Smart Meter Incremental Revenue Requirement Rate Rider

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2013 Cost of Service Orientation Session

Prudence Review of Smart Meter Costs –

Review of Updated Smart Meter Guidelines

July 9, 2012

Keith Ritchie

Project Advisor, Electricity Rates

Applications and Regulatory Audit

Ontario Energy Board

Guideline G-2011-0001: Smart Meter Funding and Cost Recovery – Final

Disposition

• Issued December 15, 2011

• Evolution of Board policy and practice for review of applications for final disposition of smart meter costs

• Smart Meter costs dealt with in cost of service or stand-alone applications

• Stranded meter cost recovery only dealt with in cost of service applications

• Cost recovery aligned with APH FAQs

– Deferred revenue requirement

– Simple interest on opening monthly principal of OM&A and depreciation expense

– On revenue side, simple interest on opening monthly principal of SMFA revenues

• While SMFA was uniform across metered customers, there is an expectation that utility can address cost allocation

2

Smart Meter Funding Adder

• Smart Meter Funding Adder (SMFA) introduced May 1, 2006

– Intended to provide funding for smart meter initiative

– Initial level of about $0.30/month per metered customer for most utilities

– Level has been allowed to increase to $1.00 or some utility-specific amount

– Initially embedded in Monthly Service Charge but shown as a separate rate adder beginning with 2010 rates

– SMFA sunsetted as of April 30, 2012 for most distributors

3

Recovery Mechanisms for Two “Buckets” of Costs

• Smart Meter Disposition Rate Rider (SMDR)

– As part of a disposition/prudence review application, to dispose of the balances recorded in the variance accounts between:

• the deferred revenue requirement amount for reviewed/approved smart meters as of the date of the latest audited financial statements; and

• SMFA revenues and associated carrying charges amounts collected over the same time period.

• Smart Meter Incremental Revenue Requirement Rate Rider (SMIRR)

– When smart meter costs are approved on a final basis in a stand-alone application, the SMIRR is a proxy for the incremental on-going change in base rates that would result if the amounts of approved smart meter costs were factored into rate base and revenue requirement.

– Remains in effect until next Cost of Service rebasing

– Not needed when disposition part of a Cost of Service application, as the costs are directly incorporated into rate base, revenue requirement, cost allocation and rate design.

4

2013 Cost of Service

• To review/approve disposition of historical costs recorded in variance accounts

– Audited for historical period

– Actual/forecasted costs for bridge or test period

– Audited actual costs > 90% of total costs

• Review of prudence of costs

– Eligibility of costs for recovery (e.g., nature of costs in relation to smart meter minimum functionality requirements)

– Level of costs in total and on a per meter basis

– Cost levels are evaluated considering the utility’s circumstances and relative to that of other utilities

– Identify and document all costs “beyond minimum functionality”

• Proposal for recovery of stranded meter costs

– Net Book Value (NBV) of removed conventional meters

– Proposal for rate rider(s) and time period for recovery

Smart meter costs included in revenue requirement; stranded meters removed

5

Stand-alone and IRM Applications

Stand-alone Applications

• Prudence review

– Same as for Cost of Service

• Proposal for recovery of stranded meter costs

– Same as for Cost of Service

• SMIRR will proxy incremental revenue requirement for approved smart meters until next rebasing

• Smart Meters will enter rate base at next rebasing at the NBV at start of test year

IRM Applications

• 2013 Chapter 3 Filing

Requirements allow distributor to apply for review and disposition of smart meter costs (i.e. SMDR and

SMIRR) as part of an IRM application where the timing would coincide for the two applications.

• Will make for a more involved IRM application. However, should be manageable for Board, applicant and other parties based on experience of stand-alone applications if the applicant complies with Guideline G-2011-

0001

6

Smart Meter Model Versions

• Evolution of previous models

– 2012 Version 2.17 treated 2012 as test year for SMIRR and 2006-2011 as historical period for SMDR

– 2013 Version 2.21 treats 2013 as test year for SMIRR and 2006-2012 as historical period for SMDR

– 2013 Version 3.00 – Version 2.21 with two new pages to calculate classspecific SMDRs and SMIRRs per PowerStream and Guelph Hydro precedents

7

Lessons Learned – so far

• Per meter smart meter costs (combined capital and OM&A)

– Mid- to large-sized urban utilities maximum $190

– Board approved costs up to about $270 for some smaller LDCs (small, non-contiguous service areas, topographical and vegetative issues affecting accurate meter reading)

• While costs and revenues were not originally ordered to be tracked on a class-specific basis, distributors generally have the information – or can adequately proxy it. Where adequate data is available, cost allocation and class-specific SMDRs and SMIRRs are expected

• Adherence to Guideline G-2011-0001 and Board-issued model strongly helps

• Adequate documentation – look at stand-alone smart meter applications currently filed

8

Cost allocation and class-specific rate riders

• Distributors must address cost allocation for SMDR and SMIRR

– Two general approaches

• Guelph Hydro’s 2012 CoS

• VECC approach – class-specific modelling

– Cost Allocation

• Capital-related costs (PILs and depreciation) – capital cost weighting from cost allocation model

