[ { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2026-05-07_southern-electric-generating-company_fa24-3", "company": "Southern Electric Generating Company", "company_raw": "Southern Electric Generating Company (FA24-3)", "docket": "FA24-3", "docket_full": "FA24-3-000", "issued_date": "2026-05-07", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20260507-3001&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20260507-3001", "captured_at": "2026-06-19", "source_note": "FERC audit report (Letter order issuing Audit Report), FA24-3; accession resolved via eLibrary AdvancedSearch API (searchText=FA24-3) during the 2026-06-19 corpus refresh (post-dates the 2026-02-03 /audits snapshot).", "archived_via": null, "page_count": 43, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2021 to December 31, 2024", "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "1", "3-Q" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Accounting for Replacement of Minor Items of Property", "summary": "SEGCO improperly capitalized costs related to the replacement of minor items of property in a manner that was not consistent with its units of property listing and the Commission’s accounting requirements. SEGCO’s accounting caused utility plant to be overstated and maintenance expenses to be understated.", "is_other_matter": false, "recommendations": [], "themes": [ "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 2, "title": "Allowance for Funds Used During Construction", "summary": "SEGCO improperly accrued allowance for funds used during construction (AFUDC) on projects that were completed or ready to be placed into service. As a result, SEGCO over accrued AFUDC and overstated electric plant in service during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 3, "title": "Computation of Depreciation Rates", "summary": "SEGCO improperly used a depreciation rate for computing depreciation expense for transmission plant that was not on file with the Commission.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 4, "title": "FERC Form Nos. 1 and 3-Q Reporting", "summary": "SEGCO did not properly follow the FERC Form Nos. 1 and 3-Q instructions and, therefore, did not report all required information in its FERC Form Nos. 1 and 3-Q filings. These actions reduced the transparency, accuracy, and usefulness of certain information in the reports. D.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Capitalization vs. expense", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "MN", "source": "Minnesota Office of Administrative Hearings", "doc_type": "ALJ findings of fact, conclusions of law & recommendation (electric rate case)", "id": "2026-04-29_xcel-energy_mn-e-002-gr-24-320-alj-report", "company": "Northern States Power Company d/b/a Xcel Energy", "company_raw": "Northern States Power Company d/b/a Xcel Energy", "docket": "CAH 28-2500-40515 / MPUC E-002/GR-24-320", "docket_full": null, "issued_date": "2026-04-29", "source_page_url": "https://mn.gov/oah/lawyers-and-litigants/administrative-law/opinion-archive.jsp", "pdf_download_url": "https://mn.gov/oah/assets/2500-37994-xcel-energy-puc-rate-increase-report_tcm19-745010.pdf", "captured_at": "2026-06-10", "source_note": "Minnesota Court of Administrative Hearings (the renamed OAH) ALJ report — Findings of Fact, Conclusions of Law, and Recommendation — in the application of Xcel Energy (Northern States Power) for authority to increase rates for electric service in Minnesota, MPUC E-002/GR-24-320 and E-002/GS-24-321 (CAH 28-2500-40515), dated April 29, 2026 (213 pp). PDF: mn.gov/oah/assets/2500-37994-xcel-energy-puc-rate-increase-report. Page-1 + 'Dated' page verified 2026-06-10.", "archived_via": null, "page_count": 213, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "IN", "source": "Indiana Utility Regulatory Commission", "doc_type": "fuel cost adjustment order", "id": "2026-04-08_duke-energy-indiana_in-38707-fac147", "company": "Duke Energy Indiana, LLC", "company_raw": "Duke Energy Indiana, LLC", "docket": "38707 FAC 147", "docket_full": null, "issued_date": "2026-04-08", "source_page_url": "https://iurc.portal.in.gov/searchlegalcase/", "pdf_download_url": "https://www.in.gov/iurc/files/ord_38707FAC147_040826.pdf", "captured_at": "2026-06-02", "source_note": "Order of the Indiana Utility Regulatory Commission on Duke Energy Indiana, LLC's application for a change in its fuel cost adjustment for electric (and high-pressure steam) service under Ind. Code 8-1-2-42, IURC Cause No. 38707 FAC 147, approved April 8, 2026. Listed for reference (metadata-only). PDF at the deterministic IURC order path www.in.gov/iurc/files/; case search iurc.portal.in.gov.", "archived_via": null, "page_count": 11, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2026-03-19_southwestern-electric-power-company_fa24-2", "company": "Southwestern Electric Power Company", "company_raw": "Southwestern Electric Power Company (FA24-2)", "docket": "FA24-2", "docket_full": "FA24-2-000", "issued_date": "2026-03-19", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20260319-3008&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20260319-3008", "captured_at": "2026-06-19", "source_note": "FERC audit report (Letter order issuing Audit Report), FA24-2; accession resolved via eLibrary AdvancedSearch API (searchText=FA24-2) during the 2026-06-19 corpus refresh (post-dates the 2026-02-03 /audits snapshot).", "archived_via": null, "page_count": 55, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2021 through December 31, 2025", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Capitalization of Vegetation Management Costs", "summary": "SWEPCo’s vegetation management policy was not consistent with the Commission’s accounting regulations. Specifically, SWEPCo (1) improperly capitalized $97 million of vegetation management costs that were not related to the initial or original clearing of land and rights-of-way (ROW); (2) accrued Allowance for Funds Used During Construction (AFUDC) on the improperly capitalized vegetation management costs; and (3) included the same vegetation management costs in two different accounts and included both accounts as input for the purposes of computing its annual transmission revenue requirement (ATRR). As a result, SWEPCo overstated its electric plant and overbilled transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Capitalization vs. expense", "Service reliability & vegetation management" ], "cost_to_customers": true }, { "index": 2, "title": "Prepaid Pension AFUDC", "summary": "SWEPCo improperly accrued AFUDC on its prepaid pension asset and included this AFUDC in the electric plant in service accounts. As a result, SWEPCo overstated its electric plant by $10 million and overbilled transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 3, "title": "Allowance for Funds Used During Construction", "summary": "SWEPCo’s AFUDC rate derivation, AFUDC accrual, and AFUDC accounting were inconsistent with the Commission’s accounting regulations. Specifically, SWEPCo incorrectly (1) calculated its long-term debt cost rate; (2) included balances of Accounts 181, Unamortized Debt Expense, 189, Unamortized Loss on Reacquired Debt, and 226, Unamortized Discount on Long-Term Debt, in the long-term debt balances; (3) accrued AFUDC on completed projects, suspended projects, and equipment purchases; and (4) recorded the state portion of AFUDC debt and equity accumulated deferred income taxes (ADIT) in Account 283, Accumulated Deferred Income Taxes – Other, instead of Account 282, Accumulated Deferred Income Taxes − Other Property. As a result, SWEPCo over accrued AFUDC included in electric plant in service accounts and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 4, "title": "Prepayments", "summary": "SWEPCo improperly recorded certain advance payments that were applicable to future accounting periods in administrative and general (A&G) and operation and maintenance (O&M) expense accounts, instead of in Account 165, Prepayments. As a result, SWEPCo did not accurately recognize certain expenses in the period in which they were incurred, leading to the misstatement of A&G, O&M, and other account balances reported in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting Misclassifications", "summary": "SWEPCo recorded various A&G expenses in a manner contrary to the Commission’s accounting regulations. Some of the improper accounting resulted in SWEPCo overstating its ATRR and overbilling its transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 6, "title": "Excess and Deficient Accumulated Deferred Income Tax", "summary": "SWEPCo improperly netted the excess and deficient ADIT related to the corporate tax rate change and associated adjustments required due to the Tax Cuts and Jobs Act of 2017 (TCJA) and recorded the amount that resulted from this improper netting in Account 254, Other Regulatory Liabilities. This action affected the transparency and accuracy of the excess and deficient ADIT amounts reported in SWEPCo’s FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 7, "title": "FERC Form No. 1 Reporting", "summary": "SWEPCo did not properly follow the FERC Form No. 1 page instructions and, therefore, did not accurately report all required information on certain pages of its FERC Form No. 1 filings. These actions affected the transparency, accuracy, and usefulness of the affected pages of the FERC Form No. 1 filings. D.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Capitalization vs. expense", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Service reliability & vegetation management" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "WA", "source": "Washington Utilities and Transportation Commission", "doc_type": "commission order", "id": "2026-03-13_pacificorp_wa-ue-230172-order", "company": "PacifiCorp d/b/a Pacific Power & Light Company", "company_raw": "PacifiCorp d/b/a Pacific Power & Light Company", "docket": "UE-230172", "docket_full": null, "issued_date": "2026-03-13", "source_page_url": "https://www.utc.wa.gov/casedocket/2023/230172", "pdf_download_url": "https://apiproxy.utc.wa.gov/cases/GetDocument?docID=5142&year=2023&docketNumber=230172", "captured_at": "2026-06-07", "source_note": "Washington UTC order (service date March 13, 2026), Washington Utilities and Transportation Commission v. PacifiCorp d/b/a Pacific Power & Light Company, Docket UE-230172 (6 pp). Listed for reference (metadata-only). Source: WA UTC document API (apiproxy.utc.wa.gov/cases/GetDocument?docID=5142&year=2023&docketNumber=230172).", "archived_via": null, "page_count": 6, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "KY", "source": "Kentucky Public Service Commission", "doc_type": "base-rate case order", "id": "2026-02-16_louisville-gas-electric_ky-2025-00114", "company": "Louisville Gas and Electric Company", "company_raw": "Louisville Gas and Electric Company", "docket": "2025-00114", "docket_full": null, "issued_date": "2026-02-16", "source_page_url": "https://psc.ky.gov/Case/ViewCaseFilings/2025-00114", "pdf_download_url": "https://psc.ky.gov/pscscf/2025%20Cases/2025-00114/20260216_PSC_ORDER01.pdf", "captured_at": "2026-06-02", "source_note": "Order on the application of Louisville Gas and Electric Company (LG&E) for an adjustment of its electric and gas base rates (forecasted test year), Kentucky PSC Case No. 2025-00114 (companion to KU Case 2025-00113), electric final order issued February 16, 2026. Listed for reference (metadata-only). PDF at psc.ky.gov/pscscf/2025 Cases/2025-00114/; case folder psc.ky.gov/Case/ViewCaseFilings/2025-00114.", "archived_via": null, "page_count": 387, "scanned_pages": [ 348, 349, 350, 351, 353, 355, 360, 361, 362, 363, 364, 365, 366, 367, 368, 369, 370 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 6, "findings": [ { "index": 1, "title": "Approval: $1,277,051,206. ", "summary": "ctric revenue requirement down from $1,323,417,452 in its original application287 to the Commission-approved overall revenue requirement of $1,277,051,206. As a result of adjusting LG&E’s electric rate base and cost of capital, the Commission finds that LG&E’s income tax expense should be recalculat", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Approval: $58,668,766, ", "summary": "uld be applied to the Commission’s revenue requirement increase allocation. Based on the Commission-approved revenue requirement increase of $58,668,766, the Commission finds that the revenue requirement increase should be allocated as follows: LG&E Rate Class Commission Commission Increase ($) Incr", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: agreement", "summary": "estimony, LG&E argued there are no changed circumstances that justify re-trading the 2014 rate case settlement agreement that both the AG and KIUC signed, just as there is no justification for the Attorney General/KIUC’s expert to change the 90 percent-10 percent sharin", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Settlement: agreement", "summary": "ation to the KBCA, the Kentucky Cable Telecommunications Association (KCTA), was a signatory to the settlement agreement.873 In 2016, the Commission approved the combined pole attachment rate.874 However, the Companies did provide the rate calculation as separate entiti", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: Agreement", "summary": "er, Appendix A. The testimony, Hornung Rebuttal Testimony at 19 also cited to Case No. 2014- 00371, Settlement Testimony of Kent W. Blake Exhibit 1, Settlement Agreement, Settlement Exhibit 4, KU Tariff, Kentucky Utilities Company P.S.C. No. 17, Original Sheet No. 40 (filed Apr. 20, 2015) (showing K", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 6, "title": "Settlement: Agreement", "summary": "d the settled rate of $7.25); Case No. 2014-00372, Settlement Testimony of Kent W. Blake Exhibit 1, Settlement Agreement, Settlement Exhibit 5, LG&E Electric Tariff, Louisville Gas and Electric Company P.S.C. Electric No. 10, Original Sheet No. 40 (filed Apr. 20, 2015)", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": false, "themes": [ "Cost of service & rates", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2026-01-08_dc-energy-holdings-llc_pa23-11", "company": "DC Energy Holdings, LLC", "company_raw": "DC Energy Holdings, LLC (PA23-11)", "docket": "PA23-11", "docket_full": "PA23-11-000", "issued_date": "2026-01-08", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20260108-3014&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20260108-3014", "captured_at": "2026-06-19", "source_note": "FERC audit report (Letter order issuing Audit Report), PA23-11; accession resolved via eLibrary AdvancedSearch API (searchText=PA23-11) during the 2026-06-19 corpus refresh (post-dates the 2026-02-03 /audits snapshot).", "archived_via": null, "page_count": 23, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to January 31, 2025", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Submittal of Required Financial Statements", "summary": "DC Energy did not submit quarterly financial statements to PJM for Quarter 3, 2022 through Quarter 3, 2024 as required by PJM’s credit policy in Attachment Q of PJM’s OATT. Also, DC Energy did not submit quarterly financial statements to SPP during the audit period as required by SPP’s credit policy in Attachment X of SPP’s OATT. This action affected PJM and SPP’s overall risk management policy of monitoring credit risk to protect the market from participant defaults. D.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Submit quarterly financial statements for the audit period to SPP.", "source_page": null }, { "number": 2, "text": "Submit quarterly financial statements for the period of Quarter 3, 2022 through Quarter 3, 2024 to PJM.", "source_page": null }, { "number": 3, "text": "Establish and implement policies and procedures to ensure compliance with credit policies, timelines, and other relevant requirements as specified in RTO/ISO tariffs.", "source_page": null }, { "number": 4, "text": "Establish and implement policies and procedures to review credit policies and requirements as RTOs/ISOs update their tariffs to ensure that DC Energy is submitting all required documents accurately and timely.", "source_page": null }, { "number": 5, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendations 3 and 4 and repeat such training as needed. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "OH", "source": "Public Utilities Commission of Ohio", "doc_type": "commission entry", "id": "2026-01-07_firstenergy-ohio_puco-20-1502-el-unc-entry-on-rehearing", "company": "FirstEnergy Ohio (Ohio Edison, Cleveland Electric Illuminating, Toledo Edison)", "company_raw": "FirstEnergy Ohio (Ohio Edison, Cleveland Electric Illuminating, Toledo Edison)", "docket": "20-1502-EL-UNC", "docket_full": null, "issued_date": "2026-01-07", "source_page_url": "https://dis.puc.state.oh.us/CaseRecord.aspx?CaseNo=20-1502-EL-UNC", "pdf_download_url": "https://dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A26A07B55341I00561", "captured_at": "2026-06-02", "source_note": "Second Entry on Rehearing of the Public Utilities Commission of Ohio adopting the Joint Stipulation and Recommendation that resolves all issues in the review of the political and charitable spending by Ohio Edison Company, The Cleveland Electric Illuminating Company, and The Toledo Edison Company, Case No. 20-1502-EL-UNC, entered January 7, 2026 (13 pages per the DIS docket). Listed for reference (metadata-only). Captured via browser from the PUCO Docketing Information System, which is F5-WAF-protected and rejects scripted requests — so this record is not machine-fetched. Document: dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A26A07B55341I00561.", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "WA", "source": "Washington Utilities and Transportation Commission", "doc_type": "order on Schedule 95 Power Cost Adjustment Clause revisions (power-cost prudence/rate order)", "id": "2025-12-24_puget-sound-energy_wa-ue-250747-schedule-95-pca-order", "company": "Puget Sound Energy", "company_raw": "Puget Sound Energy", "docket": "UE-250747", "docket_full": null, "issued_date": "2025-12-24", "source_page_url": "https://www.utc.wa.gov/casedocket/2025/250747/docsets", "pdf_download_url": "https://apiproxy.utc.wa.gov/cases/GetDocument?docID=124&year=2025&docketNumber=250747", "captured_at": "2026-06-08", "source_note": "WA UTC Order 01 on PSE Schedule 95 Power Cost Adjustment Clause revisions, Docket UE-250747, service date Dec 24, 2025. 9 pp. Page 1 verified.", "archived_via": null, "page_count": 9, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "OH", "source": "Public Utilities Commission of Ohio", "doc_type": "stipulation", "id": "2025-12-19_firstenergy-ohio_puco-20-1502-el-unc-stipulation", "company": "FirstEnergy Ohio (Ohio Edison, Cleveland Electric Illuminating, Toledo Edison)", "company_raw": "FirstEnergy Ohio (Ohio Edison, Cleveland Electric Illuminating, Toledo Edison)", "docket": "20-1502-EL-UNC", "docket_full": null, "issued_date": "2025-12-19", "source_page_url": "https://dis.puc.state.oh.us/CaseRecord.aspx?CaseNo=20-1502-EL-UNC", "pdf_download_url": "https://dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A25L19B41411B02333", "captured_at": "2026-06-02", "source_note": "Joint Stipulation and Recommendation in the Public Utilities Commission of Ohio's review of the political and charitable spending by Ohio Edison Company, The Cleveland Electric Illuminating Company, and The Toledo Edison Company (FirstEnergy's Ohio electric distribution utilities), Case No. 20-1502-EL-UNC, filed December 19, 2025 (21 pages per the DIS docket). Listed for reference (metadata-only). Captured via browser from the PUCO Docketing Information System, which is F5-WAF-protected and rejects scripted requests — so this record is not machine-fetched. Document: dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A25L19B41411B02333.", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "final order", "id": "2025-12-18_ameren-illinois_icc-25-0382-final-order", "company": "Ameren Illinois Company", "company_raw": "Ameren Illinois Company", "docket": "25-0382", "docket_full": null, "issued_date": "2025-12-18", "source_page_url": "https://www.icc.illinois.gov/docket/P2025-0382/documents/374217", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2025-0382/documents/374217/files/655909.pdf", "captured_at": "2026-06-07", "source_note": "Final Order of the Illinois Commerce Commission in Ameren Illinois Company's electric rate reconciliation case, ICC Docket 25-0382, issued December 18, 2025. Approved $48M rate increase (reconciliation case). Listed for reference (metadata-only). Source: ICC e-Docket, document 374217 / file 655909 (landing: www.icc.illinois.gov/docket/P2025-0382/documents/374217).", "archived_via": null, "page_count": 112, "scanned_pages": [ 2 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "AR", "source": "Arkansas Public Service Commission", "doc_type": "order", "id": "2025-12-12_entergy-arkansas_ar-16-036-fr-order-74", "company": "Entergy Arkansas, LLC", "company_raw": "Entergy Arkansas, LLC", "docket": "16-036-FR", "docket_full": null, "issued_date": "2025-12-12", "source_page_url": "https://apps.apsc.arkansas.gov/olsv2/Docket_Search_Documents.asp?Docket=16-036-FR&DocNumVal=1122", "pdf_download_url": "https://apps.apsc.arkansas.gov/pdf/16/16-036-FR_1122_1.pdf", "captured_at": "2026-06-02", "source_note": "Order No. 74 of the Arkansas Public Service Commission in the Formula Rate Plan filings of Entergy Arkansas, LLC, Docket No. 16-036-FR — the Commission's disposition of Entergy Arkansas's 2025 Rider FRP rate adjustment (approved December 12, 2025; 11 pp). Listed for reference (metadata-only). Source: APSC Online Services, document 16-036-FR_1122 (apps.apsc.arkansas.gov/pdf/16/16-036-FR_1122_1.pdf).", "archived_via": null, "page_count": 11, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 5, "findings": [ { "index": 1, "title": "Approval: $117.7\nmillion", "summary": "s an overview of EAL’s Application. He testifies that the revenue change necessary to achieve EAL’s allowed return of 9.65 percent is $117.7 million. The total revenue change is based upon a Projected Year deficiency of $68.9 million for 2026 and $48.8 million deficiency in the Historical Year Net", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $1,671,378.\n", "summary": "cent revenue constraint from $95,653,930 in EAL’s filing to $97,325,308 which increased the maximum allowed increase in revenue by $1,671,378. Id. at 9. Mr. Ray also states that Staff witness Sites supports a recommended change from the Company’s requested Projected Year BRORB of 5.78994 perc", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: terms", "summary": "oberts presents the results of his review of the information EAL provided in response to the agreed settlement terms as approved by the Commission in Order Nos. 10 and 14 with respect to reliability metrics and vegetation management. He also presents the results of", "is_other_matter": false, "recommendations": [], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 4, "title": "Settlement: Agreement", "summary": "ults of his review of the information EAL provided pursuant to the 2021 Evaluation Report Rider FRP Settlement Agreement with respect to the Feeder Level Investment Plan (FLIP) and integration of the Quality of Service reporting of the Worst-of-the-Worst into EAL’s FOCU", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: Agreement", "summary": "14, and updated cost information and reliability metrics for the FLIP feeders pursuant to the 2021 Settlement Agreement. Mr. Roberts testifies that Staff is monitoring the reliability metrics for certain feeders, and Staff did not identify any feeders that met the elig", "is_other_matter": false, "recommendations": [], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false } ], "structured": false, "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "VA", "source": "Virginia State Corporation Commission", "doc_type": "biennial review order", "id": "2025-11-25_virginia-electric-power_pur-2025-00058", "company": "Virginia Electric and Power Company (Dominion Energy Virginia)", "company_raw": "Virginia Electric and Power Company (Dominion Energy Virginia)", "docket": "PUR-2025-00058", "docket_full": null, "issued_date": "2025-11-25", "source_page_url": "https://www.scc.virginia.gov/docketsearch", "pdf_download_url": "https://www.scc.virginia.gov/docketsearch/DOCS/89g601!.PDF", "captured_at": "2026-06-01", "source_note": "Final Order in the 2025 biennial review of Virginia Electric and Power Company (Dominion Energy Virginia) rates, terms and conditions for generation, distribution and transmission service under Va. Code § 56-585.1 A, Case No. PUR-2025-00058, entered by the Virginia State Corporation Commission at Richmond on November 25, 2025. Listed for reference (metadata-only). Source: SCC DocketSearch, document www.scc.virginia.gov/docketsearch/DOCS/89g601!.PDF.", "archived_via": null, "page_count": 30, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "VA", "source": "Virginia State Corporation Commission", "doc_type": "CPCN order", "id": "2025-11-25_virginia-electric-power_pur-2025-00037", "company": "Virginia Electric and Power Company (Dominion Energy Virginia)", "company_raw": "Virginia Electric and Power Company (Dominion Energy Virginia)", "docket": "PUR-2025-00037", "docket_full": null, "issued_date": "2025-11-25", "source_page_url": "https://www.scc.virginia.gov/docketsearch", "pdf_download_url": "https://www.scc.virginia.gov/docketsearch/DOCS/89g501!.PDF", "captured_at": "2026-06-01", "source_note": "Final Order granting Virginia Electric and Power Company (Dominion Energy Virginia) a certificate of public convenience and necessity (CPCN) to construct and operate the ~944 MW Chesterfield Energy Reliability Center and related transmission, with Rider CERC cost recovery under Va. Code § 56-585.1 A 6, Case No. PUR-2025-00037, Virginia State Corporation Commission, entered at Richmond November 25, 2025. Listed for reference (metadata-only). Source: SCC DocketSearch, document www.scc.virginia.gov/docketsearch/DOCS/89g501!.PDF.", "archived_via": null, "page_count": 27, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Approval: $35.7 million", "summary": "illion.87 Accordingly, we find (i) that the Company’s proposed rate design for Rider CERC should be approved, and (ii) that a Rate Year revenue requirement of $35.7 million is appropriate and should be approved. 84 Staff s Post-Hearing Brief at 10. Sierra Club’s Post-Hearing Brief at 1-2. Post-Heari", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true } ], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "LA", "source": "Louisiana Public Service Commission", "doc_type": "rate case application", "id": "2025-11-24_swepco_la-u-37794-application", "company": "Southwestern Electric Power Company (SWEPCO)", "company_raw": "Southwestern Electric Power Company (SWEPCO)", "docket": "U-37794", "docket_full": null, "issued_date": "2025-11-24", "source_page_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/DocketDetails?docketId=SWEPCO-U-37794", "pdf_download_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=sh4kA6z%2B3bk%3D", "captured_at": "2026-06-07", "source_note": "Application of Southwestern Electric Power Company (SWEPCO) for Authorization of a System Improvement Plan (SIP), including related rate recovery through Fuel Adjustment Clause (FAC) beginning June 1, 2026. Plan covers grid hardening (629 line-miles) and vegetation management (6,095 line-miles) across 11 Louisiana parishes. Filed November 24, 2025, published for intervention December 5, 2025. Listed for reference (metadata-only). Source: LPSC public docket portal, Docket U-37794, file sh4kA6z+3bk= (lpscpubvalence.lpsc.louisiana.gov).", "archived_via": null, "page_count": 13, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery", "Service reliability & vegetation management" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NJ", "source": "New Jersey Board of Public Utilities", "doc_type": "basic generation service order", "id": "2025-11-21_nj-electric-distribution-utilities_nj-er25040190", "company": "New Jersey electric distribution utilities (ACE, JCP&L, PSE&G, Rockland Electric)", "company_raw": "New Jersey electric distribution utilities (ACE, JCP&L, PSE&G, Rockland Electric)", "docket": "ER25040190", "docket_full": null, "issued_date": "2025-11-21", "source_page_url": "https://publicaccess.bpu.state.nj.us/", "pdf_download_url": "https://www.nj.gov/bpu/pdf/energy/bgs/ER25040190-%202026%20BGS-%20Order%20Approving%20Auction%20Process.pdf", "captured_at": "2026-06-02", "source_note": "Decision and Order approving the auction process for Basic Generation Service (BGS) for the period beginning June 1, 2026 — the statewide descending-clock procurement that sets default-supply prices for Atlantic City Electric, JCP&L, PSE&G, and Rockland Electric customers, NJ BPU Docket No. ER25040190, issued at the November 21, 2025 agenda meeting. Listed for reference (metadata-only). PDF on the BPU energy/BGS host www.nj.gov/bpu/pdf/energy/bgs/; docket system: publicaccess.bpu.state.nj.us.", "archived_via": null, "page_count": 54, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "ND", "source": "North Dakota Public Service Commission", "doc_type": "rider update application", "id": "2025-10-31_montana-dakota-utilities_nd-pu-25-279-rrca", "company": "Montana-Dakota Utilities Co.", "company_raw": "Montana-Dakota Utilities Co.", "docket": "PU-25-279", "docket_full": null, "issued_date": "2025-10-31", "source_page_url": "https://www.psc.nd.gov/public/cases/", "pdf_download_url": "https://www.psc.nd.gov/webdocs/case/25-0279/001-010.pdf", "captured_at": "2026-06-07", "source_note": "Montana-Dakota Utilities Co. application (October 31, 2025) before the North Dakota Public Service Commission for the Annual Update to the Renewable Resource Cost Adjustment (RRCA) Rate 55 tariff, Case No. PU-25-279 (34 pp). Listed for reference (metadata-only). Source: ND PSC public case records, document 001-010 (psc.nd.gov/webdocs/case/25-0279/001-010.pdf).", "archived_via": null, "page_count": 34, "scanned_pages": [ 14, 16 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "Approval: $9.98 ", "summary": "d by the Commission, the new rates will not be effective until Commission action has been taken. If approved, a typical residential customer using 800 Kwh will see an increase of $9.98 per month, or $119.76 annually. The RRCA is shown as a separate line item on your bill. Residential & Small General", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Settlement: Agreement", "summary": "d near Hettinger, North Dakota in Case No. PU-15-703. On January 5, 2016, the Commission approved a Settlement Agreement between Montana-Dakota and the Commission Advocacy Staff thereby authorizing the Company’s RRCA Rate 55 tariff effective with service rendered on and", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": false, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "IN", "source": "Indiana Utility Regulatory Commission", "doc_type": "gas cost adjustment (GCA) order — gas-cost prudence/recovery review", "id": "2025-10-29_centerpoint-indiana-south_in-cause-37366-gca-168", "company": "Southern Indiana Gas and Electric Company d/b/a CenterPoint Energy Indiana South", "company_raw": "Southern Indiana Gas and Electric Company d/b/a CenterPoint Energy Indiana South", "docket": "Cause No. 37366 GCA 168", "docket_full": null, "issued_date": "2025-10-29", "source_page_url": "https://www.in.gov/oucc/natural-gas/tips-and-publications/gas-cost-adjustments/", "pdf_download_url": "https://www.in.gov/iurc/files/ord_37366GCA168_102925.pdf", "captured_at": "2026-06-08", "source_note": "Indiana URC order on CenterPoint Energy Indiana South (SIGECO) gas cost adjustment, Cause No. 37366 GCA 168, issued 2025-10-29 (I.C. 8-1-2-42(g)/42.3). PDF: in.gov/iurc/files/ord_37366GCA168_102925.pdf.", "archived_via": null, "page_count": 5, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MO", "source": "Missouri Public Service Commission", "doc_type": "direct testimony", "id": "2025-10-24_empire-district-electric-liberty_mo-er-2024-0261-staff-eubanks", "company": "The Empire District Electric Company d/b/a Liberty", "company_raw": "The Empire District Electric Company d/b/a Liberty", "docket": "ER-2024-0261", "docket_full": null, "issued_date": "2025-10-24", "source_page_url": "https://efis.psc.mo.gov/Case/Display/85589", "pdf_download_url": "https://efis.psc.mo.gov/Document/Display/854655", "captured_at": "2026-06-02", "source_note": "Direct Testimony of Claire M. Eubanks, PE, on behalf of the Missouri Public Service Commission Staff (Exhibit No. 106) in the electric rate case of The Empire District Electric Company d/b/a Liberty, File No. ER-2024-0261 (Transmission & Distribution issues; filed/entered October 24, 2025; 16 pp). Listed for reference (metadata-only). Source: Missouri PSC EFIS, document 854655 (efis.psc.mo.gov/Document/Display/854655; docket sheet: efis.psc.mo.gov/Case/Display/85589).", "archived_via": null, "page_count": 16, "scanned_pages": [ 10 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "KY", "source": "Kentucky Public Service Commission", "doc_type": "base-rate case order", "id": "2025-10-02_duke-energy-kentucky_ky-2024-00354", "company": "Duke Energy Kentucky, Inc.", "company_raw": "Duke Energy Kentucky, Inc.", "docket": "2024-00354", "docket_full": null, "issued_date": "2025-10-02", "source_page_url": "https://psc.ky.gov/Case/ViewCaseFilings/2024-00354", "pdf_download_url": "https://psc.ky.gov/pscscf/2024%20Cases/2024-00354/20251002_PSC_ORDER.pdf", "captured_at": "2026-06-02", "source_note": "Order on the application of Duke Energy Kentucky, Inc. for an adjustment of its electric rates and approval of new tariffs and accounting treatments, Kentucky PSC Case No. 2024-00354, issued October 2, 2025. Listed for reference (metadata-only). PDF at psc.ky.gov/pscscf/2024 Cases/2024-00354/; case folder psc.ky.gov/Case/ViewCaseFilings/2024-00354.", "archived_via": null, "page_count": 112, "scanned_pages": [ 100, 101, 102, 103, 104, 105, 106, 107 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Disallowance: $330,788.", "summary": "ed the appropriate methodology for forecasted billed revenues including the pro forma adjustment of $330,788. Consequently, the Commission will reject the Attorney General’s adjustment to test year revenues. 113 Kollen Direct Testimony at 28. 114 Lawler Rebuttal Testimony at 3. 115 Lawler Rebuttal T", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "WA", "source": "Washington Utilities and Transportation Commission", "doc_type": "power cost adjustment (PCA) prudence-review order", "id": "2025-09-29_puget-sound-energy_wa-ue-250318-pca-prudence-order", "company": "Puget Sound Energy", "company_raw": "Puget Sound Energy", "docket": "UE-250318", "docket_full": null, "issued_date": "2025-09-29", "source_page_url": "https://www.utc.wa.gov/casedocket/2025/250318/docsets", "pdf_download_url": "https://apiproxy.utc.wa.gov/cases/GetDocument?docID=323&year=2025&docketNumber=250318", "captured_at": "2026-06-08", "source_note": "WA UTC order on PSE's 2024 Power Cost Adjustment (PCA) Mechanism Report, Docket UE-250318, service date Sept 29, 2025. 10 pp. Page 1 verified.", "archived_via": null, "page_count": 10, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-09-29_kern-river-gas-transmission-company_fa23-10", "company": "Kern River Gas Transmission Company", "company_raw": "Kern River Gas Transmission Company (FA23-10)", "docket": "FA23-10", "docket_full": "FA23-10-000", "issued_date": "2025-09-29", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250929-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250929-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 61, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to December 31, 2023", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2", "501-G" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Renewable Natural Gas Quality Specifications", "summary": "Kern River posted a Biomethane Operating Policy on its Informational Postings website, which lays out gas quality specifications for Renewable Natural Gas (RNG). However, the gas quality specifications in the Biomethane Operating Policy have not been incorporated into Kern River’s Tariff; thus, consistent with the Gas Quality Policy Statement, they cannot be enforced.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "To the extent Kern River has been or intends in the future to enforce the quality specifications detailed in the Biomethane Gas Quality Policy Statement, make an NGA section 4 filing to include those quality specifications in its Tariff.", "source_page": null }, { "number": 2, "text": "Until such time as the quality specifications are accepted by the Commission and included in its Tariff, Kern River should consider removing the Biomethane Gas Quality Policy Statement from its", "source_page": null } ], "themes": [ "Tariff administration & oversight", "Informational postings" ], "cost_to_customers": false }, { "index": 2, "title": "Tariff Administration and Oversight", "summary": "Kern River misapplied certain tariff provisions for capacity allocation, capacity release, and its customer activities website. Kern River’s misapplication of these tariff provisions did not appear to have caused any harm to shippers, and Kern River promptly contacted impacted shippers to correct the misapplication of its Tariff.", "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Revise and implement policies and procedures to ensure that tariff provisions are followed when making business decisions and interacting with shippers. Ensure that employees consistently review processes and procedures to prevent noncompliance, and promptly implement corrective actions to prevent its recurrence when noncompliance is identified.", "source_page": null }, { "number": 4, "text": "Provide training to relevant staff on the policies and procedures implemented in response to Recommendation 3, and repeat such trainings as needed.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 3, "title": "Informational Postings", "summary": "Kern River did not post and/or incorrectly posted certain required information on its Informational Postings website. This primarily included information pertaining to contracts and pipeline capacity. As a result, shippers did not have timely access to information potentially needed to make informed decisions on available capacity.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Revise and implement policies and procedures to ensure that all required postings are complete, accurate, and made timely to its Informational Postings Website, consistent with Commission requirements.", "source_page": null }, { "number": 6, "text": "Provide training to relevant staff on the policies and procedures implemented in response to Recommendation 5, and repeat such trainings as needed.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 4, "title": "Allowance for Funds Used During Construction", "summary": "Kern River improperly included unpaid contract retention amounts in its Allowance for Funds Used During Construction (AFUDC) rate calculation. This error resulted in Kern River over accruing AFUDC and consequently overstating gas plant in service and depreciation expense.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise and implement policies and procedures for calculating AFUDC consistent with the requirements of GPI No. 3. Revisions should ensure that unpaid contract retentions are excluded from the CWIP balance used for the purposes of the AFUDC accrual calculation.", "source_page": null }, { "number": 8, "text": "Provide training to relevant staff on the policies and procedures implemented in response to Recommendation 7, and repeat such trainings as needed.", "source_page": null }, { "number": 9, "text": "Recalculate accrued AFUDC in a manner consistent with GPI No. 3 that corrects for the improper inclusion of unpaid contract retention in the CWIP balances used for the purposes of the AFUDC accrual calculation.", "source_page": null }, { "number": 10, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of CWIP, gas plant in service, accumulated depreciation, ADIT, and other accounts impacted by the over accrual of AFUDC within 60 days of the date of the audit report.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 5, "title": "Annual Membership Dues", "summary": "Kern River incorrectly recorded certain membership dues in Account 850, Operation Supervision and Engineering, rather than in Accounts 921, Office Supplies and Expenses, and 930.2, Miscellaneous General Expenses. Additionally, a portion of the dues paid for one membership supported lobbying activities, which Kern River should have recorded in Account 426.4, Expenditures for Certain Civic, Political and Related Activities, instead of Account 850. Such misclassifications can affect Kern River’s cost-of-service rate development and result in improper functionalization of costs and rate recovery of nonoperating expenses. D.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise and implement policies and procedures to ensure proper accounting for all membership dues consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 12, "text": "Provide training to relevant staff on the policies and procedures implemented in response to Recommendation 11, and repeat such trainings as needed.", "source_page": null }, { "number": 13, "text": "Provide a recent journal entry, and supporting documentation, which demonstrates that membership dues such as those with the identified accounting misclassifications are now being recorded in accordance with the Commission’s accounting regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 6, "title": "Creditworthiness Standards", "summary": "Under the Commission’s creditworthiness policy, pipelines may require shippers who do not meet the pipeline’s creditworthiness standards to provide collateral up to three months’ worth of reservation charges. Section 29.2 of Kern River’s Tariff, which pertains to shippers who fail to establish creditworthiness, does not establish such a ceiling on the amount of collateral required. Absent a reference to this ceiling in its Tariff, Kern River could implement its creditworthiness requirements in a manner contrary to the Commission’s general policy of ensuring that open access service is reasonably available to shippers, and without allowing the Commission to consider any deviations from its general policy. E.", "is_other_matter": true, "recommendations": [ { "number": 14, "text": "Kern River should consider revising or removing section 29.2(c) of its Tariff. If Kern River decides to revise section 29.2(c), it should file the changes with the Commission and provide audit staff notification of that filing. If Kern River determines that this provision is no longer applicable for its creditworthiness determination, and decides to remove section 29.2(c), it should file this change with the Commission and provide audit staff notification of that filing.", "source_page": null }, { "number": 15, "text": "If Kern River revises section 29.2(c), update policies and procedures to reflect the Commission’s Creditworthiness Policy Statement value limit for the security interest in collateral from a non-creditworthy shipper. F.", "source_page": null } ], "themes": [ "Tariff administration & oversight", "Creditworthiness" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Creditworthiness", "Depreciation", "Informational postings", "Membership dues & industry associations", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-09-25_medallion-pipeline-company-llc_fa23-9", "company": "Medallion Pipeline Company, LLC", "company_raw": "Medallion Pipeline Company, LLC (FA23-9)", "docket": "FA23-9", "docket_full": "FA23-9-000", "issued_date": "2025-09-25", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250925-3005&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250925-3005", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 73, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to December 31, 2023", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 8, "findings": [ { "index": 1, "title": "Annual Cost of Service Based Analysis Schedule", "summary": "Medallion’s Page 700, Annual Cost of Service Based Analysis Schedule, in its FERC Form No. 6 submissions, contained input and calculation errors, inconsistencies in the application of Commission regulations, and deficiencies in workpaper support. These errors reduced the overall accuracy and usefulness of Medallion’s Page 700 submissions.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise and implement policies and procedures to ensure that Page 700 is prepared in a manner consistent with Opinion No. 154-B, Order Nos. 620 and 620-A, and the instructions of the FERC Form No. 6. These policies and procedures should address each issue identified in this finding, including input and calculation errors, amounts that were derived inconsistently with the Commission’s regulations, and deficiencies in workpaper support.", "source_page": null }, { "number": 2, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 1, and repeat such trainings as needed.", "source_page": null }, { "number": 3, "text": "Implement the method of equally weighting the Capital Asset Pricing Model (CAPM) and Discounted Cash Flow (DCF) model for the Return on Equity (ROE) calculation on Page 700 in accordance with Commission policy established in Docket No. PL19-4-000.", "source_page": null }, { "number": 4, "text": "Provide a copy of all workpapers supporting Medallion’s Page 700 calculations and inputs for the most recent submission of its FERC Form No. 6 to DAA for review within 30 days of the issuance of this report. The workpapers should show that Medallion has included and retained calculations and other information which adequately support the balances reported for each line item on Page 700.", "source_page": null }, { "number": 5, "text": "Perform an analysis to determine the impact on Page 700 resulting from the errors identified herein, for each year, from 2019 to the present. This analysis should be submitted to DAA within 90 days of the issuance of this report. For 2019 and 2024, refile the FERC Form No. 6 (only restating and footnoting Page 700) after audit staff reviews and approves all analyses and revised procedures.", "source_page": null }, { "number": 6, "text": "For the FERC Form No. 6 annual filings submitted after the issuance of this audit report, ensure that corrections made to impacted accounts and inputs are properly reported in the current year financial statements, including prior year corrected numbers, supporting schedules, and Page 700. Also ensure footnote disclosures about the corrections made are included in the notes to the financial statements and other relevant pages of the FERC Form No. 6.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Nonoperating and Operating Expenses", "summary": "Medallion improperly recorded certain nonoperating expenses, including costs for charitable donations and lobbying costs, in operating expense accounts, rather than recording these costs 2 As a result of the ONEOK Acquisition, Medallion’s headquarters are now in Tulsa, Oklahoma. 3 A reticulated pipeline system has a “web-like” design, with multiple paths to any given point, which may allow oil to be rerouted in the event of problems on certain pipeline segments. 4 During the audit period, Medallion reported that it provided transportation service on its pipeline system exclusively by gathering lines. in a nonoperating expense account. The incorrect accounting for these expenses resulted in Medallion overstating operating expenses and the total cost of service on Page 700. Additionally, Medallion misclassified dues paid to certain industry and trade associations in an incorrect operating expense account, which did not impact the total cost of service on Page 700.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise and implement policies and procedures to ensure that operating expenses and nonoperating expenses, including charitable donations and industry trade association dues, are recorded and reported in accordance with the Commission’s accounting regulations and related orders.", "source_page": null }, { "number": 8, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 7, and repeat such trainings as needed.", "source_page": null }, { "number": 9, "text": "Review expenses for the current year and make necessary correcting entries to reclassify amounts for charitable donations, lobbying expenses, and any other expenses that are nonoperating in nature from either Account 390 or Account 590 to Account 660. Perform a similar review of expenses for the current year and make necessary correcting entries to reclassify operating expenses incorrectly recorded in Account 390 to Account 590. Continue to apply this accounting for operating and nonoperating expenses prospectively.", "source_page": null }, { "number": 10, "text": "Provide a copy of the correcting entries made to DAA for review within 60 days of the issuance of this report.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 3, "title": "Noncarrier Property Revenue, Expenses, and Net Income", "summary": "Medallion incorrectly recorded the revenues and expenses associated with noncarrier property in operating expense and revenue accounts, during the audit period. This resulted in Medallion overstating the balances in operating expense and revenue accounts associated with carrier property and understating the balances in operating expense and revenue accounts associated with noncarrier property. This also affected the accuracy, comparability and usefulness of certain schedules in the FERC Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise and implement policies and procedures to ensure that revenues, expenses, and net income associated with noncarrier property are accounted for and reported in accordance with the Commission’s accounting regulations. Also strengthen policies and procedures to ensure personnel responsible for completing and reviewing the FERC Form No. 6 follow the instructions for completing the schedules prior to submission, to eliminate errors.", "source_page": null }, { "number": 12, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 11, and repeat such trainings as needed.", "source_page": null }, { "number": 13, "text": "Reclassify revenues and expenses associated with noncarrier property to Account 620 for the current year. Submit a copy of the journal entries to DAA within 30 days of the issuance of this report.", "source_page": null }, { "number": 14, "text": "Perform an analysis to determine the impact on Page 700 resulting from the errors identified herein, for each year, from 2019 to the present. This analysis should be submitted to DAA within 90 days of the issuance of this report. For 2019 and 2024, refile the FERC Form No. 6 (only restating and footnoting Page 700) after audit staff reviews and approves all analyses and revised procedures.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": false }, { "index": 4, "title": "Crude Oil Accounting Misclassifications", "summary": "Medallion incorrectly recorded certain crude oil transactions associated with pipeline loss allowance, sales and purchases of oil, oil spills and leaks, and transportation revenues. These misclassifications reduced the accuracy of Medallion’s accounting records and financial reporting in the FERC Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Revise and implement policies and procedures to ensure that Medallion accounts for pipeline loss allowance, sales and purchases of oil, and oil spills and leaks, and EPIC transportation revenues in accordance with the Commission’s accounting regulations.", "source_page": null }, { "number": 16, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 15, and repeat such trainings as needed.", "source_page": null }, { "number": 17, "text": "Make journal entries to correct the accounting for each misclassification for the current accounting year. Provide a copy of these journal entries to DAA for review within 60 days of the issuance of this report. These journal entries should support the implementation of the revised policies and procedures to correct the accounting for all the misclassification discussed in this finding.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 5, "title": "Other Accounting Misclassifications", "summary": "Medallion incorrectly recorded certain transactions associated with the accounting for contributions in aid of constructions (CIAC), incidental revenues, and taxes other than income taxes. These misclassifications reduced the accuracy of Medallion’s accounting records and financial reporting in the FERC Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Revise and implement policies and procedures to ensure that Medallion accounts for CIAC, incidental revenues, and taxes other than income taxes in accordance with the Commission’s accounting regulations.", "source_page": null }, { "number": 19, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 18, and repeat such trainings as needed.", "source_page": null }, { "number": 20, "text": "Make journal entries to correct the accounting for each misclassification for the current accounting year. Provide a copy of these journal entries to DAA within 60 days of the issuance of this report for review. These journal entries should support the implementation of the revised policies and procedures to correct for all the accounting misclassifications discussed in this finding.", "source_page": null }, { "number": 21, "text": "Perform an analysis to determine the impact on Page 700 resulting from the errors identified herein, for each year, from 2019 to the present. This analysis should be submitted to DAA within 90 days of the issuance of this report. For 2019 and 2024, refile the FERC Form No. 6 (only restating and footnoting Page 700) after audit staff reviews and approves all analyses and revised procedures.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Property Unit Listing", "summary": "Medallion did not maintain a written property unit listing for additions and retirements of its carrier property. Medallion instead applied its capitalization policy, which did not identify and describe what constituted property units for each carrier property account. As a result, Medallion did not meet the Commission’s requirement to maintain a written property unit listing, which serves to provide consistent accounting for additions and retirements of carrier property. Absent having a written property unit listing, Medallion could not identify the criteria it used to account for additions and retirements of carrier property to comply with the Commission’s accounting requirements.", "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Establish and implement policies and procedures to ensure that all property units are defined in a property unit listing and that Medallion consistently applies its written property unit listing pursuant to 18 C.F.R. Part 352.", "source_page": null }, { "number": 23, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 22, and repeat such trainings as needed.", "source_page": null }, { "number": 24, "text": "Update Medallion’s property unit listing to contain descriptions of the property units that make up each account. Submit a copy of the updated property unit listing to DAA for review within 60 days of the issuance of this report.", "source_page": null }, { "number": 25, "text": "Review and update Medallion’s fixed asset subledger to incorporate the policy and procedural changes discussed herein to ensure Medallion captures costs for additions and retirements consistently with its property unit listing.", "source_page": null } ], "themes": [ "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 7, "title": "Depreciation Rates and Study", "summary": "Medallion did not prepare a depreciation study or seek approval from the Commission for its initial depreciation rates used to calculate depreciation expense from 2014 to 2018. In 2020, Medallion filed a depreciation study but failed to propose a depreciation rate or provide the associated support for one account. These deficiencies impeded the Commission’s ability to ensure Medallion was complying with statutory accounting and ratemaking requirements and to verify that the pipeline was systematically and rationally allocating the cost of carrier property assets over such assets’ useful lives consistent with regulatory standards.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Revise and implement policies and procedures to ensure that Medallion uses Commission-approved depreciation rates for all carrier property assets (or accounts). These policies and procedures should ensure that those depreciation rates, along with a supporting depreciation study, are timely filed with the Commission, in accordance with GI 1-8.", "source_page": null }, { "number": 27, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 26, and repeat such trainings as needed.", "source_page": null }, { "number": 28, "text": "Update the 2020 depreciation study to include appropriate schedules to support the derivation of the depreciation rate for Account 116.", "source_page": null }, { "number": 29, "text": "Based on the updated depreciation study, make a filing with the Commission that supports the depreciation rate used for the carrier property Account 116 that was depreciated without having that rate on file with the Commission.", "source_page": null }, { "number": 30, "text": "In the filing made with the Commission, explain changes or adjustments that were made to any existing depreciation rate because of the updated or new depreciation study. If applicable, include a footnote disclosure in the next FERC Form No. 6 report filed with the Commission.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 8, "title": "FERC Form No. 6 Reporting", "summary": "Medallion did not report complete and accurate information in certain supporting schedules of its FERC Form No. 6 filings. These reporting deficiencies and discrepancies reduced the accuracy and usefulness of certain information reported in Medallion’s FERC Form No. 6 during the audit period. D.", "is_other_matter": false, "recommendations": [ { "number": 31, "text": "Revise and implement policies and procedures to ensure that Medallion reports complete and accurate information according to the Commission’s FERC Form No. 6 instructions. These revised policies and procedures should address all reporting deficiencies for each page of the FERC Form No. 6 discussed in this finding.", "source_page": null }, { "number": 32, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 31, and repeat such trainings as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management efficiency investigation", "id": "2025-09-25_firstenergy-pennsylvania-electric_pa-mei", "company": "FirstEnergy Pennsylvania Electric Company", "company_raw": "FirstEnergy Pennsylvania Electric Company", "docket": null, "docket_full": null, "issued_date": "2025-09-25", "source_page_url": "https://www.puc.pa.gov/press-release/2025/puc-issues-management-efficiency-investigation-report-for-firstenergy-pennsylvania-electric-company-09252025", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1896261.pdf", "captured_at": "2026-06-01", "source_note": "Management Efficiency Investigation (follow-up to the 2022 Management & Operations Audit) issued by the PA PUC Bureau of Audits, published 2025-09-25. PDF: puc.pa.gov/pcdocs/1896261.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 65, "scanned_pages": [ 1, 65 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-09-18_pacific-gas-and-electric-company_fa23-8", "company": "Pacific Gas and Electric Company", "company_raw": "Pacific Gas and Electric Company (FA23-8)", "docket": "FA23-8", "docket_full": "FA23-8-000", "issued_date": "2025-09-18", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250918-3011&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250918-3011", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 76, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 through April 30, 2025", "industry": "electric", "audit_type": "financial", "functions": [ "transmission", "distribution" ], "forms": [ "1" ], "finding_count": 8, "findings": [ { "index": 1, "title": "Allocation of Overhead Costs to CWIP", "summary": "PG&E capitalized labor and labor-related overhead costs to Account 107, Construction Work in Progress – Electric, using an allocation method that was not based on the actual time that employees were engaged in construction activities or on a study of the time actually engaged during a representative period, thereby charging costs to Account 107 that did not have a definite relation to construction. As a result, PG&E may have overstated construction costs recorded in Account 107 and electric plant in service costs recorded in Account 101 or other plant accounts, as well as accumulated depreciation and accumulated deferred income taxes (ADIT), and may have understated operating expenses. Moreover, this accounting may have led PG&E to overstate its wholesale transmission revenue requirement (TRR) and wholesale distribution revenue requirement (DRR) and overbill customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Retain an independent third-party entity to conduct a representative labor-time study for allocation of labor and labor-related overhead costs incurred in 2025, and to assist with the development of procedures PG&E shall use after 2025 to periodically determine the allocation of overhead labor and labor-related costs capitalized into the cost of construction. The consultant should have experience independently performing time studies used in the determination of overhead capitalization rates of U.S.-based utilities subject to the accounting requirements prescribed for public utilities and licensees or for natural gas companies under 18 C.F.R. Part 101 or Part 201, respectively. The time study should involve a representative sample of study participants (employees) that provides for extrapolation of the study results to the full population of PG&E employees. The time study should include processes to apply the study results from the beginning of the audit period to the issue date of this audit report. In addition, the study should include processes to apply the capitalization rate(s) the study finds for 2025 back to the period January 1, 2020 through December 31, 2024, either with no change to the capitalization rates found in the study or with such modifications to the capitalization rate(s) that the independent consultant finds reasonable and supported by evidence. The independent consultant should use its expertise and all relevant information available to it to make recommendations as to what the capitalization rate(s) should be for prior years for PG&E, set forth the basis for its recommendations, and provide both the recommendations and the basis to PG&E and DAA. If there is no recommendation by the independent consultant for any year or other period between January 1, 2020 and December 31, 2024 for any specific capitalizable department, then PG&E should base its capitalization rate and the amount to be capitalized for such year or period on the rates and costs of such specific work orders for which PG&E can provide to DAA reasonable evidence as to the time employees charging such work orders spent having a definite relation to construction and exclude from consideration those work orders for which PG&E cannot provide such evidence, per, for example, 18 C.F.R. Part 101, General Instruction No. 2 and § 41.8.", "source_page": null }, { "number": 2, "text": "Report the progress of the study within 120 days and provide the study results to DAA for review and consideration within 180 days of the date of this audit report. The allocation procedures should be submitted when complete but no later than 60 days after completion of DAA’s review of the study. At a minimum, the allocation procedures should provide a method for overhead cost allocation and capitalization to construction based on actual timecards or, where this procedure is impractical, based on a study of the time employees were actually engaged in construction related activities during a representative period.", "source_page": null }, { "number": 3, "text": "Revise policies and procedures governing the methods used to account for, track, report, and review overhead labor, labor-related costs, and all other costs allocated to construction projects to be consistent with the Commission’s accounting requirements. In addition, adopt procedures to retain formal documentation supporting the amount of overhead costs allocated to utility plant accounts.", "source_page": null }, { "number": 4, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 3, and repeat such trainings as needed.", "source_page": null }, { "number": 5, "text": "Within 30 days of the completion of Recommendation No. 1, submit an estimate to DAA, including the calculations and determinative components, of overhead costs that would have been allocated to CWIP from January 1, 2020 through the present consistent with the requirements of Electric Plant Instruction No. 4 and General Instruction No. 9. The estimate should be based on a recalculation of 2020 and subsequent years’ overhead costs allocated to construction with labor and labor-related costs removed from the cost of plant (Transmission, Distribution, General, and Production) that were not associated with construction activities based on the methodology developed in response to Recommendation No. 1.", "source_page": null }, { "number": 6, "text": "With the response to Recommendation No. 5, submit proposed accounting entries to DAA that remove the excess overhead costs from Transmission, Distribution, General, and Production plant accounts that were allocated to CWIP and electric plant in service during the audit period. The amount of overhead costs removed should be the excess amount of such costs as determined based on the methodology developed in response to Recommendation No. 1. Also, provide proposed accounting entries to remove associated amounts from other accounts and balances affected by the inappropriately allocated costs such as the accumulated depreciation and ADIT accounts and AFUDC balances capitalized into CWIP and electric plant in service. If the adjusting entries result in a significant impact to income for the current year, PG&E may account for the transaction as a correction of a prior period error in Account 439, Adjustments to Retained Earnings. Such an entry should be submitted with the proposed accounting entries.", "source_page": null }, { "number": 7, "text": "Submit a refund analysis to DAA that explains and details the following: (1) calculation of refunds, plus interest, that result from the correction of the overstated electric plant in service amounts included in rate determinations due to the improper capitalization of labor and labor-related costs, as determined by the study conducted in response to Recommendation No. 1, from January 1, 2020 to the present; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 8, "text": "File a refund report with the Commission that accords with DAA’s assessment of the refund analysis described in the previous recommendation.", "source_page": null }, { "number": 9, "text": "Refund amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Operating and Maintenance Expenses", "summary": "PG&E recorded various operating and maintenance (O&M) expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, PG&E overstated its TRR and DRR and overbilled customers.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Revise accounting policies and procedures to help ensure that PG&E properly accounts for expenditures consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 11, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 10, and repeat such trainings as needed.", "source_page": null }, { "number": 12, "text": "Perform an analysis of O&M expense accounts from 2020 to the present to identify costs that were improperly accounted for and included in PG&E’s transmission and distribution wholesale formula rate calculations and the related customer billings. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 13, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to audit staff that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting for expenses recorded in O&M Accounts from 2020 to the present, plus interest; (2) determinative components of the refund; (3) refund method; and (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 14, "text": "File a refund report with the Commission that accords with DAA’s assessment of the refund analysis described in the previous recommendation.", "source_page": null }, { "number": 15, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Administrative and General Expenses", "summary": "PG&E recorded various administrative and general (A&G) expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, PG&E overstated its TRR and DRR and overbilled customers.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise accounting policies and procedures to help ensure that PG&E properly accounts for expenditures consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 17, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 16, and repeat such trainings as needed.", "source_page": null }, { "number": 18, "text": "Perform an analysis of A&G and expense accounts from 2020 to the present to identify costs that were improperly accounted for and included in PG&E’s transmission and distribution wholesale formula rate calculations and the related customer billings. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 19, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to audit staff that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting for expenses recorded in A&G Accounts from 2020 to the present, plus interest; (2) determinative components of the refund; (3) refund method; and (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 20, "text": "File a refund report with the Commission that accords with DAA’s assessment of the refund analysis described in the previous recommendation.", "source_page": null }, { "number": 21, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Compromise Settlements", "summary": "PG&E improperly recorded compromise settlement payments relating to claims of alleged employee discrimination in Account 925, Injuries and Damages, instead of in Account 426.5, Other Deductions. As a result, PG&E overstated its TRR and DRR and overbilled its customers.", "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Revise accounting policies and procedures to properly record compromise settlements, expenses of internal and external counsel’s legal defense, and other costs of employment discrimination claims (compromise settlement expenses) in Account 426.5, consistent with the Commission’s accounting regulations and AR- 12.", "source_page": null }, { "number": 23, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 22, and repeat such trainings as needed.", "source_page": null }, { "number": 24, "text": "Perform an analysis to identify compromise settlement expenses that were improperly included in accounts that had balances used as inputs to PG&E’s wholesale transmission and distribution formula rates and the determination of customer billings from 2020 to the present. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 25, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to audit staff for review that explains and details the following: (1) calculation of refunds that resulted from the improper accounting for employment discrimination claims resolved by compromise settlements expenses from 2020 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 26, "text": "File a refund report with the Commission that accords with DAA’s assessment of the refund analysis described in the previous recommendation.", "source_page": null }, { "number": 27, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Allowance for Funds Used During Construction", "summary": "PG&E’s method for computing and accounting for its AFUDC rate was deficient. Specifically, PG&E improperly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, in determining the equity component of its AFUDC rate. Also, PG&E improperly used month-end balances for long-term debt and equity instead of year-end balances for the purposes of calculating its AFUDC rate. In addition, PG&E improperly excluded certain long-term debt balances and did not calculate the long-term debt cost rate in accordance with 18 C.F.R. § 35.13.", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Revise policies and procedures to calculate the AFUDC rate consistent with Electric Plant Instruction No. 3(A)(17), and other applicable Commission requirements. Revisions should include processes to: (1) prevent the inclusion of balances in Account 216.1, (2) ensure the use of calendar year-end book balances for long-term debt, preferred stock, and common equity, (3) ensure the long-term debt cost rate is calculated in accordance with 18 C.F.R. § 35.13, and (4) ensure all outstanding long term debt is included for the purpose of computing the AFUDC rate.", "source_page": null }, { "number": 29, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 28, and repeat such trainings as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 6, "title": "Accounting for Customer Advances", "summary": "PG&E did not properly track costs recorded to Account 252, Customer Advances for Construction. As a result, PG&E overstated Account 252, which affected the accuracy of the information reported in its FERC Form No. 1.", "is_other_matter": false, "recommendations": [ { "number": 30, "text": "Revise accounting policies and procedures to ensure that PG&E properly records customer advances in Account 252 and adjusts the respective plant accounts related to Account 252, consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 31, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 30, and repeat such trainings as needed.", "source_page": null }, { "number": 32, "text": "Perform an analysis of Account 252 to identify customer advances that are associated with assets that were transferred to third parties or refunded but continue to remain in Account 252. Provide the results of the analysis and proposed accounting entries with supporting documentation to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 33, "text": "Revise CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 32.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 7, "title": "Prepayments", "summary": "PG&E improperly recorded certain advance payments that were applicable to future accounting periods in A&G and O&M expense accounts, instead of in Account 165, Prepayments. As a result, PG&E did not accurately recognize certain expenses in the period in which they were incurred, leading to the misstatement of A&G, O&M, and balance sheet account balances reported in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [ { "number": 34, "text": "Revise policies and procedures to ensure that PG&E properly records all advance payments that are applicable to future periods in accordance with the Commission’s regulations.", "source_page": null }, { "number": 35, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 34, and repeat such trainings as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 8, "title": "FERC Form No. 1 Reporting", "summary": "PG&E did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. These actions affected the transparency and accuracy of the reported information. D.", "is_other_matter": false, "recommendations": [ { "number": 36, "text": "Revise and strengthen policies, procedures, and practices to report correct, accurate, and complete information in the FERC Form No. 1 consistent with the page instructions.", "source_page": null }, { "number": 37, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 36, and repeat such trainings as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Capitalization vs. expense", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on formal challenge", "id": "2025-09-18_iso-new-england_er20-2054", "company": "ISO New England Inc. et al.", "company_raw": "ISO New England Inc. et al.", "docket": "ER20-2054", "docket_full": null, "issued_date": "2025-09-18", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250918-3062&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250918-3062", "captured_at": "2026-06-01", "source_note": "FERC Commission order on a formal challenge (Rule 206) re ISO New England Inc. et al., Docket ER20-2054, issued 2025-09-18. Found via eLibrary full-text search; accession 20250918-3062.", "archived_via": null, "page_count": 34, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-09-08_talen-energy_pa22-7", "company": "Talen Energy", "company_raw": "Talen Energy (PA22-7)", "docket": "PA22-7", "docket_full": "PA22-7-000", "issued_date": "2025-09-08", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250908-3009&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250908-3009", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 34, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2019 to October 31, 2024", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [], "finding_count": 3, "findings": [ { "index": 1, "title": "Generation Outage Requests Submitted to PJM’s electronic Dispatcher Application Reporting Tool (eDART) System", "summary": "Talen Energy submitted generation outage tickets to PJM’s eDART that were not consistent with the operational status of Talen Energy’s generation resources. Talen Energy’s inconsistent submittals to eDART may have resulted in incorrect assumptions being used during reliability and market studies performed by PJM to operate its day-ahead and real-time energy markets.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Generation Outage Reporting in Generating Availability Data System (GADS)", "summary": "Talen Energy did not properly report the operational status of certain generation resources in NERC’s GADS. Specifically, Talen Energy submitted maintenance outage events to GADS that should have been categorized as unplanned outages. Talen Energy’s improper reporting to NERC’s GADS resulted in a more favorable outage rate for subsequent accreditation in PJM’s capacity auctions.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Discrepancies between Reported Generator Outages and Offer Schedules", "summary": "Offer schedules submitted to PJM’s day-ahead and real-time energy markets in certain instances were inconsistent with outages and derates communicated to PJM and submitted to eDART. During the audit period, Talen Energy appeared to offer resources above their expected availability compared to reported generator outages or derates in eDART and appeared to offer resources below the level of their energy must-offer obligations to PJM’s day-ahead market and/or real-time market compared to reported generator outages or derates in eDART. Such mismatches can generate compliance flags for market operators, market monitors, and surveillance analysts. D.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Perform a review of all eDART outage and derate data against Talen Energy’s resource offer schedules since January 1, 2023 and submit a report to DAA that includes the following: (a) a list of instances where the eDART data does not match the resource energy offer schedules, (b) an indication as to whether the mismatch resulted in a failure to meet must offer obligations in PJM’s energy markets, (c) the duration and magnitude of any such shortfalls of capacity and any efforts made to procure replacement capacity in the event of a failure to meet a must offer obligation, (d) a list of errors or omissions in PJM eDART submissions that were identified in the review, and (e) a list of errors or omissions in the GADS data that were identified in the review.", "source_page": null }, { "number": 10, "text": "Update event reports in the GADS system for the events identified in Recommendation 9.", "source_page": null }, { "number": 11, "text": "Establish and implement policies and procedures to ensure that all applicable offer data in the day-ahead and real-time markets are consistent with the operational status of the resources at the time of submission and in compliance with must offer obligations.", "source_page": null }, { "number": 12, "text": "Establish and implement policies and procedures to ensure that communications, including communications related to energy and ancillary services market offers, outages, derates, and other operational details, between Talen Energy and its energy managers are timely and effective.", "source_page": null }, { "number": 13, "text": "Establish and implement policies and procedures to perform an after-the-fact review to ensure that energy offer and outage/derate data submitted by Talen Energy and/or its energy managers were accurately recorded and reflected the actual availability of the resource.", "source_page": null }, { "number": 14, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendations 11, 12, and 13, and repeat such trainings as needed. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "WA", "source": "Washington Utilities and Transportation Commission", "doc_type": "deferred accounting order", "id": "2025-09-04_puget-sound-energy_wa-ue-220066-order-38", "company": "Puget Sound Energy", "company_raw": "Puget Sound Energy", "docket": "UE-220066", "docket_full": null, "issued_date": "2025-09-04", "source_page_url": "https://www.utc.wa.gov/casedocket/2022/220066", "pdf_download_url": "https://apiproxy.utc.wa.gov/cases/GetDocument?docID=4536&year=2022&docketNumber=220066", "captured_at": "2026-06-07", "source_note": "Washington UTC Order 38 (service date September 4, 2025), Dockets UE-220066 / UG-220067 (Consolidated), Washington Utilities and Transportation Commission v. Puget Sound Energy — on PSE's petition for an order authorizing deferred accounting treatment for PSE's share of certain costs (5 pp). Listed for reference (metadata-only). Source: WA UTC document API (apiproxy.utc.wa.gov/cases/GetDocument?docID=4536&year=2022&docketNumber=220066).", "archived_via": null, "page_count": 5, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Approval: $88 million", "summary": "o be known and measurable, used and useful, and prudent. 