Confidential - Submitted Pursuant to 16 USC 825 and 42 USC 16452
Do Not Release Pursuant to FOIA.
Ameren Illinois Company and Ameren Transmission Company of Illinois
Response to IMEA Data Requests
Docket No.
Response Date: 09/23/2014
IMEA 1.1
Please provide work papers for A&G allocations from 2011, 2012 & 2013 for both ATXI and AIC.
You indicated in response to a question that these amounts were derived from either direct
assignments and/or allocations of costs from Ameren Services as required by the general services
agreement between Ameren Illinois and Ameren Services. Please provide the current copy of the
agreement to which you were referring (and if changes were made to the Agreement from 2011 to
2013, please provide each version).
RESPONSE:
There are no specific work papers for A&G allocations. All allocations are performed automatically
and electronically in Ameren’s PowerPlant system. The allocations are performed based on the ICC
approved General Service Agreement and the direct allocation factors and indirect allocations
included in Appendix A to that agreement.
The tables attached (Attachments 1 and 2) show the annual A&G amounts allocated from AMS to
AIC and ATXI for 2011, 2012 and 2013. These amounts are shown by applicable allocation factor
and FERC A&G account.
A copy of the General Services Agreement will be provided by email upon request.
2013 True Up Response to IMEA
Page 1of 9
IMEA 1.2
Provide descriptions for accounts #282, #283, #190, #255 used on pages 6 and 17 of the handout.
Provide work papers to show how the deferred income tax amounts for each account was derived
and calculated for 2013 and the prior 2 years.
RESPONSE:
#282 – Accumulated deferred income taxes – other property
This account includes the tax deferrals which are related to all property other than accelerated
amortization property.
#283 – Accumulated deferred income taxes – other
This account includes all credit tax deferrals other than those deferrals that are includible in
Accounts 281 and Accounts 282.
#190 – Accumulated deferred income taxes
This account includes all debit tax deferrals other than those deferrals that are includible in Accounts
281 and Accounts 282.
# 255 – Accumulated deferred investment tax credits
This account is credited with all investment tax credits deferred by companies.
See IMEA 1.2 attachment A, IMEA 1.2 attachment A-1, IMEA 1.2 attachment 3 and IMEA 1.2
attachment 4 for a reconciliation of AIC deferred income taxes.
See IMEA 1.2 attachment B, IMEA 1.2 attachment B-1, IMEA 1.2 attachment 5 and IMEA 1.2
attachment 6 for a reconciliation of ATXI deferred income taxes.
2013 True Up Response to IMEA
Page 2of 9
IMEA 1.3
Provide backup data and/or work papers for $625,430 from Line 3a on page 11 of the handout.
This sum seems high for transmission O&M for relatively new facilities.
RESPONSE:
Below is the detail of the $625,430 shown as transmission O&M on the ATXI 2013 Attachment O
True-Up calculation. These totals tie to amounts shown on page 321 of ATXI’s 2013 FERC Form 1.
Major
566
566
566
566
566
566
566
566
566
566 Total
Description
CONTRIBUTION&MEMBERSHIP ADMIN
SOFTWARE MAINTENANCE & UPGRADES
UNIX COMPUTER SYS MTCE & SUPT
E&C ENGINEERING & DESIGN
E&C PROJECT MANAGEMENT
FINANCING - LONG TERM
PROPERTY MANAGEMENT
T & D SYSTEM ADMIN - ENGINEERING
SYSTEM ADMIN - OFFICE SUPPLIES
571
571
571
571 Total
Total
$
$
$
$
$
$
$
$
$
$
250
461,646
15,521
3,979
3,112
6,830
5
626
58,448
550,416
ROW & EASEMENTS
RELIABILITY-CONSTRUCT OVHD LN
T&D OPS - VEG. CONTROL
$
$
$
$
10,800
33,057
31,156
75,014
Grand Total
$
625,430
2013 True Up Response to IMEA
Page 3of 9
IMEA 1.4
Please verify that the truncated .03% in column (i) on page 13 of the handout is .0277% (approved
FERC rate).
RESPONSE:
No, this is .0348%. The Attachment MM for 2013 was under-recovered so interest is calculated
using ATXI’s short term borrowing rate through July 31, 2014, instead of using the FERC interest
rate. The short term interest rate used for the 6/1/14 filing was .4178%, which is equivalent to
.0348%/month. The tariff requires that the interest be calculated using the short term interest rate
from January 1, 2013 until July 31, 2014. Since this was not known at the time of the 6/1/14 filing,
it was adjusted in the 2015 projection posted on August 29, 2014. The interest rate through July 31,
2014 was .3444% so the interest rate shown on the 2013 true up included in the 2015 projection was
.0287%.
Note that the FERC approved rate applicable for over-recoveries would be 3.25% annually or
0.2708% monthly.
2013 True Up Response to IMEA
Page 4of 9
IMEA 1.5
Verify/provide that the correct interest rate was used for over/under collection (FERC rate or
Ameren short term rate).
RESPONSE:
Yes, ATXI’s short-term interest rate was properly applied to the 2013 under recovery of Attachment
MM and Attachment O. AIC’s short-term interest rate was properly applied to the 2013 under
recovery of Attachment GG while the FERC interest rate was properly applied to the 2013 over
recovery of Attachment O.
The FERC rate for over-recoveries was 3.25% annually, or 0.2708% monthly.
The ATXI rate for under-recoveries was 0.3444% annually, or 0.0287% monthly.
The AIC rate for under-recoveries was 0.3788% annually, or 0.0316% monthly.
