Hydro-Quebec Trans-Énergie Application R-3605-2006 KEY ACCOUNTING POLICIES Original: 2006-07-06 HQT-4, Document 2 Page 1 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 TABLE OF CONTENTS A KEY ACCOUNTING POLICIES 6 A.1 Capital assets 6 A.2 Abandoned or delayed major projects 7 A.3 Deferral of development costs 7 A.4 Global program for the safety of the transmission network 8 A.5 Costs of switchyards owned by private producers 8 A.6 Government compensation related to 1998 ice storm 8 A.7 Materials, fuel and supplies 9 A.8 Long-term debt 9 A.9 Currency conversion and derivative instruments – currency swaps 9 A.10 Derivative instruments - interest rate swaps 9 A.11 Intangible assets 10 A.12 Long-term asset retirement and abandonment of activities 10 A.13 Asset retirement obligations 10 A.14 Long-term depreciation of assets 11 A.15 Hedging relationships 11 A.16 Re-classification of effect of hedged sales in American dollars 11 B CHANGES OR ADDITIONS TO KEY ACCOUNTING POLICIES 13 B.1 Determining whether an arrangement contains a lease 13 B.2 Application of new accounting standards coming into force January 1, 2007 regarding the accounting of financial instruments 14 Original: 2006-07-06 HQT-4, Document 2 Page 2 of 22 Hydro-Quebec Trans-Énergie Original: 2006-07-06 Application R-3605-2006 HQT-4, Document 2 Page 3 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 The Transmission Provider’s consolidated financial statements are drawn up in compliance with Canada’s generally accepted accounting principles (GAAP) as established by the Canadian Institute of Chartered Accountants (CICA,) and take into account certain accounting methods and accounting practices generally accepted by the Régie de l’Énergie (the Régie.) Where applicable in order to calculate revenue, the Transmission Provider takes into account accounting policies in use by Hydro-Quebec on December 31, 2005, as described in the supplementary notes of the consolidated financial statement presented in its 2005 annual report. Section A following summarizes those accounting policies pertinent to the current application which have been accepted by the Régie as well as a re-classification for the purposes of presentation of financial information. Section B outlines amendments or additions for which the Transmission Provider seeks approval from the Régie, as well as the Transmission Provider’s strategy regarding the application of new accounting norms which will be in force January 1, 2007 regarding the accounting of financial instruments. Original: 2006-07-06 HQT-4, Document 2 Page 4 of 22 Hydro-Quebec Trans-Énergie A Application R-3605-2006 KEY ACCOUNTING POLICIES A.1 Capital assets Tangible capital assets are recorded at cost. This cost includes materials, labor, other costs directly related to construction activities, and financing costs capitalized at the capital cost rate authorized by the Régie during the period the work is executed. It also comprises the levelized value of asset retirement obligations. When necessary, the cost takes into account contributions received from third parties other than those affected by decisions D-2006-76 and D-2006-76R, and the net cost of dismantling assets which have been replaced. Since May 10, 2006, in compliance with decisions D-2006-76 and D-2006-76R, contributions received from third parties for additions (déplacements) or modifications to the transmission network are recorded in a deferred credit account for capital assets. These contributions are amortized over the average life of the assets of each project using the compound interest method at a rate of 3 per cent. The cost of capital assets under construction is transferred to operational capital assets when construction is complete and the installations enter service, with certain exceptions to be determined by the Régie. The capital assets are then amortized for the duration of their useful life mainly using the compound interest method at a rate of 3 per cent. The Act respecting Hydro-Quebec defines the maximum amortization period as 50 years. Capital assets used to transmit electricity are mainly amortized over periods of 30 to 50 years. Upon retirement of capital assets, the cost of the assets and of dismantling the assets, minus the cumulative amortization and the recuperation value, are recorded in a separate account and amortized over a maximum period of 10 years using the compound interest method at a rate of 3 per cent. When these capital assets are Original: 2006-07-06 HQT-4, Document 2 Page 5 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 replaced, the cost of dismantling, minus the value of recuperation, is added to the cost of the new capital assets and amortized according to the method and amortization period applicable to the new asset. A.2 Abandonment or delay of major projects