3 Staff explains that PSE pursued multiple grant opportunities in excess of $88 million and that of the 19 grant applications submitted, eight were successful. However, Staff notes that not all the grants had a monetary component, and th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "final order", "id": "2025-09-04_commonwealth-edison_icc-24-0087-final-order", "company": "Commonwealth Edison Company", "company_raw": "Commonwealth Edison Company", "docket": "24-0087", "docket_full": null, "issued_date": "2025-09-04", "source_page_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/370165", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/370165/files/648653.pdf", "captured_at": "2026-06-01", "source_note": "Final Order of the Illinois Commerce Commission in Commonwealth Edison Company's reconciliation of Rider CFRA (Carbon-Free Resource Adjustment) revenues against actual carbon-mitigation-credit costs, ICC Docket 24-0087, entered September 4, 2025 (Chairman Douglas P. Scott). Listed for reference (metadata-only). Source: ICC e-Docket, document 370165 / file 648653 (landing: www.icc.illinois.gov/docket/P2024-0087/documents/370165).", "archived_via": null, "page_count": 23, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 7, "findings": [ { "index": 1, "title": "Disallowance: $175 million", "summary": "and prudent.”) (emphasis added). According to ComEd, there is no basis in fact for CICI’s proposed $175 million disallowance of CMC costs. The costs ComEd incurred and that ComEd is reconciling in this proceeding are the costs of the CMCs ComEd was statutorily required", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Disallowance: $175 million", "summary": "(as adjusted by agreement between ComEd and Staff). There is thus no basis in the record for CICI’s $175 million disallowance. ComEd further argues that there is no basis in law for such an extraordinary and unprecedented penalty. There is nothing in the record, the Act,", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $175 million", "summary": "the under-recovery could have been reduced if ComEd had acted prudently and is a sound basis for disallowance of $175 million. CICI Ex. 1.0 at 16. CICI contends that a minimum of $175 million of the under-recovery was not prudently incurred costs and should be disallowed by", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $175\nmillion", "summary": "epancy was imprudent and created a regulatory asset for ComEd. CICI argues the Commission should disallow $175 million of the under-recovery plus the associated interest amount. The Commission agrees ComEd has failed to demonstrate the reasonableness of its actions bu", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $55.4 million", "summary": "n on ComEd’s customers without providing them with any benefit. Therefore, the Commission should disallow the $55.4 million in compounded interest charges as well as the conservative disallowance of $175 million of the under-recovery discussed supra. Lastly, CICI contends", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Approval: $175 million", "summary": "ion should disallow the $55.4 million in compounded interest charges as well as the conservative disallowance of $175 million of the under-recovery discussed supra. Lastly, CICI contends that the sections of the Act authorizing the CMC program do not authorize ComEd to charg", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Approval: $55.4\nmillion", "summary": "f Rider CFRA. ComEd Ex. 4.0 at 7-8. ComEd states that CICI’s argument that the Commission should disallow the $55.4 million in interest charges because it is an operating expense on which the Commission should not allow ComEd to earn a rate of return (see CICI IB at 12-14)", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true } ], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "WA", "source": "Washington Utilities and Transportation Commission", "doc_type": "commission order", "id": "2025-09-04_avista_wa-ue-220053-order", "company": "Avista Corporation d/b/a Avista Utilities", "company_raw": "Avista Corporation d/b/a Avista Utilities", "docket": "UE-220053", "docket_full": null, "issued_date": "2025-09-04", "source_page_url": "https://www.utc.wa.gov/casedocket/2022/220053", "pdf_download_url": "https://apiproxy.utc.wa.gov/cases/GetDocument?docID=1913&year=2022&docketNumber=220053", "captured_at": "2026-06-07", "source_note": "Washington UTC order (service date September 4, 2025), Washington Utilities and Transportation Commission v. Avista Corporation d/b/a Avista Utilities, Dockets UE-220053 / UG-220054 / UE-210854 (Consolidated) — an order in Avista's general rate case proceeding (7 pp). Listed for reference (metadata-only). Source: WA UTC document API (apiproxy.utc.wa.gov/cases/GetDocument?docID=1913&year=2022&docketNumber=220053).", "archived_via": null, "page_count": 7, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "Settlement: terms", "summary": "he settlement was lawful, supported by the record, and consistent with the public interest.4 11 The settlement terms addressing the annual capital projects review process extended the company’s initial proposal for the review period from three to four months “to all", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Settlement: terms", "summary": "settlement in the general rate proceeding for Northwest Natural Gas in Docket UG-200994, et al. The settlement terms on the capital projects review were included to provide assurance that the provisional capital included prior to the rate effective period (for 2022", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "WV", "source": "Public Service Commission of West Virginia", "doc_type": "fuel cost review order", "id": "2025-09-04_appalachian-wheeling-power_wv-25-0413-e-enec", "company": "Appalachian Power Company and Wheeling Power Company", "company_raw": "Appalachian Power Company and Wheeling Power Company", "docket": "25-0413-E-ENEC", "docket_full": null, "issued_date": "2025-09-04", "source_page_url": "http://www.psc.state.wv.us/scripts/WebDocket/tblCaseActivitiesList.cfm?CaseID=84794", "pdf_download_url": "http://www.psc.state.wv.us/scripts/WebDocket/ViewDocument.cfm?CaseActivityID=648122&NotType=WebDocket", "captured_at": "2026-06-02", "source_note": "Commission Order in the annual Expanded Net Energy Cost (ENEC) review of Appalachian Power Company and Wheeling Power Company, West Virginia PSC Case No. 25-0413-E-ENEC, entered September 4, 2025 — continuing the current ENEC rate and deferring treatment of the under-recovery to the securitization case (25-0310-E-PC); the companies had proposed a $71.6 million ENEC increase. Listed for reference (metadata-only). Source: WV PSC WebDocket, document CaseActivityID 648122 (case activities list: psc.state.wv.us/scripts/WebDocket/tblCaseActivitiesList.cfm?CaseID=84794).", "archived_via": null, "page_count": 8, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "Approval: $69.8 million", "summary": "erefore, will accept its adjustments to the ENEC proposed revenue increase. The Companies should be allowed an annual ENEC increase of $69.8 million. As we explained in the Order issued in Case No. 24-0854-E-42T, we are approving the Companies’ proceeding with securitization. We anticipate that th", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 2, "title": "Approval: $68.9 million", "summary": "o tie coal contract prices to PJM energy market prices. CONCLUSIONS OF LAW 1. The Commission should allow $68.9 million in additional revenue requirements in this case, but that amount should be deferred to coincide with the decrease proposed by the Companies in their", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery", "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-09-03_alabama-power-company_pa24-5", "company": "Alabama Power Company", "company_raw": "Alabama Power Company (PA24-5)", "docket": "PA24-5", "docket_full": "PA24-5-000", "issued_date": "2025-09-03", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250903-3001&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250903-3001", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 44, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2019 to December 31, 2023", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Acquisition-Related Costs", "summary": "Alabama Power did not track and exclude $3,548,278 of outside services relating to either the TAP II or Calhoun Power acquisitions from accounts that were Commission-jurisdictional rate inputs. As a result, a portion of these acquisition-related expenses was improperly included in the Southern OATT’s system-wide transmission revenue requirement calculation and billed to transmission customers taking service under the OATT.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Acquisition-Related Internal Labor", "summary": "Alabama Power did not track and exclude $1,768,184 of internal labor for its employees who performed work on either the TAP II or Calhoun Power acquisitions from accounts that were Commission-jurisdictional rate inputs. As a result, a portion of these acquisition-related expenses was improperly included in the Southern OATT’s system-wide transmission revenue requirement calculation and billed to transmission customers taking service under the OATT.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Lobbying Expenses", "summary": "Alabama Power improperly recorded $818,002 of lobbying expenses in Account 920, Administrative and General Salaries, and Account 426.5, Other Deductions, instead of recording this amount in Account 426.4, Expenditures for Certain Civic, Political and Related Activities. As a result, a portion of these expenses was improperly included in the Southern OATT’s system-wide transmission revenue requirement calculation and improperly billed to transmission customers taking service under the OATT.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 4, "title": "Account Misclassifications", "summary": "Alabama Power improperly recorded expenses totaling $602,665 in various administrative and general (A&G) accounts. As a result, a portion of these expenses was improperly included in the Southern OATT’s system-wide transmission revenue requirement calculation and billed to transmission customers taking service under the OATT.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Edison Electric Institute Membership Dues", "summary": "Alabama Power improperly recorded $2,942,962 of Edison Electric Institute (EEI) annual membership dues, including dues designated as lobbying and donation expenditures, in various A&G and nonoperating expense accounts. As a result, a portion of these expenses was improperly included in the Southern OATT’s system-wide transmission revenue requirements calculation and billed to transmission customers taking service under the OATT. D.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Membership dues & industry associations" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "VA", "source": "Virginia State Corporation Commission", "doc_type": "net metering order", "id": "2025-08-29_appalachian-power_pur-2024-00161", "company": "Appalachian Power Company", "company_raw": "Appalachian Power Company", "docket": "PUR-2024-00161", "docket_full": null, "issued_date": "2025-08-29", "source_page_url": "https://www.scc.virginia.gov/docketsearch", "pdf_download_url": "https://www.scc.virginia.gov/docketsearch/DOCS/87nd01!.PDF", "captured_at": "2026-06-01", "source_note": "Final Order on Appalachian Power Company's petition to revise its net energy metering program under Va. Code § 56-594 E, Case No. PUR-2024-00161, Virginia State Corporation Commission, entered at Richmond August 29, 2025. Listed for reference (metadata-only). Source: SCC DocketSearch, document www.scc.virginia.gov/docketsearch/DOCS/87nd01!.PDF.", "archived_via": null, "page_count": 12, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "WI", "source": "Public Service Commission of Wisconsin", "doc_type": "fuel cost reconciliation prudence review — Final Decision", "id": "2025-08-28_wisconsin-power-light_wi-6680-fr-2024-fuel-reconciliation", "company": "Wisconsin Power and Light Company (Alliant Energy)", "company_raw": "Wisconsin Power and Light Company (Alliant Energy)", "docket": "6680-FR-2024", "docket_full": null, "issued_date": "2025-08-28", "source_page_url": "https://apps.psc.wi.gov/ERF/ERFsearch/content/documentInfo.aspx?docid=559688", "pdf_download_url": "https://apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=559688", "captured_at": "2026-06-08", "source_note": "PSC of Wisconsin Final Decision reconciling Wisconsin Power and Light (Alliant/WP&L) actual 2024 fuel costs to the authorized fuel cost plan, Docket 6680-FR-2024, issued 2025-08-28 (PSC 116.07 fuel prudence). PDF: apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=559688.", "archived_via": null, "page_count": 13, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "ND", "source": "North Dakota Public Service Commission", "doc_type": "fuel rider filing", "id": "2025-08-19_otter-tail-power_nd-pu-23-342-dual-fuel-riders", "company": "Otter Tail Power Company", "company_raw": "Otter Tail Power Company", "docket": "PU-23-342", "docket_full": null, "issued_date": "2025-08-19", "source_page_url": "https://www.psc.nd.gov/public/cases/", "pdf_download_url": "https://www.psc.nd.gov/webdocs/case/23-0342/157-010.pdf", "captured_at": "2026-06-07", "source_note": "Otter Tail Power Company filing (August 19, 2025) before the North Dakota Public Service Commission in its Dual Fuel Riders proceeding, Case No. PU-23-342 (10 pp). Listed for reference (metadata-only). Source: ND PSC public case records, document 157-010 (psc.nd.gov/webdocs/case/23-0342/157-010.pdf).", "archived_via": null, "page_count": 10, "scanned_pages": [ 5, 6, 10 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NY", "source": "New York State Department of Public Service", "doc_type": "rate case summary", "id": "2025-08_niagara-mohawk-national-grid_ny-24-e-0322-rate-case-summary", "company": "Niagara Mohawk Power Corporation d/b/a National Grid", "company_raw": "Niagara Mohawk Power Corporation d/b/a National Grid", "docket": "24-E-0322", "docket_full": null, "issued_date": "2025-08-14", "source_page_url": "https://dps.ny.gov/pending-and-recent-electric-rate-cases", "pdf_download_url": "https://dps.ny.gov/system/files/documents/2025/08/national-grid-electric-post-order-rate-case-summary_0.pdf", "captured_at": "2026-06-07", "source_note": "New York DPS post-order electric rate-case summary for Niagara Mohawk Power Corporation d/b/a National Grid, Case 24-E-0322 — published under Public Service Law §66(12)(l). The PSC adopted a joint proposal (Aug 14, 2025) granting electric delivery revenue increases of $167.3M / $297.4M / $243.4M over a three-year plan, ~67% below the request. Listed for reference (metadata-only). Source: NY DPS (dps.ny.gov/system/files/documents/2025/08/national-grid-electric-post-order-rate-case-summary_0.pdf).", "archived_via": null, "page_count": 1, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "WI", "source": "Public Service Commission of Wisconsin", "doc_type": "fuel cost reconciliation prudence review — Final Decision", "id": "2025-08-12_wisconsin-electric_wi-6630-fr-2024-fuel-reconciliation", "company": "Wisconsin Electric Power Company (We Energies)", "company_raw": "Wisconsin Electric Power Company (We Energies)", "docket": "6630-FR-2024", "docket_full": null, "issued_date": "2025-08-12", "source_page_url": "https://apps.psc.wi.gov/ERF/ERFsearch/content/documentInfo.aspx?docid=557994", "pdf_download_url": "https://apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=557994", "captured_at": "2026-06-08", "source_note": "PSC of Wisconsin Final Decision reconciling We Energies (WEPCO) actual 2024 fuel costs to the authorized fuel cost plan, Docket 6630-FR-2024, issued 2025-08-12 (Wis. Admin. Code PSC 116.07 fuel prudence). PDF: apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=557994.", "archived_via": null, "page_count": 10, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "VA", "source": "Virginia State Corporation Commission", "doc_type": "rate adjustment clause order", "id": "2025-08-01_virginia-electric-power_pur-2025-00076", "company": "Virginia Electric and Power Company (Dominion Energy Virginia)", "company_raw": "Virginia Electric and Power Company (Dominion Energy Virginia)", "docket": "PUR-2025-00076", "docket_full": null, "issued_date": "2025-08-01", "source_page_url": "https://www.scc.virginia.gov/docketsearch", "pdf_download_url": "https://www.scc.virginia.gov/docketsearch/DOCS/873b01!.PDF", "captured_at": "2026-06-01", "source_note": "Final Order on Virginia Electric and Power Company's (Dominion Energy Virginia) revised transmission rate adjustment clause Rider T1 under Va. Code § 56-585.1 A 4 (deeming prudent RTO transmission and FERC-approved demand-response costs), Case No. PUR-2025-00076, Virginia State Corporation Commission, entered August 1, 2025. Listed for reference (metadata-only). Source: SCC DocketSearch, document www.scc.virginia.gov/docketsearch/DOCS/873b01!.PDF.", "archived_via": null, "page_count": 4, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-07-25_duke-energy-progress-llc_fa23-6", "company": "Duke Energy Progress, LLC", "company_raw": "Duke Energy Progress, LLC (FA23-6)", "docket": "FA23-6", "docket_full": "FA23-6-000", "issued_date": "2025-07-25", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250725-3010&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250725-3010", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 101, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to September 30, 2024", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "3-Q", "580" ], "finding_count": 11, "findings": [ { "index": 1, "title": "Recovery of Fuel Contract Buyout Costs", "summary": "DEP included buyout costs of $12,510,674 in accounts that are inputs to DEP’s wholesale cost-based formula rates without Commission approval. As a result, DEP overstated its wholesale cost-based revenue requirements and resulting billings to FERC-jurisdictional customers by approximately $3,500,000 during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Fuel Storage and Handling", "summary": "DEP recorded $4,190,000 of fuel handling costs, including storage costs, in Account 151, Fuel Stock, rather than separately recording such costs in either Account 152, Fuel Stock Expenses Undistributed, or Account 501, Fuel. As a result, DEP overstated its wholesale cost-based revenue requirements and resulting billings to FERC-jurisdictional customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 3, "title": "Wholesale Revenue Credits", "summary": "DEP improperly allocated power production revenue credits to multiple functions, instead of assigning 100% of these revenue credits to the power production function. As a result, DEP overstated its wholesale cost-based revenue requirements and resulting billings to FERC-jurisdictional customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Auxiliary Fuel Costs in Nuclear Power Generation", "summary": "DEP misstated Account 518, Nuclear Fuel Expense, due to an incorrect application of its inventory accounting procedures for auxiliary fuel. Various other misclassifications and clerical errors caused DEP to incorrectly account for additional auxiliary fuel expense in other nuclear operations and maintenance (O&M) accounts. These errors improperly increased DEP’s wholesale cost-based revenue requirements and resulting billings to FERC- jurisdictional customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Inventory, materials & fleet", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 5, "title": "Allowance for Funds Used During Construction", "summary": "DEP improperly accrued Allowance for Funds Used During Construction (AFUDC) on ineligible projects that were completed or ready to be placed into service. As a result, DEP over-accrued AFUDC and overstated plant in service during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 6, "title": "Accounting for Distribution and Meter-Related Costs", "summary": "DEP recorded affiliate charges for distribution and customer-related IT systems in Administrative and General (A&G) expense accounts. This accounting was not consistent with the functional character of these charges, which should have instead been recorded in the relevant distribution and customer-related functional O&M expense accounts. As a result, inputs to FERC- jurisdictional formula rates and resulting wholesale customer billings were overstated.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 7, "title": "Accounting for Political Activities", "summary": "DEP improperly charged labor costs of a registered lobbyist engaged in political activities to Account 920, Administrative and General Salaries, rather than to Account 426.4, Expenditures for Certain Civic, Political and Related Activities. By improperly including these amounts in Account 920, DEP overstated FERC-jurisdictional formula rate inputs, revenue requirements, and customer billings.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Accounting for Steam Maintenance Expenses", "summary": "DEP improperly recorded O&M expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting for the O&M expense, DEP included excess costs as inputs to its system average energy formula rate that should have been included as inputs to its production capacity formula rate and shifted billing inputs from capacity to energy charges among DEP’s wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 9, "title": "Accounting for A&G Overheads and Accruals", "summary": "DEP did not use Account 922, Administrative Expenses Transferred – Credit, to record administrative expenses from Account 920 and Account 921 that were transferred to construction projects or to nonutility accounts. DEP also did not properly disaggregate its year-end salary accruals by utility function. As a result of DEP’s improper accounting, the transparency of its capitalization activities and labor cost reporting were reduced.", "is_other_matter": false, "recommendations": [], "themes": [ "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 10, "title": "FERC Form No. 580 Reporting", "summary": "DEP did not properly follow FERC Form No. 580 instructions and did not report all required information in its FERC Form No. 580 filings. These actions affected the transparency, accuracy, and usefulness of certain sections of the FERC Form No. 580.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 11, "title": "FERC Form Nos. 1 and 3-Q Reporting", "summary": "DEP did not properly follow the FERC Form Nos. 1 and 3-Q instructions and, therefore, did not report all required information in its FERC Form Nos. 1 and 3-Q filings. These actions affected the transparency, accuracy, and usefulness of certain information in the reports. D.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Capitalization vs. expense", "Form reporting (Form No. 1/2/6, Page 700)", "Fuel & purchased-power cost recovery", "Inventory, materials & fleet", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "TN", "source": "Tennessee Public Utility Commission", "doc_type": "weather normalization adjustment audit", "id": "2025-07-18_atmos-energy_tn-25-00044-wna-audit", "company": "Atmos Energy Corporation", "company_raw": "Atmos Energy Corporation", "docket": "25-00044", "docket_full": null, "issued_date": "2025-07-18", "source_page_url": "https://www.tn.gov/tpuc.html", "pdf_download_url": "https://tpucdockets.tn.gov/archive/filings/2025/2500044a.pdf", "captured_at": "2026-06-07", "source_note": "Notice of Filing by the Utilities Division of the Tennessee Public Utility Commission of the Weather Normalization Adjustment (WNA) Audit re Atmos Energy Corporation, Docket No. 25-00044, July 18, 2025 — the Division's audit of Atmos's WNA gas-cost mechanism (20 pp). Listed for reference (metadata-only). Source: TPUC dockets archive (tpucdockets.tn.gov/archive/filings/2025/2500044a.pdf).", "archived_via": null, "page_count": 20, "scanned_pages": [ 12, 13, 14, 15, 19 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "ND", "source": "North Dakota Public Service Commission", "doc_type": "rider update application", "id": "2025-07-15_montana-dakota-utilities_nd-pu-25-225-tca", "company": "Montana-Dakota Utilities Co.", "company_raw": "Montana-Dakota Utilities Co.", "docket": "PU-25-225", "docket_full": null, "issued_date": "2025-07-15", "source_page_url": "https://www.psc.nd.gov/public/cases/", "pdf_download_url": "https://www.psc.nd.gov/webdocs/case/25-0225/001-010.pdf", "captured_at": "2026-06-07", "source_note": "Montana-Dakota Utilities Co. application (July 15, 2025) before the North Dakota Public Service Commission to update the Transmission Cost Adjustment (TCA) Rate 59 tariff, Case No. PU-25-225 (55 pp). Listed for reference (metadata-only). Source: ND PSC public case records, document 001-010 (psc.nd.gov/webdocs/case/25-0225/001-010.pdf).", "archived_via": null, "page_count": 55, "scanned_pages": [ 14, 17, 19 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 3, "findings": [ { "index": 1, "title": "Approval: $3,614,892\n", "summary": "00,597) Revenue Requirement - 2026 $741,412 $740,196 $739,032 $737,918 $736,857 $735,849 $4,431,264 Approved Projects - July - December 2025 Revenue Requirement: $3,614,892 Proposed Projects - 2025 Revenue Requirement: $583,875 Total Projected Revenue Requirement: $8,630,031 Projected Revenue Requir", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $3,614,892\n", "summary": "tal Projected Revenue Requirement: $8,630,031 Projected Revenue Requirement from Approved Projects: Approved Projects - July - December 2025 Revenue Requirement: $3,614,892 Approved Projects - January - June 2026 Revenue Requirement: 3,566,978 $7,181,870 Projected Revenue Requirement from Proposed P", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $3.13 ", "summary": "d by the Commission, the new rates will not be effective until Commission action has been taken. If approved, a residential customer using 800 kWh will see an increase of $3.13 per month or an increase of $37.56 annually. The TCA is shown as a separate line item on your bill. Residential & Small Gen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2025-07-10_pike-county-light-power-leatherstocking-gas_pa-mo-audit", "company": "Pike County Light & Power Company / Leatherstocking Gas Company LLC", "company_raw": "Pike County Light & Power Company / Leatherstocking Gas Company LLC", "docket": "D-2024-3050338", "docket_full": null, "issued_date": "2025-07-10", "source_page_url": "https://www.puc.pa.gov/press-release/2025/puc-issues-management-and-operations-audit-for-pike-county-light-power-and-leatherstocking-gas-company-07102025", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1886204.pdf", "captured_at": "2026-06-18", "source_note": "Management & Operations Audit of Pike County Light & Power Company and Leatherstocking Gas Company LLC, PA PUC Bureau of Audits; PUC publication 2025-07-10, Docket No. D-2024-3050338. PDF: puc.pa.gov/pcdocs/1886204.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 62, "scanned_pages": [ 1, 62 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 10, "findings": [ { "index": 1, "title": "Executive Management, Organizational Structure, and Safety", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Expand the succession planning process to include short-term contingency plans for the PCLP General Manager, and all key employees.", "source_page": 15 }, { "number": 2, "text": "Formally document procedures for all human resources filing and reporting activities to ensure compliance.", "source_page": 16 }, { "number": 3, "text": "Implement a system to govern oversight of the review, update and documentation of all policies, and create a policy for centralized management of the system.", "source_page": 17 }, { "number": 4, "text": "Expand staffing at PCLP to ensure optimal electric operations.", "source_page": 18 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 2, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Establish an overarching internal control policy.", "source_page": 22 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 3, "title": "Cost Allocations and Affiliated Interests", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 6, "text": "File an updated AIA which accurately reflects the intercompany transactions occurring between PCLP, LGC, and their affiliates.", "source_page": 25 }, { "number": 7, "text": "Conduct routine periodic testing of intercompany transactions to ensure shared costs are distributed in accordance with approved methodologies.", "source_page": 26 }, { "number": 8, "text": "Compare total actual costs for internally performed shared services and the cost of outside services to ensure cost effectiveness for all entities regularly.", "source_page": 27 }, { "number": 9, "text": "Establish internal controls over intercompany transactions and cost allocations processes and comply with all aspects of the approved AIA.", "source_page": 27 } ], "themes": [ "Affiliate / intercompany transactions", "Internal audit & internal controls" ], "cost_to_customers": true }, { "index": 4, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Establish a process to routinely review and update financial management policies and procedures and ensure version control is in place.", "source_page": 31 }, { "number": 11, "text": "Document an internal dividend policy that provides advance notice and written explanation to the Commission for each dividend payment PCLP and LGC make in excess of 85% of net income.", "source_page": 31 } ], "themes": [ "Dividend policy & capital management" ], "cost_to_customers": false }, { "index": 5, "title": "Financial Management (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Document cash management procedures and establish guidelines for assessment of cash positions.", "source_page": 32 }, { "number": 13, "text": "Develop and document guidelines and policies for budget creation and management including the regular reporting of significant budget variance explanations.", "source_page": 33 } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Develop and maintain a comprehensive damage prevention manual that details appropriate excavating procedures for PCLP’s electric utility infrastructure and assets.", "source_page": 36 }, { "number": 15, "text": "Update PCLP’s storm response plan after a storm-related event or at least annually.", "source_page": 37 } ], "themes": [ "Gas safety & pipeline integrity" ], "cost_to_customers": false }, { "index": 7, "title": "Gas Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Establish and maintain a collection system for excavation damages and increase public awareness efforts for all involved parties about their responsibilities under PA One Call.", "source_page": 44 }, { "number": 17, "text": "Review the UFG calculation, including the adjustment factor, and document all steps to ensure accuracy of reporting.", "source_page": 45 } ], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Correct minor physical security deficiencies at PCLP and LGC and perform periodic physical security reviews of all facilities.", "source_page": 48 }, { "number": 19, "text": "Develop comprehensive business continuity plans for PCLP and LGC and review, test, and update them annually.", "source_page": 49 }, { "number": 20, "text": "Develop and maintain physical security plans for PCLP and LGC and review, update, and test annually.", "source_page": 49 }, { "number": 21, "text": "Annually review, test, and update emergency response plans for PCLP and LGC, and update PCLP’s emergency response plan to detail company response to non-storm related emergencies.", "source_page": 50 } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "index": 9, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Formally document customer service policies and procedures to govern customer service practices.", "source_page": 55 } ], "themes": [ "Customer service & billing" ], "cost_to_customers": false }, { "index": 10, "title": "Customer Service (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Revise the tariff and other customer-facing documentation to accurately reflect PCLP’s and LGC’s budget billing processes.", "source_page": 56 }, { "number": 24, "text": "Explore eliminating manual meter reading at LGC to streamline operations, reduce errors, and efficiently use staff.", "source_page": 57 }, { "number": 25, "text": "Improve the customer experience by expanding payment options and eliminating the manual process for budget billing.", "source_page": 57 } ], "themes": [ "Tariff administration & oversight", "Customer service & billing" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Customer service & billing", "Cybersecurity & physical security", "Dividend policy & capital management", "Emergency preparedness & business continuity", "Gas safety & pipeline integrity", "Internal audit & internal controls", "Tariff administration & oversight", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "rate case testimony", "id": "2025-07-08_ameren-illinois_icc-25-0382-staff-testimony", "company": "Ameren Illinois Company", "company_raw": "Ameren Illinois Company", "docket": "25-0382", "docket_full": null, "issued_date": "2025-07-08", "source_page_url": "https://www.icc.illinois.gov/docket/P2025-0382/documents/367736", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2025-0382/documents/367736/files/644187.pdf", "captured_at": "2026-06-07", "source_note": "Direct Testimony (Staff Exhibit 1.0) of Kevin Siebert (Economic & Financial Analysis Section) on behalf of the Staff of the Illinois Commerce Commission in Ameren Illinois Company's electric rate reconciliation case, ICC Docket 25-0382, filed July 8, 2025. Listed for reference (metadata-only). Source: ICC e-Docket, document 367736 / file 644187 (landing: www.icc.illinois.gov/docket/P2025-0382/documents/367736).", "archived_via": null, "page_count": 33, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "AR", "source": "Arkansas Public Service Commission", "doc_type": "application", "id": "2025-07-07_entergy-arkansas_ar-16-036-fr-frp-application", "company": "Entergy Arkansas, LLC", "company_raw": "Entergy Arkansas, LLC", "docket": "16-036-FR", "docket_full": null, "issued_date": "2025-07-07", "source_page_url": "https://apps.apsc.arkansas.gov/olsv2/Docket_Search_Documents.asp?Docket=16-036-FR&DocNumVal=1090", "pdf_download_url": "https://apps.apsc.arkansas.gov/pdf/16/16-036-FR_1090_1.pdf", "captured_at": "2026-06-02", "source_note": "Entergy Arkansas, LLC's 2025 Rider FRP filing — Application for Approval of a Rate Adjustment and the 2025 Evaluation Report pursuant to Rate Schedule No. 44, Formula Rate Plan Rider (Rider FRP), filed July 7, 2025 with the Arkansas Public Service Commission in Docket No. 16-036-FR (proposing a $92.3 million rate adjustment; 48 pp). Listed for reference (metadata-only). Source: APSC Online Services, document 16-036-FR_1090 (apps.apsc.arkansas.gov/pdf/16/16-036-FR_1090_1.pdf).", "archived_via": null, "page_count": 48, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "MS", "source": "Mississippi Public Utilities Staff", "doc_type": "utilities staff annual report", "id": "2025-06-30_mississippi-public-utilities-staff_ms-annual-report", "company": "Mississippi Public Utilities Staff", "company_raw": "Mississippi Public Utilities Staff", "docket": null, "docket_full": null, "issued_date": "2025-06-30", "source_page_url": "https://www.psc.ms.gov/", "pdf_download_url": "https://www.psc.ms.gov/sites/default/files/Documents/MPUS-2025-Annual-Report.pdf", "captured_at": "2026-06-02", "source_note": "Mississippi Public Utilities Staff (MPUS) Annual Report for the year ending June 30, 2025, 27 pp. Documents the Staff's ongoing audits of the major investor-owned utilities' fuel-adjustment clauses (Entergy Mississippi ECR, Mississippi Power FCR) and its rate/prudence review activity before the Mississippi Public Service Commission. Listed for reference (metadata-only). Source: Mississippi Public Service Commission (psc.ms.gov/sites/default/files/Documents/MPUS-2025-Annual-Report.pdf).", "archived_via": null, "page_count": 27, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NY", "source": "New York State Department of Public Service", "doc_type": "comprehensive management & operations audit implementation plans (utility response to audit recommendations)", "id": "2025-06-18_nyseg-rge_ny-23-m-0103-implementation-plans", "company": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "company_raw": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "docket": "23-M-0103", "docket_full": null, "issued_date": "2025-06-18", "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=23-M-0103", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B40F38397-0000-C120-9A8C-C2B1D73E3053%7D", "captured_at": "2026-06-22", "source_note": "NYSEG and RG&E Implementation Plans (June 18, 2025), Case 23-M-0103 (716 pp) — the utilities' filed plans describing the corrective actions they will take in response to the 128 recommendations in NorthStar's comprehensive management and operations audit (PSL §66(19)). Page 1 verified: 'Case 23-M-0103: In the Matter of a Comprehensive Management Audit of New York State Electric & Gas, and Rochester Gas and Electric Implementation Plans June 18, 2025 New York State Electric & Gas Corporation Rochester Gas and Electric Corporation'. Harvested from the NY DPS DMM. Listed for reference (metadata-only). Source: NY DPS DMM (documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={40F38397-0000-C120-9A8C-C2B1D73E3053}).", "archived_via": null, "page_count": 716, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NJ", "source": "New Jersey Board of Public Utilities", "doc_type": "rate mitigation order", "id": "2025-06-18_atlantic-city-electric_nj-rate-mitigation", "company": "Atlantic City Electric Company", "company_raw": "Atlantic City Electric Company", "docket": null, "docket_full": null, "issued_date": "2025-06-18", "source_page_url": "https://publicaccess.bpu.state.nj.us/", "pdf_download_url": "https://www.nj.gov/bpu/pdf/boardorders/2025/20250618/2E%20ORDER%20ACE%20Rate%20Mitigation%20Filing.pdf", "captured_at": "2026-06-07", "source_note": "Order on Rate Mitigation Filing of Atlantic City Electric Company (ACE / Exelon), issued at the June 18, 2025 agenda meeting. Rate mitigation filing in response to elevated wholesale electricity costs from PJM markets following July 2024 auctions. Listed for reference (metadata-only). PDF on the BPU board-orders host www.nj.gov/bpu/pdf/boardorders/2025/20250618/; docket system: publicaccess.bpu.state.nj.us.", "archived_via": null, "page_count": 19, "scanned_pages": [ 5, 9, 17 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-06-16_portland-general-electric-company_pa23-10", "company": "Portland General Electric Company", "company_raw": "Portland General Electric Company (PA23-10)", "docket": "PA23-10", "docket_full": "PA23-10-000", "issued_date": "2025-06-16", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250616-3008&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250616-3008", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 52, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2021 to October 31, 2024", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 11, "findings": [ { "index": 1, "title": "Public Access to Monthly and Yearly Capability Information", "summary": "PGE’s postings for monthly and yearly capability in the OASIS available transfer capability (ATC)/total transfer capability (TTC) Monitor were not made publicly available.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Review system settings for all OASIS posting functions that require user access and develop policies and procedures to ensure that settings are set to provide proper access for OASIS users. Provide a report to audit staff that summarizes the results of this review.", "source_page": null }, { "number": 2, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 1, and repeat such trainings as needed.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 2, "title": "Narrative Explanations for ATC Unavailability", "summary": "PGE did not post narrative explanations of the reasons for the unavailability of ATC when the monthly and yearly capability remained unchanged at a value of zero for a period of six months or longer for several transmission paths.", "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Revise policies and procedures to ensure that PGE posts a narrative explanation of the reasons for the unavailability of ATC when monthly and yearly ATC will remain unchanged at a value of zero for a period of six months or longer for a given path.", "source_page": null }, { "number": 4, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 3, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Deviation Information for Generator Interconnection Studies", "summary": "PGE did not post generator interconnection study timeline deviations on OASIS during the audit period. Also, PGE did not post generator interconnection project in-service date deviations during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Reestablish a policy and procedure to post generator interconnection study timeline deviations on OASIS.", "source_page": null }, { "number": 6, "text": "Establish a policy and procedure to post generator interconnection in-service date deviations on OASIS.", "source_page": null }, { "number": 7, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendations 5 and 6, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Interconnection Request List Study Availability", "summary": "PGE did not identify the availability of restudies related to two interconnection requests on its OASIS list of interconnection requests.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise policies and procedures to ensure that the active and inactive generator interconnection request lists indicate the availability of any studies relating to a project, including restudies.", "source_page": null }, { "number": 9, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 8, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Preservation of Records", "summary": "PGE did not preserve certain emails that were classified as records to be retained for four years pursuant to the Commission’s preservation of records regulations.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Revise document retention policies and procedures to ensure that PGE properly identifies, indexes, and retains emails that are records in accordance with the Commission’s preservation of records regulations.", "source_page": null }, { "number": 11, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 10, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Quarterly Generator Interconnection Service Metrics", "summary": "PGE did not post accurate metrics for interconnection feasibility studies processing time in its quarterly generator interconnection service metrics reports.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Develop a process to perform periodic reviews of PGE’s OASIS interconnection study metrics postings to verify that PGE is posting complete and accurate information.", "source_page": null }, { "number": 13, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 12, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Quarterly Transmission Service Metrics Reports and Study Costs", "summary": "PGE did not timely post quarterly transmission service metrics on OASIS within 15 calendar days of the end of the calendar quarter and did not post accurate system impact study costs.", "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Revise policies and procedures to ensure that quarterly transmission service metrics reports are timely uploaded to OASIS.", "source_page": null }, { "number": 15, "text": "Implement a quality control process to ensure all posted information in quarterly transmission service metrics reports is accurate and complete.", "source_page": null }, { "number": 16, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendations 14 and 15, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Listing of Transmission Service Request Completed Studies", "summary": "PGE did not update its list of completed transmission service request studies posted on OASIS during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Revise policies and procedures to ensure that PGE accurately posts transmission service request study information on OASIS and accurately and timely reports this information in its quarterly transmission service request metrics reports.", "source_page": null }, { "number": 18, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 17, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Posting of Short Circuit Information", "summary": "PGE did not post short circuit information on either its OASIS site or a password-protected website during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Revise policies and procedures to ensure that all base case data, including short circuit information, is posted on the OASIS or a password-protected website.", "source_page": null }, { "number": 20, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 19, and repeat such trainings as needed.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 10, "title": "Transmission Planning Study Cycle Meetings", "summary": "PGE did not host a public meeting to review its draft Near Term Local Transmission Plan in Quarter 3 of its eight- quarter (i.e., two-year) planning cycle and did not host a public meeting to review its draft Longer Term Local Transmission Plan in Quarter 7 of its two-year planning cycle.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Develop and implement policies, procedures, and review processes to ensure that PGE adheres to Attachment K, Section 3.2, Sequence of Events, and fulfills its responsibilities for each planning quarter, from Quarter 1 (Section 3.2.1) to Quarter 8 (Section 3.2.8).", "source_page": null }, { "number": 22, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 21, and repeat such trainings as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Posting of Transmission Planning Content", "summary": "PGE did not post certain transmission planning content on its OASIS website during the audit period. D.", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Perform a comprehensive review of PGE’s Transmission Planning Business Practice Manual, transmission planning notices, agendas, and meeting minutes posted on OASIS to correct incorrect or broken links, remove outdated materials, or add any missing information.", "source_page": null }, { "number": 24, "text": "Revise policies and procedures to ensure compliance with the posting requirements, timelines, and relevant specifications set forth in Attachment K, Section 5.2.", "source_page": null }, { "number": 25, "text": "Provide training to relevant staff on policies and procedures implemented in response to Recommendation 24, and repeat such trainings as needed.", "source_page": null }, { "number": 26, "text": "Perform periodic reviews of PGE’s OASIS postings to verify that PGE is posting all required Attachment K information timely and accurately. E.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Informational postings" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "CA", "source": "California Public Utilities Commission", "doc_type": "ERRA compliance & reasonableness review decision", "id": "2025-06-12_pacific-gas-and-electric_ca-a24-02-012-d25-06-007-erra", "company": "Pacific Gas and Electric Company", "company_raw": "Pacific Gas and Electric Company", "docket": "A.24-02-012", "docket_full": null, "issued_date": "2025-06-12", "source_page_url": "https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M569/K665/569665704.PDF", "pdf_download_url": "https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M569/K665/569665704.PDF", "captured_at": "2026-06-10", "source_note": "CPUC Decision 25-06-007 (decided June 12, 2025; date of issuance June 16, 2025), Application 24-02-012 — Decision Approving Pacific Gas and Electric Company's 2023 Energy Resource Recovery Account (ERRA) Entries and Related Matters: the annual ERRA compliance/reasonableness (prudence) review of PG&E's utility-owned generation operations, ERRA entries, contract administration, economic dispatch and fuel procurement for record year January 1 – December 31, 2023 (35 pp, born-digital PDF). Unlike the older CA ERRA decisions (HTML-only, fetch=false), this decision is a fetchable PDF on docs.cpuc.ca.gov/PublishedDocs. Page-1 verified 2026-06-10.", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "ID", "source": "Idaho Public Utilities Commission", "doc_type": "power cost adjustment order", "id": "2025-05-30_idaho-power_id-ipc-e-25-20-order-36618-pca", "company": "Idaho Power Company", "company_raw": "Idaho Power Company", "docket": "IPC-E-25-20", "docket_full": null, "issued_date": "2025-05-30", "source_page_url": "https://puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2520", "pdf_download_url": "https://puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2520/OrdNotc/20250530Final_Order_No_36618.pdf", "captured_at": "2026-06-07", "source_note": "Idaho PUC Order No. 36618 (Final Order, service date May 30, 2025), Case No. IPC-E-25-20, on Idaho Power Company's annual Power Cost Adjustment (PCA) for June 1, 2025 through May 31, 2026 (5 pp). The PCA is Idaho's fuel/purchased-power true-up — a reasonableness review of power-supply costs passed to customers. Listed for reference (metadata-only). Source: Idaho PUC fileroom (puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2520/OrdNotc/20250530Final_Order_No_36618.pdf).", "archived_via": null, "page_count": 5, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NY", "source": "New York State Public Service Commission", "doc_type": "comprehensive management & operations audit (PSC order releasing audit report, PSL §66(19))", "id": "2025-05-15_nyseg-rge_ny-23-m-0103-order-releasing-audit-report", "company": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "company_raw": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "docket": "23-M-0103", "docket_full": null, "issued_date": "2025-05-15", "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=23-M-0103", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B4090E996-0000-C72B-B490-5B99106260D1%7D", "captured_at": "2026-06-22", "source_note": "NY PSC Order Releasing Audit Report, Case 23-M-0103 (24 pp) — releases NorthStar Consulting Group's Comprehensive Management and Operations Audit of NYSEG and RG&E (PSL §66(19)) and directs the companies to file an implementation plan. Issued at the Commission session held May 15, 2025. Page 1 verified: 'STATE OF NEW YORK PUBLIC SERVICE COMMISSION At a session of the Public Service Commission held in the City of Albany on May 15, 2025 ... CASE 23-M-0103'. Harvested from the NY DPS DMM. Listed for reference (metadata-only). Source: NY DPS DMM (documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={4090E996-0000-C72B-B490-5B99106260D1}).", "archived_via": null, "page_count": 24, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "VA", "source": "Virginia State Corporation Commission", "doc_type": "fuel factor order (fuel-cost recovery review)", "id": "2025-05-12_dominion-energy-virginia_va-pur-2025-00059-fuel-factor", "company": "Virginia Electric and Power Company (Dominion Energy Virginia)", "company_raw": "Virginia Electric and Power Company (Dominion Energy Virginia)", "docket": "PUR-2025-00059", "docket_full": null, "issued_date": "2025-05-12", "source_page_url": "https://www.scc.virginia.gov/docketsearch", "pdf_download_url": "https://www.scc.virginia.gov/docketsearch/DOCS/85$601!.PDF", "captured_at": "2026-06-08", "source_note": "Virginia SCC Order establishing the 2025-2026 fuel factor for Dominion Energy Virginia, Case No. PUR-2025-00059, issued 2025-05-12 (§56-249.6 fuel-cost recovery/prudence). PDF: scc.virginia.gov/docketsearch/DOCS/85$601!.PDF.", "archived_via": null, "page_count": 15, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "MD", "source": "Maryland Public Service Commission", "doc_type": "order initiating gas-system safety-inspection investigation (documents PSC Engineering Division audit findings)", "id": "2025-05-08_baltimore-gas-electric_md-9791-gas-safety-investigation", "company": "Baltimore Gas and Electric Company (BGE)", "company_raw": "Baltimore Gas and Electric Company (BGE)", "docket": "Case No. 9791 (Order No. 91643)", "docket_full": null, "issued_date": "2025-05-08", "source_page_url": "https://psc.maryland.gov/order-initiating-bge-gas-system-case-no-9791/", "pdf_download_url": "https://psc.maryland.gov/wp-content/uploads/Order-No.-91643-Initiating-a-Proceeding-_BGEGasSystemSafety-Insp.-9791.pdf", "captured_at": "2026-06-08", "source_note": "MD PSC Order No. 91643, Case No. 9791 (issued May 8, 2025) — initiates an investigation into BGE gas-system inspection issues, documenting the PSC Engineering Division (PSCED) Investigation Report findings/recommendations (falsified-records pattern, QA/compliance-oversight gaps). 9 pp. Page 1 verified.", "archived_via": null, "page_count": 9, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "GA", "source": "Georgia Public Service Commission", "doc_type": "direct testimony", "id": "2025-05-05_georgia-power-company_ga-56002-pias-smith-kannan", "company": "Georgia Power Company", "company_raw": "Georgia Power Company", "docket": "56002", "docket_full": null, "issued_date": "2025-05-05", "source_page_url": "https://psc.ga.gov/search/facts-document/?documentId=222516", "pdf_download_url": "https://services.psc.ga.gov/api/v1/External/Public/Get/Document/DownloadFile/222516/103632", "captured_at": "2026-06-02", "source_note": "Direct Testimony and Exhibits of Douglas A. Smith and Sasikumar Kannan (Daymark Energy Advisors, Inc.) on behalf of the Georgia Public Service Commission Public Interest Advocacy Staff (PIAS) in Georgia Power Company's 2025 Integrated Resource Plan (Docket No. 56002) and 2025 Application for the Certification, Decertification, and Amended Demand-Side Management Plan (Docket No. 56003), Public Disclosure, filed May 5, 2025 (26 pp). Listed for reference (metadata-only). Source: Georgia PSC FACTS document system, document 222516 (services.psc.ga.gov DownloadFile/222516/103632; landing: psc.ga.gov/search/facts-document/?documentId=222516).", "archived_via": null, "page_count": 26, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "GA", "source": "Georgia Public Service Commission", "doc_type": "direct testimony", "id": "2025-05-05_georgia-power-company_ga-56002-pias-smith-forsythe", "company": "Georgia Power Company", "company_raw": "Georgia Power Company", "docket": "56002", "docket_full": null, "issued_date": "2025-05-05", "source_page_url": "https://psc.ga.gov/search/facts-document/?documentId=222513", "pdf_download_url": "https://services.psc.ga.gov/api/v1/External/Public/Get/Document/DownloadFile/222513/103670", "captured_at": "2026-06-02", "source_note": "Direct Testimony and Exhibits of Ralph C. Smith and Jason R. Forsythe on behalf of the Georgia Public Service Commission Public Interest Advocacy Staff (PIAS) in Georgia Power Company's 2025 Integrated Resource Plan (Docket No. 56002) and 2025 Application for the Certification, Decertification, and Amended Demand-Side Management Plan (Docket No. 56003), Public Disclosure Version, filed May 5, 2025 (130 pp). Listed for reference (metadata-only). Source: Georgia PSC FACTS document system, document 222513 (services.psc.ga.gov DownloadFile/222513/103670; landing: psc.ga.gov/search/facts-document/?documentId=222513).", "archived_via": null, "page_count": 130, "scanned_pages": [ 47, 66, 68, 79, 83, 91, 111, 124, 128 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "GA", "source": "Georgia Public Service Commission", "doc_type": "direct testimony", "id": "2025-05-05_georgia-power-company_ga-56002-pias-barber-cooper-spellman", "company": "Georgia Power Company", "company_raw": "Georgia Power Company", "docket": "56002", "docket_full": null, "issued_date": "2025-05-05", "source_page_url": "https://psc.ga.gov/search/facts-document/?documentId=222514", "pdf_download_url": "https://services.psc.ga.gov/api/v1/External/Public/Get/Document/DownloadFile/222514/103628", "captured_at": "2026-06-02", "source_note": "Direct Testimony and Exhibits of Jamie Barber, Nick Cooper, and Richard F. Spellman on behalf of the Georgia Public Service Commission Public Interest Advocacy Staff (PIAS) in Georgia Power Company's 2025 Integrated Resource Plan (Docket No. 56002) and 2025 Application for the Certification, Decertification, and Amended Demand-Side Management Plan (Docket No. 56003), filed May 5, 2025 (59 pp). Listed for reference (metadata-only). Source: Georgia PSC FACTS document system, document 222514 (services.psc.ga.gov DownloadFile/222514/103628; landing: psc.ga.gov/search/facts-document/?documentId=222514).", "archived_via": null, "page_count": 59, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "GA", "source": "Georgia Public Service Commission", "doc_type": "direct testimony", "id": "2025-05-02_georgia-power-company_ga-56002-gcv-roumpani", "company": "Georgia Power Company", "company_raw": "Georgia Power Company", "docket": "56002", "docket_full": null, "issued_date": "2025-05-02", "source_page_url": "https://psc.ga.gov/search/facts-document/?documentId=222501", "pdf_download_url": "https://services.psc.ga.gov/api/v1/External/Public/Get/Document/DownloadFile/222501/103611", "captured_at": "2026-06-02", "source_note": "Direct Testimony of Maria Roumpani, PhD on behalf of Georgia Conservation Voters in Georgia Power Company's 2025 Integrated Resource Plan (Docket No. 56002) and 2025 Application for the Certification, Decertification, and Amended Demand-Side Management Plan (Docket No. 56003), filed May 2, 2025 (68 pp). Listed for reference (metadata-only). Source: Georgia PSC FACTS document system, document 222501 (services.psc.ga.gov DownloadFile/222501/103611; landing: psc.ga.gov/search/facts-document/?documentId=222501).", "archived_via": null, "page_count": 68, "scanned_pages": [ 65 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "UT", "source": "Public Service Commission of Utah", "doc_type": "rate case report and order", "id": "2025-04-25_rocky-mountain-power_ut-24-035-04-rate-case-order", "company": "Rocky Mountain Power (PacifiCorp)", "company_raw": "Rocky Mountain Power (PacifiCorp)", "docket": "24-035-04", "docket_full": null, "issued_date": "2025-04-25", "source_page_url": "https://psc.utah.gov/electric/orders-notices/electric-2025/", "pdf_download_url": "https://pscdocs.utah.gov/electric/24docs/2403504/3395032403504,2303540,and2303544o4-25-2025.pdf", "captured_at": "2026-06-07", "source_note": "Report and Order of the Public Service Commission of Utah (April 25, 2025) on the Application of Rocky Mountain Power (PacifiCorp) for Authority to Increase its Retail Electric Utility Service Rates in Utah, Docket No. 24-035-04 (consolidated 23-035-40, 23-035-44) — a base-rate case (~$382.1M requested increase) (196 pp). Listed for reference (metadata-only). Source: Utah PSC document repository (pscdocs.utah.gov/electric/24docs/2403504/).", "archived_via": null, "page_count": 196, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 25, "findings": [ { "index": 1, "title": "Disallowance: $534,482.", "summary": "aul expenses projected to occur in 2028. The net adjustment increases Utah’s revenue requirement by $534,482. In surrebuttal testimony, DPU recommends the PSC either reject the $5.8 million or limit RMP’s forecast natural gas plant overhaul expense as speculative. Alternatively, DPU calculated an av", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $87.2\nmillion", "summary": "quirement increase with other parties, RMP reduced its proposed increase to $330.2 million. The PSC approves herein an increase to RMP’s annual revenue requirement of $87.2 million. The ordered increase is 26.4 percent of RMP’s final revised amount. The revenue requirement change is effective April ", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $70.4 million", "summary": "recover $82 million in ELI premiums, nearly a 2,800 percent increase from the 2020 GRC. The PSC disallows $70.4 million in costs related to ELI insurance that we find were driven far beyond industry norms for Utah, by PacifiCorp’s management of the wildfires in Septemb", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $2.7 million", "summary": "find some level of ID expense, not related to the extraordinary wildfire claims, is reasonable and approve $2.7 million. Fifth, the PSC’s order also reflects our view that incremental costs incurred by PacifiCorp due to specific state climate action policies or specifi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $156.9 million", "summary": "idence that those investments provide efficient wildfire mitigation measures. RMP requested the PSC approve $156.9 million in capital expenditures and $24.9 million in O&M expenses projected in the Test Year to implement the 2023 Plan. At hearing, RMP testified the typica", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Approval: $41.8 million", "summary": "ly $25 million to ratepayers.71 DPU testified that using RMP’s hypothetical capital structure would allow RMP to earn $41.8 million over what it should earn with its actual forecasted capital structure.72 FEA testified that using RMP’s hypothetical capital structure to set rates w", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Approval: $4,460.80 ", "summary": "FERC- approved transmission rates will go into effect in June 2025. OCS recommends RMP use the FERC-approved transmission rate of $4,460.80 for the first five months to calculate its estimated wheeling revenues for the first five months. Based on this recommendation, OCS adjusts wheeling r", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Approval: $624.1 million", "summary": ". Next, consistent with RMP’s approach, the PSC took the average of $1.104 billion and the 2021 GRC-approved NPC of $624.1 million, resulting in $864.2 million of Test Year Base NPC that we approve in this case. This results in a deferral of $240.1 million in NPC for potential fu", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Approval: $240.1 million", "summary": "2021 GRC-approved NPC of $624.1 million, resulting in $864.2 million of Test Year Base NPC that we approve in this case. This results in a deferral of $240.1 million in NPC for potential future EBA recovery instead of the $285.2 million that RMP proposed. 130 Id. at 4:69-77. 131 Id. at 4:65-66. DOCK", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Approval: $2,495,883 ", "summary": "r state for the purpose of fulfilling RMP’s obligations to California and Oregon under the KHSA. We approve UAE’s recommended adjustment and deny the $2,495,883 in revenue requirement that RMP seeks relating to the Fall Creek Hatchery. ii. Klamath Regulatory Asset and Klamath Transmission RMP’s Appl", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Approval: $0.1\nmillion", "summary": "as just, reasonable, and in the public interest. We decline to adopt DPU’s proposed adjustments and approve RMP’s proposed $0.1 million adjustment for the brief delay associated with the in-service date of Rock Creek I. 4. Other Regulatory Issues i. Renewable Energy Credit Program RMP", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Approval: $15,289,781 ", "summary": "costs through the base rates established in its most recent GRC.282 OCS contends the PSC should disallow recovery of at least $15,289,781 of RMP’s claimed Incremental WBA Costs (“OCS’s WBA Adjustment”).283 More specifically, OCS’s WBA Adjustment is comprised of (1) $5,681,724 relating to", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Approval: $156.9 million", "summary": "’ Recommended Adjustments After accepting an adjustment to its initial request, RMP asks the PSC to approve $156.9 million in capital expenditures and $24.9 million in O&M expenses that it projects incurring in the Test Year to implement its 2023 Plan. DPU and OCS both ad", "is_other_matter": false, "recommendations": [], "themes": [ "Information technology & systems" ], "cost_to_customers": false }, { "index": 14, "title": "Approval: $24.9 million", "summary": "has a much lower capital budget of [$]22 million for calendar year 2025.”301 OCS recommends the PSC approve an O&M budget of $24.9 million, which is the three-year average O&M cost (2023 through 2025) under RMP’s 2023 Plan. OCS explains it recommends “a much higher amount for O&M than th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Approval: $40.5 million", "summary": "302 Id. at 107:7-20. DOCKET NOS. 24-035-04, 23-035-40, and 23-035-44 - 140 - DPU recommends the PSC approve $40.5 million for capital costs and $4.8 million for O&M for the Test Year. DPU emphasizes its recommended “O&M expense still represents over a 35 percent increase", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 16, "title": "Approval: $51,223,778 ", "summary": ". at 21. 306 Id. at 22. 307 Id. DOCKET NOS. 24-035-04, 23-035-40, and 23-035-44 - 141 - ii. The PSC approves $51,223,778 in Capital Additions and $28.4 Million in O&M Test Year Fire Mitigation Costs. As discussed supra at 129, RMP is not entitled to any assurances of cos", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Approval: $28.4 million", "summary": "s’ testimony regarding the efficacy and value of O&M devoted to fire mitigation, the PSC adopts and approves RMP’s original requested O&M expenditures of $28.4 million for the Test Year. These adjustments reduce RMP’s total requested revenue requirement in the amount of $6,164,165. 316 The PSC adopt", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 18, "title": "Approval: $6,557,841 ", "summary": "rive at this amount, the PSC referred to the amount of liability insurance premiums expense the PSC approved in the 2020 GRC, $6,557,841 (on a system basis). See 2020 GRC, Direct Test. of S. McDougal at Ex. __(SRM-3). The PSC multiplied the sum approved for ELI Premiums in the 2020 GRC", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Approval: $87,232,937\nmillion", "summary": "e approve and adopt base NPC to be included in the Test Year in the amount of $864.2 million. 3. We approve a revenue requirement increase of $87,232,937 million, allocated to the various customer classes consistent with the Adjusted Phase II Settlement and reflected in Exhibits A and B to this orde", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 20, "title": "Settlement: Agreement", "summary": "eduling Order”), establishing an adjudication schedule and hearing dates for Phase III. 3. Phase II Settlement and Hearing on Settlement Agreement On January 13, 2025, RMP’s counsel notified the PSC, via e-mail, that “[t]he parties have reached a unanimous settlement on all Phase II issues” that", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: terms", "summary": "day. The PSC, therefore, canceled the Phase II hearing dates and noticed a hearing to consider the settlement’s terms for January 17, 2025.18 On January 14, 2025, RMP filed a Phase II Settlement Stipulation (“Phase II Settlement”), which represents the agreement “res", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: agreement", "summary": "for January 17, 2025.18 On January 14, 2025, RMP filed a Phase II Settlement Stipulation (“Phase II Settlement”), which represents the agreement “resolves all issues in Phase II of [the GRC].”19 Ten parties are signatories to the Phase II Settlement, and RMP represents that Walmart, though it", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 23, "title": "Settlement: agreement", "summary": "rt, though it did not sign, authorized RMP to represent to the PSC that Walmart does not oppose the settlement agreement.20 On January 17, 2025, the PSC conducted a hearing to consider approval of the Phase II Settlement at which counsel for the following parties appear", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 24, "title": "Settlement: Agreement", "summary": "at RMP constructed the Fall Creek Hatchery to fulfill an obligation under the Klamath Hydroelectric Settlement Agreement133 (“KHSA”). Very broadly, the KHSA is an agreement, first executed in 2010 and subsequently amended, wherein RMP agreed to remove certain hydroelect", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 25, "title": "Settlement: Agreement", "summary": "ENT SPREAD, AND RATE DESIGN – DISCUSSION, FINDINGS, AND CONCLUSIONS A. The PSC Adjusts the Phase II Settlement Agreement to Increase the Low- Income Lifeline Credit to $18.00 per Month RMP administers a Low-Income Lifeline Program, consistent with Utah Code § 54-7-13.6,", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true } ], "structured": false, "themes": [ "Cost of service & rates", "Information technology & systems" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "NY", "source": "New York State Department of Public Service", "doc_type": "rate case joint proposal", "id": "2025-04-25_niagara-mohawk-national-grid_ny-24-e-0322-joint-proposal", "company": "Niagara Mohawk Power Corporation d/b/a National Grid", "company_raw": "Niagara Mohawk Power Corporation d/b/a National Grid", "docket": "24-E-0322", "docket_full": null, "issued_date": "2025-04-25", "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=24-E-0322", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B90E66D96-0000-CA12-A897-0A5E5C2B9F2B%7D", "captured_at": "2026-06-07", "source_note": "Joint Proposal (filed April 25, 2025) among Niagara Mohawk Power Corporation d/b/a National Grid, NY Department of Public Service Staff, and multiple parties, in the National Grid electric and gas rate cases, Cases 24-E-0322 (electric) and 24-G-0323 (gas) — the negotiated three-year rate-plan settlement the Public Service Commission adopted by order issued/effective August 14, 2025 (149 pp). Harvested from the NY DPS Document & Matter Management (DMM) system via ViewDoc. Listed for reference (metadata-only). Source: NY DPS DMM (documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={90E66D96-0000-CA12-A897-0A5E5C2B9F2B}).", "archived_via": null, "page_count": 149, "scanned_pages": [ 137, 142, 145, 148 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 6, "findings": [ { "index": 1, "title": "Approval: $78 million", "summary": ", in aggregate, in the Company’s service territory for a given storm event. The Major Storm revenue allowance reflected in rates will be $78 million. The treatment of Major Storm costs is more fully described in Appendix 13 and Appendix 5, Schedule 16. 40 Case 24-E-0322 Case 24-G-0323 Joint Propos", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 2, "title": "Approval: $85.7 million", "summary": "Lining Storm deferral will dissolve and there will be no minor storm deferral. The minor storm rate allowance will remain at $85.7 million for Rate Year Two and $87.6 million for Rate Year Three with no deferral for any expenditures for the remainder of the rate plan. 6.5. Pre-Staging St", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 3, "title": "Approval: $61.775 million", "summary": "r component is reflected through the revenue allocation and rate design process. The EAP Total Rate Allowances are $61.775 million in Rate Year One, $87.575 million 24 The cash shortfall is equal to the difference between the negative expense levels reflected in the revenue requi", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Approval: $1 million", "summary": "cy economic assistance or other incremental economic development programs. The Economic Development Grant Program for gas will be funded by amortizing up to $1 million of the existing economic development programs gas deferral balance in each Rate Year. An example of the reconciliation is provided i", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $17.404 million", "summary": "ric and Gas) Each Rate Year, the Company will fully reconcile actual SIR expense to the annual rate allowance of $17.404 million for electric and $3.071 million for gas in Rate Year One and $17.357 65 Case 24-E-0322 Case 24-G-0323 Joint Proposal million for electric and $3.063", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Approval: $25,000 ", "summary": "n a grant program; and increases to maximum grant funding provided that the increase in the maximum grant amount does not exceed $25,000 and increase the maximum grant amount by more than 25 percent. Commission approval will continue to be required for other program adjustments, includi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Cost of service & rates", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-04-10_midcontinent-independent-system-operator-inc_pa21-2", "company": "Midcontinent Independent System Operator, Inc.", "company_raw": "Midcontinent Independent System Operator, Inc. (PA21-2)", "docket": "PA21-2", "docket_full": "PA21-2-000", "issued_date": "2025-04-10", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250410-3014&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250410-3014", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 54, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 through April 19, 2024", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "714" ], "finding_count": 3, "findings": [ { "index": 1, "title": "Preservation of Records", "summary": "MISO did not comply with the Commission’s preservation of records requirements.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Enhance record identification, archiving, indexing, and retrieval policies and procedures to properly retain and maintain records across a broad range of media and formats, including documents, laptops, and mobile devices.", "source_page": null }, { "number": 2, "text": "Develop and implement training on enhanced record identification, archiving, indexing, and retrieval policies and procedures, and repeat such training as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Posting of Generator Interconnection Study Times", "summary": "MISO did not timely post the aggregate number of hours spent studying generator interconnection projects during Quarter 3, 2022 and Quarter 4, 2022, as required by the MISO Tariff after MISO’s performance of interconnection studies exceeded the established delay threshold for more than 25% of one or more study types for two consecutive quarters beginning in Quarter 1, 2020.", "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Develop and implement a process to perform periodic reviews of MISO’s website and OASIS postings to verify that MISO is posting all required information, including posting the required interconnection study information within 30 calendar days of the end of the calendar quarter.", "source_page": null }, { "number": 4, "text": "Develop and implement quality controls to ensure all posted interconnection study information is accurate and complete. 2 Winter Storm Uri was a severe winter and ice storm that had widespread impacts across the United States, Northern Mexico, and parts of Canada from February 13 to 17, 2021.", "source_page": null }, { "number": 5, "text": "Train employees on the review process and quality controls developed under Recommendations 3 and 4, and repeat such training as needed.", "source_page": null } ], "themes": [ "Tariff administration & oversight", "Informational postings" ], "cost_to_customers": false }, { "index": 3, "title": "Posting of Transmission Service Metrics", "summary": "MISO did not post quarterly transmission service metrics on its Open Access Same-Time Information System (OASIS) website within 15 calendar days of the end of the calendar quarter for multiple quarters during the audit period. D.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Develop and implement a process to perform periodic reviews of MISO’s OASIS postings to verify that MISO is posting all required information, including posting the required transmission service metrics within 15 days of the end of each calendar quarter.", "source_page": null }, { "number": 7, "text": "Develop and implement quality controls to ensure all posted transmission service metric information is accurate and complete.", "source_page": null }, { "number": 8, "text": "Train employees on the review process and quality controls developed under Recommendations 6 and 7, and repeat such training as needed. Other Matters DAA recommends that MISO consider:", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 4, "title": "Operations Related to Economic Derates", "summary": "MISO approved fuel mix derates for generation resources that a market participant categorized as planned and forced in MISO’s outage coordination system known as CROW, despite those outage submissions not meeting the MISO Tariff or business practice manual (BPM) definitions of either a planned or forced outage, because the outages were economic in nature and not due to physical impairments of the resources. In addition, MISO’s internal tools and software did not provide its operators sufficient visibility to readily identify MISO market generation resources that were derated for economic reasons but capable of operating at a higher level of output. As a result, MISO was effectively unable to call upon such resources to increase their output above their economically-derated capability when needed.", "is_other_matter": true, "recommendations": [ { "number": 9, "text": "Enhancing tools, software, and training to better inform system operators when real-time resources are economically-derated and are capable of performing at a higher level of output above their economically-derated capability, and repeat such training as needed.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 5, "title": "Real-time Ex-Post Market Clearing Price Transparency", "summary": "MISO did not update its Market Reports following the implementation of Value of Lost Load (VOLL) pricing for eight five-minute periods falling within the time frame of 8:05 p.m. to 9:00 p.m. during Winter Storm Uri on February 16, 2021.2", "is_other_matter": true, "recommendations": [ { "number": 10, "text": "Strengthening policies, procedures, and controls regarding how price corrections are made to its Market Reports to ensure that updated price data is publicly available in a timely manner.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Monitoring of Energy Must Offer Compliance", "summary": "MISO did not resolve certain instances when its automated energy must offer compliance reporting system identified a market participant’s resource as not meeting its daily energy must offer obligation.", "is_other_matter": true, "recommendations": [ { "number": 11, "text": "Developing processes and procedures to ensure that it fully addresses and resolves all instances when its automated energy must offer compliance reporting system identifies a market participant’s resource for not meeting its daily energy must offer obligation, including considering ways to escalate for potential remediation or enforcement action instances when market participants are not fully responsive to MISO's outreach.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Email Retention Processes and Procedures", "summary": "MISO’s preservation of records practices do not ensure emails that constitute records are properly identified, archived, indexed, and retrievable as required by the Commission. E.", "is_other_matter": true, "recommendations": [ { "number": 12, "text": "Enhancing identification, archiving, indexing, and retrieval policies and procedures to properly retain and maintain emails that constitute records.", "source_page": null }, { "number": 13, "text": "Developing and implementing training on enhanced email record identification, archiving, indexing, and retrieval policies and procedures, and repeat such training as needed.", "source_page": null }, { "number": 14, "text": "Enhancing policies and procedures to ensure that records retention practices align with internal schedules and requirements. F.