Overview of Formula Rates in 7 States

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Overview of Formula Rates in 7 States Joy Nicdao-Cuyugan, Director of Financial Analysis (ICC) Joy.Nicdao-Cuyugan@Illinois.gov September 12, 2017 Springfield, IL NARUC Staff Subcommittee on Accounting & Finance Meeting 9/12/2017 1

Formula Rates - Caveats Disclaimer: The information I present today should not be construed to represent the opinions or viewpoints of the Illinois Commerce Commission or of its staff. Formula rates differ across states. And within the same state, they can differ between gas and electric. And within the same industry, they can differ across companies. Thus, some generalizations were necessary. Refer to the state statutes, orders or company tariffs for complete information. 9/12/2017 2

Formula Rate Annual Proceedings Approximate Length (Months) SC 4 Filed June 15, Effective November OK 4 Filed March 15, Effective July MS 3 Filed Nov 15, Effective February or April LA 4 Electric filed May 31, Effective Sept or Oct IL Filed by May 1, Effective January 8 AR Filed 180 days before rates in effect 6 AL 1 Filed one month before rates in effect 9/12/2017 3 0 1 2 3 4 5 6 7 8 9

Authority & Applicability Per State Law Per Commission Order 2015 March Arkansas (Act 25 and Administrative Code 23-41201 Formula Rate Plan) All IOUs. Entergy AR, OG&E, CenterPoint Energy AR Gas. 2011 October Illinois (Section 16-108.5 IL Public Utilities Act Performance Based Formula Rate) Investor owned electrics: Commonwealth Edison (Rate DSPP) and Ameren IL (Rate MAP-P) 2005 February South Carolina (Article 4, Section 58-5-400 to 480 Rate Stabilization Act) Investor owned gas: South Carolina Electric & Gas, and Piedmont Natural Gas 1982 Alabama (Rate Stabilization & Equalization) Investor owned electric & gas: Alabama Power, Alabama Gas Co., Mobile Gas Service Corporation. 1996 (electric) & 2005 (gas) Louisiana (Formula Rate Rider) Atmos Energy (Rider RSC), AEP/SWEPCO, CenterPoint Energy, CLECO, Entergy LA and Gulf States, South Coast Gas Late 1990s Mississippi Investor owned electric & gas: Mississippi Power (PEP-5A), Entergy MS (FRP-6), Atmos Energy (Stable/Rate Adjustment Rider), Wilmut Gas & Oil (Rider RSA) 2004 Oklahoma (Performance Based Rate Change Plan) Investor owned Gas: 9/12/2017 Oklahoma Natural 4 Gas and CenterPoint Energy Oklahoma Gas Company.

Test Year Most use actual data from most recent calendar year (historical test year) with the exception of Mississippi and Oklahoma. Mississippi also allows use of a projected test year. Oklahoma designates the calendar year of the filing as the test year. No pro forma adjustments. December operating expenses are annualized. Historical test years usually allow for pro forma plant additions plus known and measurable changes. 9/12/2017 5

How the Mechanism Works For 5 out of 7 states, an adjustment to base rates is made only if the earned return measure (either ROE, weighted ROE or overall rate or return on rate base) falls outside a pre-determined dead band around a target/benchmark return measure. Rates are increased (or decreased) to achieve the target return. Increase rates - Target Return Reduce rates 0% No Change in Rates in Dead Band Zone 20% Lower Band Limit Upper Band Limit In Illinois, however, rates are increased (or decreased) to bring the return measure to either the lower band limit (if company under earned) or to the upper band limit (if company over earned). Thus, companies keep the gains or losses within the dead band. In Mississippi it s more complicated! + 9/12/2017 6

Dead Band Example Assume target return is ROE of 9% and dead band is +/- 50 basis points: 7.5% 8.5% 9% 9.5% 10.5% If earned ROE is 7.5%, then rates are increased to produce 1.5% (9% target - 7.5%) incremental change in ROE. If earned ROE is 10.5%, then rates are decreased to produce -1.5% (10.5% - 9% target) incremental change in ROE. No rate change within the band. In Illinois, however, rates will change even if earned returns fall within the dead band. Under the 7.5% earned return scenario, rates would be adjusted further by 1%, which is the difference between 8.5% (lower band limit) and 7.5%. And under the 10.5% earned return scenario, rates would be adjusted further by a -1% (9.5% upper band limit - 10.5%). 9/12/2017 7

