Introduction to Rate Cases and Rate Design July 14-15, 2005

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Introduction to Rate

Cases and Rate

Design

July 14-15, 2005

Chicago, IL

Introductions

 Institute

 Instructors

 Binders

 Schedule

 Logistics – security, bathrooms, cellphones, etc.

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Session 1 - Overview of the Rate Making

Process

David G. Loomis, Ph.D.

Executive Director, Institute for Regulatory Policy Studies

Review of ECO 101

Perfect Competition (PC)

 Efficiency in Production – PC gives firms the incentive to produce at the lowest possible cost

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Graph of cost

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Perfect Competition

 Efficiency in Allocation – PC provides society with the right amount of good is produced since the marginal cost to produce equals marginal willingness to pay since both equal price

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Graph of S and D

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Perfect Competition (PC)

 Social Surplus is maximized –

 Consumer Surplus - the difference between the price that the consumer was willing to pay and what they had to pay

 Producer Surplus - the difference between the price that the producer was willing to sell at and what they had to pay

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Graph of CS and PS

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Unregulated Monopoly

Firm charges a higher price than perfect competition. This results in lower output.

There exists X-inefficiency firm doesn’t work hard to cut costs

 There is a misallocation of society resources

 Social Surplus is not maximized

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Natural Monopoly

 When it is more efficient to have one firm produce all the output than for two or more firms to produce

 Usually caused by high capital (fixed) costs

 Often associated with the public interest

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Job of Regulators

Restrain the monopolist to mimic the perfectly competitive market

Set the firms’ prices such that total revenue equals total economic cost (TR=TC)

 Rate Design deals with prices that lead to TR; quantity is determined by consumers (TR=P*Q)

 Revenue Requirement deals with the total economic cost of the firm

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Revenue

Requirement

Overview

Two Major Mandates of Regulatory

Commissions

 Uphold the rights of customers to dependable and reliable service at reasonable rates

 Preserve the financial integrity of the utility

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Company and Customers

 The regulated utility is entitled to an opportunity to recover all costs prudently incurred in providing services

 The customer has an obligation to reimburse the utility at rates that will provide such an opportunity

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Rates

 Rates should be high enough to provide the utility with a reasonable opportunity to recover the total cost of providing service and to sustain its financial integrity while maintaining dependable and reliable service

 Rates should not be higher than the minimum necessary to achieve the objective stated above

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Revenue Requirement

 The amount of money a utility must collect from its customers to pay expenses and provide a fair return to investors

 Incremental revenue requirement is positive if current revenues are insufficient; negative if current revenues are excessive

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Fundamental Rate-of-Return

Equation

 Revenue Requirement = OC + T + d + r(V-D)

 OC = Operating Costs

 T = Taxes

 d = Annual depreciation expense

 r = Rate of return

 V = Value of physical and financial capital

D = Accumulated depreciation r(VD) is called the “return portion” and V-D is called

“rate base”

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The Revenue Requirement Approach

 Basic Principle provide the company with a reasonable opportunity to earn a reasonable return on its “used and useful” investment dedicated to utility service

 Basic Method periodically adjust price levels so they are in line with costs

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Regulatory authority must

 Determine the allowed expenses, allowed rate base and allowed rate of return

(revenue requirements)

 Determine mix of prices that will achieve that revenue requirement (rate design)

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Economic versus Accounting Profit

 Total economic cost includes a fair return on invested capital. This fair return is also called accounting profit.

 Regulated firm should earn their total economic cost but no economic profit.

 Economic profit is a return in excess of the fair return on invested capital.

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Goal

When rates are functioning properly, the utility recovers the cost of service (including capital costs) and no economic profit or loss is produced

Although from the viewpoint of economic welfare, the optimal result of the rate of return regulation “reproduces” the outcome of the perfectly competitive market, traditional regulatory pricing objectives and the forces of the free market differ in significant ways.

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Process

 Select a test year

 Determine the revenue requirement

 Determine whether existing prices would yield more or less that the revenue requirement

 Adjust prices accordingly

 Rates set for the future no “retroactive” rate making

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Test Year

 Any 12 month period used for evaluating the revenues, operating expenses, depreciation, taxes, and rate base for purposes of setting rates.

 Current (or historical) Test Year – A 12 month period which reflects the actual results of current operations could be adjusted for known and measurable changes.

 Future or Forecasted Test Year - A future 12 month period which reflect the anticipated results of normal operations.