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Informational postings", "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "TX", "source": "Public Utility Commission of Texas", "doc_type": "direct testimony", "id": "2025-04-01_el-paso-electric_puct-57149-staff-testimony", "company": "El Paso Electric Company", "company_raw": "El Paso Electric Company", "docket": "57149", "docket_full": null, "issued_date": "2025-04-01", "source_page_url": "https://interchange.puc.texas.gov/search/documents/?controlNumber=57149&itemNumber=118", "pdf_download_url": "https://interchange.puc.texas.gov/Documents/57149_118_1485108.PDF", "captured_at": "2026-06-01", "source_note": "Direct Testimony of Vonetta Jackson, Rate Regulation Division, Public Utility Commission of Texas (Commission Staff), in El Paso Electric Company's fuel-cost reconciliation, PUC Docket No. 57149 / SOAH Docket No. 473-25-05084, filed April 1, 2025. Listed for reference (metadata-only). Source: PUCT Interchange, document interchange.puc.texas.gov/Documents/57149_118_1485108.PDF.", "archived_via": null, "page_count": 15, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Settlement: Agreement", "summary": "any to Amend its Distribution Cost Recovery Factor Testimony in Support ofUnopposed Stipulation and Settlement Agreement filed June 2023 Docket No. 54634 Application of Southwestern Public Service Company for Authority to Change Rates Testimony on Rate-Case Expenses fil", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "TX", "source": "Public Utility Commission of Texas", "doc_type": "direct testimony", "id": "2025-03-25_el-paso-electric_puct-57149-opuc-testimony", "company": "El Paso Electric Company", "company_raw": "El Paso Electric Company", "docket": "57149", "docket_full": null, "issued_date": "2025-03-25", "source_page_url": "https://interchange.puc.texas.gov/search/documents/?controlNumber=57149&itemNumber=113", "pdf_download_url": "https://interchange.puc.texas.gov/Documents/57149_113_1483132.PDF", "captured_at": "2026-06-01", "source_note": "Direct Testimony and Attachments of Evan D. Evans on behalf of the Office of Public Utility Counsel (OPUC, the statutory residential and small-commercial consumer advocate), challenging cost recovery in El Paso Electric Company's fuel-cost reconciliation, PUC Docket No. 57149 / SOAH Docket No. 473-25-05084, filed March 25, 2025. Listed for reference (metadata-only). Source: PUCT Interchange, document interchange.puc.texas.gov/Documents/57149_113_1483132.PDF.", "archived_via": null, "page_count": 52, "scanned_pages": [ 26 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "TX", "source": "Public Utility Commission of Texas", "doc_type": "direct testimony", "id": "2025-03-25_el-paso-electric_puct-57149-city-testimony", "company": "El Paso Electric Company", "company_raw": "El Paso Electric Company", "docket": "57149", "docket_full": null, "issued_date": "2025-03-25", "source_page_url": "https://interchange.puc.texas.gov/search/documents/?controlNumber=57149&itemNumber=114", "pdf_download_url": "https://interchange.puc.texas.gov/Documents/57149_114_1483150.PDF", "captured_at": "2026-06-01", "source_note": "Redacted Direct Testimony and Workpapers of Scott Norwood on behalf of the City of El Paso, addressing re-allocation of purchased-power-agreement energy costs, imputed capacity charge credits, and Newman Unit 6 fuel costs in El Paso Electric Company's fuel-cost reconciliation, PUC Docket No. 57149 / SOAH Docket No. 473-25-05084, filed March 25, 2025. Listed for reference (metadata-only). Source: PUCT Interchange, document interchange.puc.texas.gov/Documents/57149_114_1483150.PDF.", "archived_via": null, "page_count": 52, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 4, "findings": [ { "index": 1, "title": "Approval: $225,000\n", "summary": "nse incurred during the Reconciliation Period to the Texas 11 jurisdiction, and that the Company be allowed to carry forward the estimated $225,000 12 impact ofthis proposal for final review in EPE's next fuel reconciliation case at which time 13 a final determination of whether Newman 6 should be", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 2, "title": "Approval: $225,000 ", "summary": "nse incurred during the Reconciliation Period to the Texas jurisdiction, 22 and that the Company be allowed to carry forward the estimated $225,000 impact of this 25 See the Direct Testimony of EPE witness Julissa Reza, page 27, lines 17-31 and Exhibit JIR-3. SOAH Docket NO. 473-25-05084 DIRECT TE", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: agreement", "summary": "and presented testimony regarding the prudence of a $1.7 billion coal-fired power plant and related settlement agreements with Sierra Club. New ForkPublic Service Commission - Conducted inter-company statistical benchmarking analysis of Consolidated Edison Company to pr", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 4, "title": "Settlement: agreement", "summary": "s decision to retire the Welsh Unit 2 coal- fired generating unit in conjunction with a litigation settlement agreement with Sierra Club. Georgia Public Service Commission - Presented testimony before the Georgia Public Service Commission in Docket 3840-U, providing re", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Affiliate / intercompany transactions", "Fuel & purchased-power cost recovery" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "KY", "source": "Kentucky Public Service Commission", "doc_type": "fuel adjustment clause order", "id": "2025-03-19_kentucky-utilities_ky-2024-00146-fac", "company": "Kentucky Utilities Company", "company_raw": "Kentucky Utilities Company", "docket": "2024-00146", "docket_full": null, "issued_date": "2025-03-19", "source_page_url": "https://psc.ky.gov/Case/ViewCaseFilings/2024-00146", "pdf_download_url": "https://psc.ky.gov/pscscf/2024%20Cases/2024-00146/20250319_PSC_ORDER.pdf", "captured_at": "2026-06-10", "source_note": "Final order in the electronic examination of the Fuel Adjustment Clause (FAC) of Kentucky Utilities Company for May 1, 2023 through October 31, 2023, Kentucky PSC Case No. 2024-00146, issued March 19, 2025 (3 pp; the six-month FAC fuel-cost review under 807 KAR 5:056 — companion to the seeded Kentucky Power FAC order 2024-00136). PDF at the deterministic KY PSC path psc.ky.gov/pscscf/2024 Cases/2024-00146/; case folder psc.ky.gov/Case/ViewCaseFilings/2024-00146. Page-1 verified 2026-06-10.", "archived_via": null, "page_count": 3, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "KY", "source": "Kentucky Public Service Commission", "doc_type": "fuel adjustment clause order", "id": "2025-03-19_kentucky-power_ky-2024-00136-fac", "company": "Kentucky Power Company", "company_raw": "Kentucky Power Company", "docket": "2024-00136", "docket_full": null, "issued_date": "2025-03-19", "source_page_url": "https://psc.ky.gov/Case/ViewCaseFilings/2024-00136", "pdf_download_url": "https://psc.ky.gov/pscscf/2024%20Cases/2024-00136/20250319_PSC_ORDER.pdf", "captured_at": "2026-06-02", "source_note": "Order in the electronic examination of the Fuel Adjustment Clause (FAC) of Kentucky Power Company (AEP) for November 1, 2022 through April 30, 2023, Kentucky PSC Case No. 2024-00136, issued March 19, 2025. Listed for reference (metadata-only). PDF at the deterministic KY PSC path psc.ky.gov/pscscf/2024 Cases/2024-00136/; case folder psc.ky.gov/Case/ViewCaseFilings/2024-00136.", "archived_via": null, "page_count": 3, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "CA", "source": "CPUC Utility Audits, Risk and Compliance Division", "doc_type": "balancing accounts performance audit (Utility Audits Branch)", "id": "2025-02-19_southern-california-gas_ca-balancing-accounts-audit", "company": "Southern California Gas Company", "company_raw": "Southern California Gas Company", "docket": null, "docket_full": null, "issued_date": "2025-02-19", "source_page_url": "https://www.cpuc.ca.gov/about-cpuc/divisions/utility-audits-risk-and-compliance-division/utility-audits-branch/audit-reports-by-industry/audit-reports-energy-industry", "pdf_download_url": "https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/utility-audits--risk--and-compliance-division/reports/energy/2025/energy_2025-02-19_scg_ba.pdf", "captured_at": "2026-06-08", "source_note": "CPUC Utility Audits Branch Balancing Accounts Performance Audit of SoCalGas (review period CY2023), dated Feb 19, 2025. 15 pp. Page 1 verified: 'BALANCING ACCOUNTS PERFORMANCE AUDIT Southern California Gas Company'.", "archived_via": null, "page_count": 15, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "the balancing account. Additionally, unless approved otherwise, a balancing acco", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "the balancing account. Additionally, unless approved otherwise, a balancing account is required to accumulate monthly interest at a rate equal to one-twelfth of the most recent month’s interest rate on three-month Commercial Paper published by the Federal Reserve. Actual revenues collected by a utility in rates can be more or less than what CPUC had authorized to", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "This audit report is intended solely for the information and use of SoCalGas and", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 2, "text": "This audit report is intended solely for the information and use of SoCalGas and CPUC; it is not intended to be and should not be used by anyone other than these specified parties. This restriction is not intended to limit distribution of this final audit report, which is a matter of public record and will be available on CPUC website at Audit Reports by Industry (ca.gov).", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NY", "source": "New York State Department of Public Service", "doc_type": "comprehensive management & operations audit final report (independent auditor, PSL §66(19))", "id": "2025-02-04_nyseg-rge_ny-23-m-0103-mo-audit-final-report", "company": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "company_raw": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "docket": "23-M-0103", "docket_full": null, "issued_date": "2025-02-04", "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=23-M-0103", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B3097E996-0000-C45D-8AB2-101DC6B879E5%7D", "captured_at": "2026-06-22", "source_note": "NorthStar Consulting Group's independent Comprehensive Management and Operations Audit of New York State Electric & Gas Corporation (NYSEG) and Rochester Gas and Electric Corporation (RG&E) — the Avangrid-owned utilities — under PSL §66(19), Case 23-M-0103 (439 pp). Report dated February 4, 2025; publicly released by PSC Order Releasing Audit Report on May 15, 2025. The auditor makes 128 recommendations; key findings include that Avangrid's complex corporate structure (13 affiliates) obscures whether allocated charges follow cost causation, and that NYSEG failed enforceable reliability standards for six consecutive years. Page 1 verified: 'A COMPREHENSIVE MANAGEMENT AND OPERATIONS AUDIT OF NEW YORK STATE ELECTRIC & GAS CORPORATION AND ROCHESTER GAS & ELECTRIC CORPORATION CASE 23-M-0103 FINAL REPORT ... FEBRUARY 4, 2025 NORTHSTAR CONSULTING GROUP'. Harvested from the NY DPS Document & Matter Management (DMM) system. Listed for reference (metadata-only). Source: NY DPS DMM (documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={3097E996-0000-C45D-8AB2-101DC6B879E5}).", "archived_via": null, "page_count": 439, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 11, "findings": [ { "index": 1, "title": "Governance And Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise the Avangrid, NYSEG and RG&E organization and governance to comply with each element of the NYSPSC Order Adopting Staff Report and Approving Reorganization – Case 12-M-0066, et al. Provide a report to DPS demonstrating how each element has been satisfied.", "source_page": null }, { "number": 2, "text": "Develop SLAs that include detailed descriptions of services to be provided to clients such as NYSEG and RG&E.", "source_page": null }, { "number": 3, "text": "Revise and update the CAM to provide a detailed list of functions and charges based on the level of products and services descriptions.", "source_page": null }, { "number": 4, "text": "Develop SLAs that define units of measure and volumes of products and services to be provided over specified time periods. Units of measure and volumes are necessary to reconcile levels of services provided – whether they are directly charged or allocated.", "source_page": null }, { "number": 5, "text": "Provide comparisons of cost competitiveness between SLA products and services versus third-party providers to demonstrate whether Avangrid services charged are greater or less than other commercially available services. Report this information in SLAs and implementation plans. Provide updates to the extent information changes.", "source_page": null }, { "number": 6, "text": "Report SLA cost competitiveness to DPS on an annual basis.", "source_page": null }, { "number": 7, "text": "Develop and include comprehensive SLA key performance metrics that pertain to all products and services provided. Report this information in SLAs and implementation plans. Provide updates to the extent information changes.", "source_page": null }, { "number": 8, "text": "Provide measures of quality for SLA products and services.", "source_page": null }, { "number": 9, "text": "Establish SLA economic performance premiums and penalties for all products and services provided.", "source_page": null }, { "number": 10, "text": "Develop and report SLA true-up for budget amounts and invoice amounts based on actual volume of services, quality and cost at year-end.", "source_page": null }, { "number": 11, "text": "Provide a review of SLA agreed-upon service level expectations from the previous year, plus expectations for the upcoming year.", "source_page": null }, { "number": 12, "text": "Provide a detailed comparison of actual versus budgeted services/expenditures and invoice an amount at year-end with supporting variance information.", "source_page": null }, { "number": 13, "text": "Develop strategic planning processes and strategic plans for NYSEG and RG&E, respectively. The resulting plans must focus on the unique issues impacting each utility, with specific goals, objectives, and performance metrics that represent the strategic, operating, and regulatory environment of each utility. See Chapter XIII- Performance Management.", "source_page": null }, { "number": 14, "text": "Have an independent, third-party firm specializing in ERM maturity assessments conduct a comprehensive study of Avangrid’s ERM program using industry accepted standards. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION Review ERM Maturity Assessment RFP with DPS prior to issuance to obtain feedback. Review vendor selection with DPS. Upon completion of the study, provide a full copy of results and plans to implement recommendations with DPS.", "source_page": null }, { "number": 15, "text": "Develop a comprehensive and fully resourced ERM program for Avangrid Networks, NYSEG, and RG&E incorporating all recommendations from the third-party maturity assessment. Furthermore, the ERM program should be aligned with internal controls such that risks can be monitored on a continuous basis. Internal audits of ERM programs, processes, and risk registers must be performed at least on a biennial basis and documented and maintained for future evaluation.", "source_page": null } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 2, "title": "Budget And Finance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Simplify the service company cost-allocation process. Increase the illustration and support documentation so the user can easily understand and verify the allocations to the FERC Form 1. Also, prepare an annual report that summarizes and supports the amounts charged to NYSEG and RG&E. Reporting should be provided to DPS during interim periods between rate cases to support affiliate charges.", "source_page": null }, { "number": 17, "text": "Improve unitization process. Going forward, Avangrid must ensure that unitized fixed- asset data are accurate and consistent for NYSEG and RG&E. Future plant in-service additions must accurately reflect cost, units, vintage and material.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 3, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Improve the electric load forecast model(s) used to address issues specific to NYSEG and RG&E, focusing on the following: 1.1 Accuracy 1.2 Weather-normalization methodologies 1.3 Sector segmentation 1.4 Forecasting horizon 1.5 CLCPA considerations 1.6 Econometric equation specification", "source_page": null }, { "number": 19, "text": "Issue RFP for planning services for an asset-management system. Work products should include the following: 2.1 Data needs assessment 2.2 Software needs assessment 2.3 System needs assessment 2.4 Staffing needs assessment 2.5Change management assessment 2.6 List of proposed systems, business and system integrators", "source_page": null }, { "number": 20, "text": "Implement a trim cycle of five or six years consistent with the last Joint Proposal.", "source_page": null }, { "number": 21, "text": "Edit the link to the Hosting Capacity website to read “Hosting Capacity Portal (PV, BESS, Electrification)”. Update hosting-capacity maps according to the documented schedule.", "source_page": null }, { "number": 22, "text": "Conduct an independent, third-party audit with DPS oversight of storm costs to determine the accuracy of costs recorded to storm events that comply with the current rate plan and to provide more timely recovery of storm expenditures for NYSEG and RG&E. This includes but is not limited to tracing a major storm and a vegetation management work order to financial statements and reviewing the work order procedure to ensure there are no overlapping or duplicate cost collectors in storms, vegetation management, and capital. As a substantial portion of storm expenditures are paid to external parties, it is difficult to evaluate the reasonableness or accuracy of costs without auditing a valid sample of costs. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION", "source_page": null } ], "themes": [ "Service reliability & vegetation management", "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 4, "title": "Gas Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Comply with §192.1007(a): based on the DIMP presentations of 18 risk categories, identify missing data for the entire pipeline system and develop a plan to collect all relevant information as part of normal pipeline activities.", "source_page": null }, { "number": 24, "text": "Utilize sources of information such as past O&M procedures, abnormal operating events, purchase orders, material lists from old field orders or standards, and information from industry sources (e.g., plastic pipe database committee (PPDC), NTSB accident reports, or PHMSA advisory bulletins) to help identify threats. PHMSA identified potential threats that include, but are not limited to, non-leak events such as near misses, over pressurizations, and material and appurtenance failures.", "source_page": null }, { "number": 25, "text": "Comply with §192.1007(b): use the information gathered in compliance with §192.1007(a) to identify threats to the integrity of the entire gas distribution systems by segment or lengths of similar characteristics – LPM, traditional LPM, non-traditional LPM and non LPM.", "source_page": null }, { "number": 26, "text": "Do not eliminate any existing or potential threat to a system segment or lengths of pipeline without an adequate basis and justification for doing so. PHMSA clarified through enforcement guidance that to exclude a threat from consideration (i.e., the absence of a risk category as identified in the DIMP), an operator should document the basis for that conclusion and should not exclude a threat based on the unavailability of information to support the existence of such a threat.", "source_page": null }, { "number": 27, "text": "Establish a formal schedule for the identification of missing risk data and report progress to the DPS quarterly.", "source_page": null }, { "number": 28, "text": "Comply with §192.1007(c): subdivide all the NYSEG/RG&E pipeline systems into multiple regions based on similar pipeline characteristics (e.g., contiguous areas within a distribution pipeline consisting of mains, services and other appurtenances; areas with common materials or environmental factors), and for which similar mitigation actions would be effective in reducing risk.", "source_page": null }, { "number": 29, "text": "Comply with §192.1007(d): determine and implement measures designed to reduce the risks from failure of their gas distribution pipelines. Define measures (actions and activities not merely statistical measures) to improve the leak management program.", "source_page": null }, { "number": 30, "text": "Comply with §192.1007(d): prioritize, plan and address the risks of greatest concern first in the NYSEG/RG&E pipeline system replacement program.", "source_page": null }, { "number": 31, "text": "Accelerate the replacement of LPM before the life expectancy expiration of pipeline materials.", "source_page": null }, { "number": 32, "text": "Reconcile, correct and report solutions on record keeping discrepancies in the inspection data based on Conclusion 15. Add records that are missing or perform inspections and update the work management system to include missing inspections.", "source_page": null }, { "number": 33, "text": "Comply with 16 NYCRR 255.825 and change the methodology per DPS guidance to calculate emergency response time. Report these changes to DPS and revise/correct the emergency response data reported since 2019.", "source_page": null }, { "number": 34, "text": "Improve the gas load forecast model(s) to better address CLCPA considerations and to increase the forecasting horizon.", "source_page": null } ], "themes": [ "Emergency preparedness & business continuity", "Gas safety & pipeline integrity" ], "cost_to_customers": false }, { "index": 5, "title": "Project Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Develop industry-accepted Work Breakdown Structures for capital programs/projects and use WBSs in initial phases of project justification and conceptual estimating. Continue refinement as a project progresses. 1.1. Develop well-defined work packages that can be used to track and measure project performance based on earned value. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION 1.2. Plan work in logical work groupings or packages and subdivide into smaller work groupings. 1.3. Ensure that activities required to perform work in each group are identified and defined, and that dependent relationships are established. 1.4. Formalize use of WBS elements by all project participants in their respective areas of responsibility and as an identification tool for project-management performance measurement. 1.5. Use new WBSs in procurement/contracting activities and specify WBS in contractor framework agreements. 1.6. Use new WBSs for project costing and as a means to assess impact of programmatic changes in funding levels on work content, schedules and contractual support. 1.7. Prepare cost estimates for each WBS element to assist budgeting and project validation. 1.8. Integrate new WBSs with ", "source_page": null }, { "number": 36, "text": "Address deficiencies in project estimating by making process improvements. 2.1. Formally assess process used to develop and update capital program/project cost estimates and develop detailed study. Submit detailed study to DPS. 2.2. Formally document in detail development of all electric and gas program/project cost estimates at each level of estimate according to Avangrid’s SOP.E-CD.04.04: Cost Management Standard Operating Procedure and at various stages of project life cycle. 2.3. Formally document in detail project cost-estimate reviews at each level of estimate. 2.4 Continuously verify accuracy of estimates versus actual project costs and maintain record of updates to cost-estimating tools. 2.5 Keep all detailed cost estimates in program/project folder for regulatory and audit purposes.", "source_page": null }, { "number": 37, "text": "Standardize project-prioritization process across all Avangrid departments that provide services to NYSEG and RG&E. Record and retain meeting minutes for all governance committees involved in project-prioritization process.", "source_page": null }, { "number": 38, "text": "Integrate CLCPA requirements into electric and gas capital project-prioritization process/algorithm. Review requirements and prioritization process/algorithm with DPS.", "source_page": null }, { "number": 39, "text": "Identify and document all tangible benefits for each capital program/project as part of Project Charters and Project Management Plans. Develop and implement method to track and report project benefits for life of program/project. Provide benefit realization reports to DPS for each completed program/project.", "source_page": null }, { "number": 40, "text": "Conduct an independent, third-party audit with DPS oversight of Avangrid’s record- management practices that includes electric and gas program/project records. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION", "source_page": null }, { "number": 41, "text": "Develop project plan and schedule and assign resources to update all Avangrid QMS procedure documentation. Include incentive compensation metrics for VPs of Electric and Gas Operations, respectively, to complete documentation updates. Review plan, schedule and incentive compensation metrics with DPS.", "source_page": null }, { "number": 42, "text": "Engage an independent monitor to oversee electric and gas program/project planning, management and delivery. Key responsibility of the independent monitor is to review and report to DPS Staff on effectiveness of capital program/project planning, capital budgeting processes and program/project management, plus program/project cost effectiveness, efficiency, appropriate cost assignment, benefit realization and tracking, and other information. Include DPS in RFP development, vendor proposal review and selection, and contracting. Shareholders should be responsible for the cost of the independent monitor.", "source_page": null }, { "number": 43, "text": "Improve coordination and management of public improvement and interference projects. 9.1 Develop and implement procedure documentation for coordination of electric and gas public improvement and interference projects with municipalities and agencies. Integrate with Project Outreach group’s procedures. 9.2. Actively solicit short- and long-term capital plans from key municipal and agency stakeholders. 9.3. Work with DPS to develop annual post-project survey for public improvement and interference projects to be delivered to municipalities and agencies upon project completion. 9.3.1. Incorporate results into continuing process-improvement efforts. 9.3.2. Provide annual report of survey results and process-improvement initiatives/progress to DPS. 9.3.3. Include completed survey metric as part of incentive compensation for VPs delivering services to municipalities and agencies. Review survey completion metric to be included in incentive compensation plan with", "source_page": null }, { "number": 44, "text": "Include all project outreach costs in capital program/project cost estimates. Directly charge all actual project outreach costs to capital programs/projects so that booked capital costs reflect actual project costs.", "source_page": null }, { "number": 45, "text": "Initiate an independent review with DPS oversight to determine if Avangrid is following its own project management policies and procedures on select, completed gas projects over $500K and select completed electric projects over $1M up to CY2023 to quantify the cost of unreasonable management. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Work Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 46, "text": "Develop an integrated work management system covering all NYSEG and RG&E Gas and Electric operations, maintenance and construction resources based on engineered time standards. This system should cover routine operations, repetitive maintenance activities, planned work and support requirements, while also providing continuous feedback on workforce effectiveness. The system should be in an easy-to-use format expressed in man- hours, along with the combined employee and contractor capacity available, supported by real-time reporting of capacity utilization. The system should include the following specific elements: 1.1. Documentation of work level versus resource histogram development and work plan process 1.2. Enhanced methods to calculate workforce capacity and utilization 1.3. Expanded workforce coverage in reports 1.4. Documentation of processes for establishing workforce levels 1.5. Documentation of criteria for adding contractor capacity 1.6. Real-time variance reporting for O&M and project costs 1.7. Tracking performance targets versus actuals.", "source_page": null }, { "number": 47, "text": "Develop management information reporting and organizational reporting relationships to support integrated work management system.", "source_page": null }, { "number": 48, "text": "Develop formal reports on trends covering NYSEG and RG&E workload levels, workforce productivity and utilization. Analysis of these trends should identify high- performing functional areas, along with areas needing improvement. This should serve as a foundation for developing strategies to improve workforce performance.", "source_page": null }, { "number": 49, "text": "Integrate reported information covering NYSEG and RG&E workload levels, workforce productivity and utilization with SLA recommendations contained in Chapter III – Governance.", "source_page": null }, { "number": 50, "text": "Establish formal processes to use work management data as part of annual business planning for NYSEG and RG&E operations and maintenance.", "source_page": null }, { "number": 51, "text": "Refine formal work management practices for NYSEG and RG&E Gas and Electric engineering and design functions. Work management systems should include appropriate system tools to support various individual and distinct engineering functional processes and integrate with SLA recommendations contained in Chapter III – Governance. Elements that should be formalized include the following: 6.1. Scheduling 6.2. Prioritization and planning 6.3. Resource allocation and leveling 6.4. Performance measurement 6.5. Budget planning and control 6.6. Vendor tracking 6.7. Document/drawing control 6.8. Records management 6.9. Procurement management 6.10. Time reporting.", "source_page": null }, { "number": 52, "text": "Develop and report on overtime targets and performance metrics for NYSEG and RG&E Gas and Electric operations and maintenance organizations. These metrics should be based on economic analyses and verified industry norms.", "source_page": null }, { "number": 53, "text": "Annually review the design of monitoring and controlling reports to improve their usefulness. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Customer Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 54, "text": "Perform in-depth analysis to cross reference NYCRR Part 11 and 13 regulations with built-in system controls and manual processes required for compliance with each customer service rule. Exception reports should be created to ensure controls are sufficient.", "source_page": null }, { "number": 55, "text": "Implement the following as related to compliance assessment findings for 16 NYCRR Part 11 and 13: 2.1. Create metric to monitor Timing of Service non-compliance instances. 2.2. Include actual payment due date on customer bills. 2.3. Provide training and updated materials related to security-deposit requirements and reasonable proof of identify. 2.4. Allow for negotiation of Deferred Payment Agreements (DPAs) to ensure fair and equitable consideration of the customer’s financial circumstances. 2.5. Mail the Annual Notification of Rights to every customer", "source_page": null }, { "number": 56, "text": "Implement version control for process and procedure/training documents, including but not limited to, description of content changed, date content changed, required update frequency, content author, reviewer and approver.", "source_page": null }, { "number": 57, "text": "Eliminate bi-monthly meter readings and complete universal AMI implementation. Until then, offer to move customers complaining of bill estimates to a levelized payment plan.", "source_page": null }, { "number": 58, "text": "Develop quarterly report of shared-meter investigations, including status and pending issues for upper management. Include milestones of investigations.", "source_page": null }, { "number": 59, "text": "Develop database of shared-meter investigations including customer information, date of complaint, date of investigation, resulting actions and dates, and record locator.", "source_page": null }, { "number": 60, "text": "Maintain shared-meter investigation records for a minimum of five years.", "source_page": null }, { "number": 61, "text": "Include additional information on letters sent to customers about rate changes. 8.1. Current rate schedule – NYSEG only 8.2. Requirements of current rate schedule – NYSEG only 8.3. Detailed reason for change (e.g., the demand on your facility was 512 kW, exceeding 500 kW twice in the past 12 months) – both RG&E and NYSEG. 8.4. Requirements of new rate schedule – NYSEG only", "source_page": null }, { "number": 62, "text": "Provide more visibility on the utilities’ websites for time-of-use rate options.", "source_page": null }, { "number": 63, "text": "Determine drivers of substantial increase in Call Center costs between 2018 and 2023. Ensure costs are directly attributable to NYSEG and RG&E.", "source_page": null }, { "number": 64, "text": "Formally communicate to DPS any planned changes to business operations that result in consolidation or situations where outsourcing of utility work is done.", "source_page": null }, { "number": 65, "text": "Implement formal contract management to ensure such things as agreement-number assignments, change-order numbering, and monitoring of contract values in comparison to invoiced amounts.", "source_page": null }, { "number": 66, "text": "Unsupported expenses such as Customer Operations charges that cannot be substantiated by invoices and proven to be directly attributable to services for NYSEG and RG&E, should be classified as “below the line” and paid by shareholders.", "source_page": null }, { "number": 67, "text": "Improve QRS and SRS case file documentation. Include a minimum of the following: 14.1. Usage and billing history. 14.2. Customer communication log. 14.3. Root cause assessment. 14.4. Proof of feedback sent to responsible department. 14.5. Copy of customer letter for case closeout.", "source_page": null }, { "number": 68, "text": "Create KPIs to track and monitor the following: 15.1. First Call resolution EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION 15.2. Delayed bills. 15.3. Commitments to follow-up with customers on issues when call-back is promised.", "source_page": null }, { "number": 69, "text": "Create a formal invoice review process and ensure this review process includes, but is not limited to, the following: 16.1. Invoices received and added to transaction record. 16.2. Invoice contains appropriate line-item information. 16.3. Invoice aligns with invoiceable items, per contract, and item amounts match. 16.4. Cost allocations are justified, and methodology is within transaction record. Also ensure that charges to NYSEG and RG&E can be directed supported, and that each budget owner has approved. 16.5. Transaction record indicates all budget owners have approved cost allocations. 16.6. Transaction is recorded correctly.", "source_page": null }, { "number": 70, "text": "Several areas of deficiency were noted in the Low-Income Program area: 17.1. Create a comprehensive Program Manual to include end-to-end program management. Include a minimum of the following: 17.1.1. Stakeholders. 17.1.2. Applicable tariffs. 17.1.3. Proof of eligibility requirements. 17.1.4. Process and procedure documentation. 17.1.5. Program goals and KPIs. 17.1.6. Program budget by admin, marketing/outreach and implementation. 17.1.7. OTDA file-matching cadence. 17.1.8. Tier discounts – maintenance of Tier discounts. 17.1.9. EAP form – English and other languages. 17.1.10. EAP letters – English and other languages. 17.1.11. Marketing and Outreach collateral – English and other languages. 17.1.12. Marketing and Outreach Strategy. 17.1.13. Community Based Organization partners. 17.1.14. List of reports with samples. 17.1.15. Training material locations. 17.1.16. Quality audit report locations. 17.2. Update Tariffs as noted in chapter. 17.3. Implement monthly quality review process.", "source_page": null }, { "number": 71, "text": "Provide supplemental data on the monthly CSPI report to DPS to include the number of bills not yet issued, number of bills issued late, number of days bills delayed by situation category (i.e. implausible, CDG Bill, etc.). In addition, each month indicates the number of accounts where consecutive bills were delayed including the number of consecutive months.", "source_page": null }, { "number": 72, "text": "Perform further financial review of Marketing and Outreach transactions to determine if costs are attributable to NYSEG and RG&E – and to define extent of corporate marketing transactions included in reporting. Eliminate corporate marketing costs in Outreach and Education and costs that are not directly attributable to NYSEG and", "source_page": null }, { "number": 73, "text": "Update CSPI process documentation to define how percentage of calls answered is calculated and retain numerator and denominator values in workpapers. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION", "source_page": null }, { "number": 74, "text": "Create formal override process to allow proper authority to approve adjustments made to CSPI metrics with appropriate supporting information on why it meets OCS definition and reason raw data reflected a different outcome.", "source_page": null }, { "number": 75, "text": "Ensure CSPI report model calculates all data in all cells, make sure quality checks are evident, review, document and certify all metric adjustments, and re-file CSPI metrics.", "source_page": null }, { "number": 76, "text": "Develop narrative of observations/actions to accompany staffing reports.", "source_page": null }, { "number": 77, "text": "Continue to make improvements to scam-tracking database to allow for reporting of scam types, amounts, verified scams, completed actions, and customer contact for closeout.", "source_page": null }, { "number": 78, "text": "Implement quality review and controls to ensure accuracy of Energy Efficiency data.", "source_page": null }, { "number": 79, "text": "Create implementation plan for all vendor recommendations to improve Energy Efficiency programs and data. Physical and Cybersecurity", "source_page": null } ], "themes": [ "Tariff administration & oversight", "Cybersecurity & physical security", "Workforce, training & succession planning", "Customer service & billing" ], "cost_to_customers": false }, { "index": 8, "title": "Rg&E.", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 80, "text": "Provide a detailed report and in-person presentation to DPS on Avangrid’s prior and current plans to implement NIST CSF. This report must be provided at least one month prior to an in-person presentation. The report and presentation must include, at minimum, the following: 1.1. Detailed description of CSMP from original assessment in March 2020 to current date. 1.2. Review of each CSMP reassessment/re-evaluation performed and reason each reassessment/re-evaluation was required. 1.3. Discussion of CSMP governance model and all committees – including committee membership, responsibilities and work products produced. 1.4. Discussion of project management approach and implementation. Include all changes to project management since inception to current date. 1.5. Past and current CSMP procurement plans and contracting for all vendors, equipment and materials. 1.6. Scope changes to CSMP from inception to current date, with justifications for each scope change. Include information on all scope changes currently planned. Discuss scope risks and mitigation strategies. 1.7. CSMP resource management approach, staffing plans and actuals (internal and external) from inception to current date – ", "source_page": null }, { "number": 81, "text": "Formalize CSMP expectations and planned outcomes with DPS. Provide testimony in future NYSEG and RG&E rate cases regarding CSMP expectations. Furthermore, provide DPS with semi-annual Avangrid CSMP reports going forward. At minimum, these reports should include metrics for scope, cost, schedule and resource management, plus earned value. Provide DPS with detailed variance reporting, with verifiable justification for all variances. Notify DPS of all Avangrid NIST CSF maturity assessments in terms of timing, scope, cost and vendor selection. Provide all signed Avangrid contracts, procurement assessments and full study results going forward. Meet with DPS to finalize CSMP expectations, outcomes and all reporting requirements", "source_page": null }, { "number": 82, "text": "Develop metrics to track effectiveness of remediation efforts associated with Vulnerability Assessments/Penetration Tests and similar audits/assessments. Include these metrics as part of responsible executives’/employees’ incentive compensation plans.", "source_page": null }, { "number": 83, "text": "Develop a detailed plan to implement all NERC CIP internal controls and provide to DPS. Also provide quarterly implementation progress updates. Perform internal audit of NERC CIP controls for high-risk standards, as well those for CIP 004, 007, 010, and 011 and provide results and workpapers to DPS.", "source_page": null }, { "number": 84, "text": "Provide DPS with detailed report and in-person presentation of Avangrid’s business resilience program and current effort to revise the company’s program, materials and reporting. The report must be provided to DPS at least one month in advance of in- person presentation. As part of this presentation, include a demonstration of the Business Continuity Management tool. Also provide DPS with a copy of all updated Business Impact Analysis, Business Continuity and Disaster Recovery Plans upon completion of these materials. The report and presentation should describe funding provided in rates for these activities and how funds have been used for the last five years.", "source_page": null }, { "number": 85, "text": "Include DPS in all business resilience drills/exercises to observe activities. Provide DPS with post-drill/exercise reports, findings, recommendations and implementation plans.", "source_page": null }, { "number": 86, "text": "Develop thresholds for “bad swipes” at non-NERC CIP-covered NYSEG and RG&E facilities and apply appropriate remediation for repeat offenders.", "source_page": null }, { "number": 87, "text": "Develop annual goals for all Avangrid phishing program metrics and report quarterly results to DPS.", "source_page": null }, { "number": 88, "text": "Benchmark how other industries, not just energy/utilities, are adapting proactive cybersecurity programs to the evolving cyber-threat environment (e.g., integration of AI into social engineering attacks). Complete benchmark and provide detailed report to", "source_page": null }, { "number": 89, "text": "Conduct an internal audit of all contractors using their own computers to access Avangrid networks/systems/applications. Develop the audit scope in collaboration with DPS. At minimum, this audit must assess impact to Avangrid’s cyber-security posture. Provide EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION audit results and associated work papers to DPS. Avangrid Internal Audit must make a presentation to DPS on audit results.", "source_page": null }, { "number": 90, "text": "Clearly document and provide verifiable evidence to support adherence to implementation plans filed in Case 13-M-0178. Submit document and associated materials for DPS review.", "source_page": null }, { "number": 91, "text": "Update Comprehensive Security Plan to meet all requirements in New York State’s Critical Energy Generating and Transmission Facilities pursuant to Executive Law Section 713 and provide copy of Plan to DPS.", "source_page": null }, { "number": 92, "text": "Immediately notify DPS of all physical and cyber-security staffing changes. Avangrid will meet with DPS to standardize and finalize reporting requirements as an activity in forthcoming audit recommendations implementation plan.", "source_page": null }, { "number": 93, "text": "Perform background checks on all Avangrid physical and cyber-security employees who don’t have a background check on file or have a background check that has not been updated within five years. Revise procedures to include requirement for updating physical and cyber-security personnel background checks on mutually agreeable timing with DPS and collective bargaining units (as required).", "source_page": null }, { "number": 94, "text": "Revise position descriptions for all resources supporting the NERC CIP program to clearly detail NERC CIP roles and responsibilities.", "source_page": null } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 9, "title": "Information Systems", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 95, "text": "Develop formal documentation and standardized templates to support management decision-making for IT project selection and prioritization. Documentation and templates must be aligned with and support Investment Planning’s prioritization processes.", "source_page": null }, { "number": 96, "text": "Complete all IT PDDs according to Avangrid’s documented instructions. Ensure all PDDs include comprehensive documentation of project purpose/justification, detailed cost estimates, cost-benefit analysis, estimated efficiency (ROI, quantified performance/process improvements, etc.), and standardized risk analysis. Each project should clearly map to specific NYSEG and RG&E strategic objectives.", "source_page": null }, { "number": 97, "text": "Develop a standardized method to track and report progress toward and attained benefit realization for each IT project. Provide annual reports to DPS.", "source_page": null }, { "number": 98, "text": "Perform closer monitoring of AMI-installed endpoints that are not communicating and develop cost estimates based on anticipated solution category.", "source_page": null }, { "number": 99, "text": "Create a model to track and quantify AMI benefits and review with DPS.", "source_page": null }, { "number": 100, "text": "Adhere to procurement policies. Require a formal justification document to be completed and included with all single-source and sole-source contracts.", "source_page": null }, { "number": 101, "text": "Engage a third-party to perform an independent and thorough study of Avangrid’s IT project delivery practices. Incorporate recommendations into IT project management policies and procedures. Provide a full copy of the study results and revised IT policies and procedures to DPS.", "source_page": null }, { "number": 102, "text": "Adhere to formal project management practices, with proper monitoring and controls. This includes but is not limited to the following: 8.1. Use Earned Value Management to measure project performance. 8.2. Ensure project financial health is presented to stakeholders in a transparent manner and not subject to interpretation. Include workstream by budget. 8.3. Ensure all work efforts, including work areas not started, are communicated to stakeholders with cost estimates and that work is reflected in project schedule. 8.4. Include system performance by deployment region on stakeholder reports. EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION 8.5. Perform quality reviews to ensure that invoices and SAP amounts match – and that transactions are for AMI Project, within scope, and match contract-pricing schedule. 8.6. Implement controls for contract-value monitoring and ensure products are not able to be ordered unless contracted for. 8.7. Maintain risk register with impact analysis. 8.8. Develop SAP reporting for increased visibility into internal and external costs.", "source_page": null }, { "number": 103, "text": "Formally disclose AMI AFUDC and all other AMI expenses as well as all other AMI plan deviations not captured in prior Rate Case testimony / workpapers to the DPS.", "source_page": null }, { "number": 104, "text": "Complete CIS assessment and roadmap. Provide assessment, roadmap and workpapers as part of a detailed presentation for DPS.", "source_page": null }, { "number": 105, "text": "Perform an annual comprehensive assessment to determine what routine manual work is completed outside of CIS and determine cost to business. Perform cost-benefit analysis for CIS change.", "source_page": null }, { "number": 106, "text": "Ensure vendor costs are directly charged for work performed on behalf of specific utilities. Where costs cannot be directly charged, clearly document planned allocation methodology and reasons for adjustments.", "source_page": null }, { "number": 107, "text": "Ensure that Budget Transfer forms include the name of approver and approval date fields.", "source_page": null }, { "number": 108, "text": "Initiate an independent review with DPS oversight of AMI and other IT projects to quantify the cost of unreasonable management.", "source_page": null } ], "themes": [ "AFUDC / cost of capital", "Information technology & systems" ], "cost_to_customers": true }, { "index": 10, "title": "Procurement", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 109, "text": "Redefine competitive procurement of goods and services versus transparency using accepted industrial terminology and include this in policies and procedures documents.", "source_page": null }, { "number": 110, "text": "Develop comprehensive performance metrics for the purchasing function. Formally define how each performance metric will be calculated and the data source for each.", "source_page": null }, { "number": 111, "text": "Develop a comprehensive, semi-annual report on the purchasing performance directly applicable to NYSEG and to RG&E supported by verifiable data. Ensure reports and supporting data are readily available and produced for the next management audit.", "source_page": null }, { "number": 112, "text": "Formally define how Supplier Diversity identification and certification will be conducted for NYSEG and for RG&E.", "source_page": null }, { "number": 113, "text": "Formally define how Supplier Diversity procurement will be conducted, how fair and equitable competition among suppliers will be ensured and include this in policies and procedures documents.", "source_page": null }, { "number": 114, "text": "Develop comprehensive performance metrics for Supplier Diversity procurement applicable to NYSEG and to RG&E.", "source_page": null }, { "number": 115, "text": "Develop a comprehensive, semi-annual report on Supplier Diversity purchasing performance directly applicable to NYSEG and to RG&E supported by verifiable data. Ensure reports and supporting data readily available and produced for the next management audit.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Performance Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 116, "text": "In support of developing separate NYSEG and RG&E strategic plans (see Chapter III- Governance and Management), create a performance management program that provides a clear line of sight from top-level NYSEG and RG&E corporate goals supported by subsequent department/operational goals and KPIs.", "source_page": null }, { "number": 117, "text": "Create individual incentive plans for NYSEG and RG&E.", "source_page": null }, { "number": 118, "text": "Include CLCPA initiatives in annual NYSEG and RG&E corporate goals.", "source_page": null }, { "number": 119, "text": "To the extent that New York ratepayers have contributed to annual incentive payments to Avangrid employees (i.e. ASC, AMC, NYSEG and RG&E), NYSEG and RG&E should EXECUTIVE SUMMARY NORTHSTAR Rec # RECOMMENDATION adjust incentive compensation for performance metrics not related to NYSEG and RG&E and where NYSEG and RG&E performance did not meet targets", "source_page": null }, { "number": 120, "text": "Formally document the annual goal-setting process.", "source_page": null }, { "number": 121, "text": "Ensure that annual goals presented to CNC include clear targets and measurement criteria. Clearly indicate when a goal represents a customer-benefiting measure.", "source_page": null }, { "number": 122, "text": "Expand third-party auditor review to include Avangrid Networks and the NYSEG and RG&E President and CEO individual metrics.", "source_page": null }, { "number": 123, "text": "Ensure that CNC meeting minutes are reflective of pre-meeting distributed materials. All such materials should be included in the meeting minute package for official records.", "source_page": null }, { "number": 124, "text": "Clarify the CNC role and Management Committee roles for APA plan administration within the formal APA plan documents.", "source_page": null }, { "number": 125, "text": "Include date and version for all incentive plans, along with including the plan administrator’s name.", "source_page": null }, { "number": 126, "text": "Develop individual goals and career paths for union employees.", "source_page": null }, { "number": 127, "text": "Pursue additional training and oversight to ensure individual goals are appropriately structured and focused on customer benefits.", "source_page": null }, { "number": 128, "text": "Discontinue discretionary assessments in incentive compensation plans to ensure that all employees are evaluated based on consistent and measurable performance metrics. NORTHSTAR On May 18, 2023, the NYSPSC issued a Request for Proposal (RFP) in Case 23-M-0103 for a consultant to perform a Comprehensive Management and Operations Audit of New York State Electric & Gas Corporation (NYSEG) and Rochester Gas and Electric Corporation (RG&E). NorthStar Consulting Group, Inc. (NorthStar) was selected by the NYSPSC on September 15, 2023, to perform the audit. Pursuant to Public Service Law §66(19)1, the NYSPSC is authorized to engage a consulting firm to perform comprehensive management and operations audits. These audits, managed by DPS, provide an opportunity to gain valuable insight into utility operations and management. NorthStar conducted this audit in a manner characterized by frank and open discussion of findings, conclusions and recommendations. NorthStar’s final report provides a comprehensive, independent and objective evaluation of current performance, specifically with respect to Avangrid’s governance and executive management, budgeting and finance, electric and gas operations", "source_page": null } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Affiliate / intercompany transactions", "Customer service & billing", "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Gas safety & pipeline integrity", "Information technology & systems", "Internal audit & internal controls", "Service reliability & vegetation management", "Storm cost recovery & securitization", "Tariff administration & oversight", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "IN", "source": "Indiana Utility Regulatory Commission", "doc_type": "fuel cost adjustment order", "id": "2025-01-29_northern-indiana-public-service_in-38706-fac145", "company": "Northern Indiana Public Service Company LLC", "company_raw": "Northern Indiana Public Service Company LLC", "docket": "38706 FAC 145", "docket_full": null, "issued_date": "2025-01-29", "source_page_url": "https://iurc.portal.in.gov/searchlegalcase/", "pdf_download_url": "https://www.in.gov/iurc/files/ord_38706FAC145_012925.pdf", "captured_at": "2026-06-02", "source_note": "Order of the Indiana Utility Regulatory Commission on the verified petition of Northern Indiana Public Service Company LLC (NIPSCO) for approval of a fuel cost adjustment for the February–April 2025 billing cycles under Ind. Code 8-1-2-42, IURC Cause No. 38706 FAC 145, issued January 29, 2025. Listed for reference (metadata-only). PDF at www.in.gov/iurc/files/; case search iurc.portal.in.gov.", "archived_via": null, "page_count": 17, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "Approval: $7,862,875 ", "summary": "is is $35,292,236 more than NIPSCO’s authorized amount of $407,403,229, which includes $399,540,354 approved in the applicable rate case, plus $7,862,875 of actual TDSIC operating income during the 12 months ended September 30, 2024. Since the Petitioner’s actual return exceeds the amount authorized", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $0.69 ", "summary": "will pay $201.92 (excluding taxes), which consists of $180.24 in base charges set in NIPSCO’s last approved rate case (Cause No. 45772), $0.69 in a fuel adjustment clause credit, and $20.99 in non-FAC trackers. 12. Fuel Cost Adjustment Factor. OUCC witness Eckert recommended the Commission ap", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "DC", "source": "Public Service Commission of the District of Columbia", "doc_type": "order on reconsideration", "id": "2025-01-28_potomac-electric-power_dc-fc1176-reconsideration", "company": "Potomac Electric Power Company (Pepco)", "company_raw": "Potomac Electric Power Company (Pepco)", "docket": "FC 1176", "docket_full": null, "issued_date": "2025-01-28", "source_page_url": "https://dcpsc.org/Newsroom/HotTopics/Rate-Case-Applications/FC1176.aspx", "pdf_download_url": "https://edocket.dcpsc.org/apis/api/Filing/download?attachId=217663&guidFileName=0b9bc398-bdee-4dae-b739-98414cf69ba0.pdf", "captured_at": "2026-06-02", "source_note": "Order of the Public Service Commission of the District of Columbia on applications for reconsideration of its Multiyear Rate Plan decision for Potomac Electric Power Company (Pepco), Formal Case No. 1176, issued January 28, 2025. Listed for reference (metadata-only). Source: DC PSC e-Docket, edocket.dcpsc.org (attachId 217663). DC PSC publishes on dcpsc.org (official US-government commission on .org, not .gov; admitted via the gov-guard's narrow .org allowlist).", "archived_via": null, "page_count": 46, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 3, "findings": [ { "index": 1, "title": "Approval: $63.4 million", "summary": "No. 22328 at 179-181. Order No. 22358 Page No. 33 ratemaking adjustments, culminating in a modified approved revenue requirement of $63.4 million for CY 2024, $99.6 million for CY 2025 and $123.4 million for CY 2026. 78. The Commission also observes that OPC has not identified any errors in the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $30 million", "summary": "emonstrate exactly what AOBA has argued, that the ERA is added to the GT-LV rates in advance of the approved revenue requirement, adding approximately $30 million in revenue to that rate class. As the majority concedes in Order No. 22328: “If Pepco’s forecasts were more accurate (acknowledging that ", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: agreement", "summary": "e Commission noted that “it was not until filing an application for reconsideration of the approved settlement agreement that GSA identified 21 specific issues for consideration.”116 The Commission further noted, in denying GSA’s reconsideration petition, that “GSA has", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "rate case testimony", "id": "2025-01-08_ameren-illinois_icc-25-0084-rate-base", "company": "Ameren Illinois Company", "company_raw": "Ameren Illinois Company", "docket": "25-0084", "docket_full": null, "issued_date": "2025-01-08", "source_page_url": "https://www.icc.illinois.gov/docket/P2025-0084/documents/360541", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2025-0084/documents/360541/files/631521.pdf", "captured_at": "2026-06-07", "source_note": "Direct Testimony (Exhibit 10.0) on behalf of Ameren Illinois Company d/b/a Ameren Illinois, witness Dylan W. D'Ascendis (ScottMadden, Inc.), regarding rate base and return on equity (ROE) in the Company's proposed general increase in rates for natural gas delivery service, ICC Docket 25-0084, filed January 8, 2025. Listed for reference (metadata-only). Source: ICC e-Docket, document 360541 / file 631521 (landing: www.icc.illinois.gov/docket/P2025-0084/documents/360541).", "archived_via": null, "page_count": 67, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "rate case application", "id": "2025-01-08_ameren-illinois_icc-25-0084-application", "company": "Ameren Illinois Company", "company_raw": "Ameren Illinois Company", "docket": "25-0084", "docket_full": null, "issued_date": "2025-01-08", "source_page_url": "https://www.icc.illinois.gov/docket/P2025-0084/documents/360541", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2025-0084/documents/360541/files/631501.pdf", "captured_at": "2026-06-07", "source_note": "Direct Testimony (Exhibit 1.0) on behalf of Ameren Illinois Company d/b/a Ameren Illinois in the Company's Proposed General Increase in Rates for natural gas delivery service, ICC Docket 25-0084, filed January 8, 2025. Listed for reference (metadata-only). Source: ICC e-Docket, document 360541 / file 631501 (landing: www.icc.illinois.gov/docket/P2025-0084/documents/360541).", "archived_via": null, "page_count": 20, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2025-01-06_tallgrass-pony-express-pipeline-llc_fa23-5", "company": "Tallgrass Pony Express Pipeline, LLC", "company_raw": "Tallgrass Pony Express Pipeline, LLC (FA23-5)", "docket": "FA23-5", "docket_full": "FA23-5-000", "issued_date": "2025-01-06", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20250106-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20250106-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 69, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to December 31, 2022", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Annual Cost of Service Based Analysis Schedule", "summary": "PXP’s Annual Cost of Service Based Analysis Schedule reported on Page 700 of its FERC Form No. 6 filings contained input and calculation errors, and inconsistencies with Opinion No. 154-B and other Commission guidance. These errors and inconsistencies affected the accuracy of most inputs on Page 700, which overstated PXP’s rate base and overall cost of service during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise and strengthen policies and procedures to ensure that Page 700 is prepared and reported in a manner consistent with Opinion No. 154-B and the instructions of the FERC Form No. 6. These policies and procedures should address each issue identified in the table.", "source_page": null }, { "number": 2, "text": "Train relevant staff on the revised policies and procedures and provide periodic training, as necessary, to ensure that each line item on Page 700 is calculated and reported correctly in accordance with Commission regulations.", "source_page": null }, { "number": 3, "text": "Perform an analysis to determine the impact on Page 700 resulting from the errors and inconsistencies identified in the table above, for each year, from 2019 to present. This analysis should be submitted to DAA within 90 days of the issuance of this report.", "source_page": null }, { "number": 4, "text": "Restate and footnote Page 700 of PXP’s 2019 FERC Form No. 6. For 2019, refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page 700. For the FERC Form No. 6 annual filings submitted subsequent to this audit report, ensure that corrections made to impacted accounts and inputs are properly reported in current year financial statements, including prior year corrected numbers, supporting schedules and Page 700. Also ensure appropriate footnote disclosures about the corrections made are included in the notes to the financial statements and other relevant pages of the FERC Form No. 6. Tallgrass Pony Express Pipeline, LLC Docket No. PA23-5-000", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Depreciation Rates and Dismantlement Charge", "summary": "PXP did not file and receive Commission approval for depreciation rates it used for calculating depreciation expense for some of its carrier property accounts. PXP also did not seek approval from the Commission to include a dismantlement charge, for decommissioning assets, in several carrier property accounts. PXP has applied these unapproved depreciation rates and the dismantlement charge to calculate depreciation expense since 2014. As a result, PXP was not in compliance with the Commission’s requirement to file for approval of these rates and charges within six months of acquiring property and to use only Commission-approved rates and charges to calculate depreciation expense.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Develop and implement policies and procedures to ensure that PXP uses approved rates for depreciation and dismantlement charge for its carrier property accounts. These policies and procedures should also ensure that those rates are timely filed with the Commission, in accordance with the six-month requirement set forth in General Instruction 1-8(b)(1).", "source_page": null }, { "number": 6, "text": "Update the 2014 depreciation study or consider completing a new depreciation study, including appropriate schedules to support the derivation of each depreciation rate, and to support the inclusion of a dismantlement charge, if PXP chooses to apply one, for carrier property accounts containing property that requires decommissioning at the end of its useful life.", "source_page": null }, { "number": 7, "text": "Based on the updated 2014 depreciation study or a new depreciation study, required in Recommendation 6, make a filing with the Commission requesting approval for carrier property accounts that were depreciated without an approved rate on file. Also make an explicit request for the approval of the dismantlement charge in the same filing or a separate filing.", "source_page": null }, { "number": 8, "text": "In the next FERC Form No. 6 annual filing, include a footnote disclosure to explain steps PXP has taken to comply with Commission regulations for depreciation rates as applicable to Recommendations 5-7 of this audit finding. Additionally, explain any changes or adjustments that were made to any existing depreciation rate because of the updated or new depreciation study.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 3, "title": "Property Unit Listing", "summary": "PXP did not maintain an appropriate property unit listing to use in accounting for additions and retirements of carrier property. Although PXP’s capitalization policy included a listing of the carrier property account numbers and names, it did not identify and describe what constituted property units for each carrier property account. This created challenges for audit staff in evaluating whether PXP consistently applied its property unit listing in accounting for additions and retirements of carrier property.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Revise policies and procedures to ensure that all property units are defined in PXP’s property unit listing and that PXP consistently applies its written property unit listing pursuant to 18 C.F.R. Part 352.", "source_page": null }, { "number": 10, "text": "Train relevant staff on the revised policies and procedures to its property unit listing and provide periodic training, as needed.", "source_page": null }, { "number": 11, "text": "Provide a copy of PXP’s revised property unit listing to DAA within 90 days of the issuance of this report.", "source_page": null }, { "number": 12, "text": "Review and update the fixed asset subledger to incorporate the policy and procedural changes discussed in this audit finding to ensure that all costs are properly capitalized and expensed prospectively in accordance with PXP’s revised property unit listing. Tallgrass Pony Express Pipeline, LLC Docket No. PA23-5-000", "source_page": null } ], "themes": [ "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 4, "title": "Industry Trade Association Dues", "summary": "PXP incorrectly recorded membership dues paid to the Liquid Energy Pipeline Association (LEPA) in an operating and maintenance (O&M) expense account, rather than in a general expense account, in 2020 and 2021. Further, for those same years, PXP improperly recorded the lobbying portion of membership dues paid to both LEPA and the American Petroleum Institute (API) in operating expense accounts rather than in a nonoperating expense account. Conversely, in 2022, PXP incorrectly recorded the full amount of membership dues paid to LEPA in a nonoperating expense account, rather than recording the lobbying portion in a nonoperating expense account and the remaining non-lobbying portion in a general expense account. Collectively, these errors resulted in PXP misstating the operating Tallgrass Pony Express Pipeline, LLC Docket No. PA23-5-000 expenses reported on Page 700, Line 1, and reduced the overall accuracy of the account information reported in PXP’s FERC Form No. 6 filings.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Update accounting policies and procedures to ensure that industry association dues, including the lobbying and non-lobbying portion of dues, are accounted for consistently with Commission requirements.", "source_page": null }, { "number": 14, "text": "Train relevant staff on updates made to accounting policies and procedures to ensure the proper classification of industry association dues, including the lobbying and non-lobbying portion of such dues and provide periodic training, as needed.", "source_page": null }, { "number": 15, "text": "For 2024, provide accounting support to show that PXP has corrected the accounting for all industry and trade association membership dues, including the accounting treatment for lobbying and non-lobbying portions of the invoiced amounts. This support should be submitted to DAA within 90 days of the issuance of this report.", "source_page": null } ], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting Misclassifications and Reporting", "summary": "PXP did not correctly account for certain costs on its books, which reduced the overall accuracy of the accounting and reporting of these items in PXP’s FERC Form No. 6 reports. D.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise policies and procedures to ensure that PXP accounts for and reports accurate information according to the Commission’s regulations and the instructions in the FERC Form No. 6. These policies and procedures should address all reporting deficiencies discussed in this finding, including those pertaining to DRA, depreciation, and the equity method of accounting.", "source_page": null }, { "number": 17, "text": "Train relevant staff regarding these revised policies and procedures and provide staff periodic training, as needed.", "source_page": null }, { "number": 18, "text": "Make a journal entry to account for the $2.7 million understatement in operating expenses associated with drag reducing agent. Provide a copy of the journal entries to DAA within 90 days of the issuance of this report. E.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "RI", "source": "Rhode Island Public Utilities Commission", "doc_type": "commission order", "id": "2025-01_rhode-island-energy_ri-24-38-ge-order-25247", "company": "The Narragansett Electric Company d/b/a Rhode Island Energy", "company_raw": "The Narragansett Electric Company d/b/a Rhode Island Energy", "docket": "24-38-GE", "docket_full": null, "issued_date": "2025-01-01", "source_page_url": "https://ripuc.ri.gov/utility-information/electric", "pdf_download_url": "https://ripuc.ri.gov/sites/g/files/xkgbur841/files/2025-01/RI%20Energy%2024-38-GE%20(AMF%20Opt-Out)%20Ord25247%201-2025.pdf", "captured_at": "2026-06-07", "source_note": "Rhode Island PUC Order No. 25247 (January 2025), Docket No. 24-38-GE — on The Narragansett Electric Company d/b/a Rhode Island Energy's tariff advice filing to amend its electric and gas tariffs (Advanced Metering Functionality opt-out charges) (8 pp). Listed for reference (metadata-only). Source: Rhode Island PUC (ripuc.ri.gov/sites/g/files/xkgbur841/files/2025-01/).", "archived_via": null, "page_count": 8, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-11-27_alliant-energy-corporate-services-inc_fa23-7", "company": "Alliant Energy Corporate Services, Inc.", "company_raw": "Alliant Energy Corporate Services, Inc. (FA23-7)", "docket": "FA23-7", "docket_full": "FA23-7-000", "issued_date": "2024-11-27", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20241127-3007&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20241127-3007", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 34, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "1", "60" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Service Company Allocation Factors", "summary": "AECS improperly allocated costs to both FERC-jurisdictional and non-jurisdictional entities, causing an error in accounting and reporting. As a result, WPL overcharged its wholesale power customers and IPL undercharged its wholesale power customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Lobbying Expenses", "summary": "AECS improperly recorded lobbying expenses in administrative and general (A&G) expense accounts, rather than recording the expenditures in Account 426.4, Expenditures for Certain Civic, Political and Related Activities. Due to AECS’s accounting misclassifications, these expenses were improperly accounted for and reported on the books of WPL and IPL. As a result, WPL and IPL overcharged their wholesale power customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 3, "title": "Electric Vehicle Charging Stations", "summary": "WPL incorrectly recovered a portion of the cost of distribution-related Electric Vehicle (EV) charging stations through its wholesale power formula rates. As a result, WPL overstated its wholesale power revenue requirements, which led to overbillings to wholesale power customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Donations", "summary": "AECS improperly recorded two donations totaling $10,000 in Account 921, Office Supplies and Expenses, rather than in Account 426.1, Donations. Due to the service company’s accounting misclassifications, these expenses were improperly accounted for and reported on the books of WPL and IPL. As a result, WPL and IPL included these amounts in wholesale power rate determinations and overcharged wholesale power customers. D. List of", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "DC", "source": "Public Service Commission of the District of Columbia", "doc_type": "multi-year rate plan order", "id": "2024-11-26_potomac-electric-power_dc-fc1176", "company": "Potomac Electric Power Company (Pepco)", "company_raw": "Potomac Electric Power Company (Pepco)", "docket": "FC 1176", "docket_full": null, "issued_date": "2024-11-26", "source_page_url": "https://dcpsc.org/Newsroom/HotTopics/Rate-Case-Applications/FC1176.aspx", "pdf_download_url": "https://edocket.dcpsc.org/apis/api/Filing/download?attachId=214935&guidFileName=ebccb9f7-667d-4758-af81-1489de100f91.pdf", "captured_at": "2026-06-02", "source_note": "Order and Opinion of the Public Service Commission of the District of Columbia in the application of Potomac Electric Power Company (Pepco) for authority to implement a Multiyear Rate Plan for electric distribution service, Formal Case No. 1176, issued November 26, 2024 (approved a modified plan well below the ~$190.7M request; later vacated/remanded by the DC Court of Appeals). Listed for reference (metadata-only). Source: DC PSC e-Docket, edocket.dcpsc.org (attachId 214935). The DC PSC publishes on dcpsc.org (an official US-government commission that uses .org, not .gov; admitted via the gov-guard's narrow .org allowlist — see ISSUES.md).", "archived_via": null, "page_count": 194, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 9, "findings": [ { "index": 1, "title": "Disallowance: $18 million", "summary": "ny’s proposed revenue requirement.426 218. In its Rebuttal Testimony, Pepco opposes AOBA’s proposed $18 million disallowance of projected CapEx from the revenue requirement in 2023 through 2026 for ITN 420 See generally, Pepco (H)-2 (Cantler Direct Exhibit). 421 AOBA (A", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Disallowance: $848,000.463", "summary": "of rate base. The adjustment reduces rate base by $5.3 million and increases operating expenses by $848,000.463 233. The Commission agrees with OPC’s position to deny Pepco RMA-15. Pepco does not raise any new arguments that persuade the Commission to change the basis for its prior decision in Forma", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 3, "title": "Approval: $167.3 million", "summary": "pend would ultimately be allocated to Pepco’s DC distribution rates.425 As such, AOBA’s proposed disallowance of $167.3 million is flawed for multiple reasons, not least because a large portion of the proposed disallowed costs are not even included in the Company’s proposed re", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $77\nmillion", "summary": "period by approximately $211 million (28%). This reduction is achieved by reducing plant additions approved for recover in this Order by $77 million in 2025 and by $134 million in 2026. This adjustment results in an overall reduction in rate 544 All Commission adopted RMA’s are formatted “RMA-(#)”", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $3,228.6 million", "summary": "proposed rate base adjustments, no party contests the methodology. Based on the Commission’s final approved rate base of $3,228.6 million, and $3,302.7 million, and 5.02% and 5.04% approved cost of debt for 2025 and 2026, respectively. RMA 28 reduces revenue requirement by $43 million i", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 6, "title": "Settlement: Agreement", "summary": "ted recovery period. 223. RMA Pepco-12 Reflection of Benning Insurance Proceeds. As outlined in the Settlement Agreement in Formal Case Nos. 1150 and 1151, Pepco has been pursuing recovery of insurance proceeds and agreed to return these funds to customers through rates", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: Agreement", "summary": "ng to return to customers. Pepco determined that $0.785 million was charged through rates after the Settlement Agreement until the time that regulatory asset amortization was paused upon the Commission’s approval of the Formal Case No. 1156 Modified 436 Pepco (B) (Lemin", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Settlement: agreement", "summary": "pco (3B) (Leming Rebuttal) at 25:16-18. Order No. 22328 Page 81 The Company’s reference to the EDIT Settlement agreement is misplaced. The NP EDIT agreed to in Formal Case No. 1150 did not address the PHISCO deferred income tax balances; it only addressed the Pepco bala", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: agreement", "summary": "dy was filed in 2017 in Formal Case No. 1139, and the current depreciation rates were approved in a settlement agreement in that case.620 354. Pepco proposes to follow recent Commission precedent and adopt the Financial Accounting Standards No. 143 method of calculating", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true } ], "structured": false, "themes": [ "Cost of service & rates", "Depreciation" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "VA", "source": "Virginia State Corporation Commission", "doc_type": "biennial review final order (earnings test / cost disallowance findings)", "id": "2024-11-20_appalachian-power_va-pur-2024-00024-biennial-review", "company": "Appalachian Power Company", "company_raw": "Appalachian Power Company", "docket": "PUR-2024-00024", "docket_full": null, "issued_date": "2024-11-20", "source_page_url": "https://www.scc.virginia.gov/docketsearch", "pdf_download_url": "https://www.scc.virginia.gov/docketsearch/DOCS/82my01!.PDF", "captured_at": "2026-06-08", "source_note": "Virginia SCC Final Order in the first biennial review of Appalachian Power Company, Case No. PUR-2024-00024, issued 2024-11-20 (§56-585.8). Found actual ROE below authorized. PDF: scc.virginia.gov/docketsearch/DOCS/82my01!.PDF. Source: SCC DocketSearch portal.", "archived_via": null, "page_count": 22, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "TX", "source": "Public Utility Commission of Texas", "doc_type": "preliminary order", "id": "2024-11-14_el-paso-electric_puct-57149-preliminary-order", "company": "El Paso Electric Company", "company_raw": "El Paso Electric Company", "docket": "57149", "docket_full": null, "issued_date": "2024-11-14", "source_page_url": "https://interchange.puc.texas.gov/search/documents/?controlNumber=57149&itemNumber=34", "pdf_download_url": "https://interchange.puc.texas.gov/Documents/57149_34_1442512.PDF", "captured_at": "2026-06-01", "source_note": "Preliminary Order of the Public Utility Commission of Texas identifying the issues (including prudence of fuel and purchased-power costs) in El Paso Electric Company's application to reconcile Texas-jurisdictional fuel, fuel-related, and purchased-power expenses for the reconciliation period April 1, 2022 through March 31, 2024. PUC Docket No. 57149 / SOAH Docket No. 473-25-05084, filed November 14, 2024. Listed for reference (metadata-only). Source: PUCT Interchange, document interchange.puc.texas.gov/Documents/57149_34_1442512.PDF.", "archived_via": null, "page_count": 11, "scanned_pages": [ 1 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2024-11-07_national-fuel-gas-distribution_pa-mo-audit", "company": "National Fuel Gas Distribution Corporation", "company_raw": "National Fuel Gas Distribution Corporation", "docket": "D-2023-3040107", "docket_full": null, "issued_date": "2024-11-07", "source_page_url": "https://www.puc.pa.gov/press-release/2024/puc-issues-management-and-operations-audit-for-national-fuel-gas-distribution-corporation-11-07-2024", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1855524.pdf", "captured_at": "2026-06-08", "source_note": "Management & Operations Audit issued by the PA PUC Bureau of Audits (cover: 'Issued October 2024'); PUC publication 2024-11-07; 23 recommendations. PDF: puc.pa.gov/pcdocs/1855524.