Base Rate Adjustments AL How the Mechanism Works Actual weighted ROE (common equity ratio x ROE) compared to 5.98% target weighted ROE. Actual weighted ROE dead band is <5.75% or >6.21%. Target weighted ROE = 5.98%. Performance-based adder of 0.07% if utility has an A credit rating and is in top third of most recent customer value benchmark survey. Caps/Floors Rate increase in any two consecutive years must not exceed 4%. No single year increase can exceed 5%. AR Earned ROE compared to target ROE approved by Commission in utility s last rate case. ROE dead band of plus/minus 50 basis points from target ROE. Rate adjustment based on difference from target ROE, multiplied by common equity portion of rate base and gross conversion factor. IL Revenue requirement (RR) based on most recent FERC Form 1 used to set new rates for the next year. FR case also includes a reconciliation of test year RR approved in last FR case to actual RR using actual costs for that past year. Reconciliation refund/surcharge charged in next calendar year. Total revenue increase or decrease not to exceed 4% for each rate class from preceding 12 calendar months. Average annual rate increase in the first three years of the law s operation should not exceed 2.5% Target ROE = 580 basis points + average of prior year s monthly US T-Bond yields. ROE Collar: 50 basis points above or below target ROE. ROE penalties capped to a total of 30 to 38 basis points for failure to meet 8 performance metrics. 9/12/2017 8

Sharing band at given levels for some companies. MS OK SC Base Rate Adjustments (continued) How the Mechanism Works Earned return on rate base (RORB) for prior year compared to the Range of No Change. The latter is the benchmark RORB (BRORB) plus or minus adjustments for company performance as measured by customer price, satisfaction and service reliability. RORB dead band of plus/minus 50 basis points. BRORB = target overall rate of return approved by Commission. Look Back provision Annual comparison each year after the FR case. Compares BROB to company earned RORB for that year. Difference is refunded or charged to ratepayers. Earned ROE compared to a benchmark ROE. ROE dead band of plus/minus 50 basis points. (Same as AR and SC) When earned ROE exceeds the ROE upper band limit, the excess earnings is shared by customers (75%) and the company (25%). Program has separate energy efficiency feature with a utility incentive that can increase rates. Earned ROE compared to allowed ROE at the time the utility applies for formula rates. ROE dead band of plus/minus 50 basis points from allowed ROE. (Same as OK and AR) Caps/Floors No rate change if adjustment is less than $250,000 or > than 4% increase in annual aggregate retail revenues. Rate changes less than 2% automatically go into effect in first billing cycle of February. No rate change if adjustment is less than $250,000. LA Earned ROE compared to target ROE approved by Commission. For gas, earned ROE calculated using a benchmark O&M previously established by Commission. ROE dead band of plus/minus 50 basis points (electric) or 80 basis points (gas). 9/12/2017 9

In summary With exception of IL, rates are adjusted based on a comparison of an earned return measure to a target or benchmark return measure. All have a ROE or ROR dead-band that determine if there is to be a change in rates. In contrast, IL rates change annually. The ROE collar serves as a further adjustment (+/-) to that rate change. 4 have a performance-based component (AL, IL, MS, OK). 4 have a rate cap and 2 have a floor. 2 have some type of sharing excess returns between shareholders and ratepayers (LA and MS). 2 have a type of reconciliation after the formula rate case (IL and MS). 9/12/2017 10

How is it Working? Residential Average Price of Electricity Jun-17 Jun-16 New England 19.37 18.9 Middle Atlantic 16.49 15.98 East North Central 13.49 13.02 llinois 12.95 12.2 West North Central 13.36 12.75 South Atlantic 12.2 11.84 East South Central 11.47 10.93 Alabama 12.79 12.16 Mississippi 11.4 10.6 West South Central 10.93 10.54 Arkansas 10.73 10.31 Louisiana 10.19 8.96 9/12/2017 11 Source: EIA Table 5.6.A Avg Price of Electricity to Ultimate Customers by End Use Sector, August 24, 2017