So, what kind of kool-aid is FirstEnergy and its PSC minions serving up to help the medicine go down this time? The PSC's windbag says:
“It’s an annual true-up, and it is to cover the cost of fuel and purchased power,” PSC spokeswoman Susan Small said. “There’s not profit for the company. It’s not going to staff salaries. It’s not operations and maintenance fees. It doesn’t go to rent and pension plans or anything like that.”
And about those O&M costs? The $44.5M correction for under-recovery of the "Temporary Transaction Surcharge" ("TTS") that is being recovered in this rate increase consists of $26.1M of unexpected Operations and Maintenance expense for the Harrison Power Station. It also includes $5.7M of profit for the company. I guess Susan Small doesn't know what's she's talking about... again. Maybe she should read a case filing or two before activating the ol' pie hole?
The TTS was "designed to recover the net increase in non-fuel operation and maintenance expenses, depreciation and amortization expenses and taxes other than income taxes, and a return on incremental net plant, fuel inventory and materials/supplies resulting from the completion of the transaction [sale of Harrison]. The TTS also reflected reduction in non-fuel O&M expenses associated with the deactivation of Albright, Rivesville, and Willow Island power stations on September 1, 2012," according to the testimony filed by FirstEnergy at the PSC. Sounds like it IS operations and maintenance, Susan...
The TTS was a temporary rate increase approved by the PSC to allow the company to recover the base rate cost of the Harrison power station from ratepayers for the period October 2013 and February 2015, when the new base rates that included Harrison went into effect. At the time, the company calculated that it would need $199.8M to cover the cost of Harrison for 17 months. It designed its TTS to produce $160M of this revenue. However, the case settlement (negotiated between parties without PSC ruling) only allowed for collection of a $113M TTS. According to the company's most recent calculations, there is a $44M shortfall, which it is requesting to recover over the next year. The biggest part of this shortfall is $26M of "higher than anticipated expense related to maintenance outages at Harrison." In addition, there was an additional $9M O&M expense related to employee pensions and benefits at Harrison.
Hmm... what should you expect when your electric distribution company buys an antique coal plant? Once the ratepayers own it, the company spends generously performing all the maintenance it has put off while it was the owner responsible for the bills.
There were also some mysterious increases in the book value of Harrison, decreases in the book value of the purchased Pleasants power station, and a $10M increase in the illegal "acquisition adjustment" FirstEnergy scored from the PSC. The "acquisition adjustment" was the difference between what Harrison was actually worth and its book value, which produced $256M (now $266M) of pure profit "funny money" for FirstEnergy. Federal accounting regulations do not allow the recovery of "acquisition adjustments" from ratepayers, but the WV PSC ignored that in its haste to bless the Harrison purchase transaction. The acquisition adjustment and any adjustments related to it are pure nonsense.
Adding insult to injury, forecasted sales of power from Harrison were much higher than actual... because power market prices were low and Harrison's coal-fired power was more expensive than other resources during the period, reducing Harrison revenue that might have offset some of the costs of owning the power station.
Upon further contemplation, it looks like most of the testimony of FirstEnergy witness Kevin Wise is nonsense. What else could explain the general advertising expenses totaling nearly $5K booked to the TTS in October 2014, January and February of 2015? Did you ever see any advertising about Harrison on your TV or in your newspaper? Hear any radio commercials? Of course you didn't. This is probably just a misallocation of general FirstEnergy corporate expenses. *sigh* I hope someone goes over this nonsense with a fine tooth comb. There's probably plenty of "mistakes" in here that don't belong but coincidentally increase the rates you pay and the profits of FirstEnergy. Thank goodness for West Virginia's Consumer Advocate, who gets the blinding and thankless task of separating the legitimate from the nonsense in FirstEnergy's filing.
In addition to the $44.4 TTS adjustment, the company wants to recover around $96M of inaccurately estimated fuel, purchased power and transmission costs for the past 2 years, along with $23.6M of new rate increases for 2016, the amount it would be short if it keeps collecting at the current rate through June of 2016. Total rate increase $165M.
How did the company estimate its rate so badly that ratepayers are so far into the hole, requiring a 12.5% rate increase? This increase is for ENEC rates, which are supposed to be filed yearly to cover variable costs incurred by the company. ENEC rates are based on an estimate of the yearly costs. At the end of the year, a true-up occurs, where the company compares its actual costs to the estimate it collected, and either issues a refund, or asks to recover the shortfall. In contrast, base rates cover the company's fixed costs and are determined through occasional base rate cases, where a fixed rate is established. The company must operate within that rate until the next base rate case is filed. The last rate increase was a base rate increase where the company added Harrison to its rate base. But that wasn't the end of the Harrison costs, because as this most recent filing shows, Harrison was also racking up additional costs that the PSC said it could recover in this delayed ENEC filing. This filing got delayed because of the Harrison purchase, so now ratepayers are on the hook for 2 years of ENEC true-up, in addition to the Harrison TTS true-up.