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 106, "scanned_pages": [ 1, 106 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 11, "findings": [ { "index": 1, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Expand NFG Co.’s Board of Directors’ expertise in key skills and a variety of strategic priorities outside the natural gas industry.", "source_page": 22 }, { "number": 2, "text": "Implement a requirement that NFG Co.’s directors must formally submit signed acknowledgements of the Code of Business Conduct and Ethics, Statements of Disclosure, and Insider Trading Policy, annually.", "source_page": 22 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 2, "title": "Affiliated Interests and Cost Allocations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Update the appropriate affiliated interest agreement(s) to include a description of the emergency transfer of trucks and/or equipment during the normal course of business; however, non-emergency transfers of trucks and/or equipment, in excess of $10,000, require advance approval by the PA PUC.", "source_page": 29 }, { "number": 4, "text": "Conduct periodic market studies to support reasonableness of transactions with affiliates.", "source_page": 31 }, { "number": 5, "text": "Develop and implement a routine internal audit schedule that provides ongoing review of every department using indirect/common cost allocation and consider a periodic third-party consultant study of the entire indirect/common cost allocation process for optimal control.", "source_page": 32 }, { "number": 6, "text": "Revise the Service Agreement and Cost Allocation Manual with consistent terms and detail and then submit to the PA PUC for approval.", "source_page": 33 } ], "themes": [ "Affiliate / intercompany transactions", "Internal audit & internal controls" ], "cost_to_customers": true }, { "index": 3, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise the Dividend Policy to include advance notification to the PA PUC for any dividend payments by NFGDC-PA which would exceed 85% of net income.", "source_page": 40 }, { "number": 8, "text": "Analyze and improve the billing process to reduce billing lag and decrease associated interest expense.", "source_page": 42 } ], "themes": [ "Customer service & billing", "Dividend policy & capital management" ], "cost_to_customers": false }, { "index": 4, "title": "Gas Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Modernize the geographic information system and optimize the mapping tool interface and proactively verify historical infrastructure records to improve mapping accuracy.", "source_page": 49 } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Gas Operations (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Acquire and implement automated metering technology.", "source_page": 51 }, { "number": 11, "text": "Discontinue collecting physical forms of payment on customers’ premises.", "source_page": 53 } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Track billing adjustments by reason to identify potential process improvements to decrease the number of billing adjustments.", "source_page": 59 }, { "number": 13, "text": "Submit a supplement to revise tariff language regarding residential security deposits to ensure ample information is available for customers and applicants.", "source_page": 60 }, { "number": 14, "text": "Evaluate the effectiveness of current, while researching additional, outreach efforts to focus on the most effective outreach strategies and rigorously evaluate vendor performance to ensure optimal support.", "source_page": 61 } ], "themes": [ "Tariff administration & oversight", "Customer service & billing" ], "cost_to_customers": false }, { "index": 7, "title": "Purchasing and Materials Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Develop and implement procedures to control rolling stock to ensure accuracy of work order accounting and mapping records and to impede theft and/or material misuse.", "source_page": 66 }, { "number": 16, "text": "Develop and implement a quantitative goal for annual diverse spend considering a component of year-over-year improvement.", "source_page": 68 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 8, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Designate an individual or group to provide oversight over and develop a centralized emergency response guiding document repository.", "source_page": 72 }, { "number": 18, "text": "Identify safety and/or security measures needed at each NFGDC-PA facility and install the appropriate equipment.", "source_page": 73 } ], "themes": [ "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "index": 9, "title": "Human Resources and Diversity", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Conduct periodic salary surveys for all hourly positions to ensure offering competitive compensation to attract and retain this workforce segment.", "source_page": 80 }, { "number": 20, "text": "Reduce chronic absenteeism through the enhancement and consistent enforcement of sick leave policies and identify union contract terms that are incompatible with these policies to revise during the next contract renegotiation.", "source_page": 82 } ], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Human Resources and Diversity (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Analyze safety incident root cause data to identify areas of improvement for training and safety programs and enhance enforcement procedures to appropriately motivate employee compliance.", "source_page": 85 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 11, "title": "Information Technology", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Conduct information technology focused end-user surveys to gauge satisfaction and collect feedback to determine potential areas of improvement.", "source_page": 93 }, { "number": 23, "text": "Implement the information technology improvement strategy to improve NFG Co.’s performance on future routine third-party maturity assessments.", "source_page": 94 } ], "themes": [ "Information technology & systems" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Customer service & billing", "Dividend policy & capital management", "Emergency preparedness & business continuity", "Information technology & systems", "Internal audit & internal controls", "Inventory, materials & fleet", "Tariff administration & oversight", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "UT", "source": "Public Service Commission of Utah", "doc_type": "energy balancing account audit report", "id": "2024-11-05_rocky-mountain-power_ut-24-035-01-eba-audit-cy2023", "company": "Rocky Mountain Power (PacifiCorp)", "company_raw": "Rocky Mountain Power (PacifiCorp)", "docket": "24-035-01", "docket_full": null, "issued_date": "2024-11-05", "source_page_url": "https://psc.utah.gov/electric/orders-notices/electric-2025/", "pdf_download_url": "https://pscdocs.utah.gov/electric/24docs/2403501/336428DPUExhbt2.2DirEBAAdtRprtCY202311-5-2024.pdf", "captured_at": "2026-06-07", "source_note": "Energy Balancing Account (EBA) Audit for Rocky Mountain Power for Calendar Year 2023 by Daymark Energy Advisors (filed Nov 5, 2024 as a Utah Division of Public Utilities exhibit), Docket No. 24-035-01 — an independent audit of the prudence/recovery of RMP's net power (fuel & purchased-power) costs trued up through the EBA; the Commission's Feb 25, 2025 order in this docket disallowed ~$19.4M (Washington Climate Commitment Act compliance costs) (8 pp). Listed for reference (metadata-only). Source: Utah PSC document repository (pscdocs.utah.gov/electric/24docs/2403501/).", "archived_via": null, "page_count": 8, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "SC", "source": "Public Service Commission of South Carolina", "doc_type": "fuel cost prudence review order", "id": "2024-10-30_duke-energy-carolinas_sc-2024-3-e-fuel-order", "company": "Duke Energy Carolinas, LLC", "company_raw": "Duke Energy Carolinas, LLC", "docket": "2024-3-E", "docket_full": null, "issued_date": "2024-10-30", "source_page_url": "https://dms.psc.sc.gov/Web/Dockets/Detail/118763", "pdf_download_url": "https://dms.psc.sc.gov/Attachments/Order/80623761-72e1-4c1e-9a82-4675bdfe57c0", "captured_at": "2026-06-19", "source_note": "Order No. 2024-727 Approving Adjustment in Fuel Cost Recovery Factors in Duke Energy Carolinas, LLC's Annual Review of Base Rates for Fuel Costs, before the Public Service Commission of South Carolina, Docket No. 2024-3-E, issued October 30, 2024; 30 pp. Listed for reference (metadata-only). Source: SC PSC Document Management System, Order 80623761-72e1-4c1e-9a82-4675bdfe57c0 (docket landing: dms.psc.sc.gov/Web/Dockets/Detail/118763).", "archived_via": null, "page_count": 30, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "FL", "source": "Florida Public Service Commission", "doc_type": "final order on storm cost recovery", "id": "2024-10-24_florida-iou_fl-20240010-ei-psc-2024-0459-fof-ei", "company": "Florida investor-owned electric utilities (storm protection plan cost recovery)", "company_raw": "Florida investor-owned electric utilities (storm protection plan cost recovery)", "docket": "20240010-EI", "docket_full": null, "issued_date": "2024-10-24", "source_page_url": "https://www.psc.state.fl.us/document-detail?orderNum=PSC-2024-0459-FOF-EI", "pdf_download_url": "https://www.psc.state.fl.us/library/Orders/2024/09666-2024.pdf", "captured_at": "2026-06-07", "source_note": "Florida PSC Order No. PSC-2024-0459-FOF-EI (Final Order), Docket No. 20240010-EI, 'Storm protection plan cost recovery clause', issued October 24, 2024 (16 pp) — the Commission's annual review of storm-protection-plan cost recovery, setting the 2025 storm-protection cost-recovery factors for Florida's investor-owned electric utilities. Listed for reference (metadata-only). Source: Florida PSC document clerk, document 09666-2024 (psc.state.fl.us/library/Orders/2024/09666-2024.pdf).", "archived_via": null, "page_count": 16, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NJ", "source": "New Jersey Board of Public Utilities", "doc_type": "base-rate case order", "id": "2024-10-09_public-service-electric-gas_nj-er23120924", "company": "Public Service Electric and Gas Company", "company_raw": "Public Service Electric and Gas Company", "docket": "ER23120924 / GR23120925", "docket_full": null, "issued_date": "2024-10-09", "source_page_url": "https://publicaccess.bpu.state.nj.us/", "pdf_download_url": "https://www.nj.gov/bpu/pdf/boardorders/2024/20241009/2A%20ORDER%20PS%2023%20BRC.pdf", "captured_at": "2026-06-02", "source_note": "Order Adopting Initial Decision and Stipulation in the petition of Public Service Electric and Gas Company (PSE&G) for an increase in electric and gas base rates, NJ BPU Docket Nos. ER23120924 (electric) and GR23120925 (gas) / OAL PUC 00926-24, issued at the October 9, 2024 agenda meeting. Listed for reference (metadata-only). PDF on the BPU board-orders host www.nj.gov/bpu/pdf/boardorders/2024/20241009/; docket system: publicaccess.bpu.state.nj.us (Imperva-protected — the static board-order PDF is the fetched source).", "archived_via": null, "page_count": 504, "scanned_pages": [ 17, 65, 410 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-09-27_southern-indiana-gas-and-electric-company_fa23-4", "company": "Southern Indiana Gas and Electric Company", "company_raw": "Southern Indiana Gas and Electric Company (FA23-4)", "docket": "FA23-4", "docket_full": "FA23-4-000", "issued_date": "2024-09-27", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240927-3006&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240927-3006", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 63, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 through December 31, 2023", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Accounting for Merger Costs", "summary": "SIGECO incorrectly included $24.3 million of merger costs in wholesale transmission formula rate service cost determinations, contrary to the directives of the 2018 Merger Order. As a result, SIGECO overstated its wholesale transmission revenue requirement by approximately $2.3 million and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Update policies and procedures to ensure SIGECO accurately excludes all merger costs from its transmission formula rate, as required by the hold harmless provisions in the 2018 Merger Order.", "source_page": null }, { "number": 2, "text": "Provide training to its staff on the revised policies and procedures for tracking and excluding all merger costs from the computation of the ATRR. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Perform a comprehensive analysis to identify all merger related costs recorded in SIGECO’s books during the hold harmless commitment period.", "source_page": null }, { "number": 4, "text": "Submit a refund analysis, within 90 days of receiving the final audit report, to DAA that explains and details the following: (1) the calculation of refunds that resulted from correcting for the improper inclusion of merger related costs in wholesale transmission formula rates, plus interest; (2) the determinative components of the refund; (3) the refund method; (4) customers to receive refunds; and (5) the period(s) in which refunds will be made.", "source_page": null }, { "number": 5, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 6, "text": "Refund amounts disclosed in the refund report to transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Allowance for Funds Used During Construction", "summary": "SIGECO improperly calculated its AFUDC rate. Specifically, SIGECO: (1) incorrectly calculated its long-term debt cost rate; (2) used Generally Accepted Accounting Principles (GAAP) amounts for the prior year long-term debt and equity balances instead of FERC Form No. 1 balances; (3) did not properly update its short-term debt and CWIP prior year-end balances used in the AFUDC calculation; and (4) incorrectly calculated and reported its Accumulated Deferred Income Tax on equity AFUDC. Additionally, SIGECO recorded a portion of equity AFUDC in Account 419, Interest and Dividend Income, instead of in Account 419.1, Allowance for Other Funds used During Construction. As a result, SIGECO over accrued AFUDC included in utility plant accounts and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise and implement policies and procedures to calculate the AFUDC rate consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 8, "text": "Revise and implement policies and procedures to properly calculate and record equity AFUDC ADIT.", "source_page": null }, { "number": 9, "text": "Provide training to relevant staff on the revised policies and procedures for calculating the AFUDC rate. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 10, "text": "Recalculate accrued AFUDC consistent with the Commission’s accounting requirements from 2019 through the date of the audit report and submit the recalculations to DAA for review within 60 days of this report.", "source_page": null }, { "number": 11, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over accrual of AFUDC within 60 days of the date of the audit report.", "source_page": null }, { "number": 12, "text": "Revise CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over accrual of AFUDC after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 11.", "source_page": null }, { "number": 13, "text": "Submit a refund analysis, within 90 days of the date of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from excess AFUDC and its impacts on related accounts included in SIGECO’s transmission formula rate during the audit period, plus interest; (2) the determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) the period(s) in which refunds will be made.", "source_page": null }, { "number": 14, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 15, "text": "Refund the amounts disclosed in the refund report to transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "AFUDC / cost of capital", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 3, "title": "Operating Expense Accounting Misclassifications", "summary": "SIGECO recorded approximately $4.4 million in various A&G expense accounts in a manner contrary to the Commission’s accounting regulations. This improper accounting resulted in SIGECO overstating its ATRR by approximately $440,000 and overbilling its wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise policies and procedures to properly account for operating expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 17, "text": "Provide training to relevant staff on the revised policies and procedures for properly accounting for operating expenses. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 18, "text": "Perform an analysis of A&G expense accounts to identify costs that were improperly accounted for and included in SIGECO’s ATRR and customer billings during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 19, "text": "Perform an analysis of capital work orders to determine that AFUDC was not accrued on an asset purchase. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 20, "text": "Submit a refund analysis to DAA, within 90 days of receiving the audit report, that explains and details the following: (1) calculation of refunds resulting from inappropriate recoveries due to the improper accounting for expenses recorded in A&G accounts during the audit period, identified through completing Recommendations 18 and 19, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) the period(s) in which refunds will be made.", "source_page": null }, { "number": 21, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 22, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations. Non-operating Expense Accounting Misclassifications", "source_page": null }, { "number": 23, "text": "Revise policies and procedures to properly account for non-operating expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 24, "text": "Provide training to relevant staff on the revised processes and procedures for properly accounting for non-operating expenses. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 25, "text": "Perform an analysis of A&G expense accounts to identify non-operating expenses that were improperly accounted for and included in SIGECO’s ATRR and the related customer billings during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 26, "text": "Submit a refund analysis to DAA, within 90 days of receiving the audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting for non-operating expenses recorded in A&G accounts during the audit period, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) the period(s) in which refunds will be made.", "source_page": null }, { "number": 27, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 28, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Non-Operating Expense Accounting Misclassifications", "summary": "SIGECO recorded approximately $364,000 in various non-operating expenses in a manner contrary to the Commission’s accounting regulations. The improper accounting resulted in SIGECO overstating its ATRR by approximately $36,400 and overbilling its wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 5, "title": "Materials and Supplies", "summary": "SIGECO improperly reported construction-related materials and supplies in its FERC Form No. 1. The improper reporting resulted in SIGECO overstating its ATRR and overbilling its wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Revise policies and procedures to account for and report materials and supplies consistent with Commission accounting requirements.", "source_page": null }, { "number": 30, "text": "Provide training to relevant staff on the revised processes and procedures for properly accounting for and reporting materials and supplies on FERC Form No.", "source_page": null }, { "number": 1, "text": "Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 31, "text": "Perform an analysis of the materials and supplies account to identify expenses that were improperly accounted for and included in SIGECO’s ATRR and the related customer billings during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 32, "text": "Submit a refund analysis to DAA, within 90 days of receiving the audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting and reporting of materials and supplies during the audit period, plus interest; (2) determinative components of the refund; (3) refund method (4) customers to receive refunds; and (5); the period(s) in which refunds will be made.", "source_page": null }, { "number": 33, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 34, "text": "Refund the amounts disclosed in the refund report to transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Excess Accumulated Deferred Income Tax", "summary": "SIGECO improperly netted the excess and deficient ADIT related to the corporate tax rate change and associated adjustments required due to the Tax Cuts and Jobs Act (TCJA) of 2017 and recorded the amount that resulted from this improper netting in Account 254, Other Regulatory Liabilities. This affected the transparency and accuracy of the regulatory liability amounts reported in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Revise accounting policies and procedures to properly account for and report the effect of changes in tax laws or tax rates consistent with Commission accounting requirements.", "source_page": null }, { "number": 36, "text": "Submit correcting journal entries, within 60 days of issuance of this audit report, with proposed accounting entries and supporting documentation to DAA that reflect corrections to recorded excess and deficient ADIT in the appropriate USofA accounts.", "source_page": null }, { "number": 37, "text": "Provide training to relevant staff on the revised policies and procedures for accounting for and reporting the effect of changes in tax laws or tax rates. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 7, "title": "FERC Form No. 1 Reporting", "summary": "SIGECO did not properly follow the FERC Form No. 1 page instructions and, therefore, did not accurately report all required information in certain pages of its FERC Form No. 1 filings. These actions affected the transparency, accuracy, and usefulness of the affected pages of the FERC Form No. 1 filings. D.", "is_other_matter": false, "recommendations": [ { "number": 38, "text": "Revise and strengthen policies, procedures, and practices to report correct, accurate, complete information in the FERC Form No. 1 consistent with the page instructions of the form. Include footnotes when software limitations prevent reporting complete information.", "source_page": null }, { "number": 39, "text": "Provide training to relevant staff on the revised FERC Form No. 1 policies, procedures, and practices. Also, develop a training program that supports the provision of periodic training in this area, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "MI", "source": "MI Public Service Commission (Liberty Consulting Group)", "doc_type": "distribution reliability audit — Part Two (programs & operations)", "id": "2024-09-23_dte-electric_mi-distribution-audit-part2", "company": "DTE Electric Company", "company_raw": "DTE Electric Company", "docket": "U-21305", "docket_full": null, "issued_date": "2024-09-23", "source_page_url": "https://www.michigan.gov/mpsc/commission/news-releases/2024/09/23/mpsc-releases-utility-audit-results-of-states-two-largest-electric-utilities", "pdf_download_url": "https://www.michigan.gov/mpsc/-/media/Project/Websites/mpsc/regulatory/reports/3rdparty/DTE-Energy-Part-Two-Report.pdf", "captured_at": "2026-06-01", "source_note": "Final Report — Utility Distribution Audit of DTE Energy, Part Two, by The Liberty Consulting Group for the Michigan PSC (Case U-21305); results released 2024-09-23. (Metadata-only: Liberty Consulting audit uses narrative-based findings format, not consolidated findings list. See docs/MI_PARSER_REFINEMENT_PHASED_PLAN.md Phase 1 analysis.)", "archived_via": null, "page_count": 157, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "MI", "source": "MI Public Service Commission (Liberty Consulting Group)", "doc_type": "distribution reliability audit — Part One (infrastructure)", "id": "2024-09-23_dte-electric_mi-distribution-audit-part1", "company": "DTE Electric Company", "company_raw": "DTE Electric Company", "docket": "U-21305", "docket_full": null, "issued_date": "2024-09-23", "source_page_url": "https://www.michigan.gov/mpsc/commission/news-releases/2024/09/23/mpsc-releases-utility-audit-results-of-states-two-largest-electric-utilities", "pdf_download_url": "https://www.michigan.gov/mpsc/-/media/Project/Websites/mpsc/regulatory/reports/3rdparty/DTE-Energy-Part-One-Report.pdf", "captured_at": "2026-06-01", "source_note": "Final Report — Utility Distribution Audit of DTE Energy, Part One, by The Liberty Consulting Group for the Michigan PSC (Case U-21305); results released 2024-09-23. (Metadata-only: Liberty Consulting audit uses narrative-based findings format, not consolidated findings list. See docs/MI_PARSER_REFINEMENT_PHASED_PLAN.md Phase 1 analysis.)", "archived_via": null, "page_count": 94, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "MI", "source": "MI Public Service Commission (Liberty Consulting Group)", "doc_type": "distribution reliability audit — Part Two (programs & operations)", "id": "2024-09-23_consumers-energy_mi-distribution-audit-part2", "company": "Consumers Energy Company", "company_raw": "Consumers Energy Company", "docket": "U-21305", "docket_full": null, "issued_date": "2024-09-23", "source_page_url": "https://www.michigan.gov/mpsc/commission/news-releases/2024/09/23/mpsc-releases-utility-audit-results-of-states-two-largest-electric-utilities", "pdf_download_url": "https://www.michigan.gov/mpsc/-/media/Project/Websites/mpsc/regulatory/reports/3rdparty/Consumers-Energy-Part-Two-Report.pdf", "captured_at": "2026-06-01", "source_note": "Final Report — Utility Distribution Audit of Consumers Energy, Part Two, by The Liberty Consulting Group for the Michigan PSC (Case U-21305); results released 2024-09-23. (Metadata-only: Liberty Consulting audit uses narrative-based findings format, not consolidated findings list. See docs/MI_PARSER_REFINEMENT_PHASED_PLAN.md Phase 1 analysis.)", "archived_via": null, "page_count": 148, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "MI", "source": "MI Public Service Commission (Liberty Consulting Group)", "doc_type": "distribution reliability audit — Part One (infrastructure)", "id": "2024-09-23_consumers-energy_mi-distribution-audit-part1", "company": "Consumers Energy Company", "company_raw": "Consumers Energy Company", "docket": "U-21305", "docket_full": null, "issued_date": "2024-09-23", "source_page_url": "https://www.michigan.gov/mpsc/commission/news-releases/2024/09/23/mpsc-releases-utility-audit-results-of-states-two-largest-electric-utilities", "pdf_download_url": "https://www.michigan.gov/mpsc/-/media/Project/Websites/mpsc/regulatory/reports/3rdparty/Consumers-Energy-Part-One-Report.pdf", "captured_at": "2026-06-01", "source_note": "Final Report — Utility Distribution Audit of Consumers Energy, Part One, by The Liberty Consulting Group for the Michigan PSC (Case U-21305); results released 2024-09-23. (Metadata-only: Liberty Consulting audit uses narrative-based findings format, not consolidated findings list. See docs/MI_PARSER_REFINEMENT_PHASED_PLAN.md Phase 1 analysis.)", "archived_via": null, "page_count": 88, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "VA", "source": "Virginia State Corporation Commission", "doc_type": "rate adjustment clause order", "id": "2024-09-04_virginia-electric-power_pur-2024-00137", "company": "Virginia Electric and Power Company (Dominion Energy Virginia)", "company_raw": "Virginia Electric and Power Company (Dominion Energy Virginia)", "docket": "PUR-2024-00137", "docket_full": null, "issued_date": "2024-09-04", "source_page_url": "https://www.scc.virginia.gov/docketsearch", "pdf_download_url": "https://www.scc.virginia.gov/docketsearch/DOCS/816l01!.PDF", "captured_at": "2026-06-01", "source_note": "Order for Notice and Hearing on Virginia Electric and Power Company's (Dominion Energy Virginia) petition for a new distribution rate adjustment clause Rider DIST (grid-transformation cost recovery) and consolidation of Riders GT and U under Va. Code § 56-585.1 A 6 and A 7, Case No. PUR-2024-00137, Virginia State Corporation Commission, entered September 4, 2024. Listed for reference (metadata-only). Source: SCC DocketSearch, document www.scc.virginia.gov/docketsearch/DOCS/816l01!.PDF.", "archived_via": null, "page_count": 20, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "RI", "source": "Rhode Island Public Utilities Commission", "doc_type": "gas cost recovery filing", "id": "2024-09_rhode-island-energy_ri-24-29-ng-gas-cost-recovery", "company": "The Narragansett Electric Company d/b/a Rhode Island Energy", "company_raw": "The Narragansett Electric Company d/b/a Rhode Island Energy", "docket": "24-29-NG", "docket_full": null, "issued_date": "2024-09-01", "source_page_url": "https://ripuc.ri.gov/events-and-actions/decisions-and-orders/natural-gas", "pdf_download_url": "https://ripuc.ri.gov/sites/g/files/xkgbur841/files/2024-09/24-29-NG%20Gas%20Cost%20Recovery%20Book%201.pdf", "captured_at": "2026-06-07", "source_note": "The Narragansett Electric Company d/b/a Rhode Island Energy 2024 Gas Cost Recovery (GCR) filing (Book 1: Pre-Filed Direct Testimony and Attachments), Docket No. 24-29-NG, filed Sept 1, 2024 — the annual reconciliation/recovery of projected gas commodity costs under the Gas Cost Recovery Clause (RIPUC RIE-GAS No. 101) for the period beginning Nov 1, 2024 (177 pp). Listed for reference (metadata-only). Source: Rhode Island PUC (ripuc.ri.gov/sites/g/files/xkgbur841/files/2024-09/).", "archived_via": null, "page_count": 177, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 5, "findings": [ { "index": 1, "title": "Approval: $91,260,074\n", "summary": "$0 $0 $0 $0 $0 $0 (5) Plus: Supply Related LNG O&M Costs $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 (6) Allowable Working Capital Costs $91,260,074 (7) Number of Days Lag 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 (8) Working Capital Requirement (9) Weighted Average Co", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $9,002,911 ", "summary": "$0 $0 $0 $0 $0 (21) Plus: Supply Related LNG O&M Costs $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 (22) Allowable Working Capital Costs $9,002,911 $17,740,363 $23,348,504 $19,187,157 $14,298,113 $5,801,939 $3,365,355 $2,249,232 $1,905,760 $1,982,445 $1,989,370 $3,622,063 $104,493,212 (23) Number", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $23,806,638\n", "summary": "$0 $0 $0 $0 $0 (36) Plus: Supply Related LNG O&M Costs $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 (37) Allowable Working Capital Costs $23,806,638 (38) Number of Days Lag 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 32.92 (39) Working Capital Requirement (40) Weighted Average", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $1,089,461 ", "summary": "72,885) ($174,431) ($787,885) ($3,328,078) ($8,360,951) ($7,653,525) ($4,156,160) ($25,707,398) (5) Allowable Working Capital Costs $1,089,461 $5,193,444 $5,634,365 $5,400,060 $5,517,845 $5,668,654 $6,059,056 $6,262,313 $6,371,400 $6,299,336 $6,087,882 $6,230,292 $65,814,108 (6) Number of Day", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $5,606,412 ", "summary": "0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 (19)Total Adjustments $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 (20)Allowable Working Capital Costs $5,606,412 $3,486,113 $3,238,095 $2,661,004 $2,716,763 $2,677,824 $3,383,133 $9,959,991 $11,721,411 $23,053,617 $14,391,166 $11,932,267 $94,827,797 (21)Number of", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "SC", "source": "Public Service Commission of South Carolina", "doc_type": "fuel-cost audit testimony (ORS)", "id": "2024-08-29_duke-energy-carolinas_sc-2024-3-e-ors-fuel-audit-testimony", "company": "Duke Energy Carolinas, LLC", "company_raw": "Duke Energy Carolinas, LLC", "docket": "2024-3-E", "docket_full": null, "issued_date": "2024-08-29", "source_page_url": "https://dms.psc.sc.gov/Web/Dockets/Detail/118763", "pdf_download_url": "https://dms.psc.sc.gov/Attachments/Matter/1474abd1-c4b6-429f-9dcb-4832750064db", "captured_at": "2026-06-19", "source_note": "Direct Testimony and Exhibits of Anthony D. Briseno (Senior Audit Manager) on behalf of the South Carolina Office of Regulatory Staff in Duke Energy Carolinas' Annual Review of Base Rates for Fuel Costs, Docket No. 2024-3-E, filed August 29, 2024; 25 pp. ORS fuel-cost audit work. Listed for reference (metadata-only). Source: SC PSC Document Management System, Matter 1474abd1-c4b6-429f-9dcb-4832750064db (docket landing: dms.psc.sc.gov/Web/Dockets/Detail/118763).", "archived_via": null, "page_count": 25, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-08-22_black-hills-corporation_pa23-3", "company": "Black Hills Corporation", "company_raw": "Black Hills Corporation (PA23-3)", "docket": "PA23-3", "docket_full": "PA23-3-000", "issued_date": "2024-08-22", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240822-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240822-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 23, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to November 30, 2023", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 3, "findings": [ { "index": 1, "title": "Load Forecast Data", "summary": "The Black Hills Electric Utilities did not post their load forecasts on a daily basis, including underlying assumptions and daily peak load for the prior day. As a result, there was a lack of transparency and information on transmission system conditions, which may have impacted transmission customers and their transmission activities.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Perform a review of the automated process to determine why the transfer of load forecast data to OASIS stopped working and make corrections, as needed. Provide a report to audit staff that summarizes the results of this review.", "source_page": null }, { "number": 2, "text": "Post load forecast data since January 2022 on their respective OASIS sites.", "source_page": null }, { "number": 3, "text": "Develop and implement procedures and controls to ensure that the Black Hills Electric Utilities are timely posting all required information to OASIS, including load forecast data, underlying assumptions, and daily peak loads.", "source_page": null }, { "number": 4, "text": "Develop and implement policies and procedures for a periodic review of OASIS postings in order to verify that the Black Hills Electric Utilities are posting load forecast data, underlying assumptions, and daily peak loads.", "source_page": null }, { "number": 5, "text": "Provide training to staff on the policies and procedures developed and implemented in response to Recommendations 3 and 4 with future training as needed. Narrative Explanation for ATC Unavailability DAA recommends that Black Hills Power:", "source_page": null }, { "number": 6, "text": "Develop and implement policies and procedures to identify when monthly and yearly ATC will remain unchanged at a value of zero for a period of six months for a given path.", "source_page": null }, { "number": 7, "text": "Develop and implement policies and procedures to post a narrative explanation of the reasons for the unavailability of ATC when monthly and yearly ATC will remain unchanged at a value of zero for a period of six months for a given path.", "source_page": null }, { "number": 8, "text": "Provide training to staff on the policies and procedures developed and implemented in response to Recommendations 6 and 7 with future training as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Narrative Explanation for Available Transfer Capability (ATC) Unavailability", "summary": "Black Hills Power did not post narrative explanations of the reasons for the unavailability of ATC when the monthly and yearly capability remained unchanged at a value of zero for a period of six months or longer for several transmission paths. As a result, there was a lack of transparency and information available to transmission customers regarding ATC availability and potential transmission services across certain paths, which may have impacted transmission customers and their transmission activities.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Public Access for Monthly and Yearly Capability Information", "summary": "The Black Hills Electric Utilities’ postings for monthly and yearly capability, along with a narrative explanation, for instances in which Total Transfer Capability (TTC) changed by more than 10 percent were not made publicly available. As a result, there was a lack of transparency and information available to transmission customers regarding TTC and potential transmission services across certain paths, which may have impacted transmission customers and their transmission activities. D.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Review system settings for all OASIS posting functions that require public access and develop policies and procedures to ensure that settings are set to provide proper access for public users. Provide a report to audit staff that summarizes the results of this review.", "source_page": null }, { "number": 10, "text": "Provide training to staff on the policies and procedures developed and implemented in response to Recommendation 9 with future training as needed. E.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Informational postings" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-08-21_nextera-energy-transmission-llc_pa23-2", "company": "NextEra Energy Transmission, LLC", "company_raw": "NextEra Energy Transmission, LLC (PA23-2)", "docket": "PA23-2", "docket_full": "PA23-2-000", "issued_date": "2024-08-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240821-3003&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240821-3003", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 52, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018, to December 31, 2023", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission", "distribution" ], "forms": [ "1", "3-Q", "60" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Acquisition Integration Cost Tracking", "summary": "NEET incurred $8,801 of acquisition-related costs that it allocated to the GridLiance Transcos, which 4 These sales are limited to customers located: (i) in the balancing area authorities operated by Florida Power Corporation (d/b/a Duke Energy Florida, LLC), JEA, Seminole Electric Cooperative, Tampa Electric Company, and City of Tallahassee; and, (ii) outside of Peninsular Florida. See Florida Power & Light Company, Market-Based Rate Tariff, Volume No. 7, § 8 Limitations and Exemptions Regarding Market-Based Rate Authority (1.0.0). 5 After the consolidation of Gulf Power’s OATT into the FPL OATT, see supra n.3, FPL’s peninsular and panhandle transmission systems both served customers under the FPL OATT, with separate billing determined by the OATT’s Attachment H-1, Peninsular Florida System Network Transmission Service Rate, and the Attachment H-2, NWFL System Formula Rate (for panhandle service). 6 See Open Access and Priority Rights on Interconnection Customer’s Interconnection Facilities, Order No. 807, 150 FERC ¶ 61,211, at P 89 (2015) (discussing interconnection facility owner’s eligibility for the blanket waiver granted by Order No. 807). then recovered these costs through FERC-jurisdictional rates. As a result, the GridLiance Transcos inappropriately billed FERC-jurisdictional customers for acquisition-related costs without Commission approval.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen policies, procedures, and controls to track merger- and acquisition- related expenditures consistent with the Commission’s requirements.", "source_page": null }, { "number": 2, "text": "Provide training to relevant employees on revised procedures for properly tracking merger- and acquisition-related expenditures in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Perform an analysis for the GridLiance Transcos to identify acquisition-related expenditures that were improperly tracked and included within FERC- jurisdictional rate inputs during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 4, "text": "Submit a refund analysis, within 60 days of the date of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amounts of inappropriate recoveries that resulted from improper tracking of acquisition-related expenditures impacting charges under FERC-jurisdictional rates during the audit period; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 5, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 6, "text": "Refund the amounts disclosed in the refund report to FERC-jurisdictional customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Lobbying Expenses", "summary": "NEET improperly recorded $139,385 of lobbying expenses on the books of the GridLiance Transcos in Account 561.5, Reliability Planning and Standards Development, a transmission function account, instead of recording this amount in Account 426.4, Expenditures for Certain Civic, Political, and Related Activities. This resulted in the GridLiance Transcos inappropriately including these costs in their FERC-jurisdictional rates. As a result, FERC-jurisdictional customers were improperly billed for lobbying expenses by the GridLiance Transcos.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Strengthen policies, procedures, and controls to account for lobbying expenses consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 8, "text": "Provide training to appropriate accounting employees on the revised procedures for properly accounting for lobbying expenditures in NEET’s and the GridLiance Transcos’ books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 9, "text": "Perform an analysis for the GridLiance Transcos to identify other lobbying costs that were improperly accounted for during the audit period subsequent to NEET’s acquisition of the GridLiance Transcos. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 10, "text": "Submit a refund analysis, within 60 days of the date of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amounts of inappropriate recoveries that resulted from improper accounting of lobbying costs impacting charges under FERC-jurisdictional formula rates during the audit period; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 11, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 12, "text": "Refund the amounts disclosed in the refund report to FERC-jurisdictional customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 3, "title": "Account 920 Misclassifications", "summary": "NEET improperly recorded $14,283 of expenses in Account 920, Administrative and General Salaries, on the books of the GridLiance Transcos, that should have been classified in other expense accounts on the books of the GridLiance Transcos. This misclassification affected the transparency, accuracy, and usefulness of the Companies’ FERC Form No. 1 and 3-Q reports.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Strengthen policies, procedures, and controls to account for A&G and O&M expenditures consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 14, "text": "Provide training to appropriate accounting employees on the revised procedures for properly accounting for A&G and O&M expenditures in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 15, "text": "Perform an analysis for the GridLiance Transcos to identify other A&G and O&M expenses that were improperly accounted for during the portion of the audit period subsequent to NEET’s acquisition of the GridLiance Transcos. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 16, "text": "Submit a refund analysis, within 60 days of the date of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amounts of inappropriate recoveries that resulted from improper accounting of administrative and general expense impacting charges under FERC-jurisdictional formula rates during the audit period; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 17, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 18, "text": "Refund the amounts disclosed in the refund report to FERC-jurisdictional customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Costs in Account 922", "summary": "Trans Bay Cable did not use Account 922, Administrative Expenses Transferred – Credit, to record administrative expenses from Account 920 and Account 921 that were transferred to construction projects or to nonutility accounts. As a result of Trans Bay Cable’s improper accounting, the transparency of its capitalization activities and the ability to compare those activities and their costs to those of others in the industry were reduced.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Strengthen policies, procedures, and controls regarding the use of Account 922 to record the allocation of administrative and general overheads to construction work in progress or to nonutility accounts consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 20, "text": "Provide training to appropriate accounting employees on the use of Account 922 to record the allocation of administrative and general overheads to construction work in progress and to nonutility accounts.", "source_page": null } ], "themes": [ "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 5, "title": "Reporting of Transactions with Associated (Affiliated) Companies", "summary": "The FERC Form No. 1 filings of Trans Bay Cable and the GridLiance Transcos reported transactions with affiliated companies in a manner that lacked transparency and was inconsistent with Commission reporting requirements. Other Matter:", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Strengthen policies and procedures to ensure operating companies accurately, completely, and consistently prepare the schedules on page 429 of the FERC Form No. 1 according to schedule instructions, namely, by providing (1) the FERC account(s), as discussed in this finding, on page 429 and (2) explanations of all allocation processes applicable to amounts billed to or received from affiliates.", "source_page": null }, { "number": 22, "text": "Provide training to relevant staff on revised procedures for properly reporting the information required on page 429 of the FERC Form No. 1. Also, develop a training program that supports the provision of periodic training in this area, as needed. E.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 6, "title": "Acquisition-Related Employee Incentive Costs", "summary": "NEET and Trans Bay Cable incurred $257,000 of employee retention expenses related to the Trans Bay Cable acquisition but did not track these costs as acquisition- related. NEET is encouraged to clarify its internal policies regarding merger and acquisition costs to ensure transparent and accurate cost tracking for future merger- and acquisition-related costs. D. List of", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Form reporting (Form No. 1/2/6, Page 700)", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "direct testimony", "id": "2024-08-20_commonwealth-edison_icc-24-0087-staff-testimony", "company": "Commonwealth Edison Company", "company_raw": "Commonwealth Edison Company", "docket": "24-0087", "docket_full": null, "issued_date": "2024-08-20", "source_page_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/354448", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/354448/files/620724.pdf", "captured_at": "2026-06-01", "source_note": "Direct Testimony of Kevin Siebert (Staff Exhibit 1.0) on behalf of the Staff of the Illinois Commerce Commission in ComEd's Rider CFRA (Carbon-Free Resource Adjustment) reconciliation, ICC Docket 24-0087, filed August 20, 2024. Listed for reference (metadata-only). Source: ICC e-Docket, document 354448 / file 620724 (landing: www.icc.illinois.gov/docket/P2024-0087/documents/354448).", "archived_via": null, "page_count": 32, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "direct testimony", "id": "2024-08-20_commonwealth-edison_icc-24-0087-cici-testimony", "company": "Commonwealth Edison Company", "company_raw": "Commonwealth Edison Company", "docket": "24-0087", "docket_full": null, "issued_date": "2024-08-20", "source_page_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/354464", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/354464/files/620780.pdf", "captured_at": "2026-06-01", "source_note": "Direct Testimony of Roger W. Turner (CICI Exhibit 1.0) on behalf of the Chemical Industry Council of Illinois (intervenor) in ComEd's Rider CFRA (Carbon-Free Resource Adjustment) reconciliation, ICC Docket 24-0087, filed August 20, 2024. Listed for reference (metadata-only). Source: ICC e-Docket, document 354464 / file 620780 (landing: www.icc.illinois.gov/docket/P2024-0087/documents/354464).", "archived_via": null, "page_count": 17, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-08-15_tri-state-generation-and-transmission-associatio_pa22-6", "company": "Tri-State Generation and Transmission Association, Inc.", "company_raw": "Tri-State Generation and Transmission Association, Inc. (PA22-6)", "docket": "PA22-6", "docket_full": "PA22-6-000", "issued_date": "2024-08-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240815-3003&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240815-3003", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 24, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to December 31, 2023", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 3, "findings": [ { "index": 1, "title": "Posting of Transmission Service Metrics", "summary": "Tri-State did not post quarterly transmission service metrics on its OASIS website within 15 calendar days of the end of the calendar quarter, pursuant to 18 C.F.R. § 37.6(h)(2).", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Develop and implement procedures and controls to ensure that Tri-State is timely posting all required information to OASIS, including posting the required transmission service metrics within 15 days of the end of each calendar quarter.", "source_page": null }, { "number": 2, "text": "Develop and implement a process to perform periodic reviews of Tri- State’s OASIS postings to verify that Tri-State is posting all required information, including posting the required transmission service metrics within 15 days of the end of each calendar quarter.", "source_page": null }, { "number": 3, "text": "Develop and implement quality controls to ensure all posted information is accurate and complete.", "source_page": null }, { "number": 4, "text": "Train employees on the review process and quality controls developed under Recommendations 1, 2, and 3, and repeat such training as needed.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 2, "title": "Posting of Discount Information", "summary": "Tri-State did not post transmission service discount information on its OASIS website, pursuant to Tri-State OATT Section 7 and 18 C.F.R. § 37.6(c)(3).", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Develop policies and implement a process to ensure that all discount rates are posted on OASIS within the time frames set forth in Tri-State’s OATT and the Commission’s regulations and are made available to all transmission service customers.", "source_page": null }, { "number": 6, "text": "Train employees on the policies and on the process relating to posting discount information on Tri-State’s OASIS, and repeat and update the training as needed.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 3, "title": "Posting of Curtailment Information", "summary": "Tri-State did not state reasons for all curtailments on OASIS, in accordance with 18 C.F.R. § 37.6(e)(3)(i). D.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Develop policies and implement process improvements to ensure that all curtailment postings include a reason why the transaction could not be continued or completed.", "source_page": null }, { "number": 8, "text": "Train employees on the curtailment policies and process improvements developed under Recommendation 7 and repeat and update the training as needed. E.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Informational postings" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MN", "source": "Minnesota Office of Administrative Hearings", "doc_type": "ALJ findings of fact, conclusions of law & recommendation (electric rate case)", "id": "2024-08-15_minnesota-power_mn-e-015-gre-23-155-alj-report", "company": "Minnesota Power (Allete)", "company_raw": "Minnesota Power (Allete)", "docket": "OAH 21-2500-39686 / MPUC E-015/GRE-23-155", "docket_full": null, "issued_date": "2024-08-15", "source_page_url": "https://mn.gov/oah/lawyers-and-litigants/administrative-law/opinion-archive.jsp", "pdf_download_url": "https://mn.gov/oah/assets/2500-39686-minnesota-power-puc-rate-increase-report_tcm19-641662.pdf", "captured_at": "2026-06-08", "source_note": "Minnesota OAH ALJ report (Findings of Fact, Conclusions of Law, and Recommendation) in Minnesota Power general electric rate case, MPUC E-015/GRE-23-155 (OAH 21-2500-39686), dated 2024-08-15. PDF: mn.gov/oah/assets/2500-39686-...pdf.", "archived_via": null, "page_count": 23, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-08-14_enlink-ngl-pipeline-lp_fa22-2", "company": "EnLink NGL Pipeline, LP", "company_raw": "EnLink NGL Pipeline, LP (FA22-2)", "docket": "FA22-2", "docket_full": "FA22-2-000", "issued_date": "2024-08-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240814-3002&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240814-3002", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 60, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2019 to December 31, 2022", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Recording of Carrier Property", "summary": "EnLink NGL did not record the cost of two mainline pipeline segments in its books and records that it had used in carrier service since 2014. The cost of these pipeline segments – $80.9 million – was erroneously recorded in an affiliated company’s books and records, instead of EnLink NGL’s. As a result, EnLink NGL understated carrier property and accrued depreciation–carrier property, and understated depreciation expense and associated operating and maintenance expenses, since 2014. This understatement materially impacted EnLink NGL’s Income Statement and Balance Sheet, along with supporting schedules, and Page 700 of the FERC Form No. 6 each year.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies, procedures, and controls as needed to ensure that all carrier property is recorded on its books and records consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 2, "text": "Inform relevant staff of the procedural and control changes adopted for carrier property accounting and provide periodic training, as needed.", "source_page": null }, { "number": 3, "text": "Perform an analysis of all asset and related adjusting entries needed to correct the carrier property and all other impacted accounts, including the effect on the balance sheet, income statement, and supporting schedules.", "source_page": null }, { "number": 4, "text": "Restate and footnote Page 700 of EnLink NGL’s 2019 FERC Form No. 6. For 2019, refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page 700. For the FERC Form No. 6 annual filings subsequent to this report, ensure that corrections made to adjust carrier property costs and other impacted accounts are properly reported in current year financial statements, including prior year corrected numbers, supporting schedules and Page 700. Also ensure appropriate footnote disclosures about the corrections made are included in the notes to the financial statements and other relevant pages of the FERC Form No. 6.", "source_page": null } ], "themes": [ "Depreciation", "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "index": 2, "title": "Recording of Noncarrier Property", "summary": "EnLink NGL did not record certain property it owned in its books and records since 2014. EnLink NGL confirmed that this property was, and will continue to be, used by an affiliated company for its business, which indicates that the property should have been recorded as noncarrier property and any related expenses should also have been recorded as noncarrier. The total amount of noncarrier property unrecorded was $7.2 million, along with $0.2 million of annual expenses.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Revise policies, procedures, and controls as needed to ensure that all noncarrier property is recorded on its books and records consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 6, "text": "Inform relevant staff of the procedural and control changes adopted for noncarrier property accounting and provide periodic training, as needed.", "source_page": null }, { "number": 7, "text": "Perform an analysis of all asset and related adjusting entries needed to correct the noncarrier property and all other impacted accounts, including the effect on the balance sheet, income statement, and supporting schedules.", "source_page": null }, { "number": 8, "text": "For the FERC Form No. 6 annual filings subsequent to this report, ensure that corrections are made to adjust noncarrier property costs and that other impacted accounts are properly reported in current year financial statements, including prior year corrected numbers and supporting schedules. Also provide appropriate footnote disclosures in the notes to the financial statements and other relevant pages of the FERC Form No. 6.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions", "Property & plant records" ], "cost_to_customers": true }, { "index": 3, "title": "Recognition of Intrastate Transportation Movements", "summary": "EnLink NGL improperly classified certain intrastate movements of liquids as interstate movements. This misclassification of intrastate movements overstated the cost of service and the interstate barrel-miles on Page 700 of the FERC Form No. 6 as this schedule should only include interstate data. This also understated total barrels, by the volume of intrastate barrels transported, reported on Page 600 of the FERC Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Revise policies, procedures, and controls to ensure that all transportation movements are properly classified as either interstate or intrastate movements and volumetric information is similarly classified.", "source_page": null }, { "number": 10, "text": "Inform relevant staff of the procedural and control changes for classification of intrastate movements and provide periodic training, as needed.", "source_page": null }, { "number": 11, "text": "For the FERC Form No. 6 annual filings subsequent to this report, ensure that corrections are made to adjust the interstate and intrastate volumes and costs are properly reported in current year financial statements, including prior year corrected numbers, supporting schedules and Page 700. Also, ensure appropriate footnote disclosures are included on the relevant pages of the FERC Form No. 6 filing.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Minor Items of Carrier Property", "summary": "EnLink NGL accounted for replacement of minor items of property as a capital investment rather than maintenance expense, which was inconsistent with the Commission’s accounting rules and regulations under 18 C.F.R. Part 352. This resulted in EnLink NGL understating maintenance expenses and overstating carrier property.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise policies, procedures, and controls to ensure that EnLink NGL consistently maintains and applies its written property units listing pursuant to 18 C.F.R. Part 352. Those revised policies and procedures should ensure that only property units and improvements are capitalized and minor items of property are expensed, and that if a replacement qualifies as an improvement, then EnLink NGL retires the costs of the minor item(s) replaced and capitalizes the costs of the improvement(s).", "source_page": null }, { "number": 13, "text": "Inform relevant staff of the procedural and control changes for the accounting and reporting of retirement units and minor units of property and provide periodic training, as needed.", "source_page": null }, { "number": 14, "text": "Update the property unit listing and capitalization manual to ensure that only property units and improvements are capitalized. Provide a copy of the revised document(s) and a summary of the updates made to DAA for review within 90 days from the issuance of this report.", "source_page": null }, { "number": 15, "text": "Perform an analysis of all projects that replaced “substantial items” and other minor items of property to identify whether they were treated as a capital or maintenance expense for the audit period. Provide a copy of the analysis and proposed accounting entries to DAA staff for review within 90 days from the issuance of this report. Upon receiving DAA staff approval, make a correcting entry to adjust carrier property. If the correcting entry results in a significant impact to income for the current year, EnLink NGL may request approval from the Commission to account for the transaction as a correction of a prior period error in Account 705.", "source_page": null }, { "number": 16, "text": "Restate and footnote Page 700 of EnLink NGL’s 2019 FERC Form No. 6. For 2019, refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page 700. For FERC Form No. 6 annual filings subsequent to this report, ensure that corrections made to adjust project costs from capital to maintenance are properly reported in current year financial statements, including prior year corrected numbers, supporting schedules, and Page", "source_page": null }, { "number": 700, "text": "Also, ensure appropriate footnote disclosures in the notes to the financial statements and other relevant pages of the FERC Form No. 6.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting Period for Affiliate Transactions", "summary": "EnLink NGL’s accrual for affiliate transactions did not conform to the Commission’s rules and regulations under 18 C.F.R. Part 352. Specifically, EnLink NGL prepared books and records for affiliate transactions on a quarterly basis rather than a monthly basis. As a result, EnLink NGL’s books and records did not accurately reflect all the costs incurred at the end of each month.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Revise procedures and controls to ensure that all affiliate transactions are accrued on a monthly basis in its general ledger consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 18, "text": "Inform relevant staff of the procedural and control changes for accrual of affiliate charges and provide periodic training, as needed.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 6, "title": "Written Shipper Nominations", "summary": "EnLink NGL improperly accepted nominations for transportation of liquids that were not submitted in the written form required by its FERC tariff. While this did not impact financial statements or operations, this was a violation of its tariff. D.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Revise policies, procedures, and controls to ensure that all transportation movements are properly nominated in writing as required by EnLink NGL’s FERC tariff.", "source_page": null }, { "number": 20, "text": "Inform relevant staff of the procedural and control changes for transportation nominations and provide training, as needed. E.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-08-12_dominion-energy-services-inc-and-dominion-energy_fa22-4", "company": "Dominion Energy Services, Inc. and Dominion Energy Southeast Services, Inc.", "company_raw": "Dominion Energy Services, Inc. and Dominion Energy Southeast Services, Inc. (FA22-4)", "docket": "FA22-4", "docket_full": "FA22-4-000", "issued_date": "2024-08-12", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240812-3031&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240812-3031", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 113, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2019 to December 31, 2023", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "60" ], "finding_count": 13, "findings": [ { "index": 1, "title": "Merger-Related Voluntary Retirement Program", "summary": "DES incurred merger-related voluntary retirement program (VRP) costs of approximately $97,872,000 that it allocated to its affiliates, including VEPCO and DESC, which then partially recovered these costs through FERC-jurisdictional rates without the Commission’s approval. DESC also improperly partially recovered an additional $84,000 of its own pre-VRP merger-related severance costs through FERC-jurisdictional rates without Commission approval.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen policies, procedures, and controls to account for all merger-related costs consistent with the Commission’s accounting requirements and Dominion Energy’s hold harmless commitment.", "source_page": null }, { "number": 2, "text": "Strengthen procedures to maintain and retain documentation consistent with Commission record retention requirements.", "source_page": null }, { "number": 3, "text": "Train relevant staff and supervisory employees on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 4, "text": "Perform an analysis to identify the impact of DES VRP costs on rates subject to the Commission’s jurisdiction during the hold harmless commitment period, including costs that were reallocated to jurisdictional utility rates via special purpose entities and other cost-allocating affiliates to which DES VRP costs were initially charged. Provide the results of the analysis to DAA within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 5, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that includes the amount of inappropriate recoveries that resulted from the improper tracking of DES VRP costs, plus interest; (2) determinative components of the refund; (3) refund method(s); (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 6, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 7, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 2, "title": "Merger Compensation", "summary": "DES, VEPCO, and DESC incurred merger labor and labor- related costs, including incentive compensation, of approximately $5,176,000 that it did not track as merger-related. As a result, a portion of these costs was included in FERC-jurisdictional revenue requirements without the Commission’s approval, causing VEPCO and DESC to overcharge their FERC-jurisdictional customers.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise all policies, procedures, and controls for tracking, accounting for, and excluding merger-related labor and labor-related costs, including incentive compensation costs, from FERC-jurisdictional rates for any transactions to which a FERC hold harmless commitment applies. Among other things, the revised policies and procedures should include more timely creation of and notice to relevant employees of merger cost codes during the pre- announcement phase.", "source_page": null }, { "number": 9, "text": "Train relevant staff on the revised policies, procedures, and controls and ensure that, for transactions to which a FERC hold harmless commitment applies, recurring training and reminders are provided throughout the hold harmless period to all relevant personnel across all relevant business units.", "source_page": null }, { "number": 10, "text": "Perform an analysis of the impact of the $5,176,000 of merger costs on rates subject to the Commission’s jurisdiction. Provide the results of the analysis to DAA within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 11, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that includes the amount of inappropriate recoveries that resulted from the improper tracking of merger-related labor and labor-related costs, including incentive compensation costs, plus interest; (2) determinative components of the refund; (3) refund method(s); (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 12, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 13, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Merger Project Configuration", "summary": "DES misconfigured certain merger-related billing Work Breakdown Structure (WBS) elements within its cost accumulation system, causing it to inadvertently bill approximately $4,599,000 of merger costs to VEPCO and DESC. As a result, portions of these costs were included in FERC- jurisdictional revenue requirements without the Commission’s approval, causing VEPCO and DESC to overcharge their FERC-jurisdictional customers.", "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Revise all policies, procedures, and controls for configuring cost accumulation and billing WBS elements that are intended to exclude costs from FERC- jurisdictional rates for any transactions to which a FERC hold harmless commitment applies. Among other things, the revised policies and procedures should include more thorough review and testing of the billing behavior of all such WBS elements in the test phase and additional review of the billing of and accounting for such costs on the books of any affiliate to which a FERC hold harmless commitment applies.", "source_page": null }, { "number": 15, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training as needed.", "source_page": null }, { "number": 16, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that includes the amount of inappropriate recoveries that resulted from the improper merger WBS element configuration, plus interest; (2) determinative components of the refund; (3) refund method(s); (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 17, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 18, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Merger Integration Project Cost Tracking", "summary": "DES, VEPCO, and DESC incurred approximately $2,361,000 of merger-related costs that were not tracked as merger costs. As a result, portions of these costs were included in FERC-jurisdictional revenue requirements without the Commission’s approval, causing VEPCO and DESC to overcharge their FERC-jurisdictional customers.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Revise all policies, procedures, and controls for tracking, accounting for, and excluding merger integration project costs from FERC-jurisdictional rates for any transactions to which a FERC hold harmless commitment applies. Among other things, the revised policies and procedures should include continued monitoring of merger integration project costs against a budget or other independent authorization, procedures to ensure the completeness of costs tracked in merger WBS elements, and enhanced cost review procedures by managers who themselves are, or who supervise employees who are, responsible for any merger-related projects.", "source_page": null }, { "number": 20, "text": "Train relevant staff on the revised policies, procedures, and controls and ensure that, for transactions to which a FERC hold harmless commitment applies, recurring training and reminders are provided throughout the entire hold harmless period to all relevant personnel across all relevant business units, including emphasis on the importance in Dominion’s cost accumulation systems of selecting the proper WBS element for a given transaction.", "source_page": null }, { "number": 21, "text": "Perform an analysis to identify merger integration project costs that were included in FERC-jurisdictional revenue requirements during the hold harmless commitment period. Perform an analysis of the impact of such merger costs on rates subject to the Commission’s jurisdiction. Provide the results of the analysis to DAA within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 22, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that includes the amount of inappropriate recoveries that resulted from the improper tracking of merger integration project costs, plus interest; (2) determinative components of the refund; (3) refund method(s); (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 23, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 24, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Merger Financing Costs", "summary": "DESC incurred merger-related refinancing costs of 6 See Dominion Energy’s SEC Form 10-K, p. 105 at Note 1 “Nature of Operations,” as filed February 23, 2024. $2,552,000 but did not exclude them from FERC-jurisdictional revenue requirements. As a result, a portion of these costs were recovered from FERC- jurisdictional customers without the Commission’s approval.", "is_other_matter": false, "recommendations": [ { "number": 25, "text": "Revise policies, procedures, and controls for tracking, accounting for, and excluding merger-related financing costs from FERC-jurisdictional rates for any transactions to which a FERC hold harmless commitment applies. Among other things, the revised policies and procedures should include incremental review of significant, unusual, or non-recurring charges, including financing costs, incurred by entities to which a FERC hold harmless commitment applies.", "source_page": null }, { "number": 26, "text": "Train relevant staff on the revised policies, procedures, and controls and ensure that, for transactions to which a FERC hold harmless commitment applies, recurring training and reminders be provided throughout the entire hold harmless period to all relevant personnel across all relevant business units, including emphasis on the possible significant, unusual, or non-recurring charges, including financing costs, that could be merger-related.", "source_page": null }, { "number": 27, "text": "Perform an analysis to identify merger-related financing costs that were included in FERC-jurisdictional revenue requirements during the hold harmless commitment period. Perform an analysis of the impact of such merger costs on rates subject to the Commission’s jurisdiction. Provide the results of the analysis to DAA within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 28, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that includes the amount of inappropriate recoveries that resulted from the improper tracking of merger-related financing costs, plus interest; (2) determinative components of the refund; (3) refund method(s); (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 29, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 30, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Allocation Methods", "summary": "Certain DES allocation factors were improperly configured to allocate charges to incorrect affiliates. Certain DES expenses were also charged using incorrect allocation methods that did not correspond to the affiliates who benefited from those expenses. Finally, DES’s FERC Form No. 60 disclosures did not completely or adequately describe the operation of certain allocation methods. As a result, service company costs may have been misallocated and public utility affiliates overcharged. This may have resulted in FERC-jurisdictional utility customers likewise being overcharged.", "is_other_matter": false, "recommendations": [ { "number": 31, "text": "Strengthen procedures to maintain and retain documentation consistent with Commission record retention requirements.", "source_page": null }, { "number": 32, "text": "Amend FERC Form No. 60 and Cost Allocation Manual terminology to clearly exclude from the O&M Method asset impairments, gain/loss on disposals, and other significant nonrecurring transactions.", "source_page": null }, { "number": 33, "text": "Amend FERC Form No. 60 and Cost Allocation Manual terminology to clearly explain the mechanisms by which the Plant Factor and Aviation Factor are calculated.", "source_page": null }, { "number": 34, "text": "Submit an amended Cost Allocation Manual to DAA for review within 60 days of the issuance of this audit report.", "source_page": null }, { "number": 35, "text": "Strengthen policies, procedures, and controls to ensure that new allocation WBS elements are reviewed for correlation between the purpose as designed of the allocation WBS elements and the affiliates benefitting from the costs.", "source_page": null }, { "number": 36, "text": "Strengthen policies, procedures, and controls to ensure that all costs are charged to the proper WBS element.", "source_page": null }, { "number": 37, "text": "Strengthen policies, procedures, and controls to ensure that all supporting calculations for cost allocation methodologies are retained in accordance with the Commission’s records retention policies for centralized service companies.", "source_page": null }, { "number": 38, "text": "Train relevant staff and supervisory employees on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 39, "text": "Perform an analysis of cost centers within the service function areas Information Technology, Finance, Business Planning, Human Resources, and Legal to identify any costs that were assigned to incorrect WBS elements during the audit period. Provide the results of the analysis to audit staff within 120 days of the date of issuance of the audit report.", "source_page": null }, { "number": 40, "text": "Perform an analysis of existing allocation WBS elements to ensure that the purpose of the allocation WBS element corresponds to the benefiting affiliates. Provide the results of the analysis to audit staff within 120 days of the date of issuance of the audit report.", "source_page": null }, { "number": 41, "text": "Submit a refund analysis for VEPCO and DESC, within 30 days of receiving DAA’s approval of the cost center and WBS element analyses, to DAA for review that explains and details the following: (1) calculations of refunds that include the amount of inappropriate recoveries during the audit period that resulted from improper or inaccurate allocation methods, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 42, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 43, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 7, "title": "Accounting for Customer Accounts Expenses", "summary": "VEPCO and DESC improperly accounted for consultant fees related to customer accounts expenses that were allocated from DES. VEPCO’s accounting resulted in Account 923, Outside Services Employed, being overstated and Account 901, Supervision, being understated, while DESC’s accounting resulted in Account 905, Miscellaneous Customer Accounts Expenses, being overstated and Account 901 being understated. Because Account 923 is an input to VEPCO’s FERC-jurisdictional rates, VEPCO’s improper accounting also caused VEPCO to overstate its FERC- jurisdictional revenue requirements and overcharge its FERC-jurisdictional customers. DESC’s improper accounting did not have any impact on its jurisdictional revenue requirements.", "is_other_matter": false, "recommendations": [ { "number": 44, "text": "Strengthen policies, procedures, and controls to account for customer accounts expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 45, "text": "Train relevant staff on the methods to account for customer accounts expenses and provide periodic training, as needed.", "source_page": null }, { "number": 46, "text": "Perform an analysis for DES and VEPCO to identify all customer accounts expenses that were improperly recorded in A&G expense accounts during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 47, "text": "Submit a refund analysis for VEPCO, within 60 days of receiving the final audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper accounting for customer accounts expenses in A&G accounts, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 48, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 49, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Administrative and General Expense Misclassifications", "summary": "DES misclassified administrative and general (A&G) expenses that it incurred during the audit period. DES’s accounting resulted in such expenses being incorrectly included in accounts that are FERC-jurisdictional rate inputs for VEPCO and DESC. This caused VEPCO and DESC to overstate their FERC-jurisdictional revenue requirements and overcharge FERC-jurisdictional customers.", "is_other_matter": false, "recommendations": [ { "number": 50, "text": "Strengthen policies, procedures, and controls to account for membership dues, donations, and customer records and collection expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 51, "text": "Train relevant staff on the methods to account for membership dues, donations, and customer records and collection expenses and provide periodic training, as needed.", "source_page": null }, { "number": 52, "text": "Perform an analysis to identify other membership dues recorded in Account 921 that were Company memberships that should be recorded in Account 930.2, donations not properly recorded in Account 426.1, and customer records and collection expenses that were improperly accounted for during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 53, "text": "Submit a refund analysis for VEPCO and DESC, within 60 days of receiving the final audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper accounting for membership dues, donations, and customer records and collection expenses, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 54, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 55, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 9, "title": "Accounting for EEI Annual Membership Dues", "summary": "DES misclassified EEI annual membership dues designated as being for lobbying in Account 930.2, Miscellaneous General Expenses, rather than recording them in Account 426.4, Expenditures for Certain Civic, Political and Related Activities. DES’s improper accounting resulted in such expenses being incorrectly included in an account that is an input to FERC-jurisdictional rates. This caused VEPCO and DESC to overstate their FERC-jurisdictional revenue requirements and overcharge FERC- jurisdictional customers.", "is_other_matter": false, "recommendations": [ { "number": 56, "text": "Strengthen policies, procedures, and controls to account for trade association dues and the portions of such dues designated as being for lobbying consistent with Commission accounting requirements.", "source_page": null }, { "number": 57, "text": "Train relevant staff on the revised policies and procedures and provide periodic training, as needed.", "source_page": null }, { "number": 58, "text": "Submit a refund analysis for VEPCO and DESC, within 60 days of receiving the final audit report, to DAA for review that explains and details the following for the audit period: (1) calculation of refunds resulting from improper accounting for trade association dues, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 59, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 60, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 10, "title": "Accounting for Service Company Property", "summary": "Legacy DESS misclassified various service company assets in Account 398, Miscellaneous Equipment, which should have been classified in other service company property accounts. This misclassification affected the transparency, accuracy, and usefulness of both DES’s and legacy DESS’s FERC Form No. 60 reports.", "is_other_matter": false, "recommendations": [ { "number": 61, "text": "Strengthen policies, procedures, and controls to classify service company property costs consistent with Commission regulations.", "source_page": null }, { "number": 62, "text": "Train relevant staff on the revised plant accounting policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 63, "text": "Submit proposed accounting entries and supporting documentation to DAA to reflect the reclassification of service company property within 60 days of the date of this audit report.", "source_page": null }, { "number": 64, "text": "Correct the service company property balances after receiving DAA’s assessment of the proposed accounting entries and restate and footnote the balances reported in DES’s most recent FERC Form No. 60 as necessary to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 11, "title": "Accounting for Prepayments", "summary": "DES reclassified certain prepaid expense balances from Account 165, Prepayments, to Account 930.2, Miscellaneous General Expenses, because it lacked supporting documentation for such balances. DES’s accounting resulted in unsupported amounts being incorrectly included in an operating expense account, in conflict with the Commission’s accounting regulations. Because Account 930.2 is an input to FERC-jurisdictional rates, this caused VEPCO to overstate its FERC-jurisdictional revenue requirements and overcharge FERC-jurisdictional customers.", "is_other_matter": false, "recommendations": [ { "number": 65, "text": "Strengthen policies, procedures, and controls to maintain and retain documentation to support prepayment amounts consistent with Commission record retention requirements.", "source_page": null }, { "number": 66, "text": "Strengthen policies, procedures, and controls to properly account for the write- off of unsupported prepayments in Account 426.5.", "source_page": null }, { "number": 67, "text": "Train relevant staff on the revised prepayment policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 68, "text": "Submit a refund analysis for VEPCO, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculations of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the overstatement of Account 930.2 due to the improper inclusion in Account 930.2 of the write-off of prepayments, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 69, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 70, "text": "Refund the amounts disclosed in the refund report to customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 12, "title": "FERC Form No. 60 Reporting", "summary": "DES and legacy DESS did not accurately disclose in their FERC Forms No. 60 the functional classification of expenses between capital, utility operations & maintenance (O&M), customer accounts expense, and A&G accounts in 2019 and 2020. This caused their FERC Forms No. 60 to overstate various A&G and capital accounts and understate various O&M, customer accounts expense, and non-operating accounts on the FERC Form No.", "is_other_matter": false, "recommendations": [ { "number": 71, "text": "Strengthen policies, procedures, and controls to properly report the functional expense classifications of DES’s affiliate billings in accordance with the Commission’s accounting and reporting regulations.", "source_page": null }, { "number": 72, "text": "Provide training to relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 73, "text": "Within 120 days of the issuance of this audit report, refile revised DES FERC Forms No. 60 for 2019 and 2020 to accurately report functional expense classification by correcting the errors noted in this finding. E.