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Purpose of Test Year

 To establish the relationship between revenues, expenses and rate base that is expected to exist during the year rates are in effect

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Adjustments

 Pro-Forma Adjustments – known and measurable changes

 Non-recurring expenses

 One-time basis, irregular intervals

 Amortized over the time period between rate cases

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Separation and Verification Issues

Above Vs Below the Line

 Separate utility revenues and costs from non-utility revenues and costs

 Separate jurisdictional utility revenues and costs from non-jurisdictional utility revenues and costs

 Verify that jurisdictional utility costs are prudent and necessary

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Below the Line - BTL

 Items that have nothing to do with the provision of safe and adequate utility service and may represent either nonjurisdictional or non-regulated costs.

Examples of expenses include charitable contributions or political contributions.

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Revenue

Requirements -

Details

Fundamental Rate-of-Return

Equation

 Revenue Requirement = OC + T + d + r(V-D)

 OC = Operating Costs

 T = Taxes

 d = Annual depreciation expense

 r = Rate of return

 V = Value of physical and financial capital

D = Accumulated depreciation r(VD) is called the “return portion” and V-D is called

“rate base”

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Revenue Requirement =

OC + T + d + r(V-D)

 Operating Cost - Non-tax and non-capital costs of utility service

 Issues

 necessary?

 prudent?

 affiliate transaction concerns?

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Revenue Requirement =

OC + T + d + r(V-D)

 Taxes - All forms of payment to federal, state, and local governments

 Utilities have been an easy target for taxation

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Taxes

 Does the tax component equal taxes actually paid in the test year – are the tax benefits “flowed through” or

“normalized”

 interest on construction bonds

 accelerated depreciation

 investment tax credit

“phantom tax”

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Revenue Requirement =

OC + T + d + r(V-D)

 Depreciation - provides for the return of invested capital in “installment payments” over the years of useful life of the plant and equipment

Compensation for the “using up” of capital due to wear and tear, obsolescence, etc...

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Depreciation Example

 Cost $100,000

 Salvage 20,000

 Life 20 years d =

$100,000 - $20,000

20 years

= $4,000 / year

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Depreciation Example

Year

1

2

20

+ Salvage

Recovered

Depreciation per Year

Accrued

Depreciation

4,000

4,000

4,000

8,000

4,000 80,000

20,000

100,000

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Depreciation Issues

 Return of capital versus Return on Capital

 Accounting depreciation methods

 straight line

 accelerated

 Years of useful life

 Anticipated future market conditions

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Revenue Requirement =

OC + T + d +

r(V-D)

 r = rate of return

 (V-D) = rate base

V = value of plant and equipment, etc.

D = occurred depreciation

Payment for the “use” of capital: interest payments, dividends, and retained earnings

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Determining Rate Base (V-D)

 How to determine rate base?

 Net original cost (i.e., book) rate base (net means V-D)

 Fair market value

 Reproduction cost - the cost of duplicating the existing plant and equipment at current prices

 Replacement cost - the cost of duplicating the old plant with the modern technology version

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When to Measure Rate Base?

 End of period rate base - Value of the rate base at the end of the test year. This concept typically is used in conjunction with a current or historical test year.

 Average (normalized) rate base - Average rate base throughout the test (i.e., typical) year. This concept typically is used in conjunction with a future or projected test year.

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Utility Rate Base Major Items

 Plant in Service

 Construction Work in Progress (CWIP)

 Materials and Supplies

 Cash Working Capital

 Prepayments

 Typical Deductions:

» Accumulated Depreciation

» Deferred Taxes

» Contributions in Aid of Construction

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Revenue Requirement

Rate Base

 Includes value of plant and equipment, materials balances, land held for future use

 Issues

 valuation methods

 treatment of “excess” or unused facilities

(used and useful criteria)

 treatment of plant under construction

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Numerical Example

Revenue Requirement

Fuel

Salaries

Other Expenses

Total Operating Costs

Depreciation Exp

Federal Income Taxes

State Income Taxes

Other Taxes

Total Taxes

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$100 M

$150 M

$ 50 M

$10 M

$7 M

$43 M

$300 M

$50 M

$60 M

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Revenue Requirement

Plant in Service

CWIP

Other Capital

Value of Plant

Acc. Depreciation

Rate Base

Rate of Return

Return on Investment

$900 M

$15 M

$35 M

$950 M

($250 M)

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$700 M

10%

$70 M

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Total Revenue Requirement

Total Operating Costs

Depreciation Expense

Taxes

Return on Investment

Total Revenue Requirement

$300 M

$50 M

$60 M

$70 M

$480 M

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Revenue Deficiency

The revenue deficiency in a rate case is equal to the difference between the revenue requirement and the actual revenue during the test year:

Revenue Requirement

- Test-Year Revenue

Revenue Deficiency

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Revenue Deficiency

Total Revenue Requirement

Test-year Revenue (given)

Revenue Deficiency

$480 M

(400 M)

$80 M

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Questions?

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