2013 True Up Response to IMEA
Page 5of 9
IMEA 1.6
In response to a question about the approximate $1.4 million change in LSE Expenses for AIC, you
explained that the loss of retail customers had a corresponding reduction in the amount of MISO
charges paid. Despite this reduction in costs to AIC, actual Total O&M went up by approximately
$3.3 million. Provide explanation and work papers to show the cause of the $4.7 million increase in
Total O&M over the projection for 2013. Did any corporate changes occur that contributed to a
shifting of costs, and if so what was the change, and what is the amount of costs that were shifted?
RESPONSE:
There are many variables that changed in comparing forecast versus actual, however, these changes
independently are immaterial except as noted below. The O & M variance is less than 10% overall
when comparing the forecast to actual.
Increase due to effect of A & G wages and salaries allocator $0.9 M
Increase in FERC related Regulatory Expenses
$0.3 M
Increase in O & M expense
$2.1 M
Overall A & G was forecasted at $159.6 million, and actuals came in at approximately $140.4
million. However, the forecasted allocation factor based on wages and salaries was 7.092% versus
actual allocation factor based on wages and salaries of 8.517%.
Please note that actual total transmission O&M was only $3.354 million higher than projected (See
page 3, line 8 of Attachment O: $38.546M - $35.192M). See IMEA 1.6 _ Attachment A_2013 AIC
OM for comparison of projected and actual O&M included in the transmission revenue requirement.
Ameren Corporation did divest Ameren Energy Resources in December 2013. However, since the
transaction occurred so late in the year, it would have had very little impact on actual 2013 corporate
allocations.
2013 True Up Response to IMEA
Page 6of 9
IMEA 1.7
Provide verification of how Goodwill was either included or not included in the calculation of the
formula rate collected in 2012, 2013 and 2014 and any adjustments that were made thereto.
Please verify how Ameren will budget/bill for the portion of the charges under the formula rate that
are associated with inclusion or exclusion of Goodwill from the formula rate in 2015 and any
adjustments thereto.
RESPONSE:
Since AIC didn’t switch to a forward looking Attachment O until January 1, 2013, revenues
collected in January through June of 2012 were based on the Attachment O effective June 2011
which used the 2010 Form 1 data and revenues collected in July through December of 2012 were
based on the Attachment O effective June, 2012 which used the 2011 Form 1 data. Neither of these
Attachment O calculations included adjustments for Goodwill. On the 2013 Attachment O
projection which set rates effective 1/1/13, common stock was decreased by $411,074,207 related to
Goodwill. This Goodwill adjustment was removed in the 2013 true-up that was included in the 2015
projection posted on 8/29/14. There was not a Goodwill adjustment made on the 2014 Attachment
O projections which set rates effective 1/1/14.
Since the Goodwill case is on-going and has entered settlement proceedings, no Goodwill
adjustment has been included in the 2015 Attach O projection. Once the proceeding is concluded,
Ameren will determine how to budget/bill for an adjustment, if an adjustment is required.
2013 True Up Response to IMEA
Page 7of 9
IMEA 1.8
Provide summary of point to point (PTP) that were credited to AIC (or ATXI) for 2012, 2013 &
2014.
Preliminary projections for 2015 PTP credits given changes to MISO and PJM footprint.
RESPONSE:
The PTP credit shown on the 2015 projections posted on May 29, 2014 was calculated by doubling
the June 2014 year to date actual PTP revenues for reservations expected to continue. Since Entergy
joined MISO in December 2013, the 2014 actuals are a better representation of the expected revenue
than just using the most recent 12 months as was used in previous projections. This amount will be
trued up to actuals in the 2015 true-up filing to be posted by June 1, 2016.
Below is a summary of PTP revenue credits used in prior Attachment O filings. Please note that
PTP revenue is dependent on all transmission reservations made by all MISO market participants.
Therefore, rather than attempt to project future reservations, Ameren generally using the most recent
12 months as a projection for the future. Any difference will be reflected in the true-up calculation.
Attachment O Filing
2012 Jan-May 1/
2012 Jun-Dec 2/
2012 projection 3/
2012 actual
2013 projection
2013 actual
2014 projection
2015 projection
ATXI
N/A
N/A
$611,000
$583,131
$487,917
$544,445
$502,000
$423,000
AIC
$10,111,195
$7,014,626
N/A
N/A
$7,139,066
$10,738,966
$9,030,934
$9,608,975
/1 – AIC effective rate from Jan-May 2012 based on 2010 FERC Form 1
/2 – AIC effective rate from Jun-Dec 2012 based on 2011 FERC Form 1
/3 – ATXI 2012 projected revenue requirement effective March 1, 2012
2013 True Up Response to IMEA
Page 8of 9
IMEA 1.9
Provide the background analysis for the variance to budget for the Prairie Power, Inc. (PPI) revenues
reflected on line 1.7b on page 21 of the handout.
RESPONSE:
Prairie Power became a transmission owner (TO) in the AMIL pricing zone effective June 1, 2013.
Therefore, as of that date, its revenue requirement was added to AIC’s and ATXI’s revenue
requirement to get the total revenue requirement for the AMIL pricing zone. After becoming a TO,
PPI also started receiving a portion of the PTP and NITS revenue for the AMIL pricing zone.
Prior to PPI becoming a TO, its revenue credit (revenue requirement) was simply added to AIC’s net
revenue requirement to get the AIC adjusted revenue requirement shown on AIC’s Attachment O.
PPI’s revenue credit for 2013 was $583,724 as shown on AIC’s 2013 projection since PPI was
expected to receive this credit for all of 2013. This is equivalent to a monthly revenue requirement
of $48,643. Once PPI became a TO on June 1, 2013, it no longer received the monthly credit.
Therefore, the 2013 AIC True-up calculation only includes the PPI credit for the first five months of
2013 for a total of $243,218 as shown on the 2013 actual Attachment O and on page 21 of the
handout.
2013 True Up Response to IMEA
Page 9of 9