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 13, "title": "This affected the transparency, accuracy, and usefulness of certain sections of these financial disclosures. D. List of", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "LA", "source": "Louisiana Public Service Commission", "doc_type": "settlement agreement", "id": "2024-07-31_entergy-louisiana_la-u-36959-global-settlement", "company": "Entergy Louisiana, LLC", "company_raw": "Entergy Louisiana, LLC", "docket": "U-36959", "docket_full": null, "issued_date": "2024-07-31", "source_page_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/DocketDetails?docketId=31370", "pdf_download_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=%2BTYZ0y9CRc0%3D", "captured_at": "2026-06-02", "source_note": "Global Settlement in Entergy Louisiana, LLC, Ex Parte — In Re: Application for an Increase in Rates, Whether Through a Formula Rate Plan Extension or Rate Review, and Proposed Revisions to Certain Fees Assessed to Customers, before the Louisiana Public Service Commission, Docket No. U-36959 (32 pp). The settlement, joined by LPSC Staff and intervenors (Alliance for Affordable Energy, LEUG, Walmart, DoD/federal agencies, et al.), continues a Formula Rate Plan (Rider FRP) for three years with annual evaluation reports due May 31, 2025 and 2026. Filed 2024. Listed for reference (metadata-only). Source: LPSC public docket portal, file +TYZ0y9CRc0= (lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=%2BTYZ0y9CRc0%3D; docket landing: DocketDetails?docketId=31370).", "archived_via": null, "page_count": 32, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 3, "findings": [ { "index": 1, "title": "Settlement: AGREEMENT", "summary": "PLAN EXTENSION OR RATE REVIEW, AND PROPOSED REVISIONS TO CERTAIN FEES ASSESSED TO CUSTOMERS GLOBAL SETTLEMENT STIPULATION AGREEMENT This Stipulation Term Sheet (“Stipulation”) is entered into by and among the Louisiana Public Service Commission (“LPSC” or “Commission”) Staff (“Sta", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Settlement: terms", "summary": "ation as indicated by the signatures affixed hereto. Accordingly, the Parties propose the following settlement terms to the Commission: I. Conditions Precedent A. This Stipulation reflects a compromise, settlement, and accommodation among the Parties and the terms a", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: Agreement", "summary": "s described above in paragraphs II.B, II.C, II.D, and II.E.; b) $5.8 million credit provided in the Settlement Agreement approved in LPSC Order No. U-34951; and c) $15 million increase in nuclear depreciation expense, further discussed in Section III.C.4 below. 3. The f", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true } ], "structured": false, "themes": [ "Depreciation" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "SC", "source": "Public Service Commission of South Carolina", "doc_type": "fuel cost prudence review order", "id": "2024-07-31_duke-energy-progress_sc-2024-1-e-fuel-order", "company": "Duke Energy Progress, LLC", "company_raw": "Duke Energy Progress, LLC", "docket": "2024-1-E", "docket_full": null, "issued_date": "2024-07-31", "source_page_url": "https://dms.psc.sc.gov/Web/Dockets/Detail/118761", "pdf_download_url": "https://dms.psc.sc.gov/Attachments/Order/33f005fe-b9d0-4dbe-a626-b5ef9cd72c77", "captured_at": "2026-06-19", "source_note": "Order No. 2024-500 Approving Adjustment in Fuel Cost Recovery Factors in Duke Energy Progress, LLC's Annual Review of Base Rates for Fuel Costs, before the Public Service Commission of South Carolina, Docket No. 2024-1-E, issued July 31, 2024; 58 pp. Listed for reference (metadata-only). Source: SC PSC Document Management System, Order 33f005fe-b9d0-4dbe-a626-b5ef9cd72c77 (docket landing: dms.psc.sc.gov/Web/Dockets/Detail/118761).", "archived_via": null, "page_count": 58, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "CA", "source": "CPUC Utility Audits, Risk and Compliance Division", "doc_type": "balancing accounts performance audit (Utility Audits Branch)", "id": "2024-07-23_southern-california-edison_ca-balancing-accounts-audit", "company": "Southern California Edison Company", "company_raw": "Southern California Edison Company", "docket": null, "docket_full": null, "issued_date": "2024-07-23", "source_page_url": "https://www.cpuc.ca.gov/about-cpuc/divisions/utility-audits-risk-and-compliance-division/utility-audits-branch/audit-reports-by-industry/audit-reports-energy-industry", "pdf_download_url": "https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/utility-audits--risk--and-compliance-division/reports/energy/2024/energy_2024-07-23_sce_ba.pdf", "captured_at": "2026-06-08", "source_note": "CPUC Utility Audits Branch Balancing Accounts Performance Audit of SCE (review period CY2022), dated July 23, 2024. 16 pp. Page 1 verified: 'BALANCING ACCOUNTS PERFORMANCE AUDIT Southern California Edison Company'.", "archived_via": null, "page_count": 16, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "the balancing account. Additionally, unless approved otherwise, a balancing acco", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "the balancing account. Additionally, unless approved otherwise, a balancing account is required to accumulate monthly interest at a rate equal to one-twelfth of the most recent month’s interest rate on three-month Commercial Paper published by the Federal Reserve. Actual revenues collected by a utility in rates can be more or less than what CPUC had authorized to", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "This audit report is intended solely for the information and use of SCE and the ", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 2, "text": "This audit report is intended solely for the information and use of SCE and the CPUC; it is not intended to be and should not be used by anyone other than these specified parties. This restriction is not intended to limit distribution of this audit report, which is a matter of public record and will be available on the CPUC website at Audit Reports by Industry (ca.gov).", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "SC", "source": "Public Service Commission of South Carolina", "doc_type": "fuel cost prudence review proposed order (ORS)", "id": "2024-07-22_duke-energy-progress_sc-2024-1-e-ors-proposed-order", "company": "Duke Energy Progress, LLC", "company_raw": "Duke Energy Progress, LLC", "docket": "2024-1-E", "docket_full": null, "issued_date": "2024-07-22", "source_page_url": "https://dms.psc.sc.gov/Web/Dockets/Detail/118761", "pdf_download_url": "https://dms.psc.sc.gov/Attachments/Matter/fb34c4b6-f079-4fa2-9b38-2befcd66e54e", "captured_at": "2026-06-19", "source_note": "Office of Regulatory Staff proposed order on fuel-cost reasonableness in Duke Energy Progress, LLC's Annual Review of Base Rates for Fuel Costs, before the Public Service Commission of South Carolina, Docket No. 2024-1-E, filed July 22, 2024; 25 pp. Listed for reference (metadata-only). Source: SC PSC Document Management System, Matter fb34c4b6-f079-4fa2-9b38-2befcd66e54e (docket landing: dms.psc.sc.gov/Web/Dockets/Detail/118761).", "archived_via": null, "page_count": 25, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2024-07-11_ppl-electric-utilities_pa-mo-audit", "company": "PPL Electric Utilities Corporation", "company_raw": "PPL Electric Utilities Corporation", "docket": "D-2023-3039488", "docket_full": null, "issued_date": "2024-07-11", "source_page_url": "https://www.puc.pa.gov/press-release/2024/puc-issues-management-and-operations-audit-for-ppl-electric-utilities-corporation", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1837310.pdf", "captured_at": "2026-06-01", "source_note": "Management & Operations Audit issued by the PA PUC Bureau of Audits (cover: 'Issued June 2024'); PUC publication 2024-07-11. PDF: puc.pa.gov/pcdocs/1837310.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 93, "scanned_pages": [ 1, 93 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 8, "findings": [ { "index": 1, "title": "Executive Management and Organizational Structure", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Conduct routine employee surveys to ensure corporate culture aligns with company goals.", "source_page": 16 }, { "number": 2, "text": "Document the company’s strategic planning process and establish a formal overarching strategic plan governing all long-term corporate initiatives.", "source_page": 16 } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Cost Allocations and Affiliated Interests", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Document the services PPL Electric provides its affiliates and the associated methodologies used to allocate the costs of those services in the Corporate CAM.", "source_page": 29 }, { "number": 4, "text": "Compare the internal cost of services provided between PPL Electric Utilities and their corporate affiliates to market rates on a periodic basis and document any savings realized from resulting changes.", "source_page": 29 }, { "number": 5, "text": "Develop and implement periodic refresher training to employees to ensure reported hours are accurately charged to affiliates.", "source_page": 29 } ], "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "index": 3, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Create a formal dividend policy and notify the PUC prior to paying dividends above 85% of net income.", "source_page": 36 } ], "themes": [ "Dividend policy & capital management" ], "cost_to_customers": false }, { "index": 4, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Improve SAIDI and CAIDI performance to consistently achieve the minimum thresholds set by the Commission benchmarks and standards on reliability.", "source_page": 47 }, { "number": 8, "text": "Modify or expand existing reliability programs to eliminate CEMI10+ and set goals for reducing CEMI4.", "source_page": 47 }, { "number": 9, "text": "Complete and properly record the results of theft- of-service investigations for all accounts where theft or damage to meter is suspected.", "source_page": 47 } ], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 5, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Address minor security and safety improvements.", "source_page": 51 }, { "number": 11, "text": "Improve storm response communications to reduce logistical downtime and to improve real- time response effectiveness.", "source_page": 51 } ], "themes": [ "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "index": 6, "title": "Purchasing and Materials Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Update outdated policies and procedures.", "source_page": 59 }, { "number": 13, "text": "Improve inventory accuracy through expanded inventory count assessments and routinely conduct refresher training to resolve manual reporting inaccuracies.", "source_page": 59 }, { "number": 14, "text": "Reevaluate the processes for determining obsolete, inactive, and emergency stock inventory to include input from all involved departments.", "source_page": 59 } ], "themes": [ "Workforce, training & succession planning", "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 7, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Improve and strengthen customer service performance to at least pre-pandemic levels.", "source_page": 66 }, { "number": 16, "text": "Continue outreach efforts to engage with payment delinquent customers and leverage low- income resources to help reduce the overall level of outstanding customer balances.", "source_page": 66 }, { "number": 17, "text": "Develop internal controls for source data and reporting systems to ensure accuracy.", "source_page": 66 } ], "themes": [ "Internal audit & internal controls", "Customer service & billing" ], "cost_to_customers": false }, { "index": 8, "title": "Information Technology", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Reduce budget variances for the IT total budget and individual IT budget categories to less than ±10% and document reasons for large budget variances.", "source_page": 75 }, { "number": 19, "text": "Reassess the IT project backlog to eliminate obsolete projects and complete a comprehensive staffing and resource assessment to achieve more reasonable backlog levels.", "source_page": 76 } ], "themes": [ "Information technology & systems" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates", "Customer service & billing", "Dividend policy & capital management", "Emergency preparedness & business continuity", "Information technology & systems", "Internal audit & internal controls", "Inventory, materials & fleet", "Service reliability & vegetation management", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "MS", "source": "Mississippi Public Utilities Staff", "doc_type": "utilities staff annual report", "id": "2024-06-30_mississippi-public-utilities-staff_ms-annual-report", "company": "Mississippi Public Utilities Staff", "company_raw": "Mississippi Public Utilities Staff", "docket": null, "docket_full": null, "issued_date": "2024-06-30", "source_page_url": "https://www.psc.ms.gov/", "pdf_download_url": "https://www.psc.ms.gov/sites/default/files/2024-MPUS-Annual-Report.pdf", "captured_at": "2026-06-02", "source_note": "Mississippi Public Utilities Staff (MPUS) Annual Report for the year ending June 30, 2024 (Charles Jim Beckett, Executive Director), 20 pp. MPUS is the independent staff that, per the Mississippi PSC's General Orders, conducts year-round audits of the investor-owned utilities' fuel-adjustment clauses and purchased-gas adjustments — including Entergy Mississippi's Energy Cost Recovery (ECR) rider and Mississippi Power Company's fuel cost recovery (FCR) rider — and reviews rate and prudence matters. Listed for reference (metadata-only). Source: Mississippi Public Service Commission (psc.ms.gov/sites/default/files/2024-MPUS-Annual-Report.pdf).", "archived_via": null, "page_count": 20, "scanned_pages": [ 15, 16, 17, 18, 19 ], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "ALJ initial decision", "id": "2024-06-11_basin-electric-power-cooperative_er20-2441", "company": "Basin Electric Power Cooperative", "company_raw": "Basin Electric Power Cooperative", "docket": "ER20-2441", "docket_full": null, "issued_date": "2024-06-11", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240611-3038&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240611-3038", "captured_at": "2026-06-07", "source_note": "FERC ALJ Initial Decision re Basin Electric Power Cooperative wholesale formula-rate / cost-of-service proceeding, Docket ER20-2441 (consolidated with ER20-2442 / ER21-426), issued 2024-06-11. Metadata-only (free-form legal order). Found via the eLibrary AdvancedSearch API (searchText=ER20-2441); accession 20240611-3038.", "archived_via": null, "page_count": 906, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on rehearing", "id": "2024-05-23_constellation-mystic-power_er18-1639", "company": "Constellation Mystic Power, LLC", "company_raw": "Constellation Mystic Power, LLC", "docket": "ER18-1639", "docket_full": null, "issued_date": "2024-05-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240523-3096&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240523-3096", "captured_at": "2026-06-01", "source_note": "FERC Order on Rehearing and Clarification re Constellation Mystic Power, LLC cost-of-service recovery, Docket ER18-1639, issued 2024-05-23. Found via eLibrary full-text search; accession 20240523-3096.", "archived_via": null, "page_count": 60, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "DE", "source": "Delaware Public Service Commission", "doc_type": "base-rate case order", "id": "2024-04-18_delmarva-power-light_de-22-0897", "company": "Delmarva Power & Light Company", "company_raw": "Delmarva Power & Light Company", "docket": "22-0897", "docket_full": null, "issued_date": "2024-04-18", "source_page_url": "https://delafile.delaware.gov/CaseManagement/DocketSheet.aspx?MatterNo=22-0897&Type=Docket&ViewDocketPage=ViewDocketPage", "pdf_download_url": "https://depsc.delaware.gov/wp-content/uploads/sites/54/2024/04/Regular-Item-1f-Docket-22-0897-Order-10395-04-18-2024.pdf", "captured_at": "2026-06-02", "source_note": "Order No. 10395 on the application of Delmarva Power & Light Company for an increase in electric base rates (filed December 15, 2022), Delaware PSC Docket No. 22-0897, entered April 18, 2024. Listed for reference (metadata-only). PDF on the DE PSC host depsc.delaware.gov/wp-content/uploads/; docket sheet in DelaFile (delafile.delaware.gov, MatterNo 22-0897).", "archived_via": null, "page_count": 195, "scanned_pages": [ 6, 25, 26, 78, 80, 153 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 79, "findings": [ { "index": 1, "title": "Approval: $16.7 million", "summary": "s Pfaff, “[i]n 20-0149, which was a litigated case, the Company requested $26.3 million. The amount approved was $16.7 million. And the percentage of the request was 64%. In Docket 16-0649, which was a settled case, the amount approved was $31.5 million. The amount requested", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $31.5\nmillion", "summary": "And the percentage of the request was 64%. In Docket 16-0649, which was a settled case, the amount approved was $31.5 million. The amount requested was $60.2 million. The percentage of the request approved was 169 Tr.-276. 170 Tr.-261. 171 Id. 172 Tr.-267. 173 Tr.-259. 174 T", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: Agreement", "summary": "stimony into evidence by Delmarva, Commission Staff, the DPA and the Weldin Road Homeowner that the Settlement Agreement is in the public interest as required by 26 Del. C. §512(c); DEUG, IBEW and Walmart also submitted attorney statements that 2 PSC Docket No. 22-0897,", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Settlement: Agreement", "summary": "t also submitted attorney statements that 2 PSC Docket No. 22-0897, Order No. 10395 Cont’d that the Settlement Agreement is in the public interest; WHEREAS, Senior Hearing Examiner Lawrence issued proposed Findings and Recommendations (the “Hearing Examiner’s Report”) r", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: Agreement", "summary": "Report”) regarding the Amended Application in which he recommended that the Commission approve the Settlement Agreement; WHEREAS, Staff filed exceptions to the Hearing Examiner’s Recommendation, that the Settlement Agreement be approved; and WHEREAS, the Commission met", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Settlement: Agreement", "summary": "ement Agreement; WHEREAS, Staff filed exceptions to the Hearing Examiner’s Recommendation, that the Settlement Agreement be approved; and WHEREAS, the Commission met in public session on December 4, 2024, to hear oral argument and conduct deliberations on the issues in", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: Agreement", "summary": "NERS, IT IS SO ORDERED: 1. For the reasons set forth in the Hearing Examiner’s Report, the Proposed Settlement Agreement, attached hereto as Exhibit “A,” and the resolutions contained therein are adopted as in the public interest as required by 26 Del C. §512(c). 2. Tha", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Settlement: AGREEMENT", "summary": "COMPANY ) FOR A N INCREASE IN ELECTRIC ) DOCKET NO. 22-0897 BASE RATES (Filed December 15, 2022) ) SETTLEMENT AGREEMENT This Settlement Agreement (the “Settlement Agreement”) is entered into by and among Delmarva Power & Light Company (“Delmarva Power” or the “Company”", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: Agreement", "summary": "E IN ELECTRIC ) DOCKET NO. 22-0897 BASE RATES (Filed December 15, 2022) ) SETTLEMENT AGREEMENT This Settlement Agreement (the “Settlement Agreement”) is entered into by and among Delmarva Power & Light Company (“Delmarva Power” or the “Company”), the Delaware Division o", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Settlement: Agreement", "summary": "22-0897 BASE RATES (Filed December 15, 2022) ) SETTLEMENT AGREEMENT This Settlement Agreement (the “Settlement Agreement”) is entered into by and among Delmarva Power & Light Company (“Delmarva Power” or the “Company”), the Delaware Division of the Public Advocate (“Pub", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: Agreement", "summary": "s”). The items included herein are not binding until the Commission issues a final order as to this Settlement Agreement in this docket. I. INTRODUCTION AND PROCEDURAL BACKGROUND 1. On December 15, 2022, Delmarva Power filed an Application (the “Application”) with the C", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Settlement: terms", "summary": "eeding, and they reserve their rights to raise those issues in future proceedings, but believe that settlement of this proceeding on the terms and conditions contained herein both serve the interests of the public and Delmarva Power and its customers and satisfy the statutory requirement tha", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: Agreement", "summary": "when to seek approval of EV charging rates from the Commission. III. ADDITIONAL PROVISIONS 44. This Settlement Agreement is the product of extensive negotiation and reflects a mutual balancing of various issues and positions of the Settling Parties. This Settlement Agre", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Settlement: Agreement", "summary": "e Commission fails to grant such approval, or modifies any of the terms and conditions herein, this Settlement Agreement will terminate and be of no force and effect unless the Settling Parties agree in writing to waive the application of this provision. 45. This Settle", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Settlement: Agreement", "summary": "t unless the Settling Parties agree in writing to waive the application of this provision. 45. This Settlement Agreement represents a compromise for the purposes of settlement and shall not be regarded as a precedent with respect to any ratemaking or any other principle", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 16, "title": "Settlement: Agreement", "summary": "ings, whether as part of a document filed or otherwise, that are not specifically addressed in this Settlement Agreement, no findings, recommendations, or positions with respect to such opinions, views, or issues should be implied or inferred. 47. The Settling Parties a", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Settlement: Agreement", "summary": "or issues should be implied or inferred. 47. The Settling Parties agree that they will submit this Settlement Agreement to the Commission for a determination that it is in the public interest and results in just and reasonable rates, and that no Party will oppose such", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 18, "title": "Settlement: Agreement", "summary": "roceeding, including positions contrary to positions taken herein or in previous cases. 48. If this Settlement Agreement does not become final, either because it is not approved by the Commission or because it is the subject of a successful appeal and remand, each Party", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Settlement: Agreement", "summary": "as it deems appropriate in its sole discretion to litigate the issues in this proceeding. 49. This Settlement Agreement will become effective upon the Commission’s issuance of an order approving it and all of its terms and conditions without modification. After the iss", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 20, "title": "Settlement: Agreement", "summary": "its terms and conditions without modification. After the issuance of such order, the terms of this Settlement Agreement shall be implemented and enforceable notwithstanding the pendency of a legal challenge to the Commission’s approval of this Settlement Agreement or t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: Agreement", "summary": "enforceable notwithstanding the pendency of a legal challenge to the Commission’s approval of this Settlement Agreement or to actions taken by another regulatory agency or Court, unless such implementation and enforcement is stayed or enjoined by the Commission, anothe", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: Agreement", "summary": "egulatory agency, or a Court having jurisdiction over the matter. 16 50. The obligations under this Settlement Agreement, if any, that apply for a specific term set forth herein shall expire automatically in accordance with the term specified and shall require no furthe", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 23, "title": "Settlement: Agreement", "summary": "and shall require no further action for their expiration. 51. The Settling Parties may enforce this Settlement Agreement through any appropriate action before the Commission or through any other available remedy. Any final Commission order related to the enforcement or", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 24, "title": "Settlement: Agreement", "summary": "r available remedy. Any final Commission order related to the enforcement or interpretation of this Settlement Agreement shall be appealable to the Superior Court of the State of Delaware, in addition to any other available remedy at law or in equity. 52. If a Court gra", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 25, "title": "Settlement: Agreement", "summary": "y at law or in equity. 52. If a Court grants a legal challenge to the Commission’s approval of this Settlement Agreement and issues a final non-appealable order that prevents or precludes implementation of any material term of this Settlement Agreement, or if some other", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 26, "title": "Settlement: Agreement", "summary": "a final non-appealable order that prevents or precludes implementation of any material term of this Settlement Agreement, or if some other legal bar has the same effect, then this Settlement Agreement is voidable upon written notice by any Party to all other Settling Pa", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 27, "title": "Settlement: Agreement", "summary": "terial term of this Settlement Agreement, or if some other legal bar has the same effect, then this Settlement Agreement is voidable upon written notice by any Party to all other Settling Parties. 53. This Settlement Agreement resolves the issues specifically addressed", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 28, "title": "Settlement: Agreement", "summary": "ment Agreement is voidable upon written notice by any Party to all other Settling Parties. 53. This Settlement Agreement resolves the issues specifically addressed herein, and precludes the Settling Parties from asserting contrary positions during subsequent litigation", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 29, "title": "Settlement: Agreement", "summary": "ns during subsequent litigation in this proceeding or related appeals; provided, however, that this Settlement Agreement is made without admission against or prejudice to any factual or legal positions which any of the Settling Parties may assert: (a) if the Commission", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 30, "title": "Settlement: Agreement", "summary": "Settling Parties may assert: (a) if the Commission does not issue a final order that approves this Settlement Agreement without modification; or (b) in other proceedings before the Commission or any other governmental body, so long as such positions do not attempt to a", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 31, "title": "Settlement: Agreement", "summary": "ommission or any other governmental body, so long as such positions do not attempt to abrogate this Settlement Agreement. Upon approval by the Commission, this Settlement Agreement will constitute a final adjudication as to the Settling Parties of all of the issues in t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 32, "title": "Settlement: Agreement", "summary": "is proceeding. 17 54. The signatories hereto represent that they have the authority to execute this Settlement Agreement on behalf of the party for whom they are signing. 55. This Settlement Agreement may be executed in counterparts, and each such counterpart shall be a", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 33, "title": "Settlement: Agreement", "summary": "ity to execute this Settlement Agreement on behalf of the party for whom they are signing. 55. This Settlement Agreement may be executed in counterparts, and each such counterpart shall be as valid as if all signatures appeared on the same page. Delivery of an executed", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 34, "title": "Settlement: Agreement", "summary": "s valid as if all signatures appeared on the same page. Delivery of an executed counterpart of this Settlement Agreement by attachment to electronic mail, facsimile or other electronic method of transmission shall have the same force and effect as the delivery of an ori", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 35, "title": "Settlement: Agreement", "summary": "on shall have the same force and effect as the delivery of an original executed counterpart of this Settlement Agreement. NOW, THEREFORE, intending to bind themselves and their successors and assigns, the undersigned Settling Parties have caused this Settlement Agreemen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 36, "title": "Settlement: Agreement", "summary": "bind themselves and their successors and assigns, the undersigned Settling Parties have caused this Settlement Agreement to be signed by their duly- authorized representatives. [Signatures follow on the next page] 18 EXHIBIT A P.S.C. Del. No. 8 - Electric Delmarva Powe", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 37, "title": "Settlement: agreement", "summary": "-labor O & M inflation adjustment; (d) DPL’s alleged non-compliance with the Commission’s Order and Settlement agreement regarding Excess Accumulated Deferred Income Taxes (\"EDIT\"); (e) the Company's proposed ROE of 10.50% as Staff proposes a Rate of Return of 6.88% and", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 38, "title": "Settlement: Agreement", "summary": "n the News Journal on November 13, 2023.83 44. On November 22, 2023, I was provided with a proposed Settlement Agreement agreed to by Delmarva Power, DPA, DEUG, Walmart, and the Weldin Farms Homeowners. It was shortly thereafter also agreed to by IBEW. The sole party ob", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 39, "title": "Settlement: Agreement", "summary": "eowners. It was shortly thereafter also agreed to by IBEW. The sole party objecting to the proposed Settlement Agreement was and is Commission Staff. The parties also filed the executed, proposed Settlement Agreement in the PSC’s DelaFile document filing system. 45. On", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 40, "title": "Settlement: Agreement", "summary": "sed Settlement Agreement was and is Commission Staff. The parties also filed the executed, proposed Settlement Agreement in the PSC’s DelaFile document filing system. 45. On December 4, 2023, I conducted the duly noticed evidentiary hearing at the Commission’s office in", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 41, "title": "Settlement: Agreement", "summary": "eldin Farms homeowners proffered a total of four (4) witnesses who testified as to why the proposed Settlement Agreement is in the public interest. Additionally, DEUG, IBEW and Walmart proffered a total of three (3) Statements from respective Counsel on the record as to", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 42, "title": "Settlement: Agreement", "summary": "ffered a total of three (3) Statements from respective Counsel on the record as to why the proposed Settlement Agreement is in the public interest. Commission Staff proffered a total of four (4) witnesses who testified as to why the proposed Settlement Agreement is not", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 43, "title": "Settlement: Agreement", "summary": "rest. Commission Staff proffered a total of four (4) witnesses who testified as to why the proposed Settlement Agreement is not in the public interest. 46. The evidentiary record consists of fifty-four (54) admitted hearing exhibits (5 proposed exhibits were excluded),", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 44, "title": "Settlement: Agreement", "summary": "7 - admit those documents into evidence, and hold an evidentiary hearing as to whether the proposed Settlement Agreement is in the public interest. On December 14, 2023, IBEW filed its Answer in Opposition to Staff’s Petition. On December 15, 2023, the Company, the Publ", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 45, "title": "Settlement: AGREEMENT", "summary": "parties’ proposed Settlement Agreement, which I will attach hereto as Exhibit “A:” IV. THE PROPOSED SETTLEMENT AGREEMENT A. Rates and Charges 21. By the rate effective date of ___________, 2024, the Company’s rates will be modified (with proration) to reflect the follow", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 46, "title": "Settlement: Agreement", "summary": "within 120 days of the date the Commission approves this settlement. ADDITIONAL PROVISIONS 1. This Settlement Agreement is the product of extensive negotiation and reflects a mutual balancing of various issues and positions of the Settling Parties. This Settlement Agre", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 47, "title": "Settlement: Agreement", "summary": "ation and reflects a mutual balancing of various issues and positions of the Settling Parties. This Settlement Agreement is expressly conditioned upon the Commission’s approval of all of the specific terms and conditions contained herein without modification. If the Com", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 48, "title": "Settlement: Agreement", "summary": "e Commission fails to grant such approval, or modifies any of the terms and conditions herein, this Settlement Agreement will terminate and be of no force and effect unless the Settling Parties agree in writing to waive the application of this provision. - 33 - OTHER TA", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 49, "title": "Settlement: AGREEMENT", "summary": "d balance of Extremely Significant Storms shall earn a long-term debt return. V. EVIDENCE AS TO WHY SETTLEMENT AGREEMENT IS IN THE PUBLIC INTEREST INTRODUCED AT HEARING 61. On December 4, 2023, I conducted the duly noticed evidentiary hearing as to whether the proposed", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 50, "title": "Settlement: Agreement", "summary": "1. On December 4, 2023, I conducted the duly noticed evidentiary hearing as to whether the proposed Settlement Agreement is in the public interest at the Commission’s office in Dover. At the evidentiary hearing, the Company, DPA, and the Weldin Farms homeowners proffere", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 51, "title": "Settlement: Agreement", "summary": "eldin Farms homeowners proffered a total of four (4) witnesses who testified as to why the proposed Settlement Agreement is in the public interest. Additionally, DEUG, IBEW and Walmart proffered a total of three (3) Statements from respective Counsel on the record as to", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 52, "title": "Settlement: Agreement", "summary": "ffered a total of three (3) Statements from respective Counsel on the record as to why the proposed Settlement Agreement is in the public interest. Commission Staff proffered a total of four (4) witnesses who testified as to why the proposed Settlement Agreement is not", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 53, "title": "Settlement: Agreement", "summary": "rest. Commission Staff proffered a total of four (4) witnesses who testified as to why the proposed Settlement Agreement is not in the public interest. 62. The four (4) witnesses testifying at the evidentiary hearing that the Settlement is in the public interest were: (", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 54, "title": "Settlement: Agreement", "summary": "major points of the proposed Settlement Agreement from the DPA’s perspective. He testified that the Settlement Agreement was in the public interest.107 He testified that there was “a wide range of issues and a lot of disagreements. This is typical in any general rate ca", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 55, "title": "Settlement: terms", "summary": "lders and is viewed as a whole package that weighs multiple considerations that goes into forming a settlement. …115 [T]he terms agreed to reflect a fair and reasonable settlement that is in the best 109 Tr.-114, Tr.-109; Exh. 1; Sec. D. 110 Tr-114, Tr.-109. 111 Tr.-114-15. 112", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 56, "title": "Settlement: Agreement", "summary": "Tr.-212. 150 Tr.-213. 151 Id. 152 Id. 153 Tr.-214. 154 Id. Please see Paragraph 43 of the proposed Settlement Agreement (Exh. A hereto) as to the Electric Vehicle rate design issue. The Settling parties are awaiting initial action by the Governor’s Energy Advisory Coun", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 57, "title": "Settlement: Agreement", "summary": ". It is not something that is just picked up on day one, which ties into the Union’s support of the Settlement Agreement.” 159 91. As to ROE, Attorney Enoch stated: “we originally supported the 10.5% ROE. We do support the 9.6% ROE….” 160[A]n adequate rate of return is", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 58, "title": "Settlement: Agreement", "summary": "eno, principal of Reno Energy Consulting Services, LLC testified. She does not support the proposed Settlement Agreement because she does not believe that it is in the public interest.178 101. According to Witness Reno, the ROE of 9.60% in the proposed Settlement Agreem", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 59, "title": "Settlement: Agreement", "summary": "witness Pfaff, the resulting revenue increase is substantially less than the $42.25 million in the Settlement Agreement.”188 106. As to the proposed Significant Storm Expense Rider (SSER), Witness Bowman testified that it is Staff’s position that Delmarva “needs to mak", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 60, "title": "Settlement: Agreement", "summary": "rs, representing diverse interests, have testified or represented through Counsel that the proposed Settlement Agreement is in the public interest. The Settlement was reached after significant discovery and negotiations between the Parties, including Staff, which does n", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 61, "title": "Settlement: Agreement", "summary": "ettlement persuasive. For the following reasons, I recommend that the Commission approve the entire Settlement Agreement attached hereto as Exhibit “A.” as in the public interest. 144. From its Application through its Rebuttal Testimony when it submitted its 4th quarter", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 62, "title": "Settlement: Agreement", "summary": "671,518 (2Q) to $55,546,586 (3Q), and finally to $53,744,356 (4Q).209 145. Now, there is a proposed Settlement Agreement with a Revenue Requirement of $42,250,000 which, in addition to rates and rate allocation, includes other significant matters: 208 70 Del. Laws, C. 4", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 63, "title": "Settlement: Agreement", "summary": "s proposed Revenue Requirement would be $43.20 million, almost $1 million more than proposed in the Settlement Agreement.210 The question is whether the Company’s entire rate base except DSIC should be “averaged” over 13 months as currently done or year-end rate base ap", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 64, "title": "Settlement: Agreement", "summary": "r transformer capacity additions, asset condition and all distribution automation.” 218 150. In the Settlement Agreement, the Settlement Parties agreed upon a total of $190 million for years 2024 and 2025 combined: The parties agree as follows: D. 2024-2025 Non-Mandator", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 65, "title": "Settlement: Agreement", "summary": "ling Parties-and Staff, agree upon the Capital Spending provision as a significant provision of the Settlement Agreement. This issue is discussed in detail in Section VII of this Report. 153. As to the management audit issue, the Settling Parties have agreed to the foll", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 66, "title": "Settlement: Agreement", "summary": "e benefits of the audit to the ratepayers would greatly outweigh the cost of the audit. 157. In the Settlement Agreement, the Settlement Parties-and Staff agrees, also clarified the Company’s and the customers’ responsibilities regarding Tree Trimming and Vegetation Man", "is_other_matter": false, "recommendations": [], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 67, "title": "Settlement: Agreement", "summary": "not meaningful enough to persuade me to not recommend that the Commission adopt the entire proposed Settlement Agreement. With the Company’s next rate case being filed soon, any issues can be addressed in that case. One important factor to me is Delmarva’s witness Perry", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 68, "title": "Settlement: Agreement", "summary": "40 169. I recommend that the Commission follow the parties’ Significant Storm Rider in the proposed Settlement Agreement. One important factor to me is Delmarva’s witness Perry testifying that Delmarva will be filing “Alternative Rate Making no later than June 2024.”241", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 69, "title": "Settlement: Agreement", "summary": "miles of overbuilt lines.242 These Overvoltage issues are a significant agreed upon portion of the Settlement Agreement, which Staff also agrees to.243 171. The Company’s current ROE is 9.60%. That issue was decided in Docket 20-0149 when the Commission reduced the Com", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 70, "title": "Settlement: Agreement", "summary": "243 Exh. A; ¶¶ 25,26. 244 PSC Order 9953, ¶213; Order¶17 (Jan 26, 2022). - 59 - Before the proposed Settlement Agreement, the Company argued that its ROE should be 10.50%. 245The Settlement Agreement provides that the ROE should be 9.60%. I recommend that the ROE be 9.6", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 71, "title": "Settlement: Agreement", "summary": "Before the proposed Settlement Agreement, the Company argued that its ROE should be 10.50%. 245The Settlement Agreement provides that the ROE should be 9.60%. I recommend that the ROE be 9.60% as agreed upon by the Settling parties. The parties’ positions and my ROE fi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 72, "title": "Settlement: AGREEMENT", "summary": "in accordance with IEEE Std TM1366-2012. VIII. OTHER SIGNIFICANT CONTESTED ADJUSTMENTS SETTTLED BY SETTLEMENT AGREEMENT AND COST OF CAPITAL 183. The following significant adjustments, Cost of Capital and Rate Design are contested being settled by the Settlement Agreeme", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 73, "title": "Settlement: Agreement", "summary": "llowing significant adjustments, Cost of Capital and Rate Design are contested being settled by the Settlement Agreement: - 65 - 1. Storm Restoration Expense (Adj. No. 17) and Significant Storm Expense Rate Rider 2. Covid-19 Regulatory Asset (Adj. No. 28) 3. Excess Defe", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "index": 74, "title": "Settlement: Agreement", "summary": "(Adj. No. 17) and Proposed Significant Damage Expense Rate Rider (“SSER”) 184. Before the parties’ Settlement Agreement, the parties’ respective positions were as described below. The Company first proposed to normalize storm damage expenses based on the most recent th", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 75, "title": "Settlement: Agreement", "summary": "urned to ratepayers. The amounts to be returned to customers, and the methods were addressed in the Settlement Agreement in Delmarva’s prior electric rate case – Docket No. 17-0977. 209. The Settlement Agreement in that case provides as follows: (ii) Settling Parties ag", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 76, "title": "Settlement: Agreement", "summary": "d in the Settlement Agreement in Delmarva’s prior electric rate case – Docket No. 17-0977. 209. The Settlement Agreement in that case provides as follows: (ii) Settling Parties agree that the purpose of the EDIT adjustment is to ensure the full amount of the TCJA tax be", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 77, "title": "Settlement: Agreement", "summary": "6% Indicated Range After Adjustment 9.50% - 11.86% 10.31% - 11.98% PUBLIC ADVOCATE. 221. Before the Settlement Agreement, the Public Advocate’s ROE Expert David J. Garrett recommended a ROE of 9.10%. Witness Garrett’s result is based upon two DCF models (sustainable gro", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 78, "title": "Settlement: Agreement", "summary": "and Staff Witness Reno testified to ROEs of 10.50%, 9.10% and 9.38%, respectively. In the proposed Settlement Agreement, the Settling Parties have agreed upon a ROE of 9.60%, near the mean value of the ROEs from the written testimonies, while keeping the Company’s curr", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 79, "title": "Settlement: Agreement", "summary": "a proposed Order as Exhibit “B” adopting my Findings and Recommendations and approving the proposed Settlement Agreement. February 27, 2024 Respectfully Submitted, /s/ Mark Lawrence Mark Lawrence Senior Hearing Examiner - 114 -", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Cost of service & rates", "Service reliability & vegetation management", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "SC", "source": "Public Service Commission of South Carolina", "doc_type": "proposed order", "id": "2024-04-11_dominion-energy-south-carolina_sc-2024-2-e-proposed-order", "company": "Dominion Energy South Carolina, Inc.", "company_raw": "Dominion Energy South Carolina, Inc.", "docket": "2024-2-E", "docket_full": null, "issued_date": "2024-04-11", "source_page_url": "https://dms.psc.sc.gov/Web/Dockets/Detail/118762", "pdf_download_url": "https://dms.psc.sc.gov/Attachments/Matter/51360053-aa48-4cac-8c1c-ddd6997b76c1", "captured_at": "2026-06-01", "source_note": "Joint Proposed Order on the annual review of Dominion Energy South Carolina, Inc.'s fuel purchasing practices and policies and whether any adjustment in the fuel cost recovery factors is reasonable, before the Public Service Commission of South Carolina, Docket No. 2024-2-E, filed April 11, 2024. Listed for reference (metadata-only). Source: SC PSC Document Management System, Matter 51360053-aa48-4cac-8c1c-ddd6997b76c1 (docket landing: dms.psc.sc.gov/Web/Dockets/Detail/118762).", "archived_via": null, "page_count": 41, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 34, "findings": [ { "index": 1, "title": "Approval: $5,475 ", "summary": "\"DERP\"), as approved in Commission OrderNo. 2015-512. U CI c. DESC agrees to a one-time proposed disallowance of $5,475 from the Company's I O 0 expense for lime at Williams Station. DESC further agrees to a one-time proposed ci disallowance of $43,409 from the Company'", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $43,409 ", "summary": "pany's I O 0 expense for lime at Williams Station. DESC further agrees to a one-time proposed ci disallowance of $43,409 from the Company's DERP incremental costs. Neither of C) these removals will be treated as precedential by the Parties. m d. The cumulative balances o", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $43,409 ", "summary": "rate distributed energy component ofthe overall fuel factor. m O I 14. DESC agreed to a one-time disallowance of $43,409 from the Company's DERP C hD ) incremental costs, which will not be treated as precedentialbythe Settling Parties. 15. DESC agreed to a one-time disal", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 4, "title": "Approval: $5,475 ", "summary": ", which will not be treated as precedentialbythe Settling Parties. 15. DESC agreed to a one-time disallowance of $5,475 from the Company's expense for lime at Williams Station, which will not be treated as precedential by the Settling Parties. Ol Ol 0 16. The Settlement", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $43,409 ", "summary": "approve the DER Incremental Costs, which included an expense from 2019, and reject the proposed disallowance of $43,409 to the Incremental Costs whichwould result in calculations in Corrected ExhibitNo. (JTF-IO). (FarleyRebuttal at 8:3-5). Witness Farleytestifiedthe $43", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Approval: $43,409. ", "summary": "related to DER Incremental Costs, DESC signed the Settlement Ol Ol 0 Agreement and accepted the disallowance of $43,409. With this acceptance, the Company and I O ORS agreed the monthly per account DER Incremental Costs would be: Residential $1.00, U CI Small/Medium Gene", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Approval: $43,409 ", "summary": "$7.64, and Large General Service $100. I O 0 Commission Conclusion ci The Commissionagreesto the disallowance of $43,409 ofIncremental Costswhichresults C) in the following monthly per account DER Incremental Costs amounts: Residential $1.00, m Small/Medium General Servi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Approval: $5,475 ", "summary": "ebuttal 6:15-21). In resolving this issue, DESC signed the Settlement Agreement and accepted the disallowance of $5,475 of these environmental costs. Ol Ol 0 Commission Conclusion I The Commission agrees to the disallowance of $5,475 of expenses for lime at Williams O U", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Approval: $5,475 ", "summary": "5,475 of these environmental costs. Ol Ol 0 Commission Conclusion I The Commission agrees to the disallowance of $5,475 of expenses for lime at Williams O U CI Station. The Settlement Parties negotiated earnestly in good faith and agreed to the terms within I O 0 the Se", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Settlement: Agreement", "summary": "ntto S.C. CodeAnn. 58-4-10(B). t) m m DOCKETNO. 2024-2-E—ORDERNO. CI APRIL, 2024 0 PAGE 3 Z'. CI C. SettlementAgreement On March 26, 2024, the Company, ORS, and SCEUC (\"the Settlement Parties\" ) entered into a SettlementAgreement, acopyofwhichis attached as OrderExhibi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: Agreement", "summary": "Agreement On March 26, 2024, the Company, ORS, and SCEUC (\"the Settlement Parties\" ) entered into a SettlementAgreement, acopyofwhichis attached as OrderExhibit 1.2 Among otherthings, m O I the SettlementParties agreedthe followingpre-filedtestimonieswouldbe admitted i", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Settlement: Agreement", "summary": "e Hyatt (Direct) 4. Omari R. Thompson (Direct). The SettlementParties also agreed as follows: i The Settlement Parties discovered a scrivener's error in the filed Settlement Agreement, and on March 28, 2024, ORS filed a Corrected SettlementAgreementwith the Commission. The Corrected SettlementAgreem", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: Agreement", "summary": "a scrivener's error in the filed Settlement Agreement, and on March 28, 2024, ORS filed a Corrected SettlementAgreementwith the Commission. The Corrected SettlementAgreement is the one referencedthroughoutthis Orderas OrderExhibit I. m m DOCKETNO. 2024-2-E—ORDERNO. CI", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Settlement: Agreement", "summary": "and on March 28, 2024, ORS filed a Corrected SettlementAgreementwith the Commission. The Corrected SettlementAgreement is the one referencedthroughoutthis Orderas OrderExhibit I. m m DOCKETNO. 2024-2-E—ORDERNO. CI APRIL, 2024 0 PAGE4 Z'. a. DESC's calculation of the N", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Settlement: Agreement", "summary": "815. The Settlement Parties agree the appropriate fuel factors for DESC to charge 1. pursuanttothis SettlementAgreementfortheperiodbeginningwiththefirstbilling m m DOCKETNO. 2024-2-E—ORDERNO. CI APRIL, 2024 0 PAGE 7 Z'. CI cycle ofMay 2024 and extending through the las", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 16, "title": "Settlement: Agreement", "summary": "tness testimony. No otherparty filed testimony. As a preliminary matter, the Parties introduced the Settlement Agreement, which was identified and received into evidence as Hearing Exhibit No. I. Upon agreement between all parties, the Chair held Hearing Exhibit 7 open", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Settlement: Agreement", "summary": "2025.t Additionally, Witness Farley presented his rebuttal testimony and testified in support ofthe Settlement Agreement on behalfofthe Company. Witness Fang's exhibitswere acceptedinto evidenceascomposite HearingExhibit 5. 'itness Farley's exhibitswere acceptedinto evi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 18, "title": "Settlement: Agreement", "summary": "nation and review ofthe Company's power plant operations.\" All ORS Witnesses spoke in support ofthe Settlement Agreement. Witness Roland'sexhibitswere acceptedinto evidence ascompositeHearingExhibit9. sWitness Gordon's exhibitwas acceptedinto evidenceatHearingExhibit 8.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Settlement: Agreement", "summary": "edrates to recover fuel costs incurred during the Review Period. 111. FINDINGS OF FACT Based on the Settlement Agreement, the testimony and exhibits received into evidence at the hearing, and the entire record of these proceedings, the Commission makes the following fin", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 20, "title": "Settlement: Agreement", "summary": "Facilities and Third Net Energy Metering for Renewable U CI Energy Facilities, were attached to the Settlement Agreement as Attachments A and B, including I O 0 0 the rates, terms and conditions forthe periodbeginning withthe firstbilling cycle ofMay 2024. 8. DESC propo", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: Agreement", "summary": "Nos. 1-6 The evidence for these findings is contained in the Notice and is supported by the Ol Ol 0 Settlement Agreement; the testimony and exhibits presented by DESC and ORS; and is I uncontrovertedbythe Parties. O U DESC's witnesses, RobertL. Justice, Jr., andHenryE.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: Agreement", "summary": "4-2-E—ORDERNO. CI APRIL, 2024 0 PAGE22 Z'. CI units at the Parr site in accordance with the Partial Settlement Agreement entered in Docket No. 2021-93-E andapprovedbyCommissionOrderNo. 2022-27. (DelkDirect 3:18-21). WitnessDelk informedthe Commission about the ongoing c", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 23, "title": "Settlement: Agreement", "summary": "Evidence and Conclusions for Findings ofFact No. 14 The evidence forthis finding is supportedbythe SettlementAgreement; the testimony and exhibits presentedby DESC and ORS; and is uncontroverted by the Parties. In Company Witness Farley's Rebuttal, the Company request", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 24, "title": "Settlement: Agreement", "summary": "$100. The Settlement Parties negotiated earnestly in good faith and agreed to the terms within the Settlement Agreement, and the Commission finds this disallowance to be just and reasonable and that this term of the Settlement Agreement will notbe treated as precedenti", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 25, "title": "Settlement: Agreement", "summary": "ent, and the Commission finds this disallowance to be just and reasonable and that this term of the Settlement Agreement will notbe treated as precedential. Evidence and Conclusion for Finding ofFactNo. 15 Witness Hyatt testified, during ORS's review ofthe Company's env", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 26, "title": "Settlement: Agreement", "summary": "orded or paid until March 2023. (Farley Rebuttal 6:15-21). In resolving this issue, DESC signed the Settlement Agreement and accepted the disallowance of $5,475 of these environmental costs. Ol Ol 0 Commission Conclusion I The Commission agrees to the disallowance of $5", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 27, "title": "Settlement: terms", "summary": "ommission agrees to the disallowance of $5,475 of expenses for lime at Williams O U CI Station. The Settlement Parties negotiated earnestly in good faith and agreed to the terms within I O 0 the Settlement Agreement, and the Commission finds this disallowance to bejust and reasonable ci and that thi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 28, "title": "Settlement: Agreement", "summary": "The Settlement Parties negotiated earnestly in good faith and agreed to the terms within I O 0 the Settlement Agreement, and the Commission finds this disallowance to bejust and reasonable ci and that this term ofthe SettlementAgreement will notbe treated as precedenti", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 29, "title": "Settlement: Agreement", "summary": "nt, and the Commission finds this disallowance to bejust and reasonable ci and that this term ofthe SettlementAgreement will notbe treated as precedential. C) Evidence and Conclusions for Findings ofFact No. 16-17 m Witness Roland testifiedto examiningthe books andreco", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 30, "title": "Settlement: Agreement", "summary": "2:4-10, 13:4-9, 14:4-8, and 15:3-12 and Exhibits 3, 5-7). Pursuant to the Page 6, Section B.4 ofthe Settlement Agreement, the Settlement Parties agree to the amounts in ORS Witness Roland's Direct Testimony and Exhibits for the Fuel Adjustment Clause forthe Actual Perio", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 31, "title": "Settlement: Agreement", "summary": "d based upon the entire record of these ci proceedings, the Commission finds and concludes that the Settlement Agreement is just, C) reasonable, and in the public interest. m Evidence and Conclusions for Findings ofFactNos. 22 and 23 Dr. Fang prepared a report on behalf", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 32, "title": "Settlement: Agreement", "summary": "-210. Afterhearingandevaluatingthetestimonyofthewitnesses andbasedonthe Commission's m review ofthe SettlementAgreement, the testimony and exhibits submitted during the hearing, and the findings set forth herein, the Commission adopts as just and reasonable and in the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 33, "title": "Settlement: Agreement", "summary": "Commission adopts as just and reasonable and in the public interest all terms and provisions ofthe SettlementAgreement as a comprehensive resolution ofall issues in this docket. IT IS THEREFORE ORDERED THAT: 1. The SettlementAgreement, incorporated herein and attached", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 34, "title": "Settlement: Agreement", "summary": "ent as a comprehensive resolution ofall issues in this docket. IT IS THEREFORE ORDERED THAT: 1. The SettlementAgreement, incorporated herein and attached as Order Exhibit 1, is a reasonable resolution to the issues in this docket and is in the public interest and is he", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "SC", "source": "Public Service Commission of South Carolina", "doc_type": "settlement agreement", "id": "2024-03-28_dominion-energy-south-carolina_sc-2024-2-e-settlement", "company": "Dominion Energy South Carolina, Inc.", "company_raw": "Dominion Energy South Carolina, Inc.", "docket": "2024-2-E", "docket_full": null, "issued_date": "2024-03-28", "source_page_url": "https://dms.psc.sc.gov/Web/Dockets/Detail/118762", "pdf_download_url": "https://dms.psc.sc.gov/Attachments/Matter/63bee92e-ec9c-45c5-bbb3-723f6f840b3e", "captured_at": "2026-06-01", "source_note": "Corrected Settlement Agreement among the South Carolina Office of Regulatory Staff (ORS), Dominion Energy South Carolina, Inc. (DESC), and the South Carolina Energy Users Committee (SCEUC) resolving DESC's 2024 Annual Review of Base Rates for Fuel Costs, before the Public Service Commission of South Carolina, Docket No. 2024-2-E, filed March 28, 2024. Listed for reference (metadata-only). Source: SC PSC Document Management System, Matter 63bee92e-ec9c-45c5-bbb3-723f6f840b3e (docket landing: dms.psc.sc.gov/Web/Dockets/Detail/118762).", "archived_via": null, "page_count": 25, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 34, "findings": [ { "index": 1, "title": "Approval: $5,475 ", "summary": "ram (\"DERP\"), as approved in Commission OrderNo. 2015-512. c. DESC agrees to a one-time proposed disallowance of $5,475 from the Company's expense forlime at Williams Stations. DESC furtheragrees to a one-time proposed disallowance of $43,409 fromthe Company's DERP incr", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $43,409 ", "summary": "om the Company's expense forlime at Williams Stations. DESC furtheragrees to a one-time proposed disallowance of $43,409 fromthe Company's DERP incremental costs. Neitherof these removals will be treated as precedential by the Parties. d. The cumulative balances ofthe Co", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: Agreement", "summary": "Costs ) 4& forDominion Energy South Carolina, Inc. ) CORRECTED SETTLEMKNT Ol AGREEMENT ) 0 ) I This Settlement Agreement is made by and between the South Carolina Office of Ci 0 Regulatory Staff(\"ORS\"), Dominion Energy South Carolina, Inc. (\"DESC\" or \"Company\" ), and Ci", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Settlement: Agreement", "summary": "n\" ) pursuant to the procedure established in S.C. m Code Ann. ) 58-27-865, and the Parties to this Settlement Agreement are parties ofrecord in the above-captioned docket; WHEREAS, the actual period under review in this docket is January I, 2023, through December 31, 2", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: Agreement", "summary": "ionthis Settlement O I io Agreement. C) 2. The Parties agree to those items set out below, and this Settlement Agreement is ia ci hereby adopted, accepted, and acknowledged as the agreement ofthe Parties. co 4& A. STIPULATIONS WITH RESPECT TO TESTIMONY AND CROSS- Ol EXA", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Settlement: Agreement", "summary": "\"Stipulated ci Testimony\" ). to C) a. DESC witnesses: i. Johnathan T. Farley m With respect to this Settlement Agreement, Company Witness Farley and ORS Witness Hyatt are the witnesses designated to be primarily responsible for providing support for the SettlementAgreem", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: Agreement", "summary": "itness Hyatt are the witnesses designated to be primarily responsible for providing support for the SettlementAgreementat the hearing scheduled inthis case. The Parties to the Settlementagree to offer no other evidence in the proceeding other than the Stipulated Testim", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Settlement: Agreement", "summary": "offer no other evidence in the proceeding other than the Stipulated Testimony and Exhibits and this SettlementAgreement with the exception ofchanges to thatwhich would be presented via an erratasheet orthrough awitnessnoting a correctionorclarification, consists ofawit", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: Agreement", "summary": "rs m B.5. The Parties agree the appropriate fuel factors for DESC to charge pursuant to this O I io Settlement Agreement for the period beginning with the first billing cycle of May 2024 and C) extending through the lastbilling cycle ofApril 2025 are listedbelow. in O c", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 10, "title": "Settlement: Agreement", "summary": "me ofthis filing. O I O 0 C. RKMAINING SKTTLKMKNT TERMS AND CONDITIONS ci C. The Parties agree this SettlementAgreement is reasonable, is inthe public interest, 1 to C) is inaccordancewithlawandregulatorypolicy, andagreeto supporttheresolutionofissuesagreed to herein i", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: Agreement", "summary": "reed to herein in this proceeding and not to undertake any action to undermine that support. This m SettlementAgreementin no wayconstitutes awaiveror acceptance ofthe position ofanyParty or its affiliates in any current orfutureproceeding in South Carolina oranyotherju", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 12, "title": "Settlement: Agreement", "summary": "uth Carolina oranyotherjurisdiction. Except as specificallyprovided otherwisepreviouslyherein, this SettlementAgreementdoes not establish any precedent with respect to the issues resolved herein and in no way precludes any Party from advocating an alternative position", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: Agreement", "summary": "ative position in any current or future proceeding in South Carolina or any otherjurisdiction. This Settlement Agreement in no way constitutes a waiveroracceptance ofthe position ofany Party concerning the requirements ofS.C. Code Ann. ) 58—27—865 in any future proceedi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Settlement: Agreement", "summary": "ty facilities so as to provide reliable and high I hD qualityutility services. C) ORS believes this Settlement Agreement reached among the Parties serves the public iii ci interest as defined above. CO 4& C.3. TheParties agree this SettlementAgreementmustbereadandconstr", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Settlement: Agreement", "summary": "ng the Parties serves the public iii ci interest as defined above. CO 4& C.3. TheParties agree this SettlementAgreementmustbereadandconstruedas awhole Ol 0 and to cooperate in good faith with one another in recommending to the Commission that this I Settlement Agreemen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 16, "title": "Settlement: Agreement", "summary": "Ol 0 and to cooperate in good faith with one another in recommending to the Commission that this I Settlement Agreement be accepted and approved by the Commission in its entirety as a fair, Ci 0 reasonable and full resolution ofthe issues set forth in the Company's App", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Settlement: Agreement", "summary": "reviewingcourtintheeventofappeal ci to defend and support any Commission order issued approvingthis Settlement Agreement and the hD C) terms and conditions contained herein. C.4. The Parties offer this Settlement Agreement to the Commission in its entirety as a m 0 comp", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 18, "title": "Settlement: Agreement", "summary": "ttlement Agreement and the hD C) terms and conditions contained herein. C.4. The Parties offer this Settlement Agreement to the Commission in its entirety as a m 0 comprehensive settlement which is the product ofintensive and extensive negotiations between iu Ccl ni the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Settlement: Agreement", "summary": "roduct ofintensive and extensive negotiations between iu Ccl ni the Parties. The Parties agree this Settlement Agreement confers benefits to Parties in exchange C) 0 for concessions by Parties. As such, the Parties ask the Commission to approve this Settlement Ol Agreem", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 20, "title": "Settlement: Agreement", "summary": "ir attorneys, hired consultants, and any independent contractors) agree they have entered into this SettlementAgreement freely andvoluntarily andnone ofthemhave beenpressured orunduly encouraged to enter into this Settlement Agreement. Page 10 m m O 0 C.6. Except as sp", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: Agreement", "summary": "ement freely andvoluntarily andnone ofthemhave beenpressured orunduly encouraged to enter into this Settlement Agreement. Page 10 m m O 0 C.6. Except as specifically provided otherwise previously herein or as necessary to Z'. O effectuate the terms ofthis Settlement Agr", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: Agreement", "summary": "cifically provided otherwise previously herein or as necessary to Z'. O effectuate the terms ofthis Settlement Agreement, the Parties agree that signing this Settlement Agreement (a) will not constrain, inhibit, impair, or prejudice them or their affiliates'rguments m o", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 23, "title": "Settlement: Agreement", "summary": "tanyPartymay seekoradvocate forinanyfutureproceeding. Ifthe Commission R O declines to approve this Settlement Agreement in its entirety and without modification, then any CO 4& Party may withdraw from the Settlement Agreementwithout penalty or further obligation. Ol 0", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 24, "title": "Settlement: Agreement", "summary": "ment Agreement in its entirety and without modification, then any CO 4& Party may withdraw from the Settlement Agreementwithout penalty or further obligation. Ol 0 C.7. This Settlement Agreement shall be interpreted according to South Carolina law. I C.8. This Settlemen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 25, "title": "Settlement: Agreement", "summary": "rty may withdraw from the Settlement Agreementwithout penalty or further obligation. Ol 0 C.7. This Settlement Agreement shall be interpreted according to South Carolina law. I C.8. This Settlement Agreement contains the final and complete agreement of the O 0 O Parties", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 26, "title": "Settlement: Agreement", "summary": "0 C.7. This Settlement Agreement shall be interpreted according to South Carolina law. I C.8. This Settlement Agreement contains the final and complete agreement of the O 0 O Parties. There are no otherterms or conditions to which the Parties have agreed. I O 0 C.9. Th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 27, "title": "Settlement: Agreement", "summary": "conditions to which the Parties have agreed. I O 0 C.9. The Parties represent that the terms ofthis Settlement Agreement are based upon O full and accurate informationknown as ofthe date this SettlementAgreement is executed. If, after hD C) execution, but prior to a Com", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 28, "title": "Settlement: Agreement", "summary": "ofthis Settlement Agreement are based upon O full and accurate informationknown as ofthe date this SettlementAgreement is executed. If, after hD C) execution, but prior to a Commission decision on the merits ofthis proceeding, a Party is made aware of information that", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 29, "title": "Settlement: Agreement", "summary": "t conflicts, nullifies, or is otherwise materially different than the m information upon which this Settlement Agreement is based, that Party may withdraw from the Settlement Agreement with written notice to every otherParty. C.IO. This Settlement Agreement shall bind a", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 30, "title": "Settlement: Agreement", "summary": "n the m information upon which this Settlement Agreement is based, that Party may withdraw from the Settlement Agreement with written notice to every otherParty. C.IO. This Settlement Agreement shall bind and inure to the benefit of each of the signatories hereto and th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 31, "title": "Settlement: Agreement", "summary": "arty may withdraw from the Settlement Agreement with written notice to every otherParty. C.IO. This Settlement Agreement shall bind and inure to the benefit of each of the signatories hereto and their representatives, predecessors, successors, assigns, agents, sharehold", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 32, "title": "Settlement: Agreement", "summary": "greement ofthe Parties hereto. Therefore, each Party acknowledges its consent and agreement to this Settlement Agreement, by Page 11 m m O 0 affixing its signature or by authorizing its counsel to affix his or her signature to this document Z'. O where indicated below.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 33, "title": "Settlement: Agreement", "summary": "ture represents his or her representation that his or her client has authorized the execution ofthe Settlement Agreement. Facsimile signatures and e-mail m signatures shall be as effective as original signatures to bind any Party. This document may be O I hD signed in c", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 34, "title": "Settlement: Agreement", "summary": "re pages combined with the body ofthe document C) constituting an original and provable copy ofthis Settlement Agreement. ia ci [SIGNATURES ON THE FOLLOWING PAGES] co 4& Ol 0 I O 0 O I O 0 ci to C) m Page 12 m m O 0 Z'. WEAGREE: O Representing the South Carolina Office", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Affiliate / intercompany transactions", "Fuel & purchased-power cost recovery" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "NY", "source": "New York State Department of Public Service", "doc_type": "comprehensive management & operations audit final report (independent auditor, LIPA Reform Act)", "id": "2024-03-22_lipa-pseg-li_ny-21-00618-mo-audit-final-report", "company": "Long Island Power Authority and PSEG Long Island, LLC", "company_raw": "Long Island Power Authority and PSEG Long Island, LLC", "docket": "21-00618", "docket_full": null, "issued_date": "2024-03-22", "source_page_url": "https://dps.ny.gov/audit-lipa-and-pseg-long-island", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B00EF678E-0000-CB15-A42B-4743D2FCC852%7D", "captured_at": "2026-06-22", "source_note": "NorthStar Consulting Group's independent Comprehensive Management and Operations Audit of the Long Island Power Authority (LIPA) and its service provider PSEG Long Island, LLC — Matter No. 21-00618, conducted for the NY DPS under the LIPA Reform Act (569 pp). Final report dated March 22, 2024; the audit makes 80 recommendations across core utility operations. Page 1 verified: 'COMPREHENSIVE MANAGEMENT AND OPERATIONS AUDIT OF LONG ISLAND POWER AUTHORITY AND PSEG LONG ISLAND, LLC MATTER NO. 21-00618 ... MARCH 22, 2024 NORTHSTAR CONSULTING GROUP ... FINAL REPORT'. Harvested from the NY DPS DMM via the DPS LIPA-audit landing page. Listed for reference (metadata-only). Source: NY DPS DMM (documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={00EF678E-0000-CB15-A42B-4743D2FCC852}).", "archived_via": null, "page_count": 569, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 13, "findings": [ { "index": 1, "title": "Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "The LIPA Board of Trustee’s should utilize independent, third-party resources to provide “on-call” utility strategy and operations advisory services in review of Board meeting information packets and in advance of Board meetings, when needed, as common among investor-owned utility Boards.", "source_page": null }, { "number": 2, "text": "PSEG LI must provide LIPA with access to detailed ethics and compliance program information regarding concerns, investigations, findings, and resolutions/remediation actions taken.", "source_page": null }, { "number": 3, "text": "PSEG LI must follow its own record management procedures as stated in Practice 105-1 and 105-1- 2. Annual attestations from executive management of each PSEG LI business unit should be completed by the December due date and PSEG LI RMG should perform an evaluation of the program for PSEG LI management and the LIPA’s review. EXECUTIVE SUMMARY NORTHSTAR Rec #", "source_page": null }, { "number": 4, "text": "Conduct an audit of the PSEG LI and LIPA records management programs including Property Records, and the implementation of the ERDMS project. Once the audit is complete, work with the New York State Archive to develop a record inventory and record retention schedule.", "source_page": null }, { "number": 5, "text": "Prioritize implementation of LIPA’s ERDMS so that PSEG LI can use the platform as anticipated in the Second A&R OSA.", "source_page": null }, { "number": 6, "text": "Conduct a comprehensive organization structure analysis of LIPA as well as a skill and capabilities analysis conducted once clarity is given on the future of LIPA by the NY legislature, OSA contract is extended, or a new Service Provider is contracted. Recommendations from this study should be fully implemented in a timely fashion.", "source_page": null }, { "number": 7, "text": "Review skill and capabilities gaps of employees at LIPA and PSEG LI and use results to develop meaningful training and development programs. Increase investment in training and development to at least 2018 levels.", "source_page": null }, { "number": 8, "text": "Implement the LIPA DE&I program with program metrics to report progress to the Board.", "source_page": null }, { "number": 9, "text": "Consistently track and report PSEG LI’s key performance indicators for Management Diversity (Women and PoC), Union Diversity, and commensurate with survey cadence, Employee Engagement to PSEG LI management and LIPA.", "source_page": null }, { "number": 10, "text": "Conduct an audit of PSEG LI compliance with the OSA including, but not limited to Section 10.8.", "source_page": null }, { "number": 11, "text": "Partner with New York State universities for IT and Cybersecurity programs and develop internships for these functional areas.", "source_page": null }, { "number": 12, "text": "Continue the development of LIPA and PSEG LI ERM Programs with the following considerations. • Formally charge “Organizational risk culture and risk awareness” as the responsibility of the LIPA and PSEG LI executive management and LIPA and PSEG LI ERM teams to manage, improve, and report to the LIPA Board. - The LIPA and PSEG ERM teams must analyze “organizational risk culture and risk awareness” and the Board’s ERM policy, #1808, amended September 27, 2023, and recommend changes to the policy to promote management and employee accountability. - Develop a comprehensive program to improve “organizational risk culture and awareness” at LIPA and PSEG LI. The program must include metrics to baseline and report progress in risk culture. - “Organizational risk culture and awareness” must be evaluated during the 2024 risk assessment process for each LIPA and PSEG LI department. - LIPA/PSEG LI ERM teams must investigate incentives and accountability programs used by organizations outside the utility industry to improve risk culture and awareness. • Require risk analysis such as a “bow-tie” analysis for each risk included in department risk profiles and update annually as necessary. • Inves", "source_page": null } ], "themes": [ "Property & plant records", "Cybersecurity & physical security", "Workforce, training & succession planning", "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 2, "title": "Budget And Financial Reporting", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Implement standards and methods to reduce the large variances between budget and actuals for capital projects resulting from: imprecise estimating, overhead assessments without clear cost causation, and significant risk and contingency included in the budgeting process. Include the following enhancements to capital budgeting: - Apply the same standards and methods (or comparable standards and methods) used in the budget briefing book process to capital budgeting. - Use the Hyperion structure and functionality to improve the capital budgeting process.", "source_page": null }, { "number": 14, "text": "Implement processes to measure, analyze, and correct overhead assessments based on valid costs causation principles and clearly demonstrate LIPA/PSEG LI review of how costs were allocated appropriately, including: - Request periodic or annual listing of work orders. Obtain and review costing sheets for a selection of those work orders and analyze whether the overhead assessments assigned to the work orders are appropriate. - Develop summary overhead reporting with underlying overhead charges and allocation rates. - Perform analytics to understand large fluctuations in assessment rates or amounts.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Debt Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Provide disclosures detailing the methodology of the debt-to-asset ratio. Describe obligations not included in debt and grant funded projects included in assets. Reconcile amounts to the financial statements so various stakeholders, beyond rating agencies, can perform a more informed evaluation of fiscal sustainability. None", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Power Supply", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Begin formal record retentions of Power Market Documents", "source_page": null }, { "number": 17, "text": "Calculate the Local Supply Charge for six consecutive months using two methodologies: - The current methodology of subtracting Market Supply Costs from total PSC costs. - A separate methodology of calculating Local Supply Charge using the general ledger 69 accounts for Local Supply Charge. Report findings to DPS.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "System Planning, Dsp Development And Clcpa", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Review the CAC Scoping Plan and identify themes and strategies to align clean energy and EE programs. Identify Scoping Plan topic leads to consider new and innovative programs to further CLCPA goals.", "source_page": null }, { "number": 19, "text": "Create and appropriately resource a group in Construction Services to focus on the scope, scale, and number of projects CLCPA construction programs.", "source_page": null }, { "number": 20, "text": "Perform a review of historical EE goals and budgets to develop goals and “stretch” goals and adopt realistic budgets to meet goals and “stretch goals”.", "source_page": null }, { "number": 21, "text": "Conduct a third-party operations audit of PSEG LI’s clean energy and energy efficiency programs in 2024.", "source_page": null }, { "number": 22, "text": "Improve the visibility of Demand Response programs and their requirements and eligibility on the PSEG LI website. Provide a list of aggregators that would like to be included on the website.", "source_page": null }, { "number": 23, "text": "Develop a DAC investment “tracker” to demonstrate compliance with CLCPA goals by Q2 2024.", "source_page": null }, { "number": 24, "text": "Present CLCPA goals and progress to the Oversight and Clean Energy Committee bi-annually.", "source_page": null }, { "number": 25, "text": "Develop a CLCPA goal and progress tracker to be posted on LIPA and PSEG LI websites to increase public awareness. This CLCPA goal and progress tracker should be refreshed bi-annually. If no progress is made on CLCPA goals for that period, the companies should inform the public why.", "source_page": null }, { "number": 26, "text": "Formalize the Environmental Advisory Committee and provide resources adequate for its success. Create a formal committee charter, develop goals and objectives, track recommendations and deliverables, identify a Committee Secretary to organize meetings, record meeting minutes, and create meeting materials for distribution well in advance of meetings. Report Environmental Advisory Committee findings, recommendations, and actions to the Board’s Oversight and Clean Energy Committee bi-annually. EXECUTIVE SUMMARY NORTHSTAR Rec #", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Transmission And Distribution Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 27, "text": "Make considerations for MAIFI performance in determining the worst performing circuits list.", "source_page": null }, { "number": 28, "text": "Determine the causes for poor SAIFI performance for the following circuits [listed in Chapter IX] that have been unable to be remedied over multiple years. Determine the causes that are within PSEG LI’s control and those outside of PSEG LI’s control and report findings to DPS.", "source_page": null }, { "number": 29, "text": "Document the successful implementation of each of the EAMS functional requirements by a utility using the EAMS software selected before proceeding with implementation.