The costs involved in capital investment projects are periodically re-evaluated. During the re-evaluations, Management uses estimates and formulates hypotheses regarding the profitability of the projects as a function of expected prevailing market conditions when the project becomes operational, compliance with the principles of sustainable development and reception in local communities. A capital project is generally considered to have been delayed or suspended when work has been stopped for longer than 12 months. The capitalization of loan costs ceases as soon as a decision is made to delay or suspend a project. Costs are attributed to ongoing capital projects as long as they represent future value to the company. When they no longer represent future value, they are transferred to expenses except when a major project is abandoned. In this last case, costs identified as unrecoverable are deferred and amortized over a period of 3 years using the straightline method, subject to a decision by the Régie in each case. A.3 Deferral of development costs Development costs incurred during research and development activities are recorded against the balance sheet of the project, unless they conform to GAAP criteria and the thresholds set by the Transmission Provider for capitalization. Deferred development costs are amortized over a 5-year period using the straight-line method. This period begins the year following the year in which the costs were recorded. Development costs must be capitalized until they are concurrent with an amount which there is a reasonable certainty of recuperating through additional revenues or reduction Original: 2006-07-06 HQT-4, Document 2 Page 6 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 of future expenses. The surplus of the balance of development costs over net future income is recorded against the expenses of the project underway. A.4 Global program for the safety of the transmission network (GPSTN) After the 1998 ice storm, the Transmission Provider developed a plan involving numerous investment projects to secure the transmission network. For these projects, the Régie authorized the use of a deferred costs account to record the costs of the GPSTN, which, according to GAAP, could not be recorded as capital assets. The costs attributed to the deferred costs account accumulate by project and are amortized using the compound interest method at a rate of 3 per cent, over a period corresponding to the remaining average useful life of total project assets which benefited from improvements. A.5 Costs of switchyards owned by private producers In compliance with Appendix J of the Rates and Conditions of Hydro-Quebec Transmission Services, the Transmission Provider is obliged to reimburse, up to the maximum projected amount, costs incurred by a private producer for the acquisition and installation of equipment for the producer’s switchyard as well as an amount for operating costs and maintenance of such equipment. These amounts are recorded in a deferred costs account. The amounts contributed for the equipment are amortized over a period representing the life of similar Hydro-Quebec equipment, using the compound interest method at a rate of 3 per cent. The amounts disbursed for operating costs and maintenance are amortized over a 20-year period, using the straight-line method. A.6 Government compensation related to 1998 ice storm Government compensation for the 1998 ice storm is amortized over the remaining useful life of retired assets, except the portion equivalent to the non-amortized cost of these assets which is amortized over a 10-year period. In both cases, the compound interest method is applied at a rate of 3 per cent. A.7 Materials, fuel, and supplies Original: 2006-07-06 HQT-4, Document 2 Page 7 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 Stocks of materials, fuel and supplies are recorded at the lesser of cost or the net realizable value, using the average cost method, and including a provision for regular review and identification of obsolete material. A.8 Long-term debt Long-term debt is recorded at nominal value, except for zero-coupon or significantly discounted bonds, which are recorded at their discounted value. The discounts, premiums and issuance costs are deferred and amortized using the straight-line method for the duration of the loan. Significant discounts and premiums are amortized using the real interest method. A.9 Currency conversion and derivative instruments – foreign currency swaps The products and expenses of operations conducted in foreign currencies are converted into Canadian dollars at the exchange rate effective during the operation. The monetary elements of assets and liabilities are converted at the closing rate on the date of the balance statement. The non-monetary elements are