Alberta Utilities Commission Regulatory Accounting Procedures Pertaining to the Implementation of the International Financial Reporting Standards (IFRS) Draft Copy Version 0.9 DRAFT V 0.9 Page 1 of 16 Table of Contents 1. 2. 3. 4. 5. PURPOSE OF THE IFRS PROCEDURES........................................................................... 3 DEFINITIONS....................................................................................................................... 4 BACKGROUND ................................................................................................................... 6 GUIDING PRINCIPLES ....................................................................................................... 9 ACCOUNTING ISSUE DESCRIPTION AND EXPECTED REGULATORY ACCOUNTING DISCLOSURE ......................................................................................... 10 5.1 IFRS Initial Adoption Adjustments......................................................................... 10 5.2 Specific Regulatory Accounting Items ................................................................... 10 5.2.1 Regulatory Assets and Liabilities (Deferral Accounts) ................................... 10 5.2.2 Property Plant & Equipment ............................................................................ 10 5.2.2.1 Revaluation Option................................................................................. 10 5.2.2.2 Capitalization/Non-Capitalization of Costs: General and Administrative Overhead........................................................................ 11 5.2.2.3 Capitalization/Non-Capitalization of Costs: Borrowing Costs/Equity Allowance for Funds used During Construction (AFUDC)................................................................................................ 11 5.2.2.4 Capitalization/Non-Capitalization of Costs: Depreciation of Assets Used in the Construction of Other Assets................................... 11 5.2.2.5 Capitalization/Non-Capitalization of Costs: Asset Relocation Costs ....................................................................................................... 11 5.2.2.6 Capitalization/Non-Capitalization of Costs: Pre-Operating Costs ......... 12 5.2.2.7 Capitalization/Non-Capitalization of Costs: Training Costs.................. 12 5.2.2.8 Capitalization/Non-Capitalization of Costs: Asset Commissioning Costs............................................................................. 13 5.2.2.9 Treatment of Gains and Losses upon Retirement or Disposal of Assets...................................................................................................... 13 5.2.2.10 Componentization: Tracking, Depreciation Rates, Commencement of Depreciation............................................................ 13 5.2.2.11 Asset Retirement Obligations/Future Removal and Site Restoration Costs.................................................................................... 14 5.2.2.12 Treatment of Insurance Proceeds ........................................................... 14 5.2.2.13 Impairment of Assets.............................................................................. 14 5.2.2.14 Deemed Finance Leases ......................................................................... 15 5.2.2.15 Capital Inventories.................................................................................. 15 5.2.2.16 Treatment of Customer Contributions.................................................... 15 5.2.3 Accounting Method for Income Taxes ............................................................ 15 5.2.4 Pension Costs/Other Employment Benefits..................................................... 15 5.2.5 Intangible Assets .............................................................................................. 15 5.2.6 Debt Transaction Costs .................................................................................... 16 5.2.7 Discount Rate ................................................................................................... 16 5.2.8 Reserves for General Damages and Self Insurance ......................................... 16 5.2.9 Business Combinations .................................................................................... 16 DRAFT V 0.9 Page 2 of 16 1. PURPOSE OF THE IFRS PROCEDURES The IFRS Procedures have been prepared by the Alberta Utilities Commission (Commission or AUC) in order to summarize the rate-making accounting procedures and requirements for the use of all regulated electric utilities, gas utilities, regulated service providers, and default service providers (referred to herein as a utility or utilities) adopting the IFRS standards of financial reporting. The IFRS Procedures are intended for use primarily, but not exclusively, by: • a utility’s accounting, financial, and regulatory personnel; • a utility’s external auditors; • the Commission’s regulatory staff; and • intervenors or other interested parties, when reviewing a utility’s financial information. In order to improve and update the