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Program And Project Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 30, "text": "Continue to develop and implement the SOS capital program optimization model. • Expand the SOS platform to include projects from other business units (e.g., IT and Customer Operations) and programs (e.g., Utility 2.0) • Implement improvements such as: - Review the scoring criteria for each business area when setting up a new project in SOS. - Identify any biases toward certain types of projects. - Review the Strategic Objectives and the Success Criteria. • Share SOS output results with LIPA and the Board of Trustees. • Collaborate with Enterprise Risk Management on risk scoring capital projects.", "source_page": null }, { "number": 31, "text": "Review and address inconsistencies as well as the lack of integration in project management procedures.", "source_page": null }, { "number": 32, "text": "Revise current procedures related to quality assurance and quality controls for capital programs and projects requiring project managers to develop a comprehensive quality management plan for each capital project.", "source_page": null }, { "number": 33, "text": "Address the deficiencies in project estimating by making process improvements and adding controls. • Develop cost estimate reports for each stage of capital projects. Formally document project cost reviews at each level of estimate in detail and at various stages of project completion. • Integrate cost and schedule systems and ensure project master schedule is appropriately integrated with the approved project budget. • Continuously verify the accuracy of estimates versus the actual project cost and maintain a record of updates to the estimating database.", "source_page": null }, { "number": 34, "text": "Utilize a WBS in the initial phases of the project justification and order of magnitude estimating, and continue their refinement as the project progresses. • Develop well-defined work packages that can be used to track and measure project performance based on earned value. • Plan work in logical work groupings or packages and subdivide into smaller work groupings. Ensure that activities required to perform the work in each group are identified, defined, and dependent relationships established. • Formalize the use of WBS elements by all project participants in their respective areas of responsibility and as an identification tool for project management performance measurement. • Use the WBS in procurement/contracting activities and specify the WBS in contractor Requests for Proposals. • Use the WBS for project costing and as a means to assess the impact of programmatic changes in funding levels on work content, schedules, and contractual support. • Integrate the WBS with PSEG LI’s accounting systems, project cost management systems and schedule management systems. • Integrate master work plans and detailed contractor schedules / activities to the WBS to permit integration of schedu", "source_page": null }, { "number": 35, "text": "Formalize and incorporate risk and contingency management in capital project cost estimating and cost management. Formally report the expenditure of risk funds and contingency funds separately from project estimates rather than inflate total project budget amounts. Risk funds should be assigned to specific project risks. Use of risk and contingency funds should be approved by the URB. EXECUTIVE SUMMARY NORTHSTAR Rec #", "source_page": null }, { "number": 36, "text": "Define and report project management performance measures that focus on the effectiveness of cost estimation, earned value and schedule management. Project progress reports should contain all information which is pertinent for their target audience. Cost estimates and schedules developed for preliminary plans should be evaluated when a project is complete to determine where further enhancements to project estimating can be made. • Have project managers actively monitor overall project progress against the baseline schedule and review cost versus progress and budget. • Formalize project management performance reporting to LIPA and PSEG LI. • Integrate cost and schedule systems with the project master schedule and the approved project budget. • Develop a baseline schedule for every capital project showing the logical relationships, duration, and timing of the WBS elements for engineering and construction. • Establish processes for systematic schedule preparation, review and analysis. • Include critical path in project schedules. • Periodically, perform analyses of the initial establishment of operation/completion dates.", "source_page": null }, { "number": 37, "text": "Review governance and processes for managing work directives to ensure information on change orders and costs are readily available.", "source_page": null }, { "number": 38, "text": "Review the governance structure and processes for reviewing, screening, and approving capital projects. Develop formal charters for committees, clearly defined purpose, approval and oversight responsibilities, and deliverables. Integrate governance committees, responsibilities, capital project meeting documentation requirements, and stage-gate approvals with Project Management policies and procedures.", "source_page": null }, { "number": 39, "text": "Develop meaningful oversight activities to determine the effectiveness of PSEG LI capital project planning and management and outcomes. This includes, but not limited to, an in-depth analysis of PSEG LI’s scope development and management, risk analysis and management, cost and schedule management, project performance, and quality management practices.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Work Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 40, "text": "Develop an integrated a work management system covering all PSEG LI operations, maintenance and construction resources that are based on engineered time standards and cover routine operations, repetitive maintenance activities, planned work, support requirements, and provide continuous feedback on workforce effectiveness. The system should be in an easy-to-use format expressed in man-hours, along with the combined employee and contractor capacity available to perform the work, supported by real time reporting of capacity utilization. The system should include: • Documentation of work level versus resource histogram development and work plan process. • Enhanced methods to calculate workforce capacity and utilization. • Expanded workforce coverage in reports. • Documentation of processes for establishing workforce levels. • Documentation of criteria for adding contractor capacity. • Establish real time variance reporting for O&M and project costs. • Additional decision-making information to work plans.", "source_page": null }, { "number": 41, "text": "Continue to fill gaps in the current management information reporting and organizational reporting relationships to support an integrated work management system. • Develop formal reports on trends in work load levels, workforce productivity and utilization. The analysis of these trends identifies areas that are performing well, where improvements are needed, and is a foundation for the development of strategies to improve work force performance. • Establish formal processes to use work management data for annual resource planning as part of the annual business planning activities of PSEG LI operations and maintenance. • Refine formal work management practices for PSEG LI engineering and design functions. The work management systems should have appropriate system tools to support the various individual and distinct engineering functional processes. Elements that should be formalized include: - Scheduling EXECUTIVE SUMMARY NORTHSTAR Rec # - Prioritization and planning - Resource allocation and leveling - Performance measurement - Budget planning and control - Vendor tracking - Document/drawing control - Records management - Procurement management - Time reporting.", "source_page": null }, { "number": 42, "text": "Refine overtime targets and performance metrics for PSEG LI operations and maintenance organizations that are based on economic analyses and verified industry norms.", "source_page": null }, { "number": 43, "text": "Review the design of monitoring and controlling reports to improve their usefulness.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Outside Services", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 44, "text": "Improve LIPA and PSEG LI competitive procurement levels to significantly exceed previous levels of performance. • Edit and modify procurement policies and procedures to establish a stronger competitive bias. • Provide formal value analysis of all bid evaluations and selections to record competitive placement with an emphasis on materials and services cost. • Increase approval levels for any non-competitive transactions. • Competitively re-bid contracts or formally re-confirm competitive basis instead of providing funding extensions, renewals and selections among multiple existing contracted suppliers. • Perform a verifiable benchmarking study of large utility purchasing functions to establish best in class performance levels. Use this information to establish stretch targets for future competitive performance goals. • Adopt competitive procurement KPIs and OSA performance metrics. • Develop an improved competitive approach to contractors, their geographic coverage and staggered strategy for multi-year procurement contracts. • Remove end-users from participation in the selection of multiple service providers for similar services or provide specific guidelines to be followed and repo", "source_page": null }, { "number": 45, "text": "Conduct an independent audit of LIPA and PSEG LI supply chain functions directed by DPS to address each of the control deficiencies noted in this chapter to determine whether they have been addressed and effectively resolved.", "source_page": null }, { "number": 46, "text": "Demonstrate that all of the EAMS functional requirements pertaining to supply chain activities (including procurement, materials management and accounts payable) are presently used, operating as planned and effective at another utility using the software platform obtained by LIPA/PSEG LI before proceeding with the EAMS initiative.", "source_page": null } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 10, "title": "Customer Operations And Communication", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 47, "text": "Improve oversight, controls, reporting, and tools for Shared Meter Investigations. • Require Special Investigations supervisors to approve all Shared Meter Reports prior to submittal to Customer Relations. • Require Customer Relations supervisor to approve all Shared Meter penalties and assessments prior to notification of landlords. • Develop in-field tools for investigators that are consistent across all employees and updated as necessary. Discontinue the use of private notes. Tools may include: EXECUTIVE SUMMARY NORTHSTAR Rec # - Checklists - Forms to be completed - Photographs to be taken - New technology such as electronic notebooks etc. • Discontinue the practice of reviewing a week’s worth of investigations on Fridays and require daily reporting.", "source_page": null }, { "number": 48, "text": "For projects where PSEG LI relies heavily on external vendor expertise and support, LIPA should have closer involvement in contracting and project management oversight.", "source_page": null }, { "number": 49, "text": "Determine the extent to which PSEG LI can offer customers bill credits for the purposes of achieving OSA metrics.", "source_page": null }, { "number": 50, "text": "Improve Call Center resource planning, budgeting, and training. • PSEG LI Call Center should have a documented plan and be appropriately prepared for an increase in customer call volume for the 2024 TOD implementation. • Refine Call Center forecasting model to day-of-week and include all resources (including supplemental department support). Call volume forecast should be “tunable” to calculate needs based on variable inputs (e.g., TOD rollout). • The Call Center forecasting model output should be used to inform the call center budget. • Call Center agents should have training on EE programs and information sheets they can send or email customers • Retain records of training material, along with dates of training, and individuals who participated in the training session.", "source_page": null }, { "number": 51, "text": "PSEG LI required Call Center performance metrics should be consistent with Case 15-M-0566 reporting requirements in alignment with other New York utilities. Refer to the four metrics discussed within the Chapter.", "source_page": null }, { "number": 52, "text": "Implement process improvement initiatives for the Household Assistance Program. Scope should include at a minimum: • Update Household Assistance Program processing procedure per report findings. • Create a comprehensive Program Manual for the Household Assistance Program to include end-to-end program management. Include the following: - Stakeholders - Applicable Tariffs - Eligibility - Program goals and KPI’s - Program budget by admin, marketing/outreach and implementation. - File matching cadence - Tier discounts – maintenance of Tier discounts - HAR form – English and other languages - HAR letters – English and other languages - Marketing and Outreach collateral – English and other languages - Marketing and Outreach Strategy - Community Based Organization partners - List of reports with samples. - Training material locations - Audit report locations - Etc. • Establish cadence for receipt of OTDA file and track file match rates. Encourage customers (and change website verbiage) that have received HEAP or Emergency HEAP to apply directly to the utility until a higher rate of customer matching is achieved. • Determine reasons for HAR high rate of denials for manually processed appli", "source_page": null }, { "number": 53, "text": "Update Internal Financial Assistance Program Guide to include HAR.", "source_page": null }, { "number": 54, "text": "Track and coordinate internal referrals to maximize low-income program participation such as between the Household Assistance Program and REAP. Review REAP program eligibility rules and determine if they can be adjusted to align with the Household Assistance Program so participation in one program will qualify for the other.", "source_page": null }, { "number": 55, "text": "Revisit and clarify the net income requirements for $10 Agreement eligibility for payment agreements.", "source_page": null }, { "number": 56, "text": "Evolve marketing and outreach strategies to focus on methods that increase customer participation in the Household Assistance Program and EE programs.", "source_page": null }, { "number": 57, "text": "Implement capital project outreach recommendations from prior NorthStar audit. • Update the External Affairs Handbook to reflect recent lessons learned, the findings in NorthStar’s report. • Implement formal capital outreach training as recommended in the prior NorthStar audit, document attendees, and conduct post-training surveys for continuous improvement. • Develop Tier 3 Capital Project Outreach Plans in accordance with the prior NorthStar audit.", "source_page": null }, { "number": 58, "text": "Improve transparency and controls over EE programs. At a minimum: • Implement approval process for LIPA to approve fund-shifting between EE programs. • Implement processes to increase transparency of EE program funds. Suggest budgeting and tracking at a program level by admin, marketing/outreach, implementation, and rebates/incentives costs.", "source_page": null } ], "themes": [ "Tariff administration & oversight", "Workforce, training & succession planning", "Customer service & billing" ], "cost_to_customers": false }, { "index": 11, "title": "Advanced Metering Infrastructure (Ami)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 59, "text": "Ensure risks associated with system integration projects (Sonic ESB to MuleSoft) overlapping with the system separation program are captured within the appropriate mitigation plan to support the continuation of system separation.", "source_page": null }, { "number": 60, "text": "Create a centralized library to document Data Lake / Tableau reports specifications and business uses.", "source_page": null }, { "number": 61, "text": "Determine if any distribution automation, power quality monitoring, streetlighting controls, pre-pay and collaboration opportunities can be considered in the roadmap.", "source_page": null }, { "number": 62, "text": "Evaluate functionality of the L+G HES Command Center to determine if it is being utilized to its fullest extent.", "source_page": null }, { "number": 63, "text": "Create a mechanism to gather information to determine what factors contributed to program engagement as customers enroll in demand response and energy efficiency programs.", "source_page": null }, { "number": 64, "text": "Determine if reduced truck rolls associated with mapping corrections (eliminating a field visit) can be tracked and included as a future AMI savings category.", "source_page": null }, { "number": 65, "text": "Include documentation of actual meter reader attrition and meter services vehicles for annual O&M Savings support.", "source_page": null }, { "number": 66, "text": "Simplify the AMI benefits reporting workbooks for calculating realized savings.", "source_page": null }, { "number": 67, "text": "Expand AMI benefit workbooks to include AMI benefit tracking for other anticipated AMI benefits such as customer bills savings through TOU rates, revenue protection from theft/tamper, revenue protection from move-in/move-out, and reduced bad debt and write-offs.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Information Technology And Cyber Security", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 68, "text": "Implement the fourteen (14) recommendations as included in the LIPA’s June 2023 IV&V Final Report.", "source_page": null }, { "number": 69, "text": "Continue the development of the PSEG LI cyber security program. Implement a cyber security framework for AMI data.", "source_page": null }, { "number": 70, "text": "Engage a third-party to perform comprehensive vulnerability assessments and penetration tests of the PSEG LI environment on a frequent and consistent basis that is contracted and overseen by LIPA.", "source_page": null }, { "number": 71, "text": "Develop a comprehensive plan and implement each recommendation from the NERC Best Practices Review. EXECUTIVE SUMMARY NORTHSTAR Rec #", "source_page": null }, { "number": 72, "text": "Perform independent audits of the following areas: • The IT System Separation Program • OMS data quality. • PSEG LI’s NERC CIP program (after implementation of each recommendation from the NERC Best Practices Review). • PSEG LI’s AMAG access control system project. • LIPA’s cyber security incident response plan and practices.", "source_page": null }, { "number": 73, "text": "Implement each requirement noted in the PSC Order in Case 13-M-0178.", "source_page": null }, { "number": 74, "text": "Identify and hire a Chief Privacy Officer (CPO) and develop a comprehensive privacy program. • If PSEG LI’s service provider contract is extended with LIPA, identify and hire CPO reporting to the PSEG LI President. Provide the CPO the authority and resources to develop a privacy program. • If the PSEG LI service provider contract is not extended, the successful service provider should be contractually required to have a CPO reporting to the President/CEO of the service provider. Provide the CPO the authority and resources to develop a privacy program. • If New York legislation concerning the Future of LIPA authorizes a municipal model, identify and hire a CPO reporting to the President/CEO. Provide the CPO the authority and resource to develop a privacy program.", "source_page": null }, { "number": 75, "text": "Identify a deadline and expedite development LIPA and PSEG LI internal network monitoring policies and procedures. Assign a LIPA team to provide effective oversight of PSEG LI’s development of their internal network policies and procedures.", "source_page": null } ], "themes": [ "Cybersecurity & physical security", "Information technology & systems" ], "cost_to_customers": false }, { "index": 13, "title": "Performance Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 76, "text": "Identify data sources, methodology for developing summary data, organizational roles and responsibilities, and identify all exclusion/exceptions for the 2024 performance metric “handbook”.", "source_page": null }, { "number": 77, "text": "Track cost savings and productivity gains from capital and O&M programs and projects.", "source_page": null }, { "number": 78, "text": "Identify key operational performance metrics based on strategic goals and objectives and cascade down through the organization and in the OSA. Eliminate metrics that do not actively support these goals and objectives for contract year 2025.", "source_page": null }, { "number": 79, "text": "Align a majority of PSEG LI executive management (Grades LX and 31-33) incentive compensation with achievement of OSA metrics. XVII-1 Record and status accepted management audit recommendations in their original text without revisions, reclassification into other management topic areas or combination with other recommendations that diffuse their intent and timetable for implementation. NORTHSTAR This chapter provides background information on the Long Island Power Authority (LIPA or the Authority) and the status of the implementation of recommendations resulting from the prior management audit as the recommendations pertain to LIPA and its primary outside service provider – PSEG Long Island, LLC (PSEG LI or the Service Provider).1 LIPA provides electric delivery service to approximately 1.2 million customers in Nassau and Suffolk Counties and a portion of Queens County known as the Rockaways (Service Area). The population of the Service Area is approximately 2.9 million. Exhibit II-1 provides an overview of the service territory. Exhibit II-1 During 2022, approximately 53 percent of the Authority’s annual retail revenues were received from residential customers, 44 percent from com", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Customer service & billing", "Cybersecurity & physical security", "Information technology & systems", "Internal audit & internal controls", "Inventory, materials & fleet", "Property & plant records", "Tariff administration & oversight", "Workforce, training & succession planning" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-03-15_appalachian-power-company_fa22-1", "company": "Appalachian Power Company", "company_raw": "Appalachian Power Company (FA22-1)", "docket": "FA22-1", "docket_full": "FA22-1-000", "issued_date": "2024-03-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240315-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240315-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 42, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2019 to June 30, 2023", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "580" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Amortization of Retail Regulatory Assets", "summary": "APCo improperly included the amortization of certain regulatory assets arising from state-jurisdictional rate adjustment clauses in Account 501, Fuel Expense, as an input to the Company’s cost-based formula rates without Commission approval.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 2, "title": "Classification of Purchased Power Costs", "summary": "APCo improperly included approximately $7,606,000 of non-energy costs in the purchased power component of FAC calculations from 2019 to 2021, in which only energy-related economic purchases should be included. As a result, certain FERC-jurisdictional wholesale customers were overcharged by approximately $490,000.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 3, "title": "Fly Ash Sales Revenue and Expense", "summary": "APCo did not exclude the expenses incurred in connection with fly ash sales for beneficial reuse from its wholesale cost-based fuel recovery formulas. By not excluding fly ash sales-related costs as required by its wholesale Requirements Service formulas, APCo overstated its revenue requirement by approximately $178,000.", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 4, "title": "FERC Form No. 580 Reporting", "summary": "APCo did not properly follow the FERC Form No. 580 instructions and, therefore, did not report all required information in its FERC Form No. 580 filings. These actions affected the transparency, accuracy, and usefulness of certain sections of the FERC Form No. 580. D. List of", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-03-07_net-mexico-pipeline-partners-llc_pa23-1", "company": "NET Mexico Pipeline Partners, LLC", "company_raw": "NET Mexico Pipeline Partners, LLC (PA23-1)", "docket": "PA23-1", "docket_full": "PA23-1-000", "issued_date": "2024-03-07", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240307-3007&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240307-3007", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 63, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 to December 31, 2022", "industry": "gas", "audit_type": "non-financial", "functions": [], "forms": [ "549" ], "finding_count": 9, "findings": [ { "index": 1, "title": "Gas Quality Blending Fees", "summary": "NET Mexico charged a shipper a blending fee associated with gas quality specification requirements, without this fee being in its Commission-approved SOC or otherwise authorized by the Commission. As a result, NET Mexico charged that shipper approximately $1.3 million in blending fees that it did not have authority from the Commission to charge.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen procedures and controls to ensure all charges associated with interstate transportation services, including blending fees, are filed with the Commission for review and approval, before assessing those fees to shippers.", "source_page": null }, { "number": 2, "text": "Train staff that administer rate filings and billing processes on the revised procedures and controls and provide periodic training, as needed.", "source_page": null }, { "number": 3, "text": "File with the Commission for review and approval the fee for blending gas if NET Mexico plans to continue charging shippers to blend non- conforming natural gas to meet the gas quality specification provision in section 15.5 of its SOC.", "source_page": null }, { "number": 4, "text": "Refund the amounts collected from shippers, including the unauthorized fee with interest calculated in accordance with 18 C.F.R. § 284.2(b) of the Commission’s regulations. Provide a copy of the billing adjustments and calculations clearly identifying the refund amounts and the accrued interest to audit staff for review within 60 days of the issuance of the audit report.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Maximum Transportation Rates", "summary": "NET Mexico improperly charged two shippers rates that exceeded the maximum allowable rate for interruptible transportation service prescribed in NET Mexico’s SOC. As a result, NET Mexico overcharged these two shippers as it was not permitted to charge a rate above the maximum rate on file with the Commission.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Strengthen procedures and controls to ensure NET Mexico charges rates within the minimum and maximum limits in Exhibit A of the SOC and ensure refunds are issued timely after rates become effective.", "source_page": null }, { "number": 6, "text": "Train staff responsible for NET Mexico’s accounting and billing systems to ensure that the transportation rates in these systems do not deviate from the minimum and maximum limits prescribed in the SOC.", "source_page": null }, { "number": 7, "text": "Refund to shippers, along with interest calculated in accordance with the Commission’s regulations and NET Mexico’s SOC, the amounts overcharged during the audit period. Provide a copy of the billing adjustments and calculations clearly identifying these refunds to audit staff for review within 60 days of the issuance of the audit report.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Commodity Only Firm Transportation Service", "summary": "NET Mexico entered into two commodity only firm transportation service (COFTS) agreements, contrary to the terms of its SOC, which did not provide for COFTS. These service agreements did not include a reservation rate for firm service, and the firm usage (i.e., commodity) rate was higher than the maximum allowed firm usage rate stated in the SOC. Due to these inconsistencies and there being no COFTS rates explicitly stated in the SOC, other shippers may have been unaware of the availability of this type of firm transportation service. Irrespective of the foregoing, audit staff confirmed that there were no instances, during the audit period, when customers with COFTS received priority service over other shippers.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Strengthen procedures and controls to ensure that all transportation service agreements align with its SOC’s Statement of Rates.", "source_page": null }, { "number": 9, "text": "Train relevant staff on the revised procedures and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 10, "text": "If NET Mexico chooses to continue offering COFTS, file revisions to the SOC with the Commission within 60 days from the issuance of this audit report. Revisions made to the statement of rates and terms and conditions of service should clearly distinguish the different types of firm service. If that is the direction NET Mexico chooses, also revise transportation service agreements, as necessary, to include the type of firm service, rates, and other details.", "source_page": null }, { "number": 11, "text": "If NET Mexico chooses not to continue offering COFTS, revise those transportation service agreements to align with the SOC. Provide a copy of the revised transportation service agreements to audit staff for review within 60 days of the issuance of the audit report. Fuel Retainage Quantities", "source_page": null }, { "number": 12, "text": "Strengthen procedures and controls to ensure operational practices align with the SOC as it pertains to in-kind or cash reimbursement for natural gas compressor station fuel use.", "source_page": null }, { "number": 13, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 14, "text": "Update either its SOC or operational practices, or both, to ensure that the SOC aligns with operational practices for fuel retainage or fuel cost reimbursement. If updates are made to the SOC, file those changes with the Commission within 60 days of the issuance of this report.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Fuel Retention Quantities", "summary": "NET Mexico did not retain natural gas from quantities received from shippers used to operate compressor stations on its system, as prescribed by its SOC. Rather than obtaining all of the fuel used at compressor stations in volumes (i.e., in-kind) from its shippers, NET Mexico charged shippers in dollars a pro-rata share of the actual fuel costs incurred to operate its natural gas compressor stations.", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 5, "title": "Nomination Cycles and Deadlines", "summary": "NET Mexico’s nomination cycles and deadlines used in operations did not align with the provisions of its SOC. Although NET Mexico’s nomination procedures followed the North American Energy Standards Board (NAESB) standards, NET Mexico should ensure that the nomination cycles and deadlines specified in its SOC and the operations of its pipeline system are aligned with each other.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Strengthen procedures to ensure that NET Mexico’s nomination cycles and deadlines provided in its SOC align with its pipeline system operations.", "source_page": null }, { "number": 16, "text": "Inform staff responsible for administering and executing nomination cycles and deadlines of any updates to the SOC or changes in pipeline system operations. Similarly, inform staff responsible for updating NET Mexico’s SOC of any changes to administering and executing nomination cycles and deadlines to ensure that the SOC and operational practices align.", "source_page": null }, { "number": 17, "text": "Update either its SOC or operational procedures, or both, to ensure that the SOC and operational practices align with respect to NET Mexico’s nomination cycles and deadlines. If updates are made to the SOC, file those changes with the Commission within 60 days of the issuance of this report.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Operational Flow Order Penalty Calculation", "summary": "NET Mexico’s procedure for calculating Operational Flow Order (OFO) penalties did not align with the provisions of its SOC. Rather than using the pricing point closest to the applicable receipt or delivery point as required by its SOC, NET Mexico’s procedure was to calculate OFO penalties using the Houston Ship Channel index pricing point (HSC index). Although NET Mexico did not assess any OFO penalties during the audit period, NET Mexico should nevertheless ensure that the provisions of its SOC and procedures for calculating OFO penalties are aligned with each other.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Strengthen procedures and controls to ensure operational practices align with the SOC as it pertains to OFO penalty calculations.", "source_page": null }, { "number": 19, "text": "Train relevant staff on the revised procedures and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 20, "text": "Update either its SOC or operational procedures, or both, to ensure the SOC and its operational practices align with respect to OFO penalty calculations. If updates are made to the SOC, file those changes with the Commission within 60 days of the issuance of this report.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Transportation Service Agreements", "summary": "NET Mexico provided section 311 interruptible transportation service to one of its shippers, absent having a readily available service agreement. This prevented audit staff from evaluating whether this shipper’s executed service agreement conformed with Commission regulations and the terms and conditions of NET Mexico’s SOC.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Strengthen procedures and controls to ensure that all executed section 311 transportation service agreements are maintained and readily available for inspection upon request.", "source_page": null }, { "number": 22, "text": "Take necessary steps to locate the missing service agreement or reexecute the historical service agreement with Mex Gas Supply, S.L. (Mex Gas). Provide audit staff a copy of the service agreement upon locating or reexecuting the service agreement within 60 days of the issuance of this audit report.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "FERC Form No. 549D Filing Information", "summary": "NET Mexico did not report complete and accurate information in its FERC Form No. 549D filings. These oversights reduced the completeness, accuracy, and usefulness of the information reported in NET Mexico’s FERC Form No. 549D filings.", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Strengthen procedures and controls to ensure complete and accurate information is reported in the FERC Form No. 549D in accordance with the instructions of the form.", "source_page": null }, { "number": 24, "text": "Train relevant staff on the revised FERC Form No. 549D procedures and controls, including a review of each reporting error to ensure complete and accurate reporting occurs going forward. Also provide periodic training in this area, as needed.", "source_page": null }, { "number": 25, "text": "Refile NET Mexico’s FERC Form No. 549Ds for the audit period with accurate and complete information. Include in the resubmission on field 3a an explanation for the resubmission in accordance with the FERC Form No. 549D instructions.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 9, "title": "FERC Form No. 549D Filing Deadlines", "summary": "NET Mexico did not submit certain FERC Form No. 549D filings within 60 days after each respective quarter as required by Commission regulations. Timely reporting is essential to ensure users of the FERC Form No. 549D can collect information and make informed decisions in a timely manner. D.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Strengthen procedures and controls to ensure that the FERC Form No. 549D filings are submitted to the Commission by the filing deadline.", "source_page": null }, { "number": 27, "text": "Train relevant staff on the revised FERC Form No. 549D filing procedures and controls and provide periodic training in this area, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "SC", "source": "Public Service Commission of South Carolina", "doc_type": "direct testimony", "id": "2024-02-15_dominion-energy-south-carolina_sc-2024-2-e-fuel-testimony", "company": "Dominion Energy South Carolina, Inc.", "company_raw": "Dominion Energy South Carolina, Inc.", "docket": "2024-2-E", "docket_full": null, "issued_date": "2024-02-15", "source_page_url": "https://dms.psc.sc.gov/Web/Dockets/Detail/118762", "pdf_download_url": "https://dms.psc.sc.gov/Attachments/Matter/5fc1fa94-17bc-4d5b-9950-05b8a1f64b84", "captured_at": "2026-06-01", "source_note": "Direct Testimony and Exhibits of Hua Fang (Managing Director, Black & Veatch Corporation) on behalf of Dominion Energy South Carolina, Inc. in its 2024 Annual Review of Base Rates for Fuel Costs, before the Public Service Commission of South Carolina, Docket No. 2024-2-E, filed February 15, 2024. Listed for reference (metadata-only). Source: SC PSC Document Management System, Matter 5fc1fa94-17bc-4d5b-9950-05b8a1f64b84 (docket landing: dms.psc.sc.gov/Web/Dockets/Detail/118762).", "archived_via": null, "page_count": 69, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Approval: $12 million", "summary": "Black 8 Veatch's expert report and recommendations were accepted in its entirety bythe I Board that allowed NSPI to recover $12 million offuel cost incurred during the 2010-2011 winter. O 0 OGBE Gas Transportation and Storage Contracts Review; Oklahoma; 2011-2012 I O Project Lead — Bl", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NJ", "source": "New Jersey Board of Public Utilities", "doc_type": "base-rate case order", "id": "2024-02-14_jersey-central-power-light_nj-er23030144", "company": "Jersey Central Power & Light Company", "company_raw": "Jersey Central Power & Light Company", "docket": "ER23030144", "docket_full": null, "issued_date": "2024-02-14", "source_page_url": "https://publicaccess.bpu.state.nj.us/", "pdf_download_url": "https://www.nj.gov/bpu/pdf/boardorders/2024/20240214/2B%20ORDER%20JCP&L%20Base%20Rate%20Case.pdf", "captured_at": "2026-06-02", "source_note": "Decision and Order Adopting Initial Decision and Stipulation on the verified petition of Jersey Central Power & Light Company (JCP&L) for increases in its electric rates (2023 base-rate filing), NJ BPU Docket No. ER23030144 / OAL PUC 3346-23, issued at the February 14, 2024 agenda meeting. Listed for reference (metadata-only). PDF on the BPU board-orders host www.nj.gov/bpu/pdf/boardorders/2024/20240214/; docket system: publicaccess.bpu.state.nj.us.", "archived_via": null, "page_count": 418, "scanned_pages": [ 10, 212, 231, 329, 332, 366, 390, 402 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MN", "source": "Minnesota Office of Administrative Hearings", "doc_type": "ALJ findings & recommendation re settlement (gas rate case)", "id": "2024-02-13_centerpoint-minnesota-gas_mn-g-008-gr-23-173-alj-report", "company": "CenterPoint Energy Resources Corp. (CenterPoint Energy Minnesota Gas)", "company_raw": "CenterPoint Energy Resources Corp. (CenterPoint Energy Minnesota Gas)", "docket": "OAH 65-2500-39699 / MPUC G-008/GR-23-173", "docket_full": null, "issued_date": "2024-02-13", "source_page_url": "https://mn.gov/oah/lawyers-and-litigants/administrative-law/opinion-archive.jsp", "pdf_download_url": "https://mn.gov/oah/assets/2500-39699-centerpoint-rate-increase-report_tcm19-669397.pdf", "captured_at": "2026-06-08", "source_note": "Minnesota OAH ALJ report re parties settlement in CenterPoint Energy Minnesota Gas rate case, MPUC G-008/GR-23-173 (OAH 65-2500-39699), dated 2024-02-13. PDF: mn.gov/oah/assets/2500-39699-...pdf.", "archived_via": null, "page_count": 22, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "reconciliation petition", "id": "2024-02-02_commonwealth-edison_icc-24-0087-cfra-petition", "company": "Commonwealth Edison Company", "company_raw": "Commonwealth Edison Company", "docket": "24-0087", "docket_full": null, "issued_date": "2024-02-02", "source_page_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/346818", "pdf_download_url": "https://www.icc.illinois.gov/docket/P2024-0087/documents/346818/files/605464.pdf", "captured_at": "2026-06-01", "source_note": "Verified Petition of Commonwealth Edison Company (ComEd) for reconciliation of revenues billed under Rider CFRA (Carbon-Free Resource Adjustment) against actual costs associated with carbon-mitigation-credit expenditures, Illinois Commerce Commission Docket 24-0087, filed February 2, 2024. Listed for reference (metadata-only). Source: ICC e-Docket, document 346818 / file 605464 (landing: www.icc.illinois.gov/docket/P2024-0087/documents/346818).", "archived_via": null, "page_count": 6, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2024-01-26_northwestern-wisconsin-electric-company_fa23-3", "company": "Northwestern Wisconsin Electric Company", "company_raw": "Northwestern Wisconsin Electric Company (FA23-3)", "docket": "FA23-3", "docket_full": "FA23-3-000", "issued_date": "2024-01-26", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20240126-3008&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20240126-3008", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 40, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2020 through July 31, 2023", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Transmission Revenue Credits", "summary": "NWECo improperly excluded certain transmission-related revenues from its wholesale transmission formula rate annual transmission revenue requirement (ATRR) computation. As a result, NWECo understated the transmission revenue credits included in its transmission formula rate, which led to an overstatement of its ATRR and billings to its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies and procedures to properly include transmission revenue credit inputs in the ATRR and customer billing charges consistent with the requirements of its transmission formula rate.", "source_page": null }, { "number": 2, "text": "Provide training to relevant staff on the revised policies and procedures, and provide periodic training, as needed.", "source_page": null }, { "number": 3, "text": "Submit a refund analysis, within 90 days of issuance of this audit report, to audit staff that explains and details the following: (1) calculation of refunds that includes the amount of inappropriate recoveries that resulted from the improper exclusion of transmission-related rental revenues during the audit period, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 4, "text": "File a refund report with the Commission after receiving audit staff’s assessment of the refund analysis.", "source_page": null }, { "number": 5, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Income Tax Receivables", "summary": "NWECo improperly recorded income tax receivable amounts as prepayments in Account 165, Prepayments. As a result, NWECo improperly included the amounts in its transmission formula rate, which led to an overstatement of its ATRR and billings to its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Revise accounting policies and procedures to properly account for income tax transactions consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 7, "text": "Provide training to relevant staff on the revised policies and procedures to properly account for income tax transactions, and provide periodic training, as needed.", "source_page": null }, { "number": 8, "text": "Submit a refund analysis to audit staff, within 90 days of the date of this audit report, that explains and details the following: (1) calculation of refunds that results from excluding the 2015 and 2016 additional tax payments from its transmission rate base during the audit period, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 9, "text": "File a refund report with the Commission after receiving audit staff’s assessment of the refund analysis.", "source_page": null }, { "number": 10, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting Misclassifications", "summary": "NWECo recorded various operation and maintenance (O&M) and administrative and general (A&G) expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, NWECo overstated its ATRR and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise accounting policies and procedures to help ensure that NWECo properly accounts for expenditures consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 12, "text": "Provide training to relevant staff on the revised policies and procedures to properly account for expenditures, and provide periodic training, as needed.", "source_page": null }, { "number": 13, "text": "Perform an analysis of O&M and A&G expense accounts from 2020 to the present to identify costs that were improperly accounted for and included in NWECo’s transmission formula rate calculations and the related customer billings, such as donations and distribution O&M costs. Provide the results of the analysis to audit staff within 90 days of the date of issuance of the audit report.", "source_page": null }, { "number": 14, "text": "Submit a refund analysis, within 90 days of issuance of this audit report, to audit staff that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting for expenses recorded in O&M and A&G accounts from 2020 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 15, "text": "File a refund report with the Commission after receiving audit staff’s assessment of the refund analysis.", "source_page": null }, { "number": 16, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Application of Nonapproved Depreciation Rates", "summary": "NWECo applied depreciation rates for accounting and ratemaking purposes that were not filed with, and approved by, the Commission. As a result, the Commission was not afforded an opportunity to review or decide on the appropriateness of the inclusion of the depreciation rates in transmission service rate determinations.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Develop and implement processes and procedures to help ensure that depreciation rates and related studies are filed with the Commission for consideration and decision before being used for transmission ratemaking purposes.", "source_page": null }, { "number": 18, "text": "Provide training to relevant staff on the processes and procedures, and provide periodic training, as needed.", "source_page": null }, { "number": 19, "text": "File current depreciation studies and associated depreciation rates in dockets relating to its wholesale transmission formula rate within 180 days of issuance of the audit report. Excess Accumulated Deferred Income Tax", "source_page": null }, { "number": 20, "text": "Revise accounting policies and procedures to help ensure NWECo properly records and reports the effect of changes in tax laws or tax rates resulting from the TCJA consistent with the Commission’s accounting guidance in Docket No. AI93- 5.", "source_page": null }, { "number": 21, "text": "Provide training to relevant staff on the revised policies and procedures for recording and reporting the effect of changes in tax laws or tax rates, and provide periodic training, as needed.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 5, "title": "Excess Accumulated Deferred Income Tax (ADIT)", "summary": "NWECo improperly recorded the excess ADIT related to the corporate tax rate change and associated adjustments required due to the Tax Cuts and Jobs Act of 2017 (TCJA) in Account 282, Accumulated Deferred Income Taxes – Other Property, instead of Account 254, Other Regulatory Liabilities. This action affected the transparency and accuracy of the excess ADIT amounts reported in NWECo’s FERC Form No. 1 and 3-Q report filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "FERC Form No. 1 Reporting", "summary": "NWECo did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. These actions affected the transparency and accuracy of the reported information. D.", "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Revise and strengthen policies and procedures to report correct, accurate, and complete information in the FERC Form No. 1 consistent with the page instructions. Work with third-party vendor to correct software limitations to prevent reporting incomplete information.", "source_page": null }, { "number": 23, "text": "Provide training to relevant staff on the revised FERC Form No. 1 reporting policies and procedures, and provide periodic training, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "SD", "source": "South Dakota Public Utilities Commission", "doc_type": "rate case order", "id": "2024-01-17_northwestern-energy_sd-el23-016-amended-settlement-order", "company": "NorthWestern Corporation d/b/a NorthWestern Energy", "company_raw": "NorthWestern Corporation d/b/a NorthWestern Energy", "docket": "EL23-016", "docket_full": null, "issued_date": "2024-01-17", "source_page_url": "https://puc.sd.gov/Dockets/Electric/2023/EL23-016.aspx", "pdf_download_url": "https://puc.sd.gov/commission/dockets/electric/2023/el23-016/EL23-016settlementAmended.pdf", "captured_at": "2026-06-19", "source_note": "Amended Order Granting Joint Motion for Approval of Settlement Stipulation in NorthWestern Energy's electric rate increase, SD PUC Docket EL23-016. PDF: puc.sd.gov/commission/dockets/electric/2023/el23-016/EL23-016settlementAmended.pdf. Listed for reference (metadata-only).", "archived_via": null, "page_count": 2, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "WV", "source": "Public Service Commission of West Virginia", "doc_type": "fuel cost review order", "id": "2024-01-09_appalachian-wheeling-power_wv-23-0377-e-enec", "company": "Appalachian Power Company and Wheeling Power Company", "company_raw": "Appalachian Power Company and Wheeling Power Company", "docket": "23-0377-E-ENEC", "docket_full": null, "issued_date": "2024-01-09", "source_page_url": "http://www.psc.state.wv.us/scripts/WebDocket/tblCaseActivitiesList.cfm?CaseID=82133", "pdf_download_url": "http://www.psc.state.wv.us/scripts/WebDocket/ViewDocument.cfm?CaseActivityID=616349&NotType=WebDocket", "captured_at": "2026-06-02", "source_note": "Commission Order in the annual Expanded Net Energy Cost (ENEC) review of Appalachian Power Company and Wheeling Power Company (AEP), West Virginia PSC Case No. 23-0377-E-ENEC (consolidated with 22-0393-E-ENEC and 21-0339-E-ENEC), entered January 9, 2024 — disallowing $231.8 million of the requested ENEC under-recoveries as imprudent (coal-stockpiling practices) and assessing the remaining ~$321.1 million over a ten-year period with a 4% carrying charge. Listed for reference (metadata-only). Source: WV PSC WebDocket, document CaseActivityID 616349 (case activities list: psc.state.wv.us/scripts/WebDocket/tblCaseActivitiesList.cfm?CaseID=82133).", "archived_via": null, "page_count": 37, "scanned_pages": [ 13, 14, 19, 23 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 13, "findings": [ { "index": 1, "title": "Disallowance: $82.6 million", "summary": "at least one year; (2) a freeze on filing a full Base Rate case until April 2025; and (3) a minimum $82.6 million disallowance. Given those conditions, WVEUG preferred the securitization proposal. Staff, through the testimony and evidence of Critical Technologies Consulti", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 2, "title": "Disallowance: $231,769,431.", "summary": "prudent decisions, actions, and inactions, and have, therefore, quantified a disallowance amount of $231,769,431. We have also fully considered the disallowances recommended by other parties. The methodologies for calculating those disallowances will not be adopted by the Commission. Instead, we use", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $231.8 million", "summary": "ly the Companies) net Expanded Net Energy Cost (ENEC) costs and under-recoveries. The Commission disallows $231.8 million of requested ENEC under-recoveries. The remaining balance of the requested under-recoveries, which is currently $321.1 million, will not be allowed i", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $552.9 ", "summary": "that the Commission disallow the entire under-recovery. Alternatively, to the extent the Commission allows any portion of the $552.9 accumulated under-recovery in rates, the CAD recommended that the amount allowed be amortized over no less than five years with no carrying charge. Th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $82.6 million", "summary": "lowed be amortized over no less than five years with no carrying charge. The WVEUG recommended a disallowance of $82.6 million before any consideration of amortization or securitization. WVEUG further recommended that any balance recoverable in rates be allowed a carrying cha", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 6, "title": "Approval: $257,993,417 ", "summary": "nsulting (CTC), recommended that the Commission find imprudence on the part of the Companies and disallow $257,993,417 of the under-recovery. 2023 ENEC, Tr. Sept. 7, 2023 at 408. Q. If the Companies could have, based on the market conditions that we've talked about, th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Approval: $231,769,431.\n", "summary": "and the result of imprudent decisions, actions, and inactions, and have, therefore, quantified a disallowance amount of $231,769,431. We have also fully considered the disallowances recommended by other parties. The methodologies for calculating those disallowances will not be adopte", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Approval: $231,769,431 ", "summary": "costs and the prudence or imprudence of the Companies' actions or inactions. Our calculation and disallowance of $231,769,431 does not take into consideration that the power plants were offline and unavailable for generation at times when market prices were very high and ther", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Approval: $231.8 million", "summary": "mber 1, 2024. Accordingly, the requested under-recovery balance of $552.9 million will not be fully allowed for recovery in rates. Instead, $231.8 million will be specifically disallowed for reasons explained herein. The remaining balance, currently $321 .I million, will continue to be deferred unti", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Approval: $321 ", "summary": "on will not be fully allowed for recovery in rates. Instead, $231.8 million will be specifically disallowed for reasons explained herein. The remaining balance, currently $321 .I million, will continue to be deferred until September 1, 2024, at which time we will allow amortization through rates ove", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Approval: $231.8 million", "summary": "curitized under-recovery and deferred costs. Admittedly, there is a price tag of the decision to disallow $231.8 million of the under-recovery and allow the balance of $321.1 million to be recovered over ten years beginning September 2024. With the four percent carrying", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Approval: $321.1 million", "summary": "mittedly, there is a price tag of the decision to disallow $231.8 million of the under-recovery and allow the balance of $321.1 million to be recovered over ten years beginning September 2024. With the four percent carrying charge authorized in this Order, the allowable under-recovery", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Approval: $321 ", "summary": "Commission disallows $231,769,431 of the under-recovery requested by the Companies. The Commission approves the remaining approximately $321 .Im illion under-recovery to be recovered through an ENEC rate increment designed to recover that amount over ten years, including a 4 percent per yea", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery", "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MD", "source": "Maryland Public Service Commission", "doc_type": "multi-year rate plan order", "id": "2023-12-14_baltimore-gas-electric_md-9692", "company": "Baltimore Gas and Electric Company", "company_raw": "Baltimore Gas and Electric Company", "docket": "9692", "docket_full": null, "issued_date": "2023-12-14", "source_page_url": "https://www.psc.state.md.us/", "pdf_download_url": "https://psc.maryland.gov/wp-content/uploads/Order-No.-90948-BGE-Rate-Order-1-1.pdf", "captured_at": "2026-06-02", "source_note": "Order No. 90948 on Baltimore Gas and Electric Company's application for an electric and gas Multi-Year Rate Plan, Maryland PSC Case No. 9692, issued December 14, 2023 (Maillog 306673). Listed for reference (metadata-only). PDF on the Maryland PSC host psc.maryland.gov/wp-content/uploads/ (Cloudflare-fronted but serving); case jacket in the PSC DMS case-search (case 9692).", "archived_via": null, "page_count": 302, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 17, "findings": [ { "index": 1, "title": "Disallowance: $27.8 million", "summary": "PC witnesses Alvarez and Stephens argued that BGE’s capital spend for system performance in 2022 by $27.8 million (27.2%) over budget should be disallowed because “system performance spending is discretionary as to timing and extent…”747 OPC argued that by the time a second major storm hit the BGE t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $149.1 million", "summary": "his case, the Commission will apply the Present Value Method to BGE’s service lives. The Commission approves a depreciation expense of $149.1 million for BGE’s electric plant, as recommended by Staff. The Commission further approves BGE’s proposed net salvage rates, calculated under the Maryland Pr", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 3, "title": "Approval: $38.2 million", "summary": "GE’s proposed accelerated cable replacement schedule and recommended instead that the Commission disallow the $38.2 million that the accelerated schedule would cost. OPC witness Stephens testified that BGE has proposed to spend $89.6 million replacing underground cable in", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $4.2 million", "summary": "MYP period.299 For the same reasons articulated by Mr. Clementson, Mr. Austin recommended a full disallowance of the $4.2 million that BGE is proposing to spend on the electric side 295 The Commission also assessed a civil penalty against BGE in the amount of $437,294. Order No.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $000,000", "summary": "llowance for electric costs should be revised as follows. Table 3 BGE proposed revision to Staff Disallowance ($000,000) 2021 2022 2023 2024 2025 2026 Electric Project $7.0 $1.2 $0.3 $0.3 $0.3 $0.3 68155 In his surrebuttal testimony, Mr. Clementson reversed his recomme", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Approval: $7 million", "summary": "commendation to reflect BGE witness Frain’s revised estimation of costs in rebuttal testimony to disallow $7 million in 2021 and $1.2 million in 2022.314 In his surrebuttal testimony, Mr. Austin also changed his recommendation from his direct testimony. After review", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Approval: $4.2 million", "summary": "tated that he accepted the Company’s analysis and rescinded his previous recommendation to fully disallow the $4.2 million BGE proposed to spend on the common trench program in this MYP period.315 Therefore, Mr. Austin recommended that BGE be disallowed only $900,000 of t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Approval: $900,000 ", "summary": "n the common trench program in this MYP period.315 Therefore, Mr. Austin recommended that BGE be disallowed only $900,000 of the $4.2 million it initially proposed to spend on its CTES – Electric program for the MYP 2 period. Commission Decision The Commission accepts Sta", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Approval: $900,000 ", "summary": "BGE sought $4.2 million for the CTES- Electric program, Mr. Austin revised his recommendation to disallow only $900,000 of the $4.2 million originally requested for the MYP 2 period. The Commission accepts Staff’s recommendation. Finally, the Commission observes that th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Approval: $17.5 million", "summary": "buttal at 14. 90 reduce the 2021-2023 revenue requirements accordingly. The Commission will also disallow recovery for the $17.5 million BGE requested in its MYP application. Nevertheless, the Commission finds that BGE raises a fair point about adjusting the 2021 reconciliation under-r", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Approval: $120 million", "summary": "ed to the condition of the conduit.418 Accordingly, Mr. Stephens recommended that the Commission disallow the entire $120 million in the conduit system, as it is not in the best interest of ratepayers.419 In his rebuttal testimony, Mr. Vahos testified that a change in Baltimore", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Approval: $30\nmillion", "summary": "466 Similarly, OPC witness Stephens did not change his recommendation. Despite the lure of the IIJA grant, he argued that “misspending $30 million to capture such savings does not constitute a bargain for customers.”467 Commission Decision The Commission will grant in part Staff’s proposal by de", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Approval: $30.8 million", "summary": "communities in central Maryland, and BGE was awarded that grant on June 16, 2023.473 As part of the grant requirements, BGE must spend more than $30.8 million by the end of June 2027 in order to receive the full $15 million that the NTIA authorized.474 The Commission supports BGE’s Middle Mile Proje", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Approval: $3.38\nmillion", "summary": "ter planning.525 Instead, Dr. Hopkins recommended that for this first MYP period, the Commission disallow a portion of BGE’s capital spending on mains and services – amounting to $3.38 million.526 He argued that the Commission should send a message that if BGE’s planning does not improve, the Commis", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Approval: $27.8\nmillion", "summary": "ould be deemed imprudent. Based on the foregoing, the Commission rejects OPC’s recommendation to disallow the Company’s request for $27.8 million for its system performance work. This decision does not abrogate BGE’s duty to carefully consider if spends should be deferred into future years if c", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 16, "title": "Approval: $4.1 million", "summary": "ed future clean-up costs that may or may not be recoverable in rate base.873 He also recommended disallowance of the $4.1 million that would be required for the accelerated distribution substation oil circuit breaker replacement program, with any significant variance of expendit", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 17, "title": "Approval: $200,000 ", "summary": "was also well-argued in Case No. 9645, where the Commission found Schedule T to be over-earning and approved a $200,000 reduction from Schedule T revenues as a part of Step-One of the 1193 Id. at 18. 259 revenue allocation methodology. The Commission now directs BGE to", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Cost of service & rates", "Depreciation" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "NM", "source": "New Mexico Public Regulation Commission", "doc_type": "rate case recommended decision", "id": "2023-12-08_public-service-company-of-new-mexico_nm-22-00270-ut-recommended-decision", "company": "Public Service Company of New Mexico (PNM)", "company_raw": "Public Service Company of New Mexico (PNM)", "docket": "22-00270-UT", "docket_full": null, "issued_date": "2023-12-08", "source_page_url": "https://www.prc.nm.gov/nmprc-legal-notices/", "pdf_download_url": "https://www.prc.nm.gov/wp-content/uploads/2023/12/prs10051295doc.pdf", "captured_at": "2026-06-19", "source_note": "Hearing Examiners' Recommended Decision in PNM's retail electric rate revision, NM PRC Case No. 22-00270-UT; 384 pp. Examines PNM's costs and revenue requirement. PDF: prc.nm.gov/wp-content/uploads/2023/12/prs10051295doc.pdf. Listed for reference (metadata-only).", "archived_via": null, "page_count": 384, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on wholesale power contracts", "id": "2023-12-05_wabash-valley-power_er20-1041", "company": "Wabash Valley Power Association, Inc.", "company_raw": "Wabash Valley Power Association, Inc.", "docket": "ER20-1041", "docket_full": null, "issued_date": "2023-12-05", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20231205-3095&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20231205-3095", "captured_at": "2026-06-07", "source_note": "FERC Order Rejecting Wholesale Power Supply Contracts and Notices of Cancellation re Wabash Valley Power Association, Inc., Docket ER20-1041, issued 2023-12-05 — addressing the reasonableness of wholesale power-supply contract terms. Metadata-only (free-form legal order). Found via the eLibrary AdvancedSearch API (searchText=ER20-1041); accession 20231205-3095.", "archived_via": null, "page_count": 61, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "FL", "source": "Florida Public Service Commission", "doc_type": "final order on storm cost recovery", "id": "2023-11-29_florida-iou_fl-20230010-ei-psc-2023-0364-fof-ei", "company": "Florida investor-owned electric utilities (storm protection plan cost recovery)", "company_raw": "Florida investor-owned electric utilities (storm protection plan cost recovery)", "docket": "20230010-EI", "docket_full": null, "issued_date": "2023-11-29", "source_page_url": "https://www.psc.state.fl.us/document-detail?orderNum=PSC-2023-0364-FOF-EI", "pdf_download_url": "https://www.psc.state.fl.us/library/Orders/2023/06328-2023.pdf", "captured_at": "2026-06-07", "source_note": "Florida PSC Order No. PSC-2023-0364-FOF-EI (Final Order), Docket No. 20230010-EI, 'Storm protection plan cost recovery clause', issued November 29, 2023 (26 pp) — the Commission's annual review of the reasonableness of storm-protection-plan costs and the resulting cost-recovery factors for Florida's investor-owned electric utilities. Listed for reference (metadata-only). Source: Florida PSC document clerk, document 06328-2023 (psc.state.fl.us/library/Orders/2023/06328-2023.pdf).", "archived_via": null, "page_count": 26, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 13, "findings": [ { "index": 1, "title": "Approval: $1,307,293,308 ", "summary": "3-2032 Storm Protection Plan filed in Docket No. 20220051-EI. Based on our review of the record, we approve $1,307,293,308 as FPL’s reasonably estimated 2023 costs and an under-recovery amount of $14,860,970 as FPL’s jurisdictional cost recovery true-up amount, including i", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 2, "title": "Approval: $212,589,753 ", "summary": "d 2022 Storm Protection Plan filed in Docket No. 20220048-EI. Based on our review of the record, we approve $212,589,753 as TECO’s reasonably projected 2024 costs and a jurisdictional revenue requirement of $90,584,791 for the period January 2024 through December 2024. 2", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 3, "title": "Approval: $783,792,564 ", "summary": "ORDER NO. PSC-2023-0364-FOF-EI DOCKET NO. 20230010-EI PAGE 17 Based on our review of the record, we approve $783,792,564 as DEF’s reasonably projected 2024 costs and a jurisdictional revenue requirement of $201,370,792 for the period January 2024 through December 2024. 3", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $13,620,916 ", "summary": "proved Storm Protection Plan filed in Docket No. 20220049-EI. Based on our review of the record, we approve $13,620,916 as FPUC’s reasonably projected 2024 costs and a jurisdictional revenue requirement of $2,448,891 for the period January 2024 through December 2024. 4.", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 5, "title": "Approval: $1,389,706,289 ", "summary": "3-2032 Storm Protection Plan filed in Docket No. 20220051-EI. Based on our review of the record, we approve $1,389,706,289 as FPL’s reasonably projected 2024 costs and a jurisdictional revenue requirement of $513,855,741 for the period January 2024 through December 2024. S", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 6, "title": "Settlement: agreement", "summary": "-0364-FOF-EI DOCKET NO. 20230010-EI PAGE 3 Florida, LLC (DEF) in 2020. All of the utilities reached settlement agreements with various intervenors regarding the SPPs prior to final hearing. We approved these settlement agreements on August 28, 2020.1 On March 9, 2022, p", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: agreement", "summary": "nt agreements with various intervenors regarding the SPPs prior to final hearing. We approved these settlement agreements on August 28, 2020.1 On March 9, 2022, pursuant to Sections 366.96(5) and 366.96(6), F.S., and consistent with the terms of the above-referenced set", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Settlement: agreement", "summary": "nt to Sections 366.96(5) and 366.96(6), F.S., and consistent with the terms of the above-referenced settlement agreements,2 FPL, TECO, and DEF filed their first updated SPPs for our review.3 On that same date, Florida Public Utilities Company (FPUC) submitted its initia", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: agreement", "summary": "da Power & Light Company; and 20200092-EI, In re: Storm Protection Plan cost recovery clause. 2 The settlement agreements required these utilities to file updated plans in 2022, consistent with the requirement in section 396.96(6), F.S., that we are to review utility SP", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 10, "title": "Settlement: Agreement", "summary": "o the facts in the record related to actual costs incurred in 2022. A. TECO, DEF & FPL Based on the Settlement Agreements we approved in Order No. PSC-2020-0293-AS-EI,10 OPC takes no position on the factors only for TECO, DEF, and FPL. The remaining intervenors concur w", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: Agreement", "summary": "PP and SPPCRC dockets for TECO, DEF, and FPL/Gulf Power Company. FPUC was not a party to any of the Settlement Agreements approved in that Order. ORDER NO. PSC-2023-0364-FOF-EI DOCKET NO. 20230010-EI PAGE 7 1. TECO In support of TECO’s 2022 true-up recovery amount, TECO", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Settlement: Agreement", "summary": "ng interest, for the period January 2022 through December 2022. B. FPUC FPUC was not a party to the Settlement Agreements we approved in Order No. PSC- 2020-0293-AS-EI, and submitted its initial SPP later than the other utilities.11 Because of these distinctions and the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: agreement", "summary": "Nos. 20190110-EI, 20190222-EI & 20210016-EI, In re: Petition for limited proceeding to approve 2021 settlement agreement, including general base rate increases, by Duke Energy Florida, LLC. ORDER NO. PSC-2023-0364-FOF-EI DOCKET NO. 20230010-EI PAGE 20 3. FPUC FPUC shall", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-11-21_dte-energy-company_pa20-7", "company": "DTE Energy Company", "company_raw": "DTE Energy Company (PA20-7)", "docket": "PA20-7", "docket_full": null, "issued_date": "2023-11-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20231121-3001&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20231121-3001", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 32, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "FL", "source": "Florida Public Service Commission", "doc_type": "final order on conservation cost recovery", "id": "2023-11-16_florida-iou_fl-20230002-eg-psc-2023-0342-fof-eg", "company": "Florida investor-owned utilities (energy conservation cost recovery)", "company_raw": "Florida investor-owned utilities (energy conservation cost recovery)", "docket": "20230002-EG", "docket_full": null, "issued_date": "2023-11-16", "source_page_url": "https://www.psc.state.fl.us/document-detail?orderNum=PSC-2023-0342-FOF-EG", "pdf_download_url": "https://www.psc.state.fl.us/library/Orders/2023/06084-2023.pdf", "captured_at": "2026-06-07", "source_note": "Florida PSC Order No. PSC-2023-0342-FOF-EG (Final Order), Docket No. 20230002-EG, 'Energy conservation cost recovery clause', issued November 16, 2023 (9 pp) — the Commission's annual review of energy-conservation / demand-side-management program cost recovery, approving the conservation cost-recovery amounts, tariffs, and factors for January–December 2024 for Florida's investor-owned utilities. Listed for reference (metadata-only). Source: Florida PSC document clerk, document 06084-2023 (psc.state.fl.us/library/Orders/2023/06084-2023.pdf).", "archived_via": null, "page_count": 9, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "UT", "source": "Public Service Commission of Utah", "doc_type": "energy balancing account audit report", "id": "2023-11-07_rocky-mountain-power_ut-23-035-01-eba-audit-cy2022", "company": "Rocky Mountain Power (PacifiCorp)", "company_raw": "Rocky Mountain Power (PacifiCorp)", "docket": "23-035-01", "docket_full": null, "issued_date": "2023-11-07", "source_page_url": "https://psc.utah.gov/electric/orders-notices/electric-2023/", "pdf_download_url": "https://pscdocs.utah.gov/electric/23docs/2303501/330672DPUExhbt2.2DaymarkAdtRprtCY202211-7-2023.pdf", "captured_at": "2026-06-10", "source_note": "Energy Balancing Account (EBA) Audit for Rocky Mountain Power for Calendar Year 2022 by Daymark Energy Advisors — Public Executive Summary (filed Nov 7, 2023 as a Utah Division of Public Utilities exhibit), Docket No. 23-035-01 — the independent audit of the prudence/recovery of RMP's net power (fuel & purchased-power) costs trued up through the EBA for CY2022: RMP requested recovery of ~$175 million in deferred EBA costs; Daymark found outages at 4 units 'demonstrated sufficient imprudence that we recommend reducing EBA' (8 pp). Predecessor-year companion to the seeded CY2023 EBA audit (24-035-01). Listed for reference (metadata-only). Source: Utah PSC document repository (pscdocs.utah.gov/electric/23docs/2303501/). Page-1 verified 2026-06-10.", "archived_via": null, "page_count": 8, "scanned_pages": [ 2 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "gas cost (PGA) reconciliation order", "id": "2023-11-02_mt-carmel-public-utility_icc-22-0639-pga-reconciliation-order", "company": "Mt. Carmel Public Utility Co.", "company_raw": "Mt. Carmel Public Utility Co.", "docket": "22-0639", "docket_full": null, "issued_date": "2023-11-02", "source_page_url": "https://www.icc.illinois.gov/docket/P2022-0639/documents", "pdf_download_url": "https://icc.illinois.gov/docket/P2022-0639/documents/343711/files/600359.pdf", "captured_at": "2026-06-19", "source_note": "ICC Order in the purchased gas adjustment (PGA) reconciliation of Mt. Carmel Public Utility Co. — reconciliation of revenues collected under gas adjustment charges with the actual cost of gas demonstrated to be prudently incurred, Docket 22-0639, entered November 2, 2023; 3 pp. PDF: icc.illinois.gov/docket/P2022-0639/documents/343711/files/600359.pdf. Listed for reference (metadata-only).", "archived_via": null, "page_count": 3, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MT", "source": "Montana Public Service Commission", "doc_type": "general rate case final order", "id": "2023-10-27_northwestern-energy_mt-2022-07-078-final-order-7860y", "company": "NorthWestern Energy", "company_raw": "NorthWestern Energy", "docket": "2022.07.078", "docket_full": null, "issued_date": "2023-10-27", "source_page_url": "https://psc.mt.gov/News/2023/NWERateCaseDecision", "pdf_download_url": "https://psc.mt.gov/News/Special/FinalOrder7860y_DOC-26058.pdf", "captured_at": "2026-06-07", "source_note": "Montana PSC Final Order No. 7860y (October 27, 2023), Docket 2022.07.078, In re NorthWestern Energy's Application for Authority to Increase Retail Electric and Natural Gas Utility Service Rates — the Commission's order on NorthWestern's combined electric/gas general rate case, including cost of service, rate design, and the Power Costs and Credit Adjustment Mechanism (PCCAM) base (105 pp). Listed for reference (metadata-only). Source: Montana PSC (psc.mt.gov/News/Special/FinalOrder7860y_DOC-26058.pdf).", "archived_via": null, "page_count": 105, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MD", "source": "Maryland Public Service Commission", "doc_type": "rate case order", "id": "2023-10-18_potomac-edison_md-9695", "company": "The Potomac Edison Company", "company_raw": "The Potomac Edison Company", "docket": "9695", "docket_full": null, "issued_date": "2023-10-18", "source_page_url": "https://www.psc.state.md.us/", "pdf_download_url": "https://psc.maryland.gov/wp-content/uploads/Order-90847-Order-on-PE-and-OPC-Appeals-2.pdf", "captured_at": "2026-06-02", "source_note": "Order No. 90847 (Order on Appeals) on The Potomac Edison Company's application for adjustments to its retail electric distribution rates, Maryland PSC Case No. 9695, issued October 18, 2023. Listed for reference (metadata-only). PDF on the Maryland PSC host psc.maryland.gov/wp-content/uploads/; case jacket in the PSC DMS case-search (case 9695).", "archived_via": null, "page_count": 33, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Disallowance: $31,435,485", "summary": "ly 18, 19, 20, 21 and 28, 2023. The PULJ issued a Proposed Order on September 6, 2023,1 authorizing $31,435,485 of the Company’s request, and denying approval of the remaining request. Additionally, on May 31, 2023, the Maryland Office of People’s Counsel (“OPC”) and Potomac Edison, with the sup", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-09-29_sunoco-pipeline-l-p_pa21-4", "company": "Sunoco Pipeline L.P.", "company_raw": "Sunoco Pipeline L.P. (PA21-4)", "docket": "PA21-4", "docket_full": "PA21-4-000", "issued_date": "2023-09-29", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230929-3011&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230929-3011", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 98, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 to December 31, 2021", "industry": "oil", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "6" ], "finding_count": 10, "findings": [ { "index": 1, "title": "Prorating Pipeline Capacity", "summary": "Sunoco incorrectly calculated shippers’ historical shipments (shipper history) and improperly classified new shippers as regular shippers, during the audit period. These errors resulted in incorrect allocation percentages that overallocated capacity to some shippers and underallocated capacity to other shippers, during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies, procedures, and controls to ensure that it allocates capacity based on correct historical capacities and appropriately classifies all shippers, during times of prorationing.", "source_page": null }, { "number": 2, "text": "Inform relevant staff of the procedural and control changes for prorating pipeline capacity and provide periodic training, as needed.", "source_page": null }, { "number": 3, "text": "Implement process improvements available through automated system processes or other means to increase efficiency and accuracy of prorated capacity awarded.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "eTariff Database Records", "summary": "Sunoco did not properly file all tariff records in the Commission’s electronic eTariff database (eTariff). Specifically, Sunoco did not properly file Tariff Nos. 6.0.0 and 169.0.0 in eTariff and did not properly code and number several filings in eTariff. This impacted shippers’ and other interested parties’ ability to access and review the tariffs through eTariff.", "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Strengthen policies, procedures, and controls to ensure that all tariff records are properly filed and available for review in eTariff and monitor eTariff to ensure all tariffs are properly uploaded, removed, and numerically ordered in accordance with Order Nos. 714 and 714-A.2", "source_page": null }, { "number": 5, "text": "Perform a comprehensive review of all tariffs filed since 2010 to confirm whether tariffs are shown in eTariff as effective. As part of this review determine whether there is a need for Tariff ID 25 or whether it can be withdrawn to avoid possible confusion when filing records in eTariff.", "source_page": null }, { "number": 6, "text": "Inform relevant staff of the procedural and control changes for complying with Order Nos. 714 and 714-A and provide periodic training, as needed.", "source_page": null }, { "number": 7, "text": "File currently effective versions of Tariff Nos. 6.0.0 and 169.0.0 in eTariff, along with any prior versions that were inadvertently omitted from eTariff, so that eTariff includes an accurate record of all Commission-approved versions of these tariffs. Also, correct the collation value(s), so that they 2 Electronic Tariff Filings, Order No. 714, 124 FERC ¶ 61,270 (2008), clarified Order No. 714-A, 147 FERC ¶ 61,115 (2014). will provide proper sequencing of Sunoco’s tariff records in eTariff and update all miscoded filings.