converted at the exchange rate effective during the operations. Short-term foreign exchange gains or losses resulting from the conversion of monetary elements are included in results. Long-term foreign exchange gains or losses resulting from the conversion of monetary elements, including currency swaps, are also included in results, unless they are related to liability elements hedging sales in American dollars, in which case they are deferred to the year the transaction is realized. A.10 Derivative instruments - interest rate swaps Interest exchanges, accounted as hedges and resulting from swaps used to modify longterm interest rate risk exposure, are recorded along with the interest expense recorded for the loans to which they are tied. A.11 Intangible assets Original: 2006-07-06 HQT-4, Document 2 Page 8 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 Intangible assets are recorded at cost. Indefinite life intangible assets are not amortized. These assets undergo a depreciation test at least annually and any amount by which the carrying value exceeds the fair value is reported during the period during which the depreciation occurred. Intangible assets with a limited useful life are amortized for the duration of that period. The methods and amortization periods used for these assets are: • Software, licenses and patents: Straight-line method and compound interest method, 3 per cent, 3 to 20-year period. • Environmental studies: Composed interest method, 3 per cent, 5-year period. A.12 Long-term asset retirement and abandonment of activities Long-term assets destined for sale must be evaluated at the lesser of their carrying value and fair value, minus the costs of retirement, and must cease to be amortized. All losses must be recognized in the results. Long-term assets destined for retirement other than through sale continue to be evaluated at their carrying value and to be amortized until retirement. A.13 Asset Retirement Obligations The liability for an obligation associated with the retirement of a capital asset is initially evaluated at fair value during the period in which the obligation emerges, when it is possible to reasonably estimate the fair value. The resulting cost is capitalized into the carrying value of the capital asset in question and is amortized for the life of the asset. In subsequent periods, the liability is adjusted to reflect any change due to the passage of time through a transfer to the operating costs. The liability is also adjusted to take into account changes to the retirement time-line or non-discounted cash flow with respect to the original estimate, through a re-assignment to the cost of the asset in question. Original: 2006-07-06 HQT-4, Document 2 Page 9 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 A.14 Long-term depreciation of assets The long-term depreciation of an asset must be recognized in the results when the carrying value exceeds the total non-discounted cash flows which will result from the operation and eventual retirement of the asset. The loss in value corresponds to the surplus of the carrying value of the asset over its fair value, and this amount becomes the new base cost of the asset. A.15 Hedge Accounting The Transmission Provider applies the recommendations of the CICA Manual’s Accounting Guideline 13 (AcG-13) entitled Hedging Relationships, which establishes the conditions under which hedge accounting can be applied. The guideline discusses the identification, designation, documentation and effectiveness of hedge accounting as well as the discontinuance of hedge accounting. Derivative financial instruments which do not meet the hedge accounting admissibility criteria outlined in AcG-13 are recognized at fair value in the balance sheet and fluctuations in fair value are recognized in the results. Hedging relationships which ceased to be admissible to hedge accounting with the application of AcG-13 beginning January 1, 2004 were recorded in compliance with planned transitional guidelines. The difference between the carrying value and fair value of derivative instruments which had been the object of hedge relationships was deferred and will be recognized in the income statement for the same period as the gains, losses, revenues and expenses related to the initial hedged item. A.16 Re-classification of the effect of hedged sales in American dollars The company records the effect of hedges to compensate the hedged elements with one significant exception, which is the presentation as financial costs of foreign exchange Original: 2006-07-06 HQT-4, Document 2 Page 10 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 gains and losses associated with debts and swaps designated as hedges of sales in American dollars. More precisely, Hydro-Quebec holds debts and swaps in American dollars of which