standards for regulatory accounting and reporting, the Commission, with the involvement of stakeholders, will periodically review and amend the material contained in these IFRS Procedures as circumstances warrant. These circumstances include but are not limited to the following: - the issuance of a new International Financial Reporting Standard by the International Accounting Standards Board (IASB); the issuance of an interpretation by the International Financial Reporting Interpretations Committee; when a stakeholder has brought an IFRS issue to the AUC’s attention for resolution. The latest version of the IFRS Procedures will be available for viewing and downloading on the AUC’s web site. The AUC will formulate a process to have proposed revisions distributed to interested stakeholders for review and comments. This process will involve the formation of a working group, when required, to discuss the issues and achieve resolution on the matter. Any revisions to the IFRS Procedures will be communicated to stakeholders and posted on the AUC’s website. DRAFT V 0.9 Page 3 of 16 2. DEFINITIONS When used in these IFRS Procedures: (a) Existing accounting practice means the accounting procedures and policies in use by a utility immediately prior to the adoption of these IFRS Procedures; (b) International Accounting Standards Board or IASB means the independent standard-setting body of the International Accounting Standards Committee Foundation; (c) Regulatory accounting means the collective accounting guidelines, procedures, policies, and practices used by utilities when providing financial information to the AUC for rate-making purposes; (d) Regulatory Assets and Liabilities are assets and liabilities that result from rate actions of regulatory agencies when it is probable that specific revenues, expenses, gains and losses that would have been included in net income in one period under the general requirements of the Uniform System of Accounts will be charged or refunded to customers in a future period. Assets and liabilities can specifically result from rate regulation as follows: (i) Assets arise when the regulator has previously ruled that certain previously incurred costs will be collected from customers either directly or through rates in a future period. This can arise from the timing of collection of certain expenses in rates charged to customers that differs from the period in which the expense would be recognized under IFRS by companies that are not subject to rate regulation. (ii) Liabilities arise when the utility collects from customers in rates amounts that the regulator has previously ruled must be refunded to customers either directly or through rates in a future period or that are intended to cover costs to be incurred in the future. This can occur if costs are below a previously approved forecast or if they are collected from customers in a period before they are incurred. This can also arise when the revenue is recognized in a period that is different from the period that it would be recognized under IFRS by companies that are not subject to rate regulation. The term “costs” can include revenue shortfall, expenses, and gains and losses on sale of assets. Regulatory assets and liabilities can arise from the approval by the regulator of a specific deferral account or the approval DRAFT V 0.9 Page 4 of 16 of a methodology for recovering costs such as using the cash method to recover income taxes and post employment benefit costs; Uniform System of Accounts means the system of accounts to be filed by an electric utility as set out in AUC Decision 2007-017, or by a gas utility as set out in Alberta Regulation 546/63 (Uniform Classification of Accounts for Gas Utilities). DRAFT V 0.9 Page 5 of 16 3. BACKGROUND On February 13, 2008, the Canadian Accounting Standards Board (AcSB) confirmed that the use of IFRS will be required as at January 1, 2011 for publicly accountable profit-oriented enterprises. Starting in January 2011 Canadian Generally Accepted Accounting Principles (GAAP) as currently known and maintained by the AcSB will be replaced by IFRS for those enterprises. IFRS is used in over 100 countries and is maintained by the IASB. The requirement to change from current Canadian GAAP to IFRS will apply to many of the utilities whose rates 1 are regulated by the AUC. In May 2008, the AUC announced the formation of an internal team to examine the regulatory issues associated with the decision of the AcSB to adopt IFRS. The AUC also solicited stakeholders’ interest for the establishment of a collaborative process to address the implications of the adoption of IFRS on the AUC’s regulatory accounting and rate making processes. All of the stakeholders who responded indicated an interest to engage in a collaborative process to discuss the issues arising from the adoption of IFRS. Consequently, the AUC formed a working group comprised of industry stakeholders, and chaired a number of working sessions from September 2008 to December 2008. The first priority of the working group was to establish the guiding principles