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 3, "title": "Noncarrier Property and Expenses", "summary": "Sunoco improperly accounted for certain noncarrier property as carrier property, which affected the accuracy of several account balances reported in the FERC Form No. 6, including several line inputs used to derive cost of service on Page 700. This resulted in Sunoco overstating total cost of service by $104,113 (2018), $1,432,068 (2019), and $3,289,888 (2020).", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise accounting policies, procedures, and controls to ensure that idled and noncarrier assets are accounted for as noncarrier property and all associated expenses and revenues are recorded in Account 620 consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 9, "text": "Reclassify all idled assets for which no definite plan for future use exists and any other noncarrier assets incorrectly recorded in Account 30 to Account 34, and reclassify the related accrued depreciation from Account 31 to Account 35. Submit accounting entries supporting adjustments within the carrier and noncarrier property accounts to DAA for review within 60 days of issuance of this audit report. Make the accounting entries supporting this adjustment within 60 days of receiving approval from DAA.", "source_page": null }, { "number": 10, "text": "Perform an analysis to determine the full scale of Page 700 impacts from improperly accounting for certain noncarrier property as carrier property, including impacts to Line 1, Operating and Maintenance Expense; Line 2, Depreciation Expense; Lines 5a-5d, Rate Base; and other lines on Page 700, and provide this analysis to DAA staff for review within 60 days of receiving DAA’s approval described in Recommendation No. 9.", "source_page": null }, { "number": 11, "text": "For the next FERC Form No. 6 annual filing ensure that the noncarrier property and related expenses are accurately accounted for and reported in current and comparative years and provide appropriate footnote disclosures.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Nonoperating and Unrelated Expenses", "summary": "Sunoco improperly recorded certain nonoperating expenses – including costs for penalties and settlements resulting from violations of laws and regulations, costs for donations and sponsorships, and amortization of acquisition premiums – in operating expense and carrier property accounts. Sunoco also improperly recorded on its books costs for services performed for an affiliate that were unrelated to Sunoco’s business. The incorrect accounting for these expenses resulted in overstating operating expense and carrier property account balances, which overstated total cost of service on Page 700, ranging between $562,806 to $1,828,678, during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise and strengthen policies, procedures, and controls to ensure that carrier property, operating expenses, and nonoperating expenses are recorded and reported in accordance with the Commission’s accounting regulations.", "source_page": null }, { "number": 13, "text": "Perform an analysis of the current year’s operating expense accounts to ensure that penalties and settlement payments, donations and sponsorships, amortization of acquisition premiums, liability insurance premiums relating to affiliates, and other nonoperating expenses and charges are correctly accounted for and reported in nonoperating expense accounts in the FERC Form No. 6.", "source_page": null }, { "number": 14, "text": "Perform an analysis from 2018 through the date of the final audit report to identify nonoperating expenses improperly capitalized in Account 30. Provide the results of the analysis and all applicable work papers supporting the analysis, including factors used to calculate the amount of the error, to DAA within 60 days of receiving the final audit report.", "source_page": null }, { "number": 15, "text": "Submit proposed corrected accounting entries based on the analysis performed per Recommendation No. 14 to DAA, within 90 days of receiving the final audit report, for the removal of the estimated capitalized nonoperating expenses from Account 30, and to remove associated amounts from Account 31 and any other accounts impacted.", "source_page": null }, { "number": 16, "text": "Revise Accounts 30 and 31, and any other accounts impacted by the improperly capitalized nonoperating expenses, after receiving DAA’s assessment of the proposed accounting entries.", "source_page": null }, { "number": 17, "text": "For the next FERC Form No. 6 annual filing ensure that the nonoperating expenses and expenses unrelated to Sunoco’s business are accurately accounted for and reported in current and comparative years and provide appropriate footnote disclosures.", "source_page": null } ], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 5, "title": "Depreciation Rates and Studies", "summary": "Sunoco did not use Commission- approved depreciation rates and did not depreciate one of its primary property accounts. The application of unapproved rates to depreciate its assets and significant changes in Sunoco’s pipeline system caused Sunoco’s depreciation study and rates to become no longer relevant and outdated. These errors also caused Sunoco to improperly calculate depreciation expense and accumulated depreciation reserve balances for carrier property assets and resulted in Sunoco including incorrect amounts in its cost of service on Page 700 since 2003.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Develop and implement policies, procedures, and controls to ensure that it uses Commission-approved depreciation rates for all carrier property assets (or accounts) and that regular studies are conducted to ensure depreciation rates are relevant and do not become outdated.", "source_page": null }, { "number": 19, "text": "File a depreciation study with the Commission for all asset groups that do not have an appropriate depreciation rate on file with the Commission to reflect current economic conditions.", "source_page": null }, { "number": 20, "text": "For the next FERC Form No. 6 annual filing ensure that impacts from the changes in depreciation rates are accurately accounted for and reported in current and comparative years and provide appropriate footnote disclosures.", "source_page": null } ], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 6, "title": "Pipeline Loss Allowance Revenues", "summary": "Sunoco incorrectly omitted pipeline loss allowance (PLA) revenues recorded in Account 230, Allowance Oil Revenues, from Page 700, Line 10, Interstate Operating Revenues. This resulted in Sunoco understating its annual interstate operating revenues reported on Page 700. These understatements were approximately $5,509,857 (2018), $4,662,188 (2019), and $3,054,798 (2020).", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Revise and strengthen financial reporting policies, procedures, and controls to ensure that PLA revenues are appropriately tracked and reported as interstate operating revenues on Page 700, Line 10.", "source_page": null }, { "number": 22, "text": "Train staff on revised policies, procedures, and controls for reporting interstate operating revenues on Page 700, Line 10, and provide additional periodic training, as needed.", "source_page": null }, { "number": 23, "text": "Ensure that all future FERC Form No. 6 submissions reflect Sunoco’s revised PLA procedures. Additionally, for the next FERC Form No. 6 annual filing ensure that PLA is accurately reported in current and comparative years and provide appropriate footnote disclosures.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 7, "title": "Capitalized Interest Expense", "summary": "Sunoco included capitalized interest twice by including both interest during construction (IDC) and allowance for funds used during construction (AFUDC) in the determination of its cost of service on Page 700 of its FERC Form No. 6 filings. Consequently, Sunoco overstated its total cost of service on Page 700 by $1,706,995 and $1,986,041 in 2019 and 2020, respectively. Sunoco further compounded this overstatement by calculating AFUDC on the IDC amounts.", "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Revise and strengthen policies, procedures, and controls to ensure that IDC is removed from carrier property accounts when calculating cost of service on Page 700 of the FERC Form No. 6.", "source_page": null }, { "number": 25, "text": "Inform staff responsible for preparing Page 700 of this error and provide periodic training, as necessary.", "source_page": null }, { "number": 26, "text": "Perform an analysis to determine the impact, resulting from the error identified, to Line 3, AFUDC Depreciation; Line 5, Rate Base; Line 7, Return on Rate Base; and Line 9, Total Cost of Service, on Page 700 of the current year FERC Form No. 6 and provide this analysis to DAA within 90 days of this report.", "source_page": null }, { "number": 27, "text": "For the next FERC Form No. 6 annual filing ensure that the effects of IDC are removed from the AFUDC computation for the current and comparative years and provide appropriate footnote disclosures.", "source_page": null } ], "themes": [ "AFUDC / cost of capital", "Form reporting (Form No. 1/2/6, Page 700)", "Capitalization vs. expense", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 8, "title": "Asset Retirement Costs", "summary": "Sunoco improperly included Asset Retirement Costs (ARC) in rate base on Page 700 of its FERC Form No. 6 filings. This error caused Sunoco to overstate its cost of service on Page 700 by $2.9 million to $4.4 million annually, during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Revise and strengthen policies, procedures, and controls to ensure that cost components related to asset retirement obligations are excluded from rate base on Page 700 consistent with 18 C.F.R. § 346.3(a) and the instructions of the FERC Form No. 6.", "source_page": null }, { "number": 29, "text": "Train staff on avoiding this error and provide periodic training, as necessary, to ensure that rate base on Page 700 is calculated and reported correctly in accordance with Commission regulations.", "source_page": null }, { "number": 30, "text": "Perform an analysis to determine the impact resulting from the error identified in the prior two Recommendations on rate base and total cost of service on Page 700 for the current year and provide this analysis to DAA within 90 days of issuance of this report.", "source_page": null }, { "number": 31, "text": "For the next FERC Form No. 6 annual filing made by Sunoco, exclude cost components related to asset retirement obligations that would impact the calculation of rate base from the rate base computation for the current and comparative years and provide appropriate footnote disclosures.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 9, "title": "Annual Cost of Service Based Analysis Schedule", "summary": "Sunoco’s Annual Cost of Service Based Analysis Schedule, reported on Page 700 of its FERC Form No. 6 filings, contained miscellaneous errors and inconsistencies with Opinion No. 154-B and other Commission guidance not already discussed above in the preceding findings. These miscellaneous errors and inconsistencies affected the accuracy of most inputs and balances on Page 700, which caused Sunoco to overstate its rate base and overall cost of service in each year of the audit period.", "is_other_matter": false, "recommendations": [ { "number": 32, "text": "Revise and strengthen policies, procedures, and controls to ensure that Page 700 is prepared correctly, accurately, and consistent with Opinion No. 154- B and the instructions of the FERC Form No. 6.", "source_page": null }, { "number": 33, "text": "Train staff on avoiding these errors and provide periodic training, as necessary, to ensure that each line item on Page 700 is calculated and reported correctly in accordance with Commission regulations.", "source_page": null }, { "number": 34, "text": "Perform an analysis to determine the impact resulting from the errors identified to rate base and total cost of service on Page 700 for the current year and provide this analysis to DAA within 90 days of the issuance of this report.", "source_page": null }, { "number": 35, "text": "For the next FERC Form No. 6 annual filing, correctly include amortization related to a throughput and deficiency (T&D) agreement in the depreciation expense computation and correctly calculate working capital in the rate base computation on Page 700 for the current and comparative years and provide appropriate footnote disclosures.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 10, "title": "FERC Form No. 6 Reporting and Accounting", "summary": "Sunoco did not report complete information in certain supporting schedules of its FERC Form No. 6 filings. Sunoco also did not accurately account for certain activities in accordance with the Commission’s accounting instructions. While these oversights did not impact the determination of cost of service on Page 700, they did reduce the accuracy and usefulness of the information reported in Sunoco’s FERC Form No. 6 filings. D.", "is_other_matter": false, "recommendations": [ { "number": 36, "text": "Revise policies and procedures to ensure complete and accurate information is reported in the FERC Form No. 6 in accordance with the instructions of the report and the Commission’s accounting instructions.", "source_page": null }, { "number": 37, "text": "Review the reporting deficiencies with relevant staff to ensure they include on a prospective basis all required information in Sunoco’s FERC Form No. 6 filings. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management efficiency investigation", "id": "2023-09-21_duquesne-light_pa-mei", "company": "Duquesne Light Company", "company_raw": "Duquesne Light Company", "docket": "D-2023-3037425", "docket_full": null, "issued_date": "2023-09-21", "source_page_url": "https://www.puc.pa.gov/press-release/2023/puc-issues-management-efficiency-investigation-report-for-duquesne-light", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1799646.pdf", "captured_at": "2026-06-18", "source_note": "Management Efficiency Investigation of Duquesne Light Company, PA PUC Bureau of Audits; PUC publication 2023-09-21, Docket No. D-2023-3037425. Follow-up review; recommendations in Exhibit II-1. PDF: puc.pa.gov/pcdocs/1799646.pdf. Listed for reference (metadata-only; MEI Exhibit II-1 format not yet parsed).", "archived_via": null, "page_count": 48, "scanned_pages": [ 1, 48 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-09-18_gulf-south-pipeline-company-llc_pa21-3", "company": "Gulf South Pipeline Company, LLC", "company_raw": "Gulf South Pipeline Company, LLC (PA21-3)", "docket": "PA21-3", "docket_full": "PA21-3-000", "issued_date": "2023-09-18", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230918-3019&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230918-3019", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 120, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2019 to December 31, 2022", "industry": "gas", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "2", "501-G" ], "finding_count": 14, "findings": [ { "index": 1, "title": "Reservation Charge Credits", "summary": "Gulf South incorrectly calculated reservation charge credits for six out of eleven non-force majeure maintenance events declared during the audit period. This resulted in overpayments and underpayments in reservation charge credits to the impacted Firm Transmission Service (FTS), No-Notice Service (NNS), and Enhanced Firm Transmission (EFT) customers, during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise and strengthen policies and procedures to ensure compliance with its Tariff’s reservation charge crediting calculation methodologies.", "source_page": null }, { "number": 2, "text": "Train staff on the computation, policies, and procedures for calculating Gulf South’s reservation charge credits for force majeure and non-force majeure events. The training should also include discussion of this finding. Provide training periodically as needed.", "source_page": null }, { "number": 3, "text": "Make an informational posting on Gulf South’s Electronic Bulletin Board notifying customers of all reservation charge crediting errors, during the audit period to the present. Allowance For Funds Used During Construction", "source_page": null }, { "number": 4, "text": "Strengthen accounting procedures to ensure Gulf South properly includes all short-term debt in the determination of the maximum AFUDC rate as prescribed in Order Nos. 561 and 561-A and Gas Plant Instruction No. 3(17) (GPI No. 3(17)). This pertains to all outstanding short-term debt secured through an external third-party bank or other financial institution and through internal funding sources, such as borrowings through a cash management arrangement or direct loan from any affiliate or subsidiary company.", "source_page": null }, { "number": 5, "text": "Provide training to relevant staff on the revised AFUDC rate calculation procedures and develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 6, "text": "Recalculate AFUDC accrued each year from January 1, 2015 to December 31, 2022, in accordance with the requirements of GPI No. 3(17). Based on the calculations, in years when the AFUDC rate exceeded the maximum rate allowed under GPI No. 3(17), submit a yearly estimate within 90 days of issuance of this audit report, with proposed accounting entries and supporting documentation to DAA that reflects corrections to remove over- accrued AFUDC balances from plant and associated accounts, such as accumulated depreciation and Accumulated Deferred Income Taxes (ADIT) in Gulf South’s books and records. If the adjusting entries result in a significant impact to income for the current year, Gulf South may request approval from the Commission to account for the transaction as a correction of a prior period error in Account 439.", "source_page": null }, { "number": 7, "text": "Revise Construction Work in Progress (CWIP) and gas plant in service, accumulated depreciation, ADIT, and other account balances impacted by the over-accrual of AFUDC after receiving DAA’s assessment of the proposed accounting entries.", "source_page": null }, { "number": 8, "text": "Restate and footnote the comparative year balances reported in the current year FERC Form No. 2, including all schedules affected, to reflect and disclose that these revisions have been made. Consult with DAA in developing an appropriate footnote disclosure to ensure the necessary transparency of the impacts on all years affected.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Allowance for Funds Used During Construction", "summary": "Gulf South did not include the cost rates and balances associated with short-term debt borrowings from its cash management program in the computation of its maximum allowance for funds used during construction (AFUDC) rate. Instead, Gulf South included only the cost rates and balances for the long- term debt and equity components, which resulted in Gulf South applying AFUDC rates that exceeded the Commission’s maximum allowable rate by approximately 7.43 percent and 9.25 percent in 2019 and 2020, respectively. As a result, Gulf South over accrued the AFUDC on capital projects by approximately $12.4 million in these two years. Although the over-accrual only pertained to these two years, Gulf South confirmed that it has not considered internal short-term debt borrowings in its AFUDC rate calculations since the inception of its cash management program.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 3, "title": "Preliminary Survey and Investigation Charges", "summary": "Gulf South improperly recorded Preliminary Survey and Investigation charges (PS&I) as an operating expense in each accounting period these costs were incurred, rather than recording these costs in Account 183.2, Other Preliminary Survey and Investigation Charges. This resulted in Gulf South misclassifying and overstating its monthly operating expenses. Gulf South’s accounting practice also reduced the transparency and comparability of PS&I reported in Gulf South’s FERC Form No. 2 reports and could impact the accuracy of Gulf South’s future cost-of-service rates.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Revise policies and procedures used to track, review, and account for all PS&I associated with proposed capital projects consistent with the Commission’s accounting instructions for Account 183.2.", "source_page": null }, { "number": 10, "text": "Train staff on the updated policies and procedures to account for PS&I and provide periodic training as necessary.", "source_page": null }, { "number": 11, "text": "Reclassify all PS&I for the current year from operating expense accounts to Account 183.2 and continue accounting for PS&I in this manner prospectively. Provide a journal entry that supports that the corrected accounting entry has been made to DAA within 30 days from the issuance of this report.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Corporate Management Fee", "summary": "Gulf South improperly classified certain costs allocated from its parent companies in the form of a management fee in Account 923, Outside Services, rather than recording these costs in the appropriate operating and nonoperating expense accounts and administrative and general expense accounts based on the nature of each cost. These misclassifications affected the accuracy and usefulness of the information reported in Gulf South’s FERC Form No. 2 reports. Gulf South also did not keep adequate records and documentation to support the allocation percentage used by its parent company for certain labor charges that were allocated based on a time study. The lack of records and documents limited audit staff’s ability to evaluate the accuracy and reasonableness of the allocation percentage used to assign these labor charges to Gulf South.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise policies and procedures used to track, review, and account for all directly assigned and allocated costs, to ensure that these costs, including operations and maintenance and administrative and general expenses, are recorded in the appropriate expense account based on the nature of the cost as required by General Instruction No. 14. Additionally, communicate these revised policies and procedures to all Gulf South affiliates to ensure they understand the potential accounting impacts and effects on the development of cost-of-service rates. Provide support to DAA that this communication occurred within 90 days from the issuance of this report.", "source_page": null }, { "number": 13, "text": "Inform and train employees responsible for account coding and assignment to ensure proper classification of operating and nonoperating expenses upon initial entry into the accounting system.", "source_page": null }, { "number": 14, "text": "Retain documentation to support all the charges allocated from associated companies to comply with the requirements of 18 C.F.R. Part 225.2. Specifically, retain documentation, including time studies, that support the percentages and costs Loews allocates to Gulf South.", "source_page": null }, { "number": 15, "text": "Perform further analysis of the management fees that Gulf South considered to be outside services for the audit period (i.e., the remaining expenses of approximately $5 million (2019) and $4.5 million (2020) that Gulf South recorded in Account 923). Specifically, the review should identify any other expenses that should be recorded in a nonoperating expense account, rather than treated as an operating expense in Account", "source_page": null }, { "number": 923, "text": "Further, identify any operating expenses that do not relate to outside services and are more appropriately recorded in an account other than Account 923, based on the Commission’s accounting instructions within the USofA. Provide the results of the analysis along with any correcting entries made within 90 days of the issuance of the audit report.", "source_page": null }, { "number": 16, "text": "Provide recent journal entries and documentation to support that the accounting misclassifications identified have been corrected, and the related expenses are recorded in accordance with the Commission’s accounting requirements, to DAA within 90 days from the issuance of this report.", "source_page": null }, { "number": 17, "text": "Restate and footnote the comparative year balances reported in the current year FERC Form No. 2, including all schedules affected, to reflect and disclose the revisions made.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 5, "title": "Industry and Trade Association Dues", "summary": "Gulf South was incorrectly allocated the full share of certain membership dues by Boardwalk and misclassified the non-lobbying and lobbying portion of membership dues for some industry and trade associations. These misclassifications could result in Gulf South inappropriately recovering nonoperating expenses in its cost-of-service rate determinations, absent having other procedures and controls in place. This also reduced the transparency and comparability of the reporting of nonoperating expenses in Gulf South’s FERC Form No. 2 reports.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Strengthen accounting procedures and controls to ensure that it properly records operating and nonoperating expenses consistent with Commission accounting instructions. These procedures and controls should address the proper accounting treatment for non-lobbying and lobbying expenditures related to industry and trade association membership dues. Further the procedures and controls should ensure that only the representative share of membership dues are allocated, in accordance with the determinations of Boardwalk’s MMF and other allocation methodologies.", "source_page": null }, { "number": 19, "text": "Inform and train employees responsible for account coding and assignment to ensure proper classification of operating and nonoperating expenses upon initial entry into the accounting system.", "source_page": null }, { "number": 20, "text": "Perform an analysis of the current year to ensure that all trade and industry association membership dues are recorded in correct operating and nonoperating expense accounts and continue to apply the accounting prospectively. Provide the results of the analysis along with any correcting entries made within 90 days of the issuance of the audit report.", "source_page": null }, { "number": 21, "text": "Provide recent journal entries and supporting documentation to demonstrate that the accounting misclassifications identified in this finding have been corrected, and the related expenses are recorded in accordance with the Commission’s accounting regulations, to DAA within 90 days from the issuance of this report.", "source_page": null }, { "number": 22, "text": "Restate and footnote the comparative year balances reported in the current year FERC Form No. 2, including all schedules affected, to reflect and disclose that these revisions have been made.", "source_page": null } ], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 6, "title": "Political and Lobbying Expenditures", "summary": "Gulf South improperly accounted for certain political and lobbying expenses in operating expense accounts, rather than nonoperating expense accounts. These misclassifications could result in Gulf South inappropriately recovering nonoperating expenses in its cost-of-service rate determinations, absent having other procedures and controls in place. The misclassification of these nonoperating expenses also reduced the transparency and comparability of the reporting of nonoperating expenses in Gulf South’s FERC Form No. 2 reports. Additionally, incorrect allocation percentages were applied in assigning outside service costs under the Modified Massachusetts Formula (MMF).", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Strengthen accounting procedures and controls to ensure it properly records nonoperating expenses consistent with Commission accounting instructions. These procedures and controls should address the proper accounting treatment for costs associated with political and lobbying activities, as a nonoperating expense under the USofA.", "source_page": null }, { "number": 24, "text": "Inform and train employees responsible for account coding and assignment of political and lobbying activities to ensure proper expense classification upon initial entry into the accounting system.", "source_page": null }, { "number": 25, "text": "Communicate and work with external vendors to ensure that Gulf South and its affiliates have procedures to separately track the costs associated with political and lobbying activities. As an example, this tracking was incorporated into Energy Infrastructure Counsel, Texas Pipeline Association, and Gas Processors Association membership dues invoices, where they indicated the percentage attributed to lobbying activities. Further enhance procedures to track the labor hours associated with the employees engaged in the corporate Public Affairs Committee (PAC) affairs. These measures will ensure these costs are readily identifiable and properly recorded.", "source_page": null }, { "number": 26, "text": "Review account coding and assignment for the current year to ensure proper expense classification of all costs associated with political and lobbying activities. Besides Ogilvy and Boardwalk PAC, this review should include an analysis of all political and lobbying expenses and any other costs of a similar nature that were improperly coded to an operating expense account. Upon completion of this review, modify the account coding to reflect all political and lobbying expenses as nonoperating expenses in the accounting system. Submit the results of this review to DAA within 90 days from the issuance of this report.", "source_page": null }, { "number": 27, "text": "Provide recent journal entries and supporting documentation to demonstrate that the accounting misclassifications identified in this finding have been corrected, and the related expenses are recorded in accordance with the Commission’s accounting requirements, to DAA within 90 days from the issuance of this report.", "source_page": null }, { "number": 28, "text": "Restate and footnote the comparative year balances reported in the current year FERC Form No. 2, including all schedules affected, to reflect and disclose that these revisions have been made.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 7, "title": "Charitable Contributions", "summary": "Gulf South improperly accounted for charitable contributions that were made to foster general community awareness and good working relationships with the community in which its Index 99 project was being developed and constructed. Gulf South should have recorded these charitable contributions in a nonoperating expense account rather than in the construction work in progress account. These account misclassifications resulted in Gulf South overstating gas plant in service, which could impact future cost recoveries from customers, absent having other procedures and controls in place.", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Revise policies and procedures to ensure that the capitalization of project- related costs is consistent with GPI No. 3, and the Commission’s accounting regulations for Accounts 426.1 through 426.5. These policies and procedures should incorporate the accounting treatment for charitable contributions and other expenditures that foster general community awareness and good working relationships with the community, as a nonoperating expense under the USofA, consistent with instructions in Account 426.1.", "source_page": null }, { "number": 30, "text": "Inform and train employees responsible for account coding and assignment for capital projects to ensure proper expense classification is determined based on the nature of the costs upon initial entry into the accounting system.", "source_page": null }, { "number": 31, "text": "Perform an analysis for the years during the audit period to identify capital projects that improperly included charitable contributions and other expenditures to foster general community awareness and good working relationships with the community, or for other purposes. Provide the results of the analysis, along with any correcting entries made, to DAA for review within 90 days of the issuance of the audit report.", "source_page": null }, { "number": 32, "text": "Provide recent journal entries and supporting documentation to demonstrate that the accounting misclassifications have been corrected, and the related expenses are recorded in accordance with the Commission’s regulations, to DAA within 90 days from the issuance of this audit report.", "source_page": null }, { "number": 33, "text": "Restate and footnote the comparative year balances reported in the current year FERC Form No. 2, including all schedules affected, to reflect and disclose that these revisions have been made.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Property & plant records" ], "cost_to_customers": true }, { "index": 8, "title": "Informational and Promotional Costs", "summary": "Gulf South improperly accounted for certain informational and promotional costs in incorrect operating expense accounts. These misclassifications reduced the transparency and comparability of the reporting of these operating expenses in Gulf South’s FERC Form No. 2 reports. Further, these misclassifications could lead to improper functionalization of costs in rate design for different customer classes.", "is_other_matter": false, "recommendations": [ { "number": 34, "text": "Strengthen accounting procedures to ensure that it properly records all operating expenses consistent with Commission accounting instructions. These procedures should address proper accounting treatment for informational and promotional costs related to brand and public awareness, advertising, and other similar costs.", "source_page": null }, { "number": 35, "text": "Inform and train employees responsible for account coding and assignment of informational and promotional costs to ensure proper classification of operating expenses upon initial entry into the accounting system.", "source_page": null }, { "number": 36, "text": "Perform an analysis of the current year to ensure that informational and promotional costs are recorded in the correct operating expense accounts. Provide the results of the analysis, along with any correcting entries made, to DAA within 90 days of the issuance of the audit report.", "source_page": null }, { "number": 37, "text": "Provide recent journal entries and supporting documentation to DAA within 90 days from the issuance of this report that demonstrate the accounting misclassifications identified have been corrected, and the related expenses are recorded in accordance with the Commission’s regulations.", "source_page": null }, { "number": 38, "text": "Restate and footnote the comparative year balances reported in the current year FERC Form No. 2, including all schedules affected, to reflect and disclose that these revisions have been made.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 9, "title": "Operating Lease Accounting", "summary": "Gulf South has operating leases, which contain rent abatement or changes in the rental rate during the lease term. For those operating leases, Gulf South recognized the lease expense using a straight-line method over the lease term rather than recognizing the lease expense based on actual lease payments. For those leases, Gulf South also did not record equal offsetting amounts for the principal portion of the lease payments to reduce its right of use (ROU) assets and related lease liabilities, as required by the Commission. This accounting reduced the transparency and comparability of this information reported in the FERC Form No. 2.", "is_other_matter": false, "recommendations": [ { "number": 39, "text": "Revise policies and procedures to ensure that Gulf South correctly applies the Commission’s accounting requirements for operating leases with terms greater than 12 months that are treated as capital leases as identified by audit staff. These policies and procedures must ensure that the actual payments made under the lease arrangement are recognized as lease expenses and that the ROU assets and liabilities are reduced by equal and offsetting amounts for the principal portion of the lease payment over the lease term, or alternatively, be consistent with any determination of the Commission’s Chief Accountant received on this issue.", "source_page": null }, { "number": 40, "text": "Inform relevant staff regarding any revised policies and procedures and provide staff periodic training, as needed.", "source_page": null }, { "number": 41, "text": "Make any necessary accounting adjustments to reflect compliance with the Commission’s accounting requirements for recognition of lease expenses on the income statement and ROU assets and liabilities on the balance sheet. Provide a copy of the accounting adjustments made to DAA for review within 90 days from the issuance of this report, or the issuance of any formal approval from the Chief Accountant requested within 90 days from the issuance of this report.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 10, "title": "Property Unit Listing", "summary": "Gulf South did not consistently apply its property units listing for the replacement of a retirement unit. Gulf South instead applied its capitalization policy, which contradicted its property units listing. As a result, Gulf South treated the replacement of a retirement unit as a replacement of a minor unit of property, and expensed the costs, rather than capitalizing the costs associated with the retirement unit replaced.", "is_other_matter": false, "recommendations": [ { "number": 42, "text": "Revise policies and procedures to ensure that Gulf South consistently maintains and applies its written property units listing pursuant to GPI No.", "source_page": null }, { "number": 10, "text": "Those revised policies and procedures should identify the replacement of engines at compressor stations as retirement units to align with Gulf South’s retirement unit manual or should amend the manual so that engines are no longer considered a retirement unit.", "source_page": null }, { "number": 43, "text": "Inform and train employees on revisions made to the retirement unit manual and internal policies and procedures. This will help employees make consistent decisions for the accounting treatment of costs associated with retirement units and minor units of property.", "source_page": null }, { "number": 44, "text": "Review the retirement unit manual and make necessary updates. This should incorporate changes that have resulted due to technological advancements, mergers, and other factors. Provide a copy of the revised retirement unit manual and a summary of the updates made to the manual for review by DAA within 90 days from the issuance of this report.", "source_page": null }, { "number": 45, "text": "If necessary following updating of the retirement unit manual, make adjusting entries to reflect the appropriate accounting treatment for the replacement of engines at compressor stations. Provide a copy of the accounting adjustments made to DAA for review within 90 days from the issuance of this report.", "source_page": null } ], "themes": [ "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 11, "title": "Gas Compressor Stations", "summary": "Gulf South filed with the Commission to abandon its Napoleonville Compressor Station (Napoleonville) and Bayou Sale Compressor Station (Bayou Sale) in 2016. Upon receiving the Commission’s approval to abandon the stations, Gulf South timely retired and removed the costs associated with Napoleonville from its books. However, Gulf South did not timely cease depreciation of and remove Bayou Sale’s costs from its books, upon receiving Commission approval to abandon this compressor station. Additionally, Gulf South had other compressor stations declared as either abandoned, idled, or in a reserve status for several years, which were not used in operations. Gulf South continued to classify these compressor stations as gas plant in service, rather than transferring them to future use property or nonutility property. As a result of these accounting errors, Gulf South’s gas plant in service has been overstated for several years, which has also impacted the accuracy of other account balances.", "is_other_matter": false, "recommendations": [ { "number": 46, "text": "Strengthen accounting procedures and controls to ensure that it properly records and classifies abandoned, retired, and idled property consistent with the Commission’s accounting regulations. These procedures and controls should address the timing and proper accounting treatment for gas plant in service, future use property, and nonutility property when such property is abandoned and retired from its books. Further, property not used in gas operations and in a reserve status, pending future needs for several years, should be evaluated for retirement or classification as future use property or nonutility property, rather than keeping property in gas plant in service.", "source_page": null }, { "number": 47, "text": "Inform and train employees responsible for account coding and assignment on timely recording the retirement of property abandoned. This should also cover proper and timely classification of property that is no longer used in gas operations (e.g., idled property) as future use or nonutility property.", "source_page": null }, { "number": 48, "text": "Confirm the retirement of the costs associated with the 2016 abandonment of Bayou Sale from Gulf South’s books. Also, make an adjusting entry to remove the depreciation expense recorded for Bayou Sale since 2016. Provide journal entries and supporting documentation to DAA within 90 days from the issuance of this report", "source_page": null }, { "number": 49, "text": "Evaluate the Mineola, Longview, Sterlington, and Opelousas Compressor Stations to determine the appropriate accounting treatment as future use property or nonutility property. This evaluation should also include other compressor stations that are in the process of abandonment or not used in gas operations and in a reserve status pending future needs. Submit the results of this evaluation and any correcting entries associated with each property to reclassify the costs of the compressor station to DAA within 90 days from the issuance of this report.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 12, "title": "FERC Form No. 2 Reporting", "summary": "Gulf South did not report complete and accurate information on certain supporting schedules of its FERC Form No. 2 reports. These reporting deficiencies reduced the overall accuracy and usefulness of the information in the FERC Form No. 2. D. Other Matters Audit staff identified one other matter, which is summarized below. Section V of this report contains a detailed discussion of this other matter.", "is_other_matter": false, "recommendations": [ { "number": 50, "text": "Revise policies and procedures to ensure that Gulf South reports complete and accurate information according to the Commission’s regulations and the instructions of the FERC Form No. 2. These policies and procedures should address all reporting deficiencies discussed in this finding.", "source_page": null }, { "number": 51, "text": "Inform relevant staff regarding these revised policies and procedures and provide staff periodic training, as needed.", "source_page": null }, { "number": 52, "text": "Review the reporting deficiencies with relevant staff to ensure they include, on a prospective basis, complete and accurate information in the FERC Form No. 2 reports that are filed by Gulf South with the Commission. F.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 13, "title": "Commission Accounting Filings", "summary": "Gulf South requested and received Commission approval to abandon by sale or acquisition certain properties in three certificated project (CP) proceedings during the audit period. Gulf South filed proposed journal entries for the sale and acquisition of these properties within six months of the date each transaction was consummated, as instructed by the Commission. However, for the transaction involving a merger of two existing affiliated companies, Gulf South combined the account balances of these companies without receiving acknowledgement of approval from the Commission. Besides the merger transaction, Gulf South filed the proposed accounting entries for two other abandonment transactions in the CP docketed proceedings, rather than in an accounting (AC) docketed proceeding.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 14, "title": "Unauthorized Gas Deliveries", "summary": "Some customers took gas off Gulf South’s pipeline system without making a nomination or providing any other notification to Gulf South. This occurred on multiple occasions with customers that contracted for firm and interruptible transportation service for gas used at their Liquified Natural Gas (LNG) and power generating plants. As provided in Gulf South’s Tariff, these customers could have contracted for NNS and Alternative No Notice Service (NNS-A), as these transportation services do not require a nomination. However, Gulf South indicated that these customers did not contract for NNS or NNS-A. Accordingly, Gulf South should consider modifying its tariff to incorporate procedures that clarify this operational practice, offer additional transportation services, or require customers to contract for existing tariff services. Effectuating one or more of these options will provide the same flexibility to all similarly situated customers to meet their operational needs. E.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "AZ", "source": "Arizona Corporation Commission", "doc_type": "rate case decision", "id": "2023-08-25_tucson-electric-power_az-e-01933a-22-0107-decision-79065", "company": "Tucson Electric Power Company", "company_raw": "Tucson Electric Power Company", "docket": "E-01933A-22-0107", "docket_full": null, "issued_date": "2023-08-25", "source_page_url": "https://edocket.azcc.gov/search/docket-search", "pdf_download_url": "https://docket.images.azcc.gov/0000209684.pdf", "captured_at": "2026-06-07", "source_note": "Arizona Corporation Commission Decision No. 79065 (docketed August 25, 2023), Docket No. E-01933A-22-0107, in the matter of the application of Tucson Electric Power Company (TEP) for a rate increase — approving a revenue increase of $100,130,000 (8.93%) with a 9.55% return on equity, rates effective September 1, 2023 (189 pp, born-digital). Listed for reference (metadata-only). Source: ACC eDocket image store (docket.images.azcc.gov/0000209684.pdf).", "archived_via": null, "page_count": 189, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 7, "findings": [ { "index": 1, "title": "Approval: $483,000 ", "summary": "se as a regulatory asset would allow the Company 13 to earn a return on the plant at the Commission-approved WACC.34 TEP also included $483,000 of 14 ADIT as an offset to the M&S regulatory asset.35 15 Staff and RUCO 16 Staff objects to TEP's proposal to include the SJGS M&S because the relate", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $712,273 ", "summary": "all expenses associated with the Board of Directors should be borne by shareholders. 24 We will disallow the Board of Directors fees of $712,273 in this case, therefore, these fees shall notbe 25 26 190Ex. RUCO-3 (Michlik Surrebuttal), p. 3, Decision No. 74689 (August 12, 2014). l°1 Ex. RUCO-3", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $9.94.3", "summary": "his case. Further, based on SWEEP and WRA's BCM 18 calculations, they recommend that the Commission approve a BSC of$9.94.3\"1 19 Resolution 20 The MSM and BCM are both reasonable cost allocation methodologies. But cost allocations 21 are imperfect as they result from dispu", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $10 million", "summary": "d its Decision in the 2019 APS Rate Case on November 9, 2021. In that 5 Decision,513 the Commission approved the use of $10 million of ratepayer funds for CCT programs, 6 rejecting the terms of a proposed non-binding memorandum of understanding (\"MOU\") negotiated 7 between APS and", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: agreement", "summary": "12 First, we note that the treatment ofSJGSUnit 2 M&S in Decision No. 75975 was the result of 13 a settlement agreement among the parties, and thus, while that Decision may inform, it has no 14 precedential value in this matter. We also agree withStaff and RUCO that no", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Settlement: agreement", "summary": "out that the Decision cited by TEP to support inclusion of l 00 percent of the Fees 25 is part of a settlement agreement, which does not address how Board of Directors Fees should be 26 186 TEP Opening Brief, p. 50. 27 187 Ex. RUCO-1 (Michlik Direct). p. 16. 188 Ex. RUC", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: terms", "summary": "the result of negotiations solely between APS and the Nation. APS does not have the 17 power to set settlement terms on TEP'sbehalf. Second, the findings in rate cases are limited to the facts 18 and circumstances present in each record. The Commission may refer to", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-08-18_puget-sound-energy-inc_pa21-5", "company": "Puget Sound Energy Inc.", "company_raw": "Puget Sound Energy Inc. (PA21-5)", "docket": "PA21-5", "docket_full": "PA21-5-000", "issued_date": "2023-08-18", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230818-3022&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230818-3022", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 23, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2019 to December 31, 2022", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Filing of Transmission Service Agreements", "summary": "PSE did not file four non-conforming transmission service agreements with the Commission within 30 days after electric service had commenced, as required by 18 C.F.R. §§ 35.1(g) and 35.3(a)(2).", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Develop procedures for reviewing and filing transmission service agreements to ensure PSE has the most current and complete agreements on file with the Commission.", "source_page": null }, { "number": 2, "text": "Train employees on filing procedures developed from Recommendation 1 on an ongoing, as needed basis.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Posting of Transmission Service Request Study Metrics Reports", "summary": "PSE did not timely post several quarterly transmission service study metrics reports on OASIS during the audit period, as required by 18 CFR § 37.6(h)(2).", "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Enhance cross-office coordination practices and develop procedures to ensure timely posting of quarterly transmission service study metrics reports on OASIS.", "source_page": null }, { "number": 4, "text": "Train employees on procedures developed from Recommendation 3 on an ongoing, as needed basis. E.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Informational postings" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on complaint", "id": "2023-08-08_public-service-co-colorado_el23-21", "company": "CORE Electric Cooperative et al. v. Public Service Company of Colorado", "company_raw": "CORE Electric Cooperative et al. v. Public Service Company of Colorado", "docket": "EL23-21", "docket_full": null, "issued_date": "2023-08-08", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230808-3031&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230808-3031", "captured_at": "2026-06-07", "source_note": "FERC Order on Complaint re CORE Electric Cooperative et al. v. Public Service Company of Colorado (Xcel), Docket EL23-21, issued 2023-08-08 — a wholesale rate/cost complaint against Public Service Company of Colorado. Metadata-only (free-form legal order). Found via the eLibrary AdvancedSearch API (searchText=EL23-21); accession 20230808-3031.", "archived_via": null, "page_count": 44, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-07-27_commonwealth-edison-company_fa21-5", "company": "Commonwealth Edison Company", "company_raw": "Commonwealth Edison Company (FA21-5)", "docket": "FA21-5", "docket_full": "FA21-5-000", "issued_date": "2023-07-27", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230727-3010&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230727-3010", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 101, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2017 through August 31, 2022", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 11, "findings": [ { "index": 1, "title": "Accounting for Expenditures for Certain Civic, Political, and Related Activities", "summary": "ComEd recorded approximately $6.1 million of costs incurred for the purpose of influencing the decisions of public official in various A&G and O&M accounts. As a result, ComEd improperly included costs incurred for the performance of certain political and related activities in the computation of its annual transmission revenue requirements and in billings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies and procedures and strengthen internal controls to ensure expenditures for certain civic, political, and related activities are recorded consistent with Commission accounting regulations.", "source_page": null }, { "number": 2, "text": "Provide training to relevant staff on the revised policies and procedures, and internal control enhancements for tracking and recording expenditures for certain civic, political, and related activities. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of improper costs recovered in the transmission formula rate for civic, political, and related activities from 2021 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 4, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 5, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Settlements with the City of Chicago", "summary": "ComEd improperly recorded two settlement payments, totaling $109 million, made to the City of Chicago, that related to its distribution and production operations, in Account 186, Miscellaneous Deferred Debits, instead of expensing the cost to the distribution and production O&M accounts when it incurred the cost. Also, ComEd improperly amortized the distribution and production related settlement payments to Account 930.2, Miscellaneous General Expenses, instead of expensing the cost to the distribution and production O&M accounts when it incurred the cost. As a result of the improper accounting, ComEd overstated its annual transmission revenue requirement by approximately $9.3 million from 2007 to 2020 and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Revise policies and procedures to ensure that ComEd properly accounts for settlement expenditures in its books and records.", "source_page": null }, { "number": 7, "text": "Provide training to its staff on the revised procedures for properly accounting for settlement expenditures in ComEd’s books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Asset Retirement Obligations", "summary": "ComEd’s accounting and transmission formula rate treatment of AROs and ARCs were contrary to Commission regulations. Specifically, ComEd made the following errors: (1) removed accumulated depreciation amounts from Account 108, Accumulated Provision for Depreciation of Electric Utility Plant, without Commission approval and excluded some of the removed amounts from the wholesale transmission formula rate; (2) included ARCs recorded in Electric Plant in Service balances in wholesale transmission formula rate base without Commission approval; and (3) included depreciation and accretion, respectively, of the recorded ARC and ARO balances in its wholesale transmission formula rate without Commission approval. As a result of ComEd’s improper accounting and the inclusion of AROs in transmission formula rate determinations, ComEd overstated its annual transmission revenue requirements by approximately $14 million from 2007 to 2020 and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise policies and procedures to ensure that ComEd’s accounting and wholesale transmission formula rate treatment of AROs and ARCs are consistent with the Commission’s regulations.", "source_page": null }, { "number": 9, "text": "Provide training to its staff on the revised procedures for proper accounting and wholesale transmission formula rate treatment of AROs and ARCs. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 10, "text": "Submit a refund analysis, within 60 days of receiving the final audit report, to DAA for review that explains and details the following: (1) calculation of refunds that resulted from the improper accounting and wholesale transmission formula rate treatment of AROs and ARCs from 2021 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 11, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 12, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations. Allocation of Overhead Costs to CWIP", "source_page": null }, { "number": 13, "text": "Retain an independent third-party entity to conduct a representative labor-time study for allocation of overhead costs incurred in 2023, and to assist with the development of procedures ComEd shall use after 2023 to periodically determine the allocation of overhead labor and labor-related costs capitalized by ComEd into the cost of construction. The consultant should have experience independently performing time studies used in the determination of overhead capitalization rates of U.S.-based utilities subject to the accounting requirements prescribed for public utilities and licensees or for natural gas companies under 18 C.F.R. Part 101 or Part 201, respectively. The time study should involve a representative sample of study participants (employees) that provides for extrapolation of the study results to the full population of ComEd employees. The time study should include processes to apply the study results from the audit period to the issue date of this audit report. In addition, the study should include processes to apply the capitalization rate(s) the study finds for 2023 back to the period January 1, 2017 through December 31, 2022, either with no change to the capitalization rates found in the study or with such modifications to the capitalization rate(s) that the independent consultant finds reasonable and supported by evidence. The independent consultant should use its expertise and all relevant information available to it to make recommendations as to what the capitalization rate(s) should be for prior years for ComEd, set forth the basis for its recommendations, and provide both the recommendations and the basis to ComEd and DAA. If there is no recommendation by the independent consultant for any year or other period between January 1, 2017 and December 31, 2022 for any specific capitalizable cost center, then ComEd should base its capitalization rate and the amount to be capitalized for such year or period on the rates and costs of such specific cost centers for which ComEd can provide to DAA reasonable evidence as to the time employees in such cost centers spent having a definite relation to construction and exclude from consideration those cost centers for which ComEd cannot provide such evidence, per, for example, 18 C.F.R. Part 101, General Instruction No. 2 and § 41.8.", "source_page": null }, { "number": 14, "text": "The progress of the study should be reported to DAA within 120 days of issuance of this audit report, the time study results should be provided to DAA for review and consideration within 180 days of the date of issuance of this audit report, and the developed allocation procedures should be submitted when complete but no later than 60 days after completion of DAA’s review of the labor time study. At a minimum, the developed allocation procedures should provide a method for overhead cost allocation and capitalization to construction based on actual timecard distributions or, where this procedure is impractical, based on periodic time studies.", "source_page": null }, { "number": 15, "text": "Revise written policies, practices, and procedures governing the methods used to account for, track, report, and review overhead labor, labor-related costs, and all other costs allocated to construction projects to be consistent with Commission accounting requirements. In addition, adopt procedures to retain formal documentation supporting the amount of overhead costs allocated to electric plant accounts.", "source_page": null }, { "number": 16, "text": "Provide training to relevant staff on the revised overhead allocation policies, practices, procedures, and documentation. Provide periodic training in this area, as needed.", "source_page": null }, { "number": 17, "text": "Within 30 days of the completion of Recommendation No. 13, submit an estimate to DAA, including the calculations and determinative components, of overhead costs that would have been allocated to CWIP from January 1, 2017 through the present consistent with the requirements of Electric Plant Instruction No. 4 and General Instruction No. 9. The estimate should be based on a recalculation of 2017 and subsequent years’ overhead costs allocated to construction with labor and labor-related costs removed from the cost of plant (transmission, distribution, general, and production) that were not associated with construction activities based on the methodology developed in response to Recommendation No. 13.", "source_page": null }, { "number": 18, "text": "With the response to Recommendation No. 17, submit proposed accounting entries to DAA that remove the overhead costs that were allocated to electric plant in CWIP and in service during the audit period. The amount of overhead costs removed should be the excess amount of such costs that was allocated to the accounts based on the methodology developed in response to Recommendation No. 17. Also, provide proposed accounting entries to remove associated amounts from other accounts and balances affected by the inappropriately allocated costs such as the accumulated depreciation and ADIT accounts and AFUDC balances capitalized into CWIP and plant in service. If the adjusting entries result in a significant impact to income for the current year, ComEd may account for the transaction as a correction of a prior period error in Account 439, Adjustments to Retained Earnings. Such an entry should be submitted with the proposed accounting entries.", "source_page": null }, { "number": 19, "text": "Submit a refund analysis to DAA that explains and details the following: (1) calculation of refunds, plus interest, that result from correction of the overstatement of electric plant in service due to the improper capitalization of labor costs, as determined by the labor time study conducted in response to Recommendation No. 13, from 2021 to the present; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 20, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 21, "text": "Refund amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Allocation of Overhead Costs to Construction Work in Progress (CWIP)", "summary": "ComEd capitalized overhead costs to Account 107, CWIP – Electric, using an allocation method that was not based on the actual time that employees were engaged in construction activities or on a representative time study. This may have led to ComEd charging costs to Account 107 that did not have a definitive relationship to construction. As a result, ComEd may have overstated construction costs recorded in Account 107, Construction Work in Progress, and electric plant in service, as well as accumulated depreciation and ADIT, and may have understated operating expenses. Moreover, this accounting may have led ComEd to overstate its wholesale annual transmission revenue requirement and overbill wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting for Materials and Supplies", "summary": "ComEd’s accounting and transmission formula rate treatment of costs of materials and supplies inventory items were deficient. Specifically, ComEd charged the cost of materials and supplies that it determined to be in excess, no longer usable, or obsolete for its business operations to Account 930.2, Miscellaneous General Expenses, while continuing to retain most of these same materials and supplies in its inventory. The costs of some of these materials and supplies retained in inventory were also charged to O&M or capital work orders. In addition, ComEd improperly included the cost of missing or lost materials and supplies in Account 154, Plant Material and Operating Supplies. As a result, ComEd may have overstated its annual transmission revenue requirement and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Revise policies and procedures to ensure that the accounting for materials and supplies is consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 23, "text": "Train relevant staff on the revised procedures for properly accounting for materials and supplies, and provide periodic training in this area, as needed.", "source_page": null }, { "number": 24, "text": "Conduct an inventory audit of materials and supplies and associated costs recorded in ComEd’s financial records. Provide a list of materials and supplies with cost information for the items that could not be located (i.e., missing or lost items). Report the progress of this inventory audit within 90 days of the date of issuance of this audit report and provide the results to DAA for review and consideration within 120 days of the date of issuance of this audit report.", "source_page": null }, { "number": 25, "text": "With the response to Recommendation No. 24, submit proposed accounting entries to DAA that remove missing or lost materials and supplies items from Account 154.", "source_page": null }, { "number": 26, "text": "Submit a refund analysis, within 60 days of the date of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ComEd’s wholesale transmission customers from 2021 to the present, plus interest, relating to materials and supplies that were determined to be unusable or obsolete and inappropriately recorded in Account 930.2; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 27, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 28, "text": "Refund amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Penalties", "summary": "ComEd improperly recorded penalties for violations of city codes and ordinances in various O&M and A&G Accounts, instead of in Account 426.3, Penalties. As a result, ComEd overstated its annual transmission revenue requirement and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Revise its policies and procedures to ensure that it properly accounts for penalties for violating city codes and ordinances or other regulations or statues consistent with Commission accounting regulations.", "source_page": null }, { "number": 30, "text": "Provide training to its staff on the revised procedures for properly accounting for penalties for violating city codes and ordinances or other regulations or statues in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 31, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of improper cost of penalties recovered in the transmission formula rates from 2021 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 32, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 33, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting Misclassifications", "summary": "ComEd recorded various O&M and A&G expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, ComEd overstated its annual transmission revenue requirement and overbilled its wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 34, "text": "Revise policies and procedures to ensure that ComEd properly accounts for expenditures in consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 35, "text": "Provide training to its staff on the revised procedures for properly accounting for expenditures in ComEd’s books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 36, "text": "Perform an analysis of A&G expense accounts to identify all MGP site labor costs that were improperly recovered through ComEd’s transmission formula rate and the related transmission customer billings from 2021 to the present. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 37, "text": "Perform an analysis of A&G expense accounts to identify expenses that were improperly recovered through ComEd’s transmission formula rate and the related transmission customer billings, such as charitable contributions, customer engagement expenses, and distribution function costs improperly charged to accounts included in the transmission formula rate from 2021 to the present. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 38, "text": "Perform an analysis to determine the appropriate allocation percentage to apply to those costs accumulated in the environmental hazards, prevention, and mitigation project account by year from 2021 to the present. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 39, "text": "Submit a refund analysis to DAA, within 60 days of receiving this audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries from 2021 to the present, that resulted from the improper accounting for expenses recorded in A&G accounts, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 40, "text": "Submit a refund analysis to DAA, within 60 days of receiving this audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries from 2021 to the present that resulted from the improper accounting for MGP site labor cost in A&G accounts, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 41, "text": "Submit a refund analysis to DAA, within 60 days of receiving this audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries from 2021 to the present, that resulted from the unsupported cost allocation between transmission and distribution functions, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 42, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 43, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 8, "title": "Accounting for Compromised Settlements", "summary": "ComEd improperly recorded approximately $180 thousand of compromise settlement payments for alleged employment discrimination in Account 925, Injuries and Damages, instead of in Account 426.5, Other Deductions. As a result, ComEd overstated its wholesale annual transmission revenue requirement and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 44, "text": "Strengthen and revise accounting processes and procedures to ensure that ComEd properly records compromise settlement payments related to employment discrimination claims in Account 426.5, consistent with Accounting Release No. 12.", "source_page": null }, { "number": 45, "text": "Provide training to staff on the revised processes and procedures for properly accounting for compromise settlement payments resulting from employment discrimination claims in Account 426.5. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null }, { "number": 46, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ComEd’s wholesale transmission customers from 2021 to the present, plus interest, relating to the inclusion of compromise settlement payments and the other potential costs of the alleged employment discrimination claims; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 47, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 48, "text": "Refund amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 9, "title": "Allowance for Funds Used During Construction", "summary": "ComEd improperly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, in the equity balances used for the purpose of computing its AFUDC rate. In addition, ComEd improperly used its quarter-end book balances for long-term debt and common equity for the purpose of computing its AFUDC rate rather than using its calendar year-end balances for long-term debt and common equity reported in its FERC Form No. 1. Also, ComEd improperly recorded amounts related to equity AFUDC ADIT in Account 254, Other Regulatory Liabilities, and Account 190, Accumulated Deferred Income Taxes, instead of in Accounts 182.3, Other Regulatory Assets, 282, Accumulated Deferred Income Taxes – Other Property, and 283, Accumulated Deferred Income Taxes – Other. As a result of ComEd’s inclusion of Account 216.1 for the purpose of computing its AFUDC rate, ComEd over accrued AFUDC during the audit period, which led the company to overstate CWIP and plant-in-service balances.", "is_other_matter": false, "recommendations": [ { "number": 49, "text": "Revise and implement processes and procedures to calculate the AFUDC rate consistent with Electric Plant Instruction No. 3(A)(17), and other applicable Commission requirements. Revisions should include processes to prevent the inclusion of balances in Account 216.1 and to ensure the use of calendar year-end book balances for long-term debt, preferred stock, and common equity for the purpose of computing the AFUDC rate. The revisions should also include accounting for equity AFUDC ADIT amounts in a manner consistent with the Commission’s requirements.", "source_page": null }, { "number": 50, "text": "Provide training to staff on the revised processes and procedures for calculating the AFUDC rate consistent with Electric Plant Instruction No. 3(A)(17), and other applicable Commission requirements. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null }, { "number": 51, "text": "Recalculate accrued AFUDC in a manner consistent with Electric Plant Instruction No. 3(A)(17) that corrects for the improper inclusion of Account 216.1 from 2017 through the date of the audit report and submit the recalculation to DAA for review within 60 days of this report.", "source_page": null }, { "number": 52, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by the overaccrual of AFUDC within 60 days of the date of the audit report.", "source_page": null }, { "number": 53, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of equity AFUDC ADIT and equity AFUDC ADIT gross up amounts from Accounts 190 and 254, within 60 days of the date of the audit report.", "source_page": null }, { "number": 54, "text": "Revise CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by overaccrual of AFUDC and the improper accounting of equity AFUDC ADIT and equity AFUDC ADIT gross up amounts after receiving DAA’s assessment of the proposed accounting entries per Recommendation Nos. 52 and 53.", "source_page": null }, { "number": 55, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ComEd’s wholesale transmission customers from 2021 to the present, plus interest, relating to the excess AFUDC resulting from inclusion of Account 216.1; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 56, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 57, "text": "Refund amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 10, "title": "Excess Accumulated Deferred Income Tax", "summary": "ComEd improperly netted the excess and deficient ADIT related to the corporate tax rate change and associated adjustments required due to the TCJA of 2017 and recorded the amount that resulted from this improper netting in Account 254, Other Regulatory Liabilities. This action affected the transparency and accuracy of the excess and deficient ADIT amounts reported in ComEd’s FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [ { "number": 58, "text": "Revise accounting policies and procedures to ensure ComEd properly records and reports the effect of changes in tax laws or tax rates resulting from the TCJA of 2017 consistent with the Commission’s accounting guidance in Docket No. AI93- 5.", "source_page": null }, { "number": 59, "text": "Provide training to relevant staff on the revised policies and procedures for recording and reporting the effect of changes in tax laws or tax rates. Provide periodic training in these areas as needed.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 11, "title": "FERC Form No. 1 Reporting", "summary": "ComEd did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. These actions affected the transparency, accuracy, and usefulness of certain pages of the FERC Form No. 1 reports. D.", "is_other_matter": false, "recommendations": [ { "number": 60, "text": "Revise and strengthen policies, procedures, and practices to report correct, accurate, and complete information in the FERC Form No. 1 consistent with the pages’ instructions. Include footnotes when software limitations prevent reporting complete information.", "source_page": null }, { "number": 61, "text": "Provide training to relevant staff on the revised FERC Form No. 1 policies, procedures, and practices. Provide periodic training in these areas as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Capitalization vs. expense", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Inventory, materials & fleet", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-07-25_oklahoma-gas-and-electric-company_fa22-5", "company": "Oklahoma Gas and Electric Company", "company_raw": "Oklahoma Gas and Electric Company (FA22-5)", "docket": "FA22-5", "docket_full": "FA22-5-000", "issued_date": "2023-07-25", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230725-3008&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230725-3008", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 73, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 through December 31, 2022", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 8, "findings": [ { "index": 1, "title": "Amortization of Retail Regulatory Assets", "summary": "OG&E included the amortization of certain retail regulatory assets in its wholesale transmission formula rate without Commission approval. As a result, OG&E overstated its annual transmission revenue requirement (ATRR) and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies and procedures for computing its transmission formula rate ATRRs and transmission customer billings to exclude amortization of retail regulatory assets which were not approved by the Commission for recovery through OG&E’s transmission formula rate.", "source_page": null }, { "number": 2, "text": "Provide training to staff on the revised policies and procedures for excluding retail regulatory assets from OG&E’s transmission formula rate calculations. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of regulatory asset amortizations which were inappropriately included in OG&E’s transmission formula rate calculations and customer billings without Commission prior authorization and the refunds resulting from the inclusion of those regulatory asset amortizations in the transmission formula rate calculations from 2012 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 4, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. In addition, notify the audit team after filing the refund report.", "source_page": null }, { "number": 5, "text": "Refund amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Transmission Incentives", "summary": "OG&E improperly included the amortization of Allowance for Funds Used During Construction (AFUDC) associated with transmission incentive projects as inputs to its transmission formula rate. The Commission had already authorized these projects for Construction Work in Progress (CWIP) in rate base treatment. As a result, OG&E overstated its ATRR by approximately $1.8 million and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Revise procedures for computing transmission formula rate ATRRs and customer billings to exclude amortized retail AFUDC consistent with the Commission’s order approving the OG&E transmission incentives.", "source_page": null }, { "number": 7, "text": "Provide training to staff on the revised transmission formula rate policies and procedures for excluding amortized retail AFUDC from OG&E’s transmission formula rate calculations. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 8, "text": "Submit a refund analysis, within 60 days of the issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of the amount of refunds resulting from correction of the inappropriate inclusion of amortized AFUDC relating to the two projects in transmission formula rate calculations from 2012 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 9, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. In addition, notify the audit team after filing the refund report.", "source_page": null }, { "number": 10, "text": "Refund amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 3, "title": "Asset Retirement Obligations", "summary": "OG&E’s accounting and rate treatment of asset retirement obligations (AROs) and asset retirement costs (ARCs) were contrary to Commission regulations. Specifically, OG&E made the following errors: (1) removed accumulated depreciation amounts from Account 108, Accumulated Provision for Depreciation of Electric Utility Plant (Major Only), without Commission approval, resulting in excluding some of the removed accumulated depreciation amounts from the calculation of OG&E’s transmission formula rate ATRR calculations, thereby overstating the ATRR and transmission customer billings; and (2) included ARCs recorded in Electric Plant in Service balances in the transmission formula rate base without Commission approval. As a result, OG&E may have overstated its ATRR and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise policies and procedures to ensure that OG&E’s accounting and transmission formula rate treatment of AROs and ARCs are consistent with the Commission’s regulations.", "source_page": null }, { "number": 12, "text": "Provide training to its staff on the revised policies and procedures for proper accounting and transmission formula rate treatment of AROs and ARCs. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 13, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that resulted from correcting the improper accounting and transmission formula rate treatment of AROs and ARCs from 2008 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) transmission customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 14, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. In addition, notify the audit team after filing the refund report.", "source_page": null }, { "number": 15, "text": "Refund the amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Allowance for Funds Using During Construction", "summary": "OG&E improperly calculated its AFUDC rate. Specifically, OG&E incorrectly: (1) calculated its short-term debt cost rate; (2) included Account 226, Unamortized Discount on Long-Term Debt, in long-term debt balances; and (3) recorded Accumulated Deferred Income Tax (ADIT) amounts related to equity AFUDC gross-up in Account 282, Accumulated Deferred Income Taxes – Other Property, instead of Account 283, Accumulated Deferred Income Taxes – Other. As a result, OG&E over accrued AFUDC included in utility plant accounts and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise and implement policies and procedures to calculate the AFUDC rate consistent with Electric Plant Instruction No. 3(A)(17), and other applicable Commission regulations and orders.", "source_page": null }, { "number": 17, "text": "Provide training to staff on the revised policies and procedures for calculating the AFUDC rate consistent with Electric Plant Instruction No. 3(A)(17), and other applicable Commission regulations and orders. