or Transmission. Production plants have original cost of offices recorded in their functional Structures and improvements account. These offices are furnished with equipment of a general nature. Member companies would like assistance determining whether the office equipment should be recorded to general plant or functional plant. Gas Pressure Changes In today s gas operations, pipeline pressure is changed from time to time from distribution levels to transmission levels and back again. Member companies are requesting clarification for the functional classification of gas pipe lines into Gathering Lines (Account 353), Transmission Mains (Account 367), and Distribution Mains (Account 376). What is the FERC guidance on when to transfer assets between functional groups and Is there a conflict between the Department of Transportation (DOT) and the FERC in regards to the determination of when pipe is to be functionalized as Gathering Lines and Transmission Mains? Generation Unit Classification and Reporting Expansion of Accounts all of the below matters were brought to the attention of FERC at the 2013 EEI-FERC Accounting Liaison Meeting. Whereas FERC s response to the requests discussed at the meeting was very non-committal, we feel it beneficial to continue to pursue change in these areas. Currently, the Uniform System of Accounts ( USofA ) does not contain specific accounts for renewable sources of generation ( Renewables ). Considering the growth in this area, member companies feel FERC should consider expanding the chart of accounts to include specific accounts for Renewables. Most companies, if not all, include renewable generation O&M and plant expenditures as part of Other Production. There would be better transparency in reporting if we had specific accounts. Spr i n g A c c o u n t i n g C o n f e r e n c e P a g e 2

3 The FERC USofA currently does not address which accounts to use for various utility transactions such as Renewable Energy Credits and NOx and Carbon Allowances. For example, Other Power Generation O&M (FERC accounts ) does not have an account for allowances. Some member companies have emission allowance costs associated with Other Power Generation (natural gas) and are currently recording the expense to FERC account 509, which is the allowance account for Steam Power Generation. This is another example of where transparency in reporting is limited by the lack of specific accounts. Member companies would like clarity from FERC regarding classifying certain production assets, such as Combined Cycle Generating Facilities and Integrated Gasification Combined Cycles. These facilities do not have a specific classification and more often times than not are classified as Other Production. Earnings and Expenses during Construction In the current regulatory environment, many electric utilities are facing significant retirements within their coal-fired generation fleet. In some cases, it is economically feasible to convert the fuel source of an existing coal-fired unit from coal to another source, such as natural gas or wood waste, and doing so would allow the unit to continue to operate under current/new environmental regulations. Significant testing is required as part of the fuel source conversion construction process. FERC s Electric Plant Instruction 18 states The earnings and expenses during construction shall constitute a component of construction costs. Member companies would like clarity on whether this instruction applies only to new plants under construction that have yet to go commercial, or could it also apply to plants already in service. Plant Held for Future Use Land o EITHER acquired and never used but with a plan for use OR used and retired with a plan for reuse Other than land o EITHER acquired and never used but with a definite plan for use OR used and retired with a definite plan for reuse Member companies would like examples of plan and definite plan to understand the distinction. If land is sold or otherwise disposed of, the gain is recorded to or loss to Member companies would like it made clear whether gains or losses resulting from sales or dispositions of plant other than land should also be recorded to 411.6/411.7; otherwise please provide account(s). Spr i n g A c c o u n t i n g C o n f e r e n c e P a g e 3

4 FERC has indicated that no AFUDC is to be calculated on assets held in account 105, unless the utility can prove that account 105 is not subject to rate base treatment. Member companies would like to know: If this position is still supported by the Commission; If the land is subsequently transferred to account 107, can AFUDC be accrued on the transferred land until the project is complete; and What should be the land s role in AFUDC calculations? Energy Storage Order 784 requires that plant costs related to energy storage are recorded in identifiable functional classes. A single asset can be used in multiple functional groups (generation, transmission, distribution) during a reporting period, and the distributed use of that asset between functional groups can change over time. Member companies would like clarification on the following accounting and ratemaking issues related to allocation of plant costs: The factors of cost causation and how the utilities measure usage for each function (e.g., time of usage). The FERC and other jurisdictional regulatory bodies will coordinate changes to the cost recovery allocation percentages so that 100% of energy storage plant costs are recovered in rates (no under- or over-collections). A reasonable basis for changing the allocation factors, such as only through period rate case decisions. Changes to allocation percentages between functional groups are applied prospectively, so that historic plant costs do not require restatement. In addition, different functional classes have different depreciation rates. Periodic reclassification of plant for reporting and ratemaking purposes can create scenarios where plant is over or undercollected. Member companies would also like clarification that FERC and other jurisdictional regulatory bodies will coordinate establishment of depreciation rates so that all energy storage plant assets are depreciated using the same rates, regardless of the functional group. Order 784 also established new FERC Form 1 pages , Energy Storage Operations (Small Plants). Member companies would like to know what costs should be recorded in Other Expenses (Column I)?" Spr i n g A c c o u n t i n g C o n f e r e n c e P a g e 4