that would serve as the touchstone to evaluate the outcomes of the discussions on the IFRS specific issues. In addition, these guiding principles will be used to evaluate any IFRS specific issues that were not addressed by the working group. Once the guiding principles were established, the working group discussed the IFRS specific issues that were identified as being matters of importance for the stakeholders. For each issue discussed, AUC staff used the discussion notes to develop a specific procedure to provide utilities with direction regarding the regulatory reporting requirement relating to each issue. The AUC consequently developed these IFRS Regulatory Accounting Procedures (“IFRS Procedures”) to document the understanding reached by the working group. These IFRS Procedures are intended to provide guidance to utilities on accounting procedures and requirements in order to: 1. Accommodate the transition by the utilities to IFRS; and 1 The term “rate” is used in the generic sense and includes the distribution, rate regulated, and transmission tariffs of the electric and gas utilities under the jurisdiction of the AUC. DRAFT V 0.9 Page 6 of 16 2. Specify the methodology and the basis of accounting for presenting financial information in a rate application or other reporting to the AUC. The IFRS Procedures are being developed and made available in early 2009 to provide certainty to utilities and other stakeholders with regards to the AUC’s expectations for the accounting information to be used in a rate application to the AUC or when required to report financial information to the AUC. Utilities and other stakeholders will be given the opportunity to comment upon the draft version of these IFRS Procedures before they are received and approved by the Commission. The implementation date for IFRS in Canada is January 1, 2011 with a transition date of January 1, 2010. Therefore Canadian companies will be required to provide comparative IFRS financial statements for 2010; however these statements will generally not be published until 2011. Canadian companies will initially provide financial statements under Canadian GAAP for 2010. Utilities will be allowed to adopt these IFRS Procedures effective either January 1, 2010 or January 1, 2011 to accommodate the utilities’ preferred schedule for implementation. During the transition period of 2009 through 2011, utilities adopting IFRS will prepare their financial forecasts and actual financial results for filing with the AUC as follows: Fiscal Year 2009 Year Filed 2010 Actual / Forecast Actual 2010 2011 Actual 2011 2012 Actual 2012 & beyond 2009 & beyond 2011 & beyond 2013 & beyond 2009 to 2010 2011 & beyond Actual Forecast Forecast Accounting / Reporting Standard to Use Current accounting practice for other regulatory filings (for example Rule 005). Existing Canadian GAAP requirements for financial statements. Current accounting practice for other regulatory filings (for example Rule 005). Existing Canadian GAAP requirements for financial statements. IFRS Procedures for other regulatory filings (for example Rule 005) complete with 2010 comparatives prepared under AUC IFRS Procedures. IFRS requirements for financial statements complete with 2010 comparatives prepared under IFRS. IFRS Procedures for all other regulatory filings. IFRS requirements to prepare financial statements. Utilities may elect to forecast based on IFRS Procedures commencing with the 2011 forecast year. IFRS procedures. DRAFT V 0.9 Page 7 of 16 Instances may occur where a utility’s forecast has been submitted under existing Canadian GAAP, and the actual results submitted are under IFRS. In those instances where the utility files a comparative report, the utility is to report the forecast as filed under existing Canadian GAAP and to report the actual results under IFRS. The utility is then expected to explain the impacts of differences resulting from the two reporting standards. Utilities not required to, or not electing to adopt IFRS will be required to file an application with the AUC indicating the basis of accounting and reporting which the utility plans to use when providing financial information in a rate application and when reporting financial results to the AUC, and what affect that choice will have on the financial information submitted to the AUC. DRAFT V 0.9 Page 8 of 16 4. GUIDING PRINCIPLES The Guiding Principles as set out in this IFRS Procedures document are all equally important and are to be viewed as a collective set of principles rather than a list of individual statements. • The methodologies used by the AUC to establish just and reasonable rates have not always been the same as those used for external financial reporting purposes. The Commission has and will retain the authority to establish regulatory accounting and regulatory reporting requirements and as such, IFRS requirements will not be the sole driver of regulatory requirements. • Future regulatory accounting and regulatory reporting requirements established by the Commission will continue to be based on historical, sound