the fluctuations due to the exchange rate compensate the company for the inverse effect on its sales in American dollars. These debts and swaps are, from an economic and accounting point of view, in a hedge relationship with the sales. Historically, all foreign exchange gains and losses were recorded in the line-item Exchange Losses in the category Financial Costs, regardless of the hedged item. In a report submitted in March 2005, Hydro-Quebec’s external auditors noted this state of affairs. Hydro-Quebec’s management decided to delay implementing change until more profound analyses could be conducted; on the one hand, of the accounting of all its financial instruments, including derivative instruments, and on the other hand, of the implications of this change for the matter of the regulatory approach to the risk of change in the presumed cost of the debt. Following work completed in 2005, Hydro-Quebec adopted in 2006 a method under which the effect of the hedging of sales in American dollars with debts and swaps is reclassified under the Products line-item, therefore including the hedged item. This hedging effect is therefore no longer included in financial costs. In this way, the presentation is coherent with the economic objectives of the hedge and with the accounting standards for hedging applicable to this relationship. Further, the cost of the debt is largely protected against the volatility caused by the risk of change. The impact of this re-classification is a transfer to the Products of Hydro-Quebec of a gain of $130 M for 2006 and $200 M for 2007. Original: 2006-07-06 HQT-4, Document 2 Page 11 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 B AMENDMENTS OR ADDITIONS TO THE KEY ACCOUNTING POLICIES B.1 How to determine if an arrangement contains a lease As of January 1, 2005, for the purposes of the Transmission Provider, Abstract of deliberations EIC-150, produced by the CICA’s Committee on New Problems, stipulates that an arrangement regarding an operation or a series of related operations which does not take the legal form of a rental agreement, but which confers the right to use a capital asset in consideration of a payment or series of payments, falls under the scope of Chapter 3065 of the CICA Manual, entitled Rental contracts. When a rental contract transfers practically all the advantages and risks inherent in property to the lessee, it is defined as a capital-leasing and the lessee must record an asset and an obligation for the levelized value of the required payments, minus the part of those payments covering costs related to use of the good. In other cases, it is defined as an operating lease where the required rent must be recorded in the income statement using a linear formula applied for the duration of the agreement, except if another formula can better respect the curve along which the user of the good obtains an advantage. For example, the application of this new accounting practice could produce a case in which a connection contract with the private owner of a generating station would be considered to contain a capital lease insofar as it involves contributions disbursed for the switchyard. This modifies the nature of the transaction to be recorded on the Transmission Provider’s books. In this case, the contribution to reimburse the cost of acquisition and installation of the switchyard equipment is part of the rate base, but is recorded under the line-item Operational Capital Assets instead of Non-amortized Expenses and Other Assets, as Other Deferred Costs. This type of modification has no Original: 2006-07-06 HQT-4, Document 2 Page 12 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 impact on the calculation of revenue required from the Transmission Provider because the method and amortization period of this contribution remain the same. Further, the nature of the contribution in terms of the operating costs and maintenance recorded by the Transmission Provider remains the same. B.2 Application of new accounting policies in use beginning January 1, 2007 concerning the accounting of financial instruments Hedging relationships prior to January 1, 2007 As of January 1, 2004, The Transmission Provider has adopted the Accounting Guideline entitled Hedging Relations (AcG-13) which sets out the conditions of application of hedge accounting, and which can be summed up as requiring adequate documentation and a demonstration of the effectiveness of the hedging relationships. Since the majority of the company’s hedging relationships respect the criteria established by AcG-13, hedge accounting may be applied in these cases. The derivative financial instruments which do not meet the admissibility criteria for hedge accounting set out in AcG-13 are recognized in the balance sheet at fair value, and variations in fair value are