• OM&A – allocated by number of meters

• PILs – allocated by revenue requirement before PILs

• SMFA revenues (SMDR only) – direct allocation of SMFA revenues to applicable classes (Residential, GS < 50 kW, …) with residual

SMFA revenues evenly split between these classes

9

Guelph Hydro 2012 cost of service example

GUELPH HYDRO - 2012 COS - EB-2011-0123

Revenue Requirement for the Historical Years

2009

$42,551.42

2010

$535,381.23

2011

$1,634,988.25

Total 2009 to

2011

$2,212,920.90

Explanation

Allocator

ID and Factors Total Residential

General

Service Less than 50 kW

Total Return on Capital

Amortization and interest Expense

Operating Expenses (Note 1)

Grossed-up Taxes/PILs

TOTAL REVENUE REQUIREMENT

$45,429.25

$70,515.16

$0.00

$275,990.11

$355,587.68

$84,834.00

$454,228.78

$643,071.22

$527,410.00

$775,648.14

Weighted

Meter -Capital CWMC

Allocated per Class

$1,069,174.06

Weighted

Meter -Capital CWMC

Allocated per Class

Number of

Smart Meters

$612,244.00

Installed for each Class

Allocated per Class

Revenue

Requirement allocated to each Class

-$244,145.30

before PILs

Allocated per Class

100.00%

$775,648.14

100.00%

$1,069,174.06

49,033

$612,244.00

74.03%

$574,200.17

74.03%

$791,492.82

46,027

$574,709.98

25.97%

$201,447.97

25.97%

$277,681.24

3,006

$37,534.02

-$73,393.00

-$181,030.55

$10,278.25

$2,457,066.20

-$244,145.30

Total

$1,940,402.97

-$192,807.29

Residential

$1,747,595.68

$516,663.23

-$51,338.01

General

Service Less than 50 kW

$465,325.21

Revenue Generated from Smart Meter Funding Adder

$2,212,920.90

Percentage of costs allocated to Residential and GS

< 50 kW customer classes

$2,608,669.33

$2,212,920.90

SMFA Revenues directly attributable to class

100.00%

Revenues Generated from SMFA

Net Deferred Revenue Requirement

Residual SMFA revenues (from other metered classes) attributed evenly

Total

$2,608,669.33

-$395,748.43

Allocated per Class

Number of Metered Customers (2012)

Smart Meter Disposition Rate Rider

-$395,748.43

78.97%

91.42%

0.60%

92.02%

$ 2,400,436.56

-$652,840.88

47,848

-$1.14

21.03%

7.39%

0.60%

7.98%

$208,232.77

$257,092.45

3,788

$5.66

Note (1): The Operating Expenses were reduced by $89,067 to reflect the SH&ED Tax Credit -

Energy Probe TCQ # 21 c

Smart Meter Funding Adder Revenues

Year

From 'Rate Class Customer Model" of Guelph's weather normalization load forecast model spreadsheet filed in the application.

Number of customers

Residential GS < 50 kW Other Metered Residential

Estimated SMFA Revenues

GS < 50 kW Other Metered Total

2006 (May 1, 2006)

2012 (to March 30, 2012)

2007

2008

2009

2010

2011

41,643

42,728

43,747

44,584

45,477

46,647

47,848

3,468

3,534

3,581

3,624

3,661

3,724

3,788

Customer Classes

554

566

584

583

589

603

617

$

$

$

$

$

$

138,439.53

269,481.01

535,002.00

545,719.00

623,207.69

167,946.89

$ 7,491.78

$ 11,449.89

$

$

$

$

$

22,057.93

43,485.00

43,929.00

49,749.17

13,295.23

Customer Classes

$

$

$

$

$

$

$

1,196.28

1,832.76

3,597.44

6,990.00

7,070.00

8,053.93

2,165.08

$ 98,635.86

Even allocation

Allocation of 1.19% to Res and GS < 50 kW

91.42%

78.97%

50.00%

0.596%

92.02%

$ 191,458.00

7.39%

21.03%

50.00%

0.596%

7.98%

1.19%

$ 2,592,107.40

100.00%

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Things to watch for

• 90% of smart meter costs (historical and test) should be audited actuals

• TOU implementation costs are “beyond minimum functionality” as defined in legislation and Guideline G-2011-0001

– Provide disaggregation and explanation of costs “beyond minimum functionality”

• Stranded Meters

– While stranded meters are not dealt with outside of a cost of service application, stranded meters continue to be depreciated as the assets continue to be in rate base and attract a return on capital and depreciation expense.

Stranded meter rate riders should generally be class-specific, relating to how these costs should have been directly allocated in cost allocation studies.

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Things to watch for (continued)

• Explain any negative costs on sheet 2

• Check cost of capital parameters against previous cost of service applications

• Tax rates should correspond with rates used for tax/PILs expense in cost of service or with tax-sharing module of IRM applications

• Sheet 8A calculating interest on monthly OM&A and depreciation expense is preferred to annual average calculations on sheet 8B, and data should be available from Account 1556 sub-accounts

• SMDR (Residential) > SMDR (GS < 50 kW) is indication of misallocation of costs or revenues

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