regulatory principles. Examples of these principles can be found in statutes, regulatory and court decisions and regulatory texts and include intergenerational equity, minimizing rate volatility and use of historical costs rather than fair market, or any other values. • Future regulatory accounting and regulatory reporting requirements established by the Commission will, in considering IFRS requirements, balance the effects on customer rates and shareholders’ return. Any shifting of risk between customers and shareholders will be minimized. • Future regulatory accounting and regulatory reporting requirements established by the Commission will be aligned as much as possible with IFRS. In establishing any future regulatory accounting and regulatory reporting requirements that deviate from IFRS, the Commission will ensure that any such deviations and their impact are in the public interest. • Future regulatory accounting and regulatory reporting requirements established by the Commission will be universal and standardized for all utilities while still recognizing that utility-specific issues can be addressed through that utility’s applications. DRAFT V 0.9 Page 9 of 16 5. ACCOUNTING ISSUE DESCRIPTION AND EXPECTED REGULATORY ACCOUNTING DISCLOSURE 5.1 IFRS Initial Adoption Adjustments As a general rule, for rate-making purposes, utilities will disclose each IFRS adoption adjustment separately if the adjustment has an impact on a regulatory account. These adjustments will be included in the utility’s rates application. The utilities will propose in their rates applications the method for settling the adjustment (e.g. the establishment of a regulatory asset or liability). The AUC and other interested parties will review these proposals as part of the ratemaking process. Specific items and their proposed treatment are discussed in the following subsections. 5.2 Specific Regulatory Accounting Items 5.2.1 Regulatory Assets and Liabilities (Deferral Accounts) Regulatory deferral accounts will continue regardless of the IFRS reporting standards. The utilities will maintain the existing practice of applying for deferral accounts for the purpose of establishing regulatory assets or liabilities and proposing the mechanism for their disposition. The AUC will continue to determine the process that the utilities must follow in order to have their deferral accounts approved as well as the process to have the deferral accounts recovered in a timely and effective manner. The Commission will consider including wording in future decisions that the approved methodologies that gave rise to the regulatory asset or liability will continue into the future. This will provide evidence on the high probability, subject to future regulatory review as required, of the collection or payment of regulatory assets and liabilities that may help utilities to record these items in their financial statements. 5.2.2 Property Plant & Equipment 5.2.2.1 Revaluation Option Utilities will maintain the existing accounting practice of using original costs to record property plant and equipment accounts for rate-making purposes. DRAFT V 0.9 Page 10 of 16 5.2.2.2 Capitalization/Non-Capitalization of Costs: General and Administrative Overhead IFRS does not allow the capitalization of costs that are not ‘directly attributable’ to the asset. On a prospective basis for rate making purposes, utilities will adhere to the IFRS requirements. Any financial difference that arises as a result of the adoption of the IFRS requirements is to be identified in a utility’s first rate filing after IFRS adoption. The utility will propose in its rate application the method for settling the difference (e.g. the establishment of a regulatory asset or liability). In addition, the utility will file a copy of its updated capitalization policy as a part of its first rate filing after IFRS adoption. The AUC and other interested parties will review these proposals and capitalization policies as part of the rate-making process. 5.2.2.3 Capitalization/Non-Capitalization of Costs: Borrowing Costs/Equity Allowance for Funds used During Construction (AFUDC) For rate making purposes, utilities will maintain the existing accounting practice of including the equity component of AFUDC when accounting for construction work in progress and plant in service. Utilities can submit an application to the AUC requesting approval to make their regulatory practice the same as the practice under IFRS. This request would be subject to review by the AUC and other interested parties as part of the ratemaking process. 5.2.2.4 Capitalization/Non-Capitalization of Costs: Depreciation of Assets Used in the Construction of Other Assets For rate-making purposes, utilities will adhere to the IFRS requirement of capitalizing the depreciation of assets used in the construction of other assets. 