Due to the timing of rate case filings, regulators may allow a regulated utility to recover a carrying cost (including both debt and equity return, similar to AFUDC) on the value of plant placed in service from the commercial operation date to the effective date of inclusion of the plant in rates charged to customers. A regulated utility may also request other similar arrangements to compensate it for delays in including significant capital projects in rate base.
ASC 980-340-25-5 through
25-6 clarify that regulated utilities applying
ASC 980 are not permitted to capitalize the cost of equity, except while a plant is under construction.
Excerpt from ASC 980-340-25-5
If specified criteria are met, paragraph 980-340-25-1 requires capitalization of an incurred cost that would otherwise be charged to expense. An allowance for earnings on shareholders’ investment is not an incurred cost that would otherwise be charged to expense. Accordingly, such an allowance shall not be capitalized pursuant to that paragraph.
Consistent with this guidance, although a regulator may permit a utility to recover the “cost” of equity in rates, the regulated utility should not capitalize the equity component or otherwise record a regulatory asset for financial reporting purposes, regardless of whether future recovery is probable. The equity component should not be recognized until it is collected through rates. However, if recovery is probable, it would be permissible to defer debt-only carrying costs as a regulatory asset. Any debt-related amounts capitalized under this type of arrangement should be classified as a regulatory asset, not as part of the utility plant balance. Furthermore, the regulated utility should base the amount deferred on its actual interest costs incurred associated with that plant or capital project. It would not be appropriate to base the deferral amount on the regulated utility’s hypothetical capital structure.
Examples UP 18-2 and UP 18-3 illustrate the capitalization of debt-only carrying costs.
EXAMPLE UP 18-2
Recovery of carrying costs — acquisition financed through debt issuance
On February 1, 20X1, Rosemary Electric & Gas Company (REG) acquires a 300 MW combined-cycle natural gas-fired electric generation plant for $250 million. The next general rate case is not expected until 20X3; therefore, REG petitions for and receives approval from its regulator to:
- Defer operating and maintenance expense, depreciation, taxes, and cost of capital invested in rate base beginning with the filing date of the petition and ending with the effective date of new rates from the 20X3 general rate proceeding
- Defer monthly carrying costs on the deferred costs at its approved rate of return of 10% until amortization begins
- Recover the deferred amounts over the three-year period commencing the earlier of January 1, 20X2, or the effective date of implementation of new rates from the general rate case
REG has a rate order permitting it to recover its carrying costs as well as operating costs for the new plant until the plant is included in rates. The approved carrying cost of 10% includes an equity component. REG’s weighted-average debt cost is 6.5%. The acquisition of this facility was financed through issuance of new debt with financing cost of 5%.
How should REG account for its carrying costs during the period from receipt of its rate order until the implementation of new rates?
Analysis
For financial reporting purposes, REG should defer only the carrying cost related to the cost of debt used to finance the plant (5% in the example). Although the regulator approved recovery of REG’s full cost of capital, in accordance with
ASC 980-340-25-5 through
25-6, REG is not permitted to defer equity carrying costs because the plant is not under construction (where deferral of equity carrying costs would be permitted as part of AFUDC). The regulated utility should record deferral of debt cost as a regulatory asset separate from utility plant.
EXAMPLE UP 18-3
Recovery of carrying costs — acquisition financed through general funds
Assume the same facts as Example 18-2, except that REG financed acquisition of the new facility through its general funds.
How should REG account for its carrying costs during the period from receipt of its rate order until the implementation of new rates?
Analysis
Similar to the analysis in Example 18-2, REG would not be permitted to defer its equity-related carrying costs. Furthermore, because acquisition of the facility was financed through general funds, REG would need to estimate the amount of debt costs associated with the acquisition. One approach to determining the amount to defer is to multiply the carrying value of the facility by its weighted-average cost of debt. The rate used to calculate the amount deferred should be updated periodically. In addition, amounts deferred should be recorded in a regulatory asset separate from utility plant.