In his article “Paradox of Thrift,” (July 2009), author James M. Seibert looks to be calculating his average service lives as the reciprocal of depreciation rates, whereas utility depreciation rates reflect both life and net salvage. For electric utilities, the cost of removal for most types of transmission and distribution property exceeds the salvage, resulting in the net salvage component having the effect of increasing the rate. Therefore, the reciprocal of an electric transmission or distribution depreciation rate is likely to indicate a life less than the inherent average service life. How much less will be influenced by the extent to which regulatory bodies allow net salvage to be reflected in depreciation rates, and there is considerable variation in this from state to state.
Mr. Seibert notes that the calculated lives for Pennsylvania are high, which is not surprising, given that Pennsylvania precludes net salvage from being reflected in the depreciation rates for transmission and distribution property. Therefore, the reciprocal of Pennsylvania depreciation rates is the average service life, whereas for every other state it reflects both life and net salvage. The variation in the regulatory treatment of net salvage among states is also evident in Mr. Seibert’s Figure 7, because Georgia requires a form of cash treatment that allows only enough net salvage in depreciation rates to equal the amount of current expenditures, whereas most other states (Delaware and Maryland are exceptions) allow accrual treatment of net salvage that results in higher depreciation rates and an accumulation of net removal amounts in book depreciation reserves.
The influence of net salvage on the calculated average service lives is also evident from the lives on Figure 7 for station equipment being higher than the lives for poles. Station equipment tends to exhibit positive net salvage that would cause the rate reciprocal to overstate the life, whereas poles exhibit negative net salvage that would cause the reciprocal to understate the life. I note that Figure 7 incorrectly identifies the transmission accounts (350 through 359) as being distribution accounts and the distribution accounts (361 through 373) as being being transmission accounts. [Editor’s note: The error was Fortnightly’s, not Seibert’s.] I also note that the shape of the survivor curve on Figure 4 is somewhat similar to the Iowa patterns, but is not the same as any of the 30 Iowa patterns.
Mr. Seibert makes a case for increasing depreciation rates to provide capital for system modernization. However, there is a long-term downside to higher depreciation rates, because rate base regulation causes any depreciation change to reverse in a few years as the higher accruals accumulate in the book reserve. Therefore, a depreciation increase today will decrease the total cash flow over the typically long life of electric utility property, but this would be offset to an unknown extent by the investment increasing as a consequence of modernization. The FERC has the authority to authorize accelerated depreciation to encourage transmission line construction, but I do not believe there have been any requests to do so. It would be interesting to know why there have been no requests.
The net salvage incorporated into electric utility depreciation rates nearly always reflects some form of deferral, which is most commonly a consequence of adopting the net salvage experienced in the past rather than the estimated average or future net salvage that is supposed to be utilized for calculating depreciation rates. Therefore, what Mr. Seibert considers to be accelerated depreciation could easily be implemented by regulatory bodies willing to abandon net salvage deferral mechanisms and to allow ratable treatment of the estimated average net salvage that is supposed to be utilized for calculating whole life depreciation rates and the estimated future net salvage that is supposed to be utilized for calculating remaining life rates.
John S. Ferguson, CDP Richardson, Texas
My comment used in Mr. Radford’s August story, “The Smart-Enough Grid” implied that I was not supportive of smart grid, which is not the case. The comment, “Consumers are staring down the barrel of a host of extraordinary costs,” was written with the notion that utilities are asking for additional incentives to their rates of return to implement smart grid even after the federal government has offered stimulus dollars that reduces the uncertainty of cost recovery by as much as 50 percent.
These incentives are not warranted and should not be awarded. Instead, the best way to address this uncertain cost recovery is to require utilities to submit plans for pre-approval that are audited and verified. Provided that utilities adhere to a plan of prudent and justifiable costs, they would be allowed reasonable cost recovery.
We must be mindful of the impact of incentives considering that struggling consumers will be the ones with the burden of paying all costs—smart grid, climate-change legislation and new transmission lines alike. Utilities should treat ratepayer expenditures with the same care that they treat shareholder dollars, and regulators must assure that electric service is affordable for all.
Janine Migden-Ostrander, Ohio Consumers’ Counsel