5.2.2.5 Capitalization/Non-Capitalization of Costs: Asset Relocation Costs Under IFRS, the installation cost in the new location can be capitalized as long as the costs in the old location are retired. The cost of actually relocating existing assets has to be expensed as it is deemed to not provide future economic benefit. On a prospective basis for rate making purposes, utilities will adhere to DRAFT V 0.9 Page 11 of 16 the IFRS requirements. Any financial difference that arises as a result of the adoption of the IFRS requirements is to be identified in a utility’s first rate filing after IFRS adoption. The utility will propose in its rate application the method for settling the difference (e.g. the establishment of a regulatory asset or liability). In addition, the utility will file a copy of its updated capitalization policy as a part of its first rate filing after IFRS adoption. The AUC and other interested parties will review these proposals and capitalization policies as part of the rate-making process. 5.2.2.6 Capitalization/Non-Capitalization of Costs: Pre-Operating Costs There is potential that certain costs currently capitalized under generally accepted accounting principles would not be capitalized under IFRS. On a prospective basis for rate making purposes, utilities will adhere to the IFRS requirements. Any financial difference that arises as a result of the adoption of the IFRS requirements is to be identified in a utility’s first rate filing after IFRS adoption. The utility will propose in its rate application the method for settling the difference (e.g. the establishment of a regulatory asset or liability). In addition, the utility will file a copy of its updated capitalization policy as a part of its first rate filing after IFRS adoption. The AUC and other interested parties will review these proposals and capitalization policies as part of the rate-making process. 5.2.2.7 Capitalization/Non-Capitalization of Costs: Training Costs There is potential that certain training costs currently capitalized would not be capitalized under IFRS. On a prospective basis for rate making purposes, utilities will adhere to the IFRS requirements. Any financial difference that arises as a result of the adoption of the IFRS requirements is to be identified in a utility’s first rate filing after IFRS adoption. The utility will propose in its rate application the method for settling the difference (e.g. the establishment of a regulatory asset or liability). In addition, the utility will file a copy of its updated capitalization policy as a part of its first rate filing after IFRS adoption. The AUC and other interested parties will review these proposals and capitalization policies as part of the ratemaking process. DRAFT V 0.9 Page 12 of 16 5.2.2.8 Capitalization/Non-Capitalization of Costs: Asset Commissioning Costs There is potential that certain asset commissioning costs currently capitalized under generally accepted accounting principles would not be capitalized under IFRS. On a prospective basis for rate making purposes, utilities will adhere to the IFRS requirements. Any financial difference that arises as a result of the adoption of the IFRS requirements is to be identified in a utility’s first rate filing after IFRS adoption. The utility will propose in its rate application the method for settling the difference (e.g. the establishment of a regulatory asset or liability). In addition, the utility will file a copy of its updated capitalization policy as a part of its first rate filing after IFRS adoption. The AUC and other interested parties will review these proposals and capitalization policies as part of the rate-making process. 5.2.2.9 Treatment of Gains and Losses upon Retirement or Disposal of Assets For rate-making purposes, utilities will maintain the existing accounting practice of recording gains and losses. Utilities will identify and record any difference in accounting between the IFRS reporting requirements and the regulatory reporting requirements in a separate subsidiary accumulated depreciation account. 5.2.2.10 Componentization: Tracking, Depreciation Rates, Commencement of Depreciation For rate-making purposes, utilities will maintain the existing accounting practice and use the current depreciation rates if these rates are the same as the IFRS requirements. If the adoption of the IFRS requirements result in a difference in depreciation rates or a difference in the timing of commencement of depreciation, or both, then utilities will have the opportunity to submit an application to the AUC requesting approval to become consistent with this IFRS reporting requirement. These proposed depreciation rates would be subject to review by the AUC and other interested parties as part of the AUC’s regulatory process. IFRS requires that expected major overhauls be estimated and separately componentized upon initial recognition of an asset. This portion of the asset’s cost would then be depreciated over a different period of time than the related asset. On a prospective basis for rate making purposes, utilities will adhere to the IFRS requirements. Any financial difference that arises as a result of the adoption of the IFRS requirements is to be identified in a utility’s first rate filing after IFRS adoption. The utility will propose in its rate