5 Other Accounting Guidance Retirements and AROs Member companies would like clarification whether ARO assets should be retired when the underlying asset is retired or when the ARO is fully remediated. Member companies would also like guidance on how to account for the long-term monitoring of assets, such as ash ponds, that give rise to AROs. Should the ARO remain open until the on-going monitoring period is over? Plant Purchased or Sold (Account 102) o Gains and losses should be recognized when an operating unit or system is sold. Member companies would like additional guidance and examples on what constitutes an operating unit or system. Interconnection Studies o Costs incurred to conduct generation interconnection studies for proposed interconnections with the transmission system should be recorded in FERC account o Utilities may incur costs for solar studies that connect to the distribution system as opposed to the transmission system. Member companies would like clarification on which FERC account should be used to record costs incurred to conduct generation interconnection studies for proposed interconnections with the distribution system. Derivative Instrument Assets (Account 175) o Record gains in account 421, miscellaneous nonoperating income, and losses in account 426.5, other deductions. o However, for FTR assets recoded in account 175, revenues and losses are being flowed through fuel recovery mechanisms. Member companies would like clarification that this treatment of FTR assets is more similar to more similar to cash flow hedges recorded in account 176, and the change in fair value should be charged to account 219 (AOCI). Page-Specific Instructions Users of the FOSS software would benefit from updated or improved instructions on individual pages. Specific areas for clarification include: Provide specificity on whether pages request quarter-to-date or year-to-date data (Form 3-Q). Specific examples for clarification will include pages 231, 232, 300, 324, 328, 332, and 397. Spr i n g A c c o u n t i n g C o n f e r e n c e P a g e 5

6 Additional clarifications include: o Page 335: No specific instructions are provided on the page. o Page : Do the reporting requirements only include activity in FERC account 928? o Pages 400 & 401b: These pages have similar instructions. Provide clarification to ensure correct reporting. o Page : Per instructions 7 and 10, FERC account 547 is included in two different reporting lines, resulting in double-counting. o Page : Please clarify if the sum of Production Expenses should agree to Operating & Maintenance expense amounts reported on Page 320. o Page : Please clarify whether Instruction 6 requests total pole miles or circuit miles. o Page : Please provide threshold for identifying minor revisions of lines. Long-Term and Other Issues Codification or Communication of Accounting Guidance EEI s constituent members appreciate FERC s hard work in providing detailed guidance via FERC orders and detailed findings on individual audit findings by company. However, when accounting interpretations are provided by individual company orders (including compliance audit findings) that are relied upon by the FERC staff as precedence, it is difficult to keep up with all the orders and extract this information. A codification similar to what the FASB has constructed, that links all guidance, examples and FERC orders, all accessible in one place, will cut down on the hours of research time when issues arise and ensure both higher company compliance and lower audit findings, reducing wasted effort by both FERC staff and the companies it regulates. Some specific examples include: Clarifying common coding errors discovered across FERC audits in the chart of accounts (which may not be posted on the FERC website s Accounting Guidance section), such as: o FERC account 426.4, Expenditures for certain civic, political and related activities, should also include portion of industry and professional association dues that support lobbying. o FERC account 426.5, Other deductions, should include legal settlements pertaining to discrimination matters. AFUDC calculation -- The FERC chart of accounts provides information and the formula for the calculation of AFUDC. However, many of the finer points and requirements of the calculation can only be found in Federal Power Commission (FPC) Orders dating back to the 1970s. There is no definitive source to search orders to find all references to accounting topics so as to understand all of FERC s requirements. Searches of the FERC website are difficult and do not yield information such as the AFUDC FPC Orders. Spr i n g A c c o u n t i n g C o n f e r e n c e P a g e 6