recognized in the results. The impact of these guidelines on the cost of the regulatory debt is therefore insignificant. Financial instruments and hedge accounting after January 1, 2007 Beginning January 1, 2007, Hydro-Quebec will adopt new accounting norms for financial instruments. These new norms are covered in the three new chapters of the CICA Manual: Chapter 3855, Financial Instruments – Accounting and evaluation This chapter establishes the policies for accounting and evaluating financial assets, financial liabilities and non-financial derivatives. It also covers recording of gains Original: 2006-07-06 and losses on financial instruments. HQT-4, Document 2 Page 13 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 Chapter 3865, Hedges This chapter reiterates the recommendations of AcG-13 regarding the application of hedge accounting and gives specifics on the application of hedge accounting. Chapter 1530, Comprehensive Income This chapter introduces new rules concerning certain gains and losses which are temporarily accumulated outside net income to be re-classified when appropriate. The comprehensive income and the elements it comprises must be presented in a financial statement of the same prominence as other statements included in a complete financial statement. Effects of the implementation of the new norms a) Accounting of derivative instruments and application of hedge accounting Beginning January 1, 2007, all derivative instruments will be evaluated at fair value. The gains and losses associated with fluctuations in fair values will need to be recognized in the results unless these items are designated as part of a hedging relationship. Under such conditions, the new norms allow the application of special accounting rules which allow gains, losses, products and expenses which compensate each other effectively to be recorded in the results in the same period or periods. The effect of these special rules, essentially, is to preserve the objective of hedge accounting as practiced under existing policies. Therefore, the application of the new policies will ultimately have little impact on the level of cost of the regulatory debt. There are two types of hedges: 1. Fair value hedge This type of hedge generally applies to situations where the Transmission Provider converts a fixed-rate debt to a floating-rate debt through a swap. In the case of a fair value hedge, the fluctuations in fair value of a derivative (where the swap receiver fixed and the payer floating) are recognized in the Original: 2006-07-06 HQT-4, Document 2 Page 14 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 results. Simultaneously, the fluctuations in fair value of the hedged item (the debt) attributable to hedged risk must be recorded as adjustments of the carrying value of the hedged item and recorded in the income statement. Analysis of the accounting of this type of hedging relationship shows that the effect of recording a derivative at its fair value is compensated by the effect of having to record an adjustment to the hedged item, except when the relationship is ineffective. Ineffectiveness exists when the fluctuations in value of the hedging instrument and the hedged item do not cancel each other out completely. The presence of ineffectiveness is not systematic. Many existing relationships, as well as most of the new relationships, are considered perfectly effective. Furthermore, if there is inefficiency, the effect remains secondary because otherwise accounting norms would not permit hedge accounting. The new norms do not modify the criteria which must be met to benefit from hedge accounting. But any imperfection in the hedge relationship must be recognized and reported on an on-going basis rather than deferred. Compared to existing policies, there is therefore a temporal difference in the recognition of imperfections in hedge relationships. However, this difference obviously works out to zero over the duration of the relationship. 2. Cash flow hedge This type of hedge applies, for example, when a company transforms a floating Canadian debt into a fixed-rate debt or when it converts a fixed- or floating-rate foreign currency debt into a fixed-rate debt in Canadian dollars. In the case of a cash flow hedge, the fluctuations in fair value of the derivative which constitute an effective hedge are reported in the comprehensive income statement while, if necessary, the ineffective portion of these variations must be recorded on the net income statement. The recording of the efficient element in Original: 2006-07-06 HQT-4, Document 2 Page 15 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 the comprehensive income statement allows the deferral of recognition of gains and losses in the income statement, in order to recognize them when appropriate. In this way, gains