Hey, remember when FirstEnergy told everyone that purchasing Harrison would offset itself because Harrison would sell its excess power capacity into the PJM electric market and credit the proceeds to ratepayers? Well, guess what? There were no proceeds! Prices and sales were much lower than FirstEnergy anticipated, making the ratepayers subsidize the Harrison plant, instead of profit from it. There was no offset, just more expense. Gee, that's exactly what all the other parties told the PSC during the Harrison proceeding. "I told you so" x multiple rate increases. The purchase of Harrison was nothing but a ratepayer-funded subsidy for FirstEnergy and the coal industry. The plant wasn't economic without these subsidies and should have been closed, instead, FirstEnergy "sold" it to West Virginia ratepayers and collected a huge windfall. We'll be paying for this mistake made by the WV PSC for a long, long, long time.
This article introduces something I haven't had to contemplate for a long time (and what a nice time that was!), the senseless babble of FirstEnergy spokespuppet Toad Meyers. As regular readers will recall, Toad uses "Magic Math" to explain the benefit of rate increases.
FirstEnergy spokesman Todd Meyers said the $165 million increase proposed in the Aug. 14 filing is largely the result of lower-than-expected wholesale electric prices over the past year.
Meyers noted the current rates were set partly based on projections of what amount of revenue the utility would be able to pass on to customers as a result of selling the excess electricity generated at its power plants.
“When we set the rates ahead of time based on where we think power prices are going to be, and then power prices aren’t there, we’ve already built in what we project the net benefit of sales to come back to customers will be. That’s built into the rates as they stand,” Meyers said. “That’s why the lower sales then really have an effect in the next true-up.”
Meyers said the Harrison Power transaction was never meant to be evaluated on the basis of a single year, but over the entire projected life of the plant. Prices can change year to year, sometimes in unforeseen ways, he said.
“We’re never looking at things to be a benefit to customers at one particular snapshot in time. We’re looking at what the best-case scenario is over time,” Meyers said. “You just don’t know what’s going to come around the corner, and we thought that having our whole strategy dependent on market purchases, then you’re really at the mercy of the market.
While recent case filings may create the impression that FirstEnergy has continued to seek rate increases, Meyers noted that there have also been decreases, such as the 5 percent rate decrease resulting from the 2012 ENEC filing.
At that time — roughly a year before the Harrison Power transaction was approved — the companies cited lower fuel and wholesale electric costs as reasons for the decrease.
“The perception that we keep raising the rates lately — that perception may be true — but there’s also times that we lower the rates, and people forget about the downswings,” Meyers said. “I wouldn’t call it a pattern. Every year, it’s a different look based on different circumstances.”
Cathy Kunkel, a fellow with the Institute for Energy Economics and Financial Analysis who testified against the Harrison Power transaction, said the PSC’s 2013 decision has a direct correlation to the scope of the proposed ENEC increase.
Had the transaction never occurred, Mon Power and Potomac Edison would have purchased more electricity from the market than what they generated at the power plants under their control. This means ratepayers would have directly benefited from the low wholesale electric rates during the current ENEC review period, Kunkel said.
“One of the fundamental things we were saying at the time is the transaction was about risk, and it was about shifting risk from shareholders to ratepayers. And whether or not the risk actually materializes, it was still a shift of that risk,” Kunkel said. “And I think now we’re seeing the risk has materialized, and we’re seeing it in this rate increase.”
In recent years, wholesale electric rates have been driven down by low-cost natural gas, Kunkel said. But with a lack of fuel diversity in Mon Power and Potomac Edison’s generation fleet, West Virginia ratepayers haven’t seen as much benefit from this downward pressure on the wholesale electric market, she said.
The Harrison Power Station is one example of a larger strategy that FirstEnergy has adopted in recent years of moving more of its largely coal-fired generation fleet into regulated markets where the company is able to pass on more costs to ratepayers, according to Kunkel.
“I think the big picture is we’re just seeing coal less competitive in the marketplace than it used to be, and ratepayers are paying the difference, because Mon Power has invested so heavily in coal,” Kunkel said. “No one can say what the power prices are going to be, but it looks like a bad deal at least in the short run. It’s a high-risk investment for ratepayers. Let’s put it that way.”
“We are very concerned about the level of rate relief the company’s requesting,” Jackie Roberts, executive director of the PSC’s Consumer Advocate Division, said. “We are in the process of evaluating the filing to understand what drives their cost request.
“This is a very large rate increase following on the heels of other large rate increases, and we will be carefully scrutinizing this case.”
Because... I've saved the best part for last. FirstEnergy has proposed doing away with these annual ENEC filings in favor of quarterly filings that raise your rates 4 times per year. Can you imagine having to go through these thousands of documents 4 times a year, instead of just once? Your Consumer Advocate won't be able to keep up, unless its funding is increased three-fold in order to hire more staff to do nothing but pore through FirstEnergy's quarterly ENEC filings. And if the PSC allows FirstEnergy to switch to quarterly filings, then all the other utility kids are going to want the same treatment, until your advocate gives up in desperation. As well, the news media would soon tire of reporting on small quarterly increases, and there would be no bad publicity for FirstEnergy or the PSC. Get in line and eat what you're served, little ratepayer...