application the method for settling the DRAFT V 0.9 Page 13 of 16 difference (e.g. the establishment of a regulatory asset or liability). In addition, the utility will file a copy of its updated capitalization policy as a part of its first rate filing after IFRS adoption. The AUC and other interested parties will review these proposals and capitalization policies as part of the rate-making process. With respect to componentization, for rate-making purposes, utilities will record assets at the level of detail being reported under their existing accounting practice. If the IFRS reporting requirement results in a different level of componentization, utilities will have the opportunity to submit an application to the AUC requesting approval to become consistent with this IFRS reporting requirement. Such request would be subject to review by the AUC and other interested parties as part of the rate-making process. 5.2.2.11 Asset Retirement Obligations/Future Removal and Site Restoration Costs For rate-making purposes, utilities will maintain their existing accounting practice. Utilities will have the opportunity to submit an application to the AUC requesting approval to become consistent with this IFRS reporting requirement. Such request would be subject to review by the AUC and other interested parties as part of the rate-making process. 5.2.2.12 Treatment of Insurance Proceeds Under IFRS, insurance proceeds are treated as income. Currently insurance proceeds received for a loss of an asset are considered proceeds of disposition with the resulting gain of loss going to accumulated depreciation. On a prospective basis for rate-making purposes, utilities will identify any insurance proceeds and record these in a separate deferral account. Utilities will propose in their rate application the method for settling the deferral account. The AUC and other interested parties will review the proposal as part of the rate-making process. 5.2.2.13 Impairment of Assets For rate-making purposes, utilities will continue with their existing accounting practice of having no impairment (or impairment reversal) charges included when providing or reporting financial information to the AUC. DRAFT V 0.9 Page 14 of 16 5.2.2.14 Deemed Finance Leases For rate-making purposes, utilities will continue with their existing accounting practice. 5.2.2.15 Capital Inventories Under IFRS, capital inventories will be classified as property plant and equipment and amortized when available for use. For rate-making purposes, utilities will continue with their existing accounting practice of recognizing capital inventory and any associated depreciation. 5.2.2.16 Treatment of Customer Contributions For rate-making purposes, utilities will continue with their existing accounting practice of recognizing customer contributions in their Property, Plant & Equipment accounts and including the amortization as an offset to depreciation. 5.2.3 Accounting Method for Income Taxes For rate-making purposes, utilities will maintain their existing accounting practice for income taxes. Utilities will include the future income tax regulatory asset or liability in their rate applications when necessary and this future income tax regulatory asset or liability will have no impact on the revenue requirement as it will be offset by the future income tax liability or asset. 5.2.4 Pension Costs/Other Employment Benefits For rate-making purposes, utilities will continue with their existing accounting practice of recognizing pension costs and other post employment benefits. Utilities will include the regulatory asset or liability in their rate applications when necessary and this regulatory asset or liability will have no impact on the revenue requirement as it will be offset by the pension liability or asset. 5.2.5 Intangible Assets Under IFRS, software development costs and land rights will be classified as intangible assets. For rate-making purposes, utilities will continue with their existing accounting practice of recognizing intangible assets as part of their Property, Plant & Equipment accounts. DRAFT V 0.9 Page 15 of 16 5.2.6 Debt Transaction Costs For rate-making purposes, utilities will continue to use their existing accounting practice for amortizing debt costs. Utilities have the opportunity as part of a future application to the AUC to request approval to become consistent with this IFRS requirement. This request would be subject to review by the AUC and other interested parties as part of the AUC’s regulatory process. 5.2.7 Discount Rate For rate-making purposes, utilities will continue with their existing accounting practice of having no impairment (or impairment reversal) charges included when determining rates. Consequently, the issue of differing discount rates will not affect regulatory reporting. 5.2.8 Reserves for General Damages and Self Insurance For rate-making purposes, utilities will continue their existing accounting practice. 5.2.9 Business Combinations For rate-making purposes, utilities will continue with their existing accounting practice. DRAFT V 0.9 Page 16 of 16