and losses deferred in the comprehensive income statement are re-classified in statements for the period or periods when the hedged item affects the results. Original: 2006-07-06 HQT-4, Document 2 Page 16 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 Here is an illustration of the application of the new standards for the accounting of derivative instruments. Table 1 Accounting of derivative instruments Before Balance After Statement Balance Long-term results Statement Currency swap Fixed US-Var CAD: Fair Value Hedging Relationship See Example 1 At cost DEBT SWAP NET +reevaluation at current exchange rate At cost = 0 Fluctuation in exchange rate -fixed-rate coupon $US Re-evaluation at fair value1 Fluctuation in fair value -fixed-rate coupon $US +reevaluation at current exchange rate Fluctuation in exchange rate + fixed-rate coupon $US – floating-rate coupon $CAD Re-evaluation at fair value Fluctuation in fair value + fixed-rate coupon $US – floating-rate coupon $CAD Perfect compensation Perfect compensation – floating-rate coupon $CAD Perfect compensation if no ineffectiveness Perfect compensation if no ineffectiveness – floating-rate coupon $CAD Interest rate swap Floating CAD-Fixed CAD: Cash Flow Hedging Relationship See Example 2 At cost -floating-rate coupon $CAD DEBT At cost = 0 SWAP + floating-rate coupon $CAD –fixed-rate coupon $CAD -fixed-rate coupon $US At cost Fluctuation in fair value Re-evaluation at fair value Effective portion of the fluctuation in fair value of the swap NET – fixed-rate coupon $CAD Perfect compensation if no ineffectiveness + floating-rate coupon $CAD – fixed-rate coupon $CAD Reclassification of the fluctuation in fair value in the comprehensive income statement2 Perfect compensation if no ineffectiveness – fixed-rate coupon $CAD 1 : Adjustment due to the application of hedge accounting and corresponding to the fair value of the portion attributable to hedged risk only. 2 : Reclassification due to the application of hedge accounting and corresponding to the effective portion of the fluctuation in fair value of the swap. Original: 2006-07-06 HQT-4, Document 2 Page 17 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 Example 1: Fair value hedge Hedged item: Fixed-rate debt 5,5 %, $100M US issued January 1, 2006 Hedging item: SWAP received $100M US at fixed-rate 5,5 % disbursed $100M CAD at floating rate (first fixing at 7,2 per cent) transaction date January 1, 2006 Hedged risk: Fluctuation in fair value of the debt associated with the risk of the interest rate swap and the exchange rate Date of designation: January 1, 2006 Exchange rate: Historic rate: 1,00 January 31 rate: 1,07 Note: The hedging relationship is assumed to be perfectly effective. Original: 2006-07-06 HQT-4, Document 2 Page 18 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 After Before 2006-01-01 (100) - (100) - - - - - (7) 7 (7) 7 7 (7) 7 (7) Re-evaluation of the derivative at fair value (excluding conversion) _ _ (5) 5 Re-evaluation of the derivative at fair value3 (excluding conversion) _ _ 5 (5) (0,5) 0,5 (0,5) 0,5 Interest coupon for: Swap- receipt Swap – disbursed 0,5 (0,6) (0,5) 0,6 0,5 (0,6) (0,5) 0,6 Debt Interest (100) (0,6) 0,6 (100) (0,6) 0,6 Issuance of debt ($100m US * 1,00) Conversion of debt at current exchange rate $100M US * (1,07-1,00) Conversion of swap at current exchange rate Coupon for debt interest Total Results Results Cost of derivative 2006-01-31 Balance sheet Balance sheet Example 2: Cash flow hedge Hedged item: Floating-rate debt $100M US issued January 1, 2006 (first fixing at 6 %) Hedging item: SWAP received $100M at floating-rate (first fixing at 6 %) disbursed $100M at fixed rate 7,2 % transaction date January 1, 2006 Hedged risk: Variation in cash flow associated with interest rate swap Date of designation: January 1, 2006 Note: The hedging relationship is assumed to be perfectly effective. 3 Adjustment necessary due to application of hedge accounting and corresponding to the fair value only for the portion attributable to hedged risk. Original: 2006-07-06 HQT-4, Document 2 Page 19 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 Before 2006-01-01 2006-01-31 After Balance sheet Results Balance sheet (100) - (100) Cost of derivative - - - Re-evaluation of swap at fair value - - (2) Issuance of debt Re-classification of fair value of swap for comprehensive income. Coupon for interest on debt Interest coupon for: Swap- receipt Swap – disbursed 2006-02-06 - ResultS - 2 2 (2) (0,5) 0,5 (0,5) 0,5 0,5 (0,6) - (0,5) 0,6 - 0,5 (0,6) (0,5) 0,6 2 (2) Re-evaluation of swap at fair value Re-classification of fair value of swap for comprehensive income. Total Resultat etendu (2) Coupon for interest on debt (0,5) 0,5 Interest coupon for: Swap- receipt Swap – disbursed 0,5 (0,6) (0,5) 0,6 Debt Interest (100) (1,2) 1,2 2 (0,5) 0,5 0,5 (0,6) (0,5) 0,6 (100) (1,2) - 1,2 Table 1 above illustrates clearly that the changes imposed by the new norms on financial instruments will have little impact on the cost of the regulatory debt. First, in the absence of ineffectiveness in the hedge relationships, there will be no impact because the net effect on the results is the same as under the current policies. Second, if a relationship is not perfectly efficient, the impact in terms of the current policies will essentially be the recognition of the ineffectiveness in the period in which it occurs, which as indicated above, represents a secondary impact which will ultimately sum to zero over the duration of the hedge relationship. Original: 2006-07-06 HQT-4, Document 2 Page 20 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 On the other hand, because the accounting of derivative instruments at fair value will lead to the recording of a compensatory element and give rise to significant modifications to the balance sheet and the presentation of financial information, the formula for the cost of the regulatory debt will need to be reviewed in order to ensure it corresponds to the fundamental definition. However, the adaptation of the definition of the cost of the regulatory debt should not be addressed before the projection of the regulatory debt cost for the next rate application for the following reasons: • As previously indicated, once the definition of the regulatory debt is adapted to the changes ensuing from the application of the new norms on accounting of financial instruments, the Transmission Provider believes the changes will have little impact on the cost of the regulatory debt. The impact, if any, will be in temporal in terms of the recognition of certain minor effects in the results. As a result, the projected cost of the 2007 regulatory debt as a function of the current accounting policies is adequate and coherent with the fact that the real figures used in the reference 2006 are a function of the existing policies. On the other hand, for the next rate application, the real figures will reflect the effect of the new norms, which will require an adjustment of the definition of the cost of the regulatory debt and the model used to project it. • Before the end of the year 2006, the Transmission Provider intends to acquire the software tools necessary to ensure that accounting practices comply with the new norms. Once the new accounting procedures are in place, the company will be able to make the necessary modifications to the definition of the cost of the regulatory debt to reflect the new norms. Then, when presenting the projected cost of the debt for the next rate application, Hydro-Quebec will propose Original: 2006-07-06 HQT-4, Document 2 Page 21 of 22 Hydro-Quebec Trans-Énergie Application R-3605-2006 modifications to the definition of the cost of the regulatory debt and will be able to confirm the marginal impact of the new norms, in the context of the proposed adjustments. b) Long-term debt Beginning January 1, 2007, the long-term debt will be recorded at cost after amortization using the effective rate method. Therefore, the discounts, premiums and issuing expenses currently recorded under the line-item Deferred Costs Related to the Longterm Debt, or Deferred Discounts and other Credits Related to the Long-term Debt and amortized using a straight-line method for the duration of the loan, will be recorded in the balance of the long-term debt. The impact will be limited to the timing of the recognition of discounts and issuing expenses, which will have a zero sum effect over duration of the of the items. The Transmission Provider will not be in a position to precisely evaluate these effects before the installation of software to implement the new norms. Therefore, the projected cost of the regulatory debt for 2007 is based on the norms currently in force. The new method will be integrated in time for the evaluation of the cost of the debt for the next rate application. The company will then identify the impact of this change in procedure on the base year and the projected year. c) Hedging of sales in American dollars Currently, in cases where Hydro-Quebec hedges the debt with sales in American dollars, only the principal of the debt is designated. Beginning January 1, 2007, Hydro-Quebec will also have to designate the interest on the debt. Therefore, in view of the reclassification explained in section A.16, the exchange gains and losses on the interest of these debts will henceforth be presented under the line-item Products while interest will be recorded at historic rates under the Financial costs line-item. The impact of this element will be identified along with the others for the next rate application. Original: 2006-07-06 HQT-4, Document 2 Page 22 of 22