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null }, { "number": 18, "text": "Recalculate accrued AFUDC in a manner consistent with Electric Plant Instruction No. 3(A)(17) and the Commission order on the AFUDC waiver that corrects the short-term debt rate and long-term debt balances from 2018 through present and submit the recalculation to DAA for review within 60 days of this report.", "source_page": null }, { "number": 19, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over accrual of AFUDC within 90 days of the date of issuance of this audit report.", "source_page": null }, { "number": 20, "text": "Revise CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over accrual of AFUDC and the improper accounting of equity ADIT gross-up amounts after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 19.", "source_page": null }, { "number": 21, "text": "Submit a refund analysis, within 90 days of the date of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of excess AFUDC and impacts on related accounts included in the transmission formula rates, since January 1, 2018 to the present, plus interest computed in accordance with section 35.19a of the Commission’s regulations; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 22, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. In addition, notify the audit team after filing the refund report.", "source_page": null }, { "number": 23, "text": "Refund the amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting Misclassifications", "summary": "OG&E recorded various operation and maintenance (O&M) and administrative and general (A&G) expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, OG&E overstated its ATRR and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Revise policies and procedures to ensure that OG&E properly accounts for expenditures consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 25, "text": "Provide training to its staff on the revised policies and procedures for properly accounting for expenditures in OG&E’s books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 26, "text": "Perform an analysis of O&M and A&G expense accounts to identify expenses that were improperly accounted for and included in OG&E’s transmission formula rate and the related customer billings, such as lobbying expenses, advertising costs, employee related expenses, and production costs improperly charged to accounts included in the transmission formula rate from 2018 to the present. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 27, "text": "Submit a refund analysis to DAA, within 60 days of issuance of the audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting for expenses recorded in A&G and O&M accounts from 2018 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 28, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. In addition, notify the audit team after filing the refund report.", "source_page": null }, { "number": 29, "text": "Refund the amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Compromise Settlements", "summary": "OG&E improperly recorded compromise settlement payments made for alleged employment discrimination in Account 925, Injuries and Damages, instead of Account 426.5, Other Deductions. As a result, OG&E overstated its ATRR and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 30, "text": "Strengthen and revise accounting policies and procedures to ensure that OG&E properly records compromise settlement payments related to employment discrimination claims in Account 426.5, consistent with Commission accounting regulations.", "source_page": null }, { "number": 31, "text": "Provide training to relevant staff on the revised policies and procedures for properly accounting for compromise settlement payments resulting from employment discrimination claims in Account 426.5. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null }, { "number": 32, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that result from correcting the improper accounting for compromise settlement payments, the internal and external legal defense costs, and other potential costs of the settled alleged employment discrimination claims from 2018 to the present, plus interest,; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 33, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. In addition, notify the audit team after filing the refund report.", "source_page": null }, { "number": 34, "text": "Refund amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Commitment Fees", "summary": "OG&E improperly accounted for upfront fees it paid associated with revolving credit facility agreements in Account 181, Unamortized Debt Expense, and improperly accounted for quarterly commitment fees in Account 431, Other Interest Expense. In addition, OG&E improperly included the amortization of the upfront and quarterly commitment fees associated with the revolving credit facility agreements in its calculation of short-term debt interest expense used to compute its AFUDC rate. As a result of the improper accounting, OG&E overstated its ATRR and overbilled its transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Revise accounting policies and procedures relating to accounting for revolving credit facility agreements to be consistent with Commission accounting regulations.", "source_page": null }, { "number": 36, "text": "Revise policies and procedures for calculating the AFUDC rate to be consistent with Electric Plant Instruction No. 3(A)(17) and other applicable Commission regulations. Revisions should include processes to exclude upfront and quarterly commitment fees from AFUDC rate calculations unless the costs are associated with debt issuances and are approved by the Commission for inclusion.", "source_page": null }, { "number": 37, "text": "Train relevant staff on the revised policies and procedures, and provide periodic training, as needed.", "source_page": null }, { "number": 38, "text": "Within 60 days of issuance of this audit report, submit proposed accounting entries and supporting documentation to DAA that reflect the transfer of credit facility agreement-related balances improperly recorded in Account 181 to Account 186.", "source_page": null }, { "number": 39, "text": "Revise miscellaneous deferred debit balances to appropriately account for and report credit agreement-related balances after receiving DAA’s assessment of the proposed accounting entries and restate and footnote the balances reported in the FERC Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions.", "source_page": null }, { "number": 40, "text": "Submit a refund analysis, within 60 days of the date of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of excess AFUDC and impacts on related accounts included in the transmission formula rate ATRR and billings to transmission customers, since January 1, 2018 to the present, plus interest computed in accordance with section 35.19a of the Commission’s regulations; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 41, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. In addition, notify the audit team after filing the refund report.", "source_page": null }, { "number": 42, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 8, "title": "FERC Form No. 1 Reporting", "summary": "OG&E did not properly follow the FERC Form No. 1 reporting instructions and, therefore, did not accurately report all required information in its FERC Form No. 1 filings. These actions affected the transparency, accuracy, and usefulness of the reports. D.", "is_other_matter": false, "recommendations": [ { "number": 43, "text": "Revise and strengthen policies and procedures to report correct, accurate, complete information in the FERC Form No. 1 consistent with the page instructions. Include footnotes when software limitations prevent reporting complete information.", "source_page": null }, { "number": 44, "text": "Provide training to relevant staff on the revised FERC Form No. 1 policies and procedures. Provide periodic training in these areas as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-06-29_pacificorp_pa22-2", "company": "PacifiCorp", "company_raw": "PacifiCorp (PA22-2)", "docket": "PA22-2", "docket_full": "PA22-2-000", "issued_date": "2023-06-29", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230629-3002&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230629-3002", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 18, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 to October 31, 2022", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-06-21_public-service-company-of-colorado_fa22-3", "company": "Public Service Company of Colorado", "company_raw": "Public Service Company of Colorado (FA22-3)", "docket": "FA22-3", "docket_full": "FA22-3-000", "issued_date": "2023-06-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230621-3003&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230621-3003", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 59, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 through January 31, 2023", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Allocation of Overhead Costs to CWIP", "summary": "PSCo capitalized overhead costs to Account 107, Construction Work in Progress (CWIP) – Electric, using an allocation method that was not based on the actual time that employees were engaged in construction activities or on a study of the time actually engaged during a representative period. This led to PSCo charging costs to Account 107 that did not have a definite relation to construction. As a result, PSCo may have overstated construction costs recorded in Account 107 and electric plant in service costs recorded in Account 101 or other plant accounts, as well as accumulated depreciation and accumulated deferred income tax (ADIT), and may have understated operating expenses. Moreover, this accounting may have led PSCo to overstate its annual transmission revenue requirement (ATRR) and annual production revenue requirement (APRR) and overbill customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Retain an independent third-party entity to conduct a representative labor-time study for allocation of overhead costs incurred in 2023, and to assist with the development of procedures PSCo shall use after 2023 to periodically determine the allocation of overhead labor and labor-related costs capitalized by PSCo into the cost of construction. The consultant should have experience independently performing time studies used in the determination of overhead capitalization rates of U.S.-based utilities subject to the accounting requirements prescribed for public utilities and licensees or for natural gas companies under 18 C.F.R. Part 101 or Part 201, respectively. The time study should involve a representative sample of study participants (employees) that provides for extrapolation of the study results to the full population of PSCo employees. The time study should include processes to apply the study results from the beginning of the audit period to the issue date of this audit report. In addition, the study should include processes to apply the capitalization rate(s) the study finds for 2023 back to the period January 1, 2018 through December 31, 2022, either with no change to the capitalization rates found in the study or with such modifications to the capitalization rate(s) that the independent consultant finds reasonable and supported by evidence. The independent consultant should use its expertise and all relevant information available to it to make recommendations as to what the capitalization rate(s) should be for prior years for PSCo, set forth the basis for its recommendations, and provide both the recommendations and the basis to PSCo and DAA. If there is no recommendation by the independent consultant for any year or other period between January 1, 2018 and December 31, 2022 for any specific capitalizable department and associated internal orders, then PSCo should base its capitalization rate and the amount to be capitalized for such year or period on the rates and costs of such specific internal orders for which PSCo can provide to DAA reasonable evidence as to the time employees charging such internal orders spent having a definite relation to construction and exclude from consideration those internal orders for which PSCo cannot provide such evidence, per, for example, 18 C.F.R. Part 101, General Instruction No. 2 and § 41.8.", "source_page": null }, { "number": 2, "text": "Report the progress of the study within 120 days and provide the time study results to DAA for review and consideration within 180 days of the date of this audit report. The allocation procedures should be submitted when complete but no later than 60 days after completion of DAA’s review of the labor time study. At a minimum, the allocation procedures should provide a method for overhead cost allocation and capitalization to construction based on actual timecards or, where this procedure is impractical, based on periodic time studies.", "source_page": null }, { "number": 3, "text": "Revise policies and procedures governing the methods used to account for, track, report, and review overhead labor, labor-related costs, and all other costs allocated to construction projects to be consistent with Commission accounting requirements. In addition, adopt procedures to retain formal documentation supporting the amount of overhead costs allocated to electric plant accounts.", "source_page": null }, { "number": 4, "text": "Provide training to relevant staff on the revised overhead allocation policies, practices, procedures, and documentation. Provide periodic training in this area, as needed.", "source_page": null }, { "number": 5, "text": "Within 30 days of the completion of Recommendation No. 1, submit an estimate to DAA, including the calculations and determinative components, of overhead costs that would have been allocated to CWIP from January 1, 2018 through the present consistent with the requirements of Electric Plant Instruction No. 4 and General Instruction No. 9. The estimate should be based on a recalculation of 2018 and subsequent years’ overhead costs allocated to construction with labor and labor-related costs removed from the cost of plant (Transmission, Distribution, General, and Production) that were not associated with construction activities based on the methodology developed in response to Recommendation No. 1.", "source_page": null }, { "number": 6, "text": "With the response to Recommendation No. 5, submit proposed accounting entries to DAA that remove excess overhead costs from Transmission, Distribution, General, and Production plant accounts that were allocated to electric plant in CWIP and in service during the audit period. The amount of overhead costs removed should be the excess amount of such costs as determined based on the methodology developed in response to Recommendation No. 1. Also, provide proposed accounting entries to remove associated amounts from other accounts and balances affected by the inappropriately allocated costs such as the accumulated depreciation and ADIT accounts and AFUDC balances capitalized into CWIP and plant in service. If the adjusting entries result in a significant impact to income for the current year, PSCo may account for the transaction as a correction of a prior period error in Account 439, Adjustments to Retained Earnings. Such an entry should be submitted with the proposed accounting entries.", "source_page": null }, { "number": 7, "text": "Submit a refund analysis, within 60 days of DAA’s approval of the time study performed, to DAA that explains and details the following: (1) calculation of refunds, plus interest, that result from correction of the overstatement of electric plant in service due to the improper capitalization of labor costs, as determined by the labor time study conducted in response to Recommendation No. 1, from January 1, 2018 to the present; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 8, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 9, "text": "Refund amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Joint Owner Billing", "summary": "PSCo did not functionalize portions of third- party billings characterized as administrative and general (A&G) expenses for the operation and maintenance of the Craig Generating Station. As a result, PSCo overstated A&G expenses and understated expenses recorded in the production operation and maintenance (O&M) expense accounts. Moreover, this accounting error led PSCo to overstate its ATRR and overbill transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Revise policies and procedures governing the methods used to account for, track, report, and review costs associated with joint-owner billings to comply with the Commission’s accounting regulations.", "source_page": null }, { "number": 11, "text": "Train relevant staff on the revised policies and procedures for properly accounting for costs associated with joint-owner billings, and provide periodic training in this area, as needed.", "source_page": null }, { "number": 12, "text": "Submit a refund analysis, within 60 days of the date of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper inclusion of production costs associated with joint-owner billings in the ATRR from 2018 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 13, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 14, "text": "Refund amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting Misclassifications", "summary": "PSCo recorded various A&G expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, PSCo overstated its ATRR and APRR and overbilled customers.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Revise policies and procedures to help ensure that PSCo properly accounts for expenditures consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 16, "text": "Provide training to relevant staff on the revised policies and procedures for properly accounting for expenditures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 17, "text": "Perform an analysis of A&G expense accounts to identify expenses that were improperly included in accounts that had balances used as inputs to PSCo’s transmission and production formula rates and the determination of customer billings from 2018 to the present. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 18, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting for expenses recorded in A&G accounts from 2018 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 19, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 20, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Mutual Aid Services", "summary": "PSCo improperly recorded revenues and expenses associated with mutual aid services in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, PSCo overstated its ATRR and APRR and overbilled customers.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Develop and implement procedures and policies to help ensure that mutual aid service revenues and costs are properly accounted for consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 22, "text": "Provide training to relevant staff on the revised policies and procedures for properly accounting for mutual aid revenues and costs. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 23, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from the improper accounting for mutual aid revenues and expenses from 2013 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 24, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 25, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Compromise Settlements", "summary": "PSCo improperly recorded $82,195 in compromise settlement payments relating to claims of alleged employee discrimination in Account 920, Administrative and General Salaries, and in Account 925, Injuries and Damages, instead of in Account 426.5, Other Deductions. As a result, PSCo overstated its ATRR and APRR and overbilled its customers.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Revise accounting policies and procedures to properly record compromise settlement payments related to employment discrimination claims in Account 426.5, consistent with Commission accounting regulations.", "source_page": null }, { "number": 27, "text": "Provide training to relevant staff on the revised processes and procedures for properly accounting for compromise settlement payments relating to employment discrimination claims in Account 426.5. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null }, { "number": 28, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that resulted from the improper accounting for employment discrimination claims resolved by compromise settlements, expenses of internal and external counsel’s legal defense, and other costs of employment discrimination claims from 2018 to the present, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 29, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 30, "text": "Refund amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of Commission regulations. Allowance for Funds Used During Construction", "source_page": null }, { "number": 31, "text": "Revise policies and procedures to calculate and account for AFUDC and equity ADIT consistent with Commission accounting regulations.", "source_page": null }, { "number": 32, "text": "Provide training to relevant staff on the revised policies and procedures for accounting for AFUDC and equity ADIT consistent with Commission accounting regulations. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null }, { "number": 33, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the accounting for equity ADIT in Account 283, within 60 days of the date of the audit report.", "source_page": null }, { "number": 34, "text": "Revise ADIT account balances after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 33. E.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 6, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "PSCo’s method for computing and accounting for its AFUDC rate was deficient. Specifically, PSCo improperly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, and Account 219, Accumulated Other Comprehensive Income, in determining the equity component of its AFUDC rate. Also, PSCo improperly recorded ADIT amounts related to equity AFUDC gross-up in Account 282, Accumulated Deferred Income Taxes – Other Property, instead of Account 283, Accumulated Deferred Income Taxes – Other. D.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Capitalization vs. expense", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "NY", "source": "New York State Public Service Commission", "doc_type": "comprehensive management & operations audit (PSC order initiating audit, PSL §66(19))", "id": "2023-05-18_nyseg-rge_ny-23-m-0103-order-initiating-audit", "company": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "company_raw": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "docket": "23-M-0103", "docket_full": null, "issued_date": "2023-05-18", "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=23-M-0103", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B60E82F88-0000-C61D-BA6F-699DDCFC0768%7D", "captured_at": "2026-06-22", "source_note": "NY PSC Order Initiating a Management and Operations Audit, Case 23-M-0103 (5 pp) — commences the PSL §66(19) comprehensive management and operations audit of NYSEG and RG&E that produced the February 2025 NorthStar final report. Issued at the Commission session held May 18, 2023. Page 1 verified: 'STATE OF NEW YORK PUBLIC SERVICE COMMISSION At a session of the Public Service Commission held in the City of Albany on May 18, 2023 ... CASE 23-M-0103'. Harvested from the NY DPS DMM. Listed for reference (metadata-only). Source: NY DPS DMM (documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={60E82F88-0000-C61D-BA6F-699DDCFC0768}).", "archived_via": null, "page_count": 5, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "ALJ initial decision", "id": "2023-05-15_system-energy-resources_el20-72", "company": "Louisiana Public Service Commission et al. v. System Energy Resources, Inc.", "company_raw": "Louisiana Public Service Commission et al. v. System Energy Resources, Inc.", "docket": "EL20-72", "docket_full": null, "issued_date": "2023-05-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230515-3006&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230515-3006", "captured_at": "2026-06-07", "source_note": "FERC ALJ Initial Decision re Louisiana Public Service Commission et al. v. System Energy Resources, Inc., Docket EL20-72, issued 2023-05-15. The states' complaint challenges the prudence of costs System Energy recovers through the Unit Power Sales Agreement for the Grand Gulf nuclear plant (uprate, sale-leaseback, and related cost recovery). Metadata-only (free-form legal order). Found via the eLibrary AdvancedSearch API (searchText=EL20-72); accession 20230515-3006.", "archived_via": null, "page_count": 383, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management efficiency investigation", "id": "2023-04-01_ugi-utilities_pa-mei", "company": "UGI Utilities, Inc.", "company_raw": "UGI Utilities, Inc.", "docket": "D-2022-3032778", "docket_full": null, "issued_date": "2023-04-01", "source_page_url": "https://www.puc.pa.gov/press-release/2023/puc-issues-management-efficiency-investigation-report-for-ugi-utilities", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1785721.pdf", "captured_at": "2026-06-18", "source_note": "Management Efficiency Investigation of UGI Utilities, Inc. (follow-up to the 2019 Focused Management & Operations Audit), PA PUC Bureau of Audits; PUC publication April 2023, Docket No. D-2022-3032778. Recommendations in Exhibit II-1. PDF: puc.pa.gov/pcdocs/1785721.pdf. Listed for reference (metadata-only; MEI Exhibit II-1 format not yet parsed).", "archived_via": null, "page_count": 61, "scanned_pages": [ 2, 60, 61 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2023-03-02_philadelphia-gas-works_pa-mo-audit", "company": "Philadelphia Gas Works", "company_raw": "Philadelphia Gas Works", "docket": "D-2022-3030321", "docket_full": null, "issued_date": "2023-03-02", "source_page_url": "https://www.puc.pa.gov/press-release/2023/puc-issues-management-and-operations-audit-for-philadelphia-gas-works", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1775875.pdf", "captured_at": "2026-06-08", "source_note": "Management & Operations Audit issued by the PA PUC Bureau of Audits; PUC publication 2023-03-02. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 95, "scanned_pages": [ 1, 95 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 11, "findings": [ { "index": 1, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Streamline corporate governance processes to efficiently align with PGW’s current regulatory framework.", "source_page": 18 }, { "number": 2, "text": "Streamline the annual budget approval process.", "source_page": 18 }, { "number": 3, "text": "Establish committee charters for all PFMC board committees.", "source_page": 18 }, { "number": 4, "text": "Evaluate director performance annually to identify opportunities for improvement and to ensure emerging needs and priorities are met.", "source_page": 18 } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Executive Management and Organizational Structure", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Develop specific guidance for span of control expectations, periodically review spans of control, and document any narrow or wide spans for PGW’s management positions.", "source_page": 26 }, { "number": 6, "text": "Implement a safety management system and improve safety culture at PGW.", "source_page": 26 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 3, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Update Internal Audit policies and procedures.", "source_page": 34 }, { "number": 8, "text": "Formally document explanations for variances from the capital and operating budgets.", "source_page": 34 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 4, "title": "Gas Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Implement a policy and metrics-tracked plan to replace mercury regulators within the distribution system.", "source_page": 46 }, { "number": 10, "text": "Accelerate cast iron main replacement.", "source_page": 46 }, { "number": 11, "text": "Plan and implement a process for gathering equipment and installation data in the GIS database.", "source_page": 46 }, { "number": 12, "text": "Reorganize the CARC reporting structure to eliminate conflicts of interest with the SVP of Operations.", "source_page": 46 } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 13, "text": "File Self-Certification forms with the Pennsylvania PUC annually.", "source_page": 53 }, { "number": 14, "text": "Correct various deficiencies in physical security.", "source_page": 53 }, { "number": 15, "text": "Establish a company-wide program for inspections for safety, security, medical, and fire equipment, and make assessable standardized first aid kits at all regularly occupied facilities.", "source_page": 53 } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "index": 6, "title": "Emergency Preparedness (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Explore ways to eliminate or mitigate the identified security risk through a business case analysis.", "source_page": 53 }, { "number": 17, "text": "Increase focus on cybersecurity by developing a dedicated cybersecurity budget, performing a staffing study and adjusting resources as needed, and create an executive level cybersecurity leadership position.", "source_page": 53 }, { "number": 18, "text": "Reinforce contingencies with the OT systems by cross-training, increasing resources, or by some other method.", "source_page": 53 }, { "number": 19, "text": "Document the threshold where cybersecurity risks will be relayed to the cabinet and board levels.", "source_page": 53 }, { "number": 20, "text": "Implement a cybersecurity-focused risk registry.", "source_page": 53 } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 7, "title": "Materials Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Document the policies and procedures of PGW’s cycle counting function.", "source_page": 57 }, { "number": 22, "text": "Implement and/or increase automation of materials management processes to improve efficiency, accuracy, and ease-of-use.", "source_page": 57 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 8, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Leverage pandemic and low-income resources to help reduce the overall level of outstanding customer balances and maintain outreach efforts to engage payment troubled customers.", "source_page": 67 }, { "number": 24, "text": "Improve customer service performance through expanding call center resources.", "source_page": 67 }, { "number": 25, "text": "Complete implementation of the replacement CIS.", "source_page": 67 }, { "number": 26, "text": "Establish reporting and key performance metrics for all back-office activities that support electronic, self-service, and alternative exchanges with customers.", "source_page": 68 }, { "number": 27, "text": "Repurpose or divest interest in district offices and reallocate resources to benefit PGW ratepayers.", "source_page": 68 } ], "themes": [ "Customer service & billing" ], "cost_to_customers": false }, { "index": 9, "title": "Information Technology", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Establish IS departmental performance metrics for transparency, evaluation, and improvement of productivity and efficiency.", "source_page": 72 }, { "number": 29, "text": "Leverage and integrate data visualization software consistently across PGW.", "source_page": 72 } ], "themes": [ "Information technology & systems" ], "cost_to_customers": false }, { "index": 10, "title": "Fleet Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 30, "text": "Improve efficiencies within the fleet department.", "source_page": 77 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 11, "title": "Human Resources and Diversity", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 31, "text": "Implement strategies for recruitment and retention of “at-risk” positions.", "source_page": 84 }, { "number": 32, "text": "Drive safety performance to meet industry standards.", "source_page": 84 } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Customer service & billing", "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Information technology & systems", "Internal audit & internal controls", "Inventory, materials & fleet", "Workforce, training & succession planning" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2023-02-10_wec-business-services-llc_fa21-2", "company": "WEC Business Services LLC", "company_raw": "WEC Business Services LLC (FA21-2)", "docket": "FA21-2", "docket_full": null, "issued_date": "2023-02-10", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20230210-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20230210-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 65, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "1", "60" ], "finding_count": 8, "findings": [ { "index": 1, "title": "Merger-Related Capital Expenditures", "summary": "WEC Business Services and the WEC 3 electric utilities, which were allocated a portion of the service company’s costs, improperly accounted for their portion of approximately $142.2 million of merger- related capital costs in operating capital expenditure accounts and also improperly accounted for the related, resulting depreciation in operating expense accounts, rather than accounting for their portion of the $142.2 million in non-operating Account 426.5, Other Deductions. This improper accounting resulted in the inappropriate recovery of merger-related costs through two of the WEC electric utilities’ cost-based rate recovery mechanisms without the WEC electric utilities first seeking and obtaining the Commission’s approval for recovery under section 205 of the Federal Power Act as required by the 2015 merger order. As a result, the WEC electric utilities over- collected approximately $1,419,000 from wholesale customers during the hold- harmless period between 2015 and 2020.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Reserves for Directors’ Charitable Awards", "summary": "WEC Business Services improperly accounted for a reserve for charitable contributions established under WEC Energy’s Directors’ Charitable Awards Program. WEC Business Services’ improper accounting resulted in such expenses being allocated to and misclassified on the books of WEC electric utilities. This led the WEC electric utilities to overstate the revenue requirements underlying their wholesale cost-based rates and overcharge wholesale customers by approximately $22,000.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Strengthen policies, procedures, and controls to account for donations, accruals and reserves consistent with the Commission accounting requirements.", "source_page": null }, { "number": 8, "text": "Train relevant staff on the revised policies, procedures, and controls and perform periodic training in this area, as needed.", "source_page": null }, { "number": 9, "text": "Perform an analysis to identify other donations that were improperly accounted for during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 10, "text": "Perform an analysis of all charges recognized in connection with the Directors’ Charitable Awards program. Show and reconcile the amounts included in reserves as of the beginning of the audit period, the amounts accrued and payments made during the audit period, and the total amount remaining in reserves as of the end of the audit period and the date of this report. Provide WEC Business Services LLC Docket No. FA21-2-000 the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 11, "text": "Submit proposed accounting entries and supporting documentation that reflect the correction of amounts improperly charged to operating expense accounts during the audit period to DAA for review.", "source_page": null }, { "number": 12, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from donations recorded in the wrong accounts as identified pursuant to the analyses performed in response to Recommendations No. 9 and 10, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale and other customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 13, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 14, "text": "Refund the amounts disclosed in the refund report to the customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 3, "title": "Misclassification of Administrative & General and Nonoperating Expenses", "summary": "WEC Business Services misclassified various expenses as determined from audit staff’s review of selected transactions. As a result of the service company’s accounting misclassifications, those expenses were ultimately misclassified on the books of the WEC electric utilities. This led WEC electric utilities to overstate their revenue requirements and overcharge wholesale customers.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Strengthen policies, procedures, and controls to account for lobbying expenses, membership dues, advertising expenses, regulatory commission expenses, and other misclassified A&G expenses consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 16, "text": "Strengthen policies, procedures, and controls to ensure that costs are charged to the proper service request.", "source_page": null }, { "number": 17, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 18, "text": "Perform an analysis to identify lobbying expenses, membership dues, advertising expenses, regulatory commission expenses, and other A&G expenses that were improperly accounted for during the audit period. Provide the results of the analysis to DAA within 60 days of the date of issuance of this audit report. WEC Business Services LLC Docket No. FA21-2-000", "source_page": null }, { "number": 19, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper accounting for lobbying expenses, membership dues, advertising expenses, regulatory commission expenses, and other A&G expenses recorded in the wrong accounts as identified pursuant to the analysis performed in response to Recommendation No. 18, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale and other customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 20, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 21, "text": "Refund the amounts disclosed in the refund report to the customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 4, "title": "Service Company Cost Allocation Process", "summary": "WEC Business Services improperly allocated costs associated with non-regulated affiliates to the WEC electric utilities and made other allocation errors among its affiliates. This led WEC electric utilities to overstate their wholesale cost-based revenue requirements and overcharge wholesale customers.", "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Strengthen policies, procedures, and controls to ensure that costs are properly allocated to non-regulated and regulated affiliates.", "source_page": null }, { "number": 23, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 24, "text": "Perform an analysis to identify other costs related to non-regulated affiliates that were improperly allocated to the WEC utilities during the audit period. Provide the results of the analysis to DAA within 60 days of the issuance of this audit report.", "source_page": null }, { "number": 25, "text": "Perform an analysis to identify other costs directly charged to WEC utilities that should have been allocated to other regulated affiliates during the audit period. Provide the results of the analysis to DAA within 60 days of the issuance of this audit report.", "source_page": null }, { "number": 26, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit WEC Business Services LLC Docket No. FA21-2-000 period that resulted from the improper allocation of costs as identified pursuant to the analyses performed in response to Recommendations No. 24 and 25, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale and other customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 27, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 28, "text": "Refund the amounts disclosed in the refund report to the customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 5, "title": "Elm Road Generating Station Environmental Settlement Payments", "summary": "WEC Business Services improperly accounted for total payments of around $3.3 million made annually to comply with a settlement agreement instrumental in the relicensing of a power plant it co-owns and operates through its franchised public utility, WEPCO. As a result, WEPCO understated its Steam Power Generation expenses and overstated its Administrative & General (A&G) expenses as reported in its FERC Form No. 1 filings. 4", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Revise policies and procedures to ensure that steam power generation expenses are recorded in the appropriate accounts.", "source_page": null }, { "number": 30, "text": "Train relevant staff on the revised policies and procedures and provide periodic training in this area, as needed.", "source_page": null }, { "number": 31, "text": "Perform an analysis and submit to DAA for review the impact of improper accounting of Elm Road Generating Station (ERGS) settlement payments on wholesale billings during the audit period, based on WEPCO’s tariffs filed with the Commission, within 60 days of issuance of this audit report. The analysis should take into consideration which components of the rates are subject to true up based on actual costs.", "source_page": null }, { "number": 32, "text": "Submit a refund analysis, if applicable, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper accounting for ERGS settlement payments as identified pursuant to the analysis performed in response to Recommendation No. 31, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale and other customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 33, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. WEC Business Services LLC Docket No. FA21-2-000", "source_page": null }, { "number": 34, "text": "Refund the amounts disclosed in the refund report to the customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Rent Prepayments and Related Facility Expenses", "summary": "WEC Business Services improperly accounted for certain lease costs in the current period instead of amortizing those costs over the lease term. Also, WEC Business Services misclassified certain expenses related to leasehold properties in other A&G accounts. Those costs were allocated to the WEC electric utilities where those costs were also misclassified. As a result, WEC electric utilities overstated their wholesale revenue requirements and overcharged wholesale customers.", "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Strengthen policies, procedures, and controls to account for rent prepayments and expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 36, "text": "Strengthen policies, procedures, and controls to ensure that costs are charged to the proper service request.", "source_page": null }, { "number": 37, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 38, "text": "Perform an analysis to identify rent prepayments and expenses, and related other expenses that were improperly accounted for during the audit period. Provide the results of the analysis to DAA for review within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 39, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper accounting for rent prepayments and expenses, and other related expenses recorded in the wrong accounts as identified pursuant to the analysis performed in response to Recommendation No. 38, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale and other customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 40, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 41, "text": "Refund the amounts disclosed in the refund report to the customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations. WEC Business Services LLC Docket No. FA21-2-000", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Vendor Early Payment Discounts and Credit Card Rebates", "summary": "WEC Business Services improperly accounted for vendor discounts for early payment of various invoices and rebates relating to the use of corporate credit cards as credits to Account 431, Other Interest Expense, and Account 921, Office Supplies and Expenses, rather than recording these credits in the accounts in which the costs were originally recorded. As a result of this improper accounting, WEC electric utilities overstated various A&G, Operating and Maintenance (O&M), and Electric Plant in Service Accounts. In addition, WEC Business Services did not maintain sufficient records to demonstrate the distribution of discounts and rebates to A&G, O&M, and capital cost accounts that had been overstated due to its improper accounting.", "is_other_matter": false, "recommendations": [ { "number": 42, "text": "Revise policies and procedures to properly account for vendor discounts and rebates consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 43, "text": "Institute recordkeeping methods for vendor discounts and rebates to permit accurate accounting for costs incurred by WEC Business Services and its affiliates. These methods should directly match discounts and rebates to their respective costs, or else should provide a basis for estimating the distribution of discounts and rebates. File a description of the proposed methods and the expected implementation date within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 44, "text": "Provide training to its staff on the revised procedures for properly accounting for vendor discounts and rebates in its books and records and provide periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 8, "title": "FERC Form No. 60 Reporting", "summary": "WEC Business Services inaccurately reported information on Schedule V – Accounts Receivable from Associate Companies and omitted information from Schedule XVIII – Analysis of Billing – Non-associate Companies in its 2018, 2019, 2020, and 2021 FERC Form No. 60 filings. D. List of Recommendations Audit staff’s", "is_other_matter": false, "recommendations": [ { "number": 45, "text": "Revise and strengthen policies, procedures, and practices to report correct, accurate, complete information in the FERC Form No. 60 consistent with the instructions of each schedule page.", "source_page": null }, { "number": 46, "text": "Provide training to relevant staff on the revised FERC Form No. 60 policies, procedures, and practices. Provide periodic training in these areas, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "NJ", "source": "NJ Board of Public Utilities", "doc_type": "affiliate-transactions audit & management audit, Phase Two (Liberty Consulting)", "id": "2023-02-07_jcpl_nj-ea20110733-affiliate-management-audit-phase2", "company": "Jersey Central Power & Light Company (JCP&L)", "company_raw": "Jersey Central Power & Light Company (JCP&L)", "docket": "EA20110733", "docket_full": null, "issued_date": "2023-02-07", "source_page_url": "https://www.nj.gov/bpu/about/divisions/audits/auditreports.html", "pdf_download_url": "https://www.nj.gov/bpu/pdf/auditpdfs/2023%20JCPL%20Final%20Audit%20Report%20-%20Phase%202.pdf", "captured_at": "2026-06-08", "source_note": "NJ BPU audit (Liberty Consulting Group): Phase Two of an Audit of the Affiliated Transactions and a Management Audit of JCP&L. Docket EA20110733, dated Feb 7, 2023. 601 pp. Page 1 verified.", "archived_via": null, "page_count": 601, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "WA", "source": "Washington Utilities and Transportation Commission", "doc_type": "general rate case Final Order 24 (deferred-accounting / cost-recovery prudence determinations)", "id": "2022-12-22_puget-sound-energy_wa-ue-220066-final-order-24", "company": "Puget Sound Energy", "company_raw": "Puget Sound Energy", "docket": "UE-220066/UG-220067", "docket_full": null, "issued_date": "2022-12-22", "source_page_url": "https://www.utc.wa.gov/casedocket/2022/220066/docsets", "pdf_download_url": "https://apiproxy.utc.wa.gov/cases/GetDocument?docID=3215&year=2022&docketNumber=220066", "captured_at": "2026-06-08", "source_note": "WA UTC Final Order 24 in the consolidated PSE general rate case, Dockets UE-220066/UG-220067, service date Dec 22, 2022. 144 pp. Page 1 verified.", "archived_via": null, "page_count": 144, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "CO", "source": "Colorado Public Utilities Commission", "doc_type": "rate case advice letter", "id": "2022-11-30_public-service-company-colorado_co-22al-0530e-advice-letter-1906", "company": "Public Service Company of Colorado", "company_raw": "Public Service Company of Colorado", "docket": "22AL-0530E", "docket_full": null, "issued_date": "2022-11-30", "source_page_url": "https://www.dora.state.co.us/pls/efi/EFI.Show_Docket?p_docket_id=22AL-0530E", "pdf_download_url": "https://www.dora.state.co.us/pls/efi/efi.show_document?p_dms_document_id=984848&p_session_id=", "captured_at": "2026-06-02", "source_note": "Advice Letter No. 1906 - Electric of Public Service Company of Colorado (Xcel Energy), filed November 30, 2022 with the Colorado Public Utilities Commission, initiating its electric Phase I rate case, Proceeding No. 22AL-0530E (6 pp). Listed for reference (metadata-only). Source: Colorado PUC E-Filings System, document 984848 (dora.state.co.us/pls/efi/efi.show_document?p_dms_document_id=984848).", "archived_via": null, "page_count": 6, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-11-04_tucson-electric-power-company_fa21-3", "company": "Tucson Electric Power Company", "company_raw": "Tucson Electric Power Company (FA21-3)", "docket": "FA21-3", "docket_full": "FA21-3-000", "issued_date": "2022-11-04", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20221104-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20221104-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 82, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 to December 31, 2021", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 11, "findings": [ { "index": 1, "title": "Accounting for Electric Distribution Maintenance Expenses", "summary": "TEP improperly accounted for and reported $1.96 million of electric distribution maintenance expenses in Account 570, Maintenance of Station Equipment (Major Only) for transmission expenses, instead of in Account 592, Maintenance of Station Equipment (Major Only) for distribution expenses, during the audit period. TEP’s accounting resulted in distribution-related maintenance expenses being improperly recorded in accounts that were for transmission-related maintenance expenses and that were FERC-jurisdictional transmission formula rate inputs. This led the company to overstate its FERC-jurisdictional annual transmission revenue requirement during the audit period by approximately $3.66 million.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies and procedures to properly account for substation maintenance work orders consistent with Commission accounting requirements.", "source_page": null }, { "number": 2, "text": "Provide training to its staff on the revised procedures for properly accounting for substation maintenance in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Perform an analysis of costs incurred at substations during the audit period to determine whether distribution-related expenses were charged to the correct account(s) and that the appropriate allocators were used to charge costs to transmission and distribution expense accounts when applicable. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 4, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper accounting for distribution-related O&M expenses in transmission expense accounts, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 5, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 6, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Research, Development, and Demonstration Expenses", "summary": "TEP improperly accounted for and reported $667,500 of Research, Development, and Demonstration (RD&D) expenses associated with renewable power generation in Account 909, Informational and Instructional Advertising Expenses (Major Only), and Account 923, Outside Services Employed, instead of in Account 549, Miscellaneous Other Power Generation Expenses (Major Only). TEP’s accounting resulted in expenses being improperly included in accounts that were FERC-jurisdictional transmission formula rate inputs. This led the company to overstate its FERC-jurisdictional annual transmission revenue requirement during the audit period by approximately $50,000.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise policies and procedures to properly account for RD&D expenditures consistent with Commission accounting requirements.", "source_page": null }, { "number": 8, "text": "Provide training to its staff on the revised procedures for properly accounting for RD&D expenditures in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 9, "text": "Perform an analysis of costs incurred for RD&D activities, including costs relating to RD&D performed by outside research institutions, during the audit period to determine whether RD&D activities were charged to the correct utility function. Provide the results of the analysis to audit staff within 60 days of issuance of this audit report.", "source_page": null }, { "number": 10, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper accounting for RD&D expenses in administrative & general expense accounts, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 11, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 12, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Unrecovered Costs of Plant Facilities", "summary": "TEP accounted for and reported approximately $29 million of unrecovered plant on its books when it retired, prior to the end of their useful life, certain generating assets during the audit period. However, TEP did not record the unrecovered plant balance in Account 182.2, Elec. Power Co., Docket No. ER22-1212-000 (May 4, 2022) (delegated order accepting revised tariff provisions authorizing TEP to participate in CAISO’s Energy Imbalance Market). Unrecovered Plant and Regulatory Study Costs, nor seek authorization from the Commission for its proposed accounting entries for this early retirement of the generating assets. TEP also misclassified the amortization of the unrecovered plant balance to Account 403, Depreciation Expense, rather than recording the amortization in Account 407, Amortization of Property Losses, Unrecovered Plant, and Regulatory Study Costs. As a result, TEP did not complete an important step in enabling the Commission to exercise its regulatory accounting oversight (i.e., submitting accounting entries regarding unrecovered plant balances to the Commission for review and authorization) and did not adequately distinguish the balance of assets and other debits reported in its FERC Form No. 1. In addition, the foregoing errors led TEP to overstate its annual transmission revenue requirement by approximately $11,500 during the audit period and over collect from FERC-jurisdictional transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Revise policies and procedures to properly account for early retirements of significant electric plant facilities consistent with Commission accounting requirements.", "source_page": null }, { "number": 14, "text": "Provide training to its staff on the revised procedures for properly accounting for asset retirements in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 15, "text": "File, within 60 days of issuance of this audit report, a request for approval of proposed retirement journal entries to justify its proposed use of Account 182.2 and period of amortization, including a description of the policies and procedures in place to prevent any additional early plant retirement costs from being charged to FERC-jurisdictional customers absent separate Commission approval of changes to its FERC-jurisdictional tariffs.", "source_page": null }, { "number": 16, "text": "Perform an analysis of costs recorded in Depreciation Expense accounts during the audit period to determine whether early plant retirement costs were recorded in these accounts. Provide the results of the analysis to audit staff within 60 days of the date of the final audit report.", "source_page": null }, { "number": 17, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper accounting for early plant retirement costs; (2) determinative components of the refund; (3) refund method; (4) transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 18, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 19, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Tariff administration & oversight", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Compromise Settlement Agreement", "summary": "TEP misclassified $372,368 of expenditures relating to a compromise settlement agreement in various administrative and general (A&G) expense accounts, rather than recording the expenditures in Account 426.5, Other Deductions. TEP’s accounting resulted in expenses being improperly included and reported in accounts that were FERC- jurisdictional transmission formula rate inputs. This led the company to overstate its FERC-jurisdictional annual transmission revenue requirement during the audit period by approximately $39,300.", "is_other_matter": false, "recommendations": [ { "number": 20, "text": "Strengthen policies, procedures, and controls to account for expenditures associated with compromise settlements consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 21, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 22, "text": "Perform an analysis to identify other expenditures associated with compromise settlements that were improperly accounted for during the audit period. Provide the results of the analysis to audit staff within 60 days of issuance of this audit report.", "source_page": null }, { "number": 23, "text": "Submit a refund report, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from improper accounting for expenditures associated with compromise settlements, which impacted inputs to TEP’s transmission formula rate during the audit period; (2) determinative components of the refund; (3) refund method; (4) customers to receive the refunds, and (5) period(s) refunds will be made.", "source_page": null }, { "number": 24, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 25, "text": "Refund the amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Payments on Behalf of Affiliates", "summary": "TEP improperly accounted for and reported $211,000 in its A&G and operations and maintenance (O&M) accounts that should have been allocated to one or more of its affiliates. TEP overstated certain A&G and O&M expense accounts, which led to utility customers improperly subsidizing non-regulated operations. This also led the company to overstate its FERC-jurisdictional annual transmission revenue requirement during the audit period by approximately $19,300.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Revise policies and procedures to properly account for transactions with affiliate companies consistent with Commission accounting requirements.", "source_page": null }, { "number": 27, "text": "Provide training to its staff on the revised procedures for properly accounting for affiliate transactions in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 28, "text": "Perform an analysis of costs incurred in its utility O&M accounts and A&G accounts during the audit period to determine whether expenses were charged to the correct affiliate(s) and that the appropriate allocators were used to charge costs to transmission, distribution, and A&G expense accounts when applicable. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 29, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper allocation of costs associated with affiliate transactions, plus interest; (2) determinative components of the refund; (3) refund method; (4) FERC-jurisdictional customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 30, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 31, "text": "Refund the amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 6, "title": "Administrative and General Expense Misclassifications", "summary": "TEP improperly accounted for and reported various A&G expenses, and then reported account balances reflecting these expenses in its FERC Form No. 1 filings. TEP’s accounting resulted in expenses being improperly included in accounts that were FERC-jurisdictional transmission formula rate inputs. This led the company to overstate its FERC-jurisdictional annual transmission revenue requirement during the audit period by approximately $26,500.", "is_other_matter": false, "recommendations": [ { "number": 32, "text": "Revise policies and procedures to properly account for A&G expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 33, "text": "Provide training to its staff on the revised procedures for properly accounting for A&G expenses in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 34, "text": "Perform an analysis of costs incurred in A&G accounts during the audit period to determine whether expenses were charged to the correct account(s) and that the appropriate allocators were used to charge costs to transmission, distribution, and A&G expense accounts when applicable. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 35, "text": "Submit a refund analysis, within 60 days of the date of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper accounting for lobbying and general advertising expenses, plus interest; (2) determinative components of the refund; (3) refund method; (4) transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 36, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 37, "text": "Refund the amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 7, "title": "Operation and Maintenance Expense Misclassifications", "summary": "TEP improperly accounted for and reported various utility O&M expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting for certain O&M expenses, TEP overstated its annual transmission revenue requirement by approximately $58,800 and over collected revenues from FERC- jurisdictional transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 38, "text": "Revise policies and procedures to properly account for O&M expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 39, "text": "Provide training to its staff on the revised procedures for properly accounting for O&M expenses in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 40, "text": "Perform an analysis of costs reported in Transmission O&M accounts during the audit period to determine whether such costs were charged to the correct account(s) and that the appropriate allocators were used to charge costs to transmission, distribution, and A&G expense accounts when applicable. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 41, "text": "Submit a refund analysis, within 60 days of the date of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from improper accounting for power generation and distribution-related expenses, plus interest; (2) determinative components of the refund; (3) refund method; (4) transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 42, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 43, "text": "Refund the amounts disclosed in the refund report to transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 8, "title": "Use of Unapproved Depreciation Rates", "summary": "TEP did not use Commission-approved depreciation rates to calculate depreciation expense for plant balances in Account 397, Communication Equipment. The use of depreciation rates not approved by the Commission resulted in TEP understating Account 403, Depreciation Expense, and Account 108, Accumulated Provision for Depreciation of Electric Utility Plant (Major Only). In addition, by understating the accumulated depreciation, TEP overstated the net balance of Account 397.", "is_other_matter": false, "recommendations": [ { "number": 44, "text": "Revise policies and procedures to ensure that Commission-approved depreciation rates are used to determine depreciation expense for all classes of property.", "source_page": null }, { "number": 45, "text": "Provide training to its staff on the revised procedures for properly accounting for depreciation expense in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 46, "text": "Use Commission-approved depreciation rates to calculate inputs to its formula rate, or timely file a request under FPA section 205 for a change in rates.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 9, "title": "Asset Retirement Obligations", "summary": "TEP improperly accounted for and reported the accretion and depreciation expense associated with its Asset Retirement Obligations (AROs) in Account 108, Accumulated Provision for Depreciation of Electric Utility Plant (Major Only), instead of correctly recording such expenses in Account 182.3, Other Regulatory Assets.", "is_other_matter": false, "recommendations": [ { "number": 47, "text": "Revise and implement policies, procedures, and controls to ensure TEP properly accounts for ARO-related costs consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 48, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 49, "text": "Within 60 days of issuance of this audit report, submit proposed accounting entries and supporting documentation to DAA that reflect the transfer of ARO-related costs improperly recorded in Account 108 to Account 182.3.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 10, "title": "Accounting for Vendor Discounts", "summary": "TEP improperly accounted for and reported approximately $1.8 million of vendor discounts for early payment of various invoices in Account 921, Office Supplies and Expenses. As a result of this improper accounting for vendor discounts, TEP understated balances in various A&G expense accounts and overstated balances in various O&M, as well as electric plant in service, accounts.", "is_other_matter": false, "recommendations": [ { "number": 50, "text": "Revise policies and procedures to properly account for vendor discounts consistent with Commission accounting requirements.", "source_page": null }, { "number": 51, "text": "Provide training to its staff on the revised procedures for properly accounting for vendor discounts in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 11, "title": "FERC Form No. 1 Reporting Schedules", "summary": "TEP did not report complete and accurate information as required in certain supporting schedules of its 2018, 2019, 2020, and 2021 FERC Form No. 1 reports. This reduced the overall accuracy and usefulness of the information reported in the FERC Form No. 1. D. List of", "is_other_matter": false, "recommendations": [ { "number": 52, "text": "Strengthen policies, procedures, and controls to ensure that all FERC Form No. 1 schedules are completed in accordance with Commission instructions.", "source_page": null }, { "number": 53, "text": "Strengthen procedures for completing review of the FERC Form No. 1 instructions, prior to submission, to eliminate errors.", "source_page": null }, { "number": 54, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-09-28_northern-border-pipeline-company_fa21-1", "company": "Northern Border Pipeline Company", "company_raw": "Northern Border Pipeline Company (FA21-1)", "docket": "FA21-1", "docket_full": "FA21-1-000", "issued_date": "2022-09-28", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220928-3032&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220928-3032", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 58, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 to December 31, 2020", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2", "501-G" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Company Use Gas Percentage Filings", "summary": "Northern Border did not make required filings to show the inputs and calculations that support the adjustments it made to its Company Use Gas Percentages. Absent making these annual filings there was a lack of transparency and opportunity for interested parties to opine on the changes to the Company Use Gas Percentages in prior years and review the inputs and calculations supporting these percentages.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies and procedures to ensure that annual filings are made with the Commission to include a detailed explanation of the methodology used to develop its monthly Company Use Gas Percentages.", "source_page": null }, { "number": 2, "text": "Inform Northern Border’s staff regarding these revised policies and procedures, and provide periodic training as needed.", "source_page": null }, { "number": 3, "text": "Post on its informational website a notice that it will be making Company Use Gas Percentage filings with the Commission annually.", "source_page": null }, { "number": 4, "text": "File with the Commission an annual report showing the inputs and calculations for deriving its monthly Company Use Gas Percentages for 2022 and file a similar report in all future years in which this fuel mechanism remains in effect.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Shared Services and Nonoperating Expenses", "summary": "Northern Border recorded all shared services costs in Account 923, Outside Services, rather than recording these costs to the appropriate operations and maintenance (O&M) and administrative and general (A&G) accounts based on the nature of each cost. Northern Border also improperly recorded nonoperating expenses allocated to it in Accounts 853, Compressor Station Labor and Expenses; 923, Outside Services; and 930.2, Miscellaneous General Expenses instead of the appropriate accounts. Absent proper procedural safeguards, these misclassifications could affect Northern Border’s cost-of-service rate development and result in improper functionalization of costs and rate recovery of nonoperating expenses. Furthermore, reporting all costs in the appropriate accounts, based on the nature of the activity associated with the costs, will ensure that Northern Border is submitting FERC Form No. 2 reports that are comparable with those of other natural gas pipelines that follow the USofA.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Revise policies and procedures used to track, review, and account for all directly assigned and allocated costs, to ensure that O&M and A&G expenses are recorded in the appropriate account based on the nature of the cost consistent with GI No. 14 and that nonoperating expenses are properly recorded in the 426 series of accounts. These policies and procedures should have no dollar threshold (i.e., $100,000) for classifying O&M, A&G, and nonoperating expenses based on the nature of the costs.", "source_page": null }, { "number": 6, "text": "Inform relevant staff of the need for these revised policies and procedures and provide staff periodic training, as needed. Additionally, communicate the need for these revised policies and procedures to all corporate accounting personnel to ensure they understand potential accounting impacts and effects on the development of cost-of-service rates. Provide support that this communication was provided within 30 days of this report.", "source_page": null }, { "number": 7, "text": "Provide recent journal entries and supporting documentation that demonstrate that the accounting misclassifications identified in this finding have been corrected and the related expenses are now recorded in accordance with the Commission’s accounting requirements.", "source_page": null }, { "number": 8, "text": "Restate and footnote the comparative year balances reported in the next FERC Form No. 2 filed, including all schedules affected, to reflect and disclose these revisions. Allowance for Funds Used During Construction", "source_page": null }, { "number": 9, "text": "Revise policies and procedures for calculating AFUDC consistent with the requirements of GPI No. 3. Revisions should prevent the improper inclusion of unpaid contract retention in the AFUDC accrual calculations, and ensure that capital projects stop accruing AFUDC when construction delays occur and when completed projects are placed in service.", "source_page": null }, { "number": 10, "text": "Inform relevant staff of these revised policies and procedures and provide staff periodic training, as needed.", "source_page": null }, { "number": 11, "text": "Recalculate AFUDC accrued in accordance with GPI No. 3 for projects on which AFUDC was over-accrued. Also provide proposed accounting entries and documentation that reflect these corrections to remove over-accrued AFUDC balances from plant and associated accounts, such as accumulated depreciation, deferred taxes, and depreciation expense within 30 days of the issuance of this report.", "source_page": null }, { "number": 12, "text": "Restate and footnote the comparative year balances reported in the next FERC Form No. 2 filed, including all schedules affected, to reflect and disclose these revisions.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 3, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "Northern Border inappropriately included unpaid contract retentions in its AFUDC accrual calculation and improperly accrued AFUDC on delayed and completed construction projects. These errors resulted in the over accrual of AFUDC and consequently overstated plant in service by approximately $369,000 during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 4, "title": "FERC Form No. 2 Reporting", "summary": "Northern Border did not report complete and accurate information in certain supporting schedules of its FERC Form No. 2 reports. This reduced the overall accuracy and usefulness of the information in the FERC Form No. 2. D. Other Matter Audit staff identified one other matter, which is summarized below. Section V of this report contains a detailed discussion of this other matter.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Revise policies and procedures to ensure complete and accurate information is reported in the FERC Form No. 2 in accordance with the instructions of the report. This includes addressing all reporting deficiencies in this finding and, in particular, ensuring that all costs associated with its incremental rate projects are reported in columns (g) and (h) of pages 217 and 217a, Non- Traditional Rate Treatment Afforded New Projects.", "source_page": null }, { "number": 14, "text": "Inform relevant staff regarding these revised policies and procedures and provide staff periodic training, as needed.", "source_page": null }, { "number": 15, "text": "Review the reporting deficiencies with relevant staff to ensure they include, on a prospective basis, all required information in the FERC Form No. 2. F.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 5, "title": "Company Use Gas Percentage Methodology", "summary": "Northern Border’s Tariff did not include a detailed explanation of the methodology used to adjust its monthly Company Use Gas Percentage as directed by the Commission in Order No. 582. Absent this detailed explanation there was a lack of transparency regarding Northern Border’s Company Use Gas Percentage in Part 6 of the general terms and conditions of its FERC NGA Tariff. E.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-09-15_dayton-power-and-light-company_fa21-4", "company": "Dayton Power and Light Company", "company_raw": "Dayton Power and Light Company (FA21-4)", "docket": "FA21-4", "docket_full": null, "issued_date": "2022-09-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220915-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220915-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 64, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 8, "findings": [ { "index": 1, "title": "AFUDC Rate Inputs", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 2, "title": "AFUDC Computations", "summary": "DP&L’s methodology for computing AFUDC was deficient in multiple areas. Audit staff found that DP&L did the following: • Incorrectly compounded AFUDC during the audit period; • Did not suspend AFUDC when projects had been delayed or suspended; and • Improperly included RWIP balances in the CWIP base when computing AFUDC. As a result, DP&L over accrued AFUDC included in CWIP and utility plant accounts, and overbilled FERC-jurisdictional transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Income Tax Receivables", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Distribution-Related Expenses", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Customer-Related Expenses", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Service Company Costs", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Accounting for RECs", "summary": "DP&L improperly accounted for the purchase of RECs in Account 154, Materials and Supplies. DP&L also improperly amortized the Alternative Energy Rider regulatory asset in Account 930.2, Miscellaneous General Expenses. As a result of the improper accounting, DP&L overstated Account 154 and Account 930.2 account balances reported in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 8, "title": "Accounting Misclassification", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-09-01_pjm-interconnection-l-l-c_pa19-2", "company": "PJM Interconnection, L.L.C.", "company_raw": "PJM Interconnection, L.L.C. (PA19-2)", "docket": "PA19-2", "docket_full": "PA19-2-000", "issued_date": "2022-09-01", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220901-3021&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220901-3021", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 62, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2016 through May 31, 2021", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Offer Capping of Generation Resources", "summary": "PJM did not offer cap a self- scheduled generation resource in the Day-ahead energy market for 18 hours on January 21, 2019 despite the fact that its owner had failed the Three Pivotal Supplier (TPS) test. The error was caused by operators applying outdated provisions of PJM’s OATT and not applying the updated offer capping provisions in effect since November 1, 2017, along with a lack of written procedures and operator instructions. PJM’s application of the outdated provisions may have resulted in additional self-scheduled resources not being appropriately offer capped since November 1, 2017 when the new OATT provisions went into effect. D.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Order No. 760 Reporting", "summary": "PJM should consider improving its data reporting under Order No. 760 by strengthening policies and procedures, devoting additional resources, and enhancing its internal data gathering and reporting processes.", "is_other_matter": true, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Day-ahead Resource Commitment", "summary": "PJM should consider increasing transparency, regarding whether Day-ahead resource commitments minimize overall system production costs as required by OATT Attachment K-Appendix, Section 6.4.", "is_other_matter": true, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Incentives to Follow Dispatch", "summary": "PJM should consider strengthening internal procedures to encourage generation resources to follow dispatch instructions.", "is_other_matter": true, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Software Issues", "summary": "PJM should consider improving limitations in certain software applications to ensure accuracy of results.", "is_other_matter": true, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2022-08-25_peco-energy_pa-mo-audit", "company": "PECO Energy Company", "company_raw": "PECO Energy Company", "docket": "D-2021-3023906", "docket_full": null, "issued_date": "2022-08-25", "source_page_url": "https://www.puc.pa.gov/press-release/2022/puc-issues-management-and-operations-audit-and-implementation-plan-for-peco-energy-company", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1756720.pdf", "captured_at": "2026-06-08", "source_note": "Management & Operations Audit issued by the PA PUC Bureau of Audits (cover: 'Issued July 2022'); PUC publication 2022-08-25; 22 recommendations. PDF: puc.pa.gov/pcdocs/1756720.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 126, "scanned_pages": [ 126 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 7, "findings": [ { "index": 1, "title": "Affiliated Interests and Cost Allocations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Submit a detailed proposal to the Commission for the appropriate crediting of ratepayers due to PECO’s corrected billings for the use of PECO’s fiber network.", "source_page": 30 }, { "number": 2, "text": "Document PECO’s annual process and continue to perform detailed reviews of all allocation factors, including utility-owned project allocation rates, to ensure costs are distributed in accordance with approved agreements.", "source_page": 30 }, { "number": 3, "text": "File PECO’s money pool agreement for approval with the PUC.", "source_page": 30 } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 2, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Reduce Electric Operations staff overtime to 15% overtime hours per normal hours worked or less.", "source_page": 55 }, { "number": 5, "text": "Improve SAIDI and CAIDI to at or below the PUC Benchmarks.", "source_page": 55 }, { "number": 6, "text": "Reduce the number of customers experiencing multiple interruptions and strive to have zero CEMI 10+.", "source_page": 55 }, { "number": 7, "text": "Reduce outages caused by broken/uprooted vegetation to the 2015-2018 average levels", "source_page": 55 }, { "number": 8, "text": "Reduce interruptions caused by equipment failures.", "source_page": 55 } ], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 3, "title": "Gas Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Reduce company-at-fault hits on gas infrastructure.", "source_page": 73 }, { "number": 10, "text": "Study and then identify ways to reduce plastic pipe main and service damages with a focus on line hits.", "source_page": 73 } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Gas Operations (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Reduce Gas Operations staff overtime to 15% overtime hours per normal hours worked or less.", "source_page": 73 }, { "number": 12, "text": "Accelerate the rate of GPS location for key gas infrastructure.", "source_page": 73 } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Correct minor deficiencies in physical security.", "source_page": 78 }, { "number": 14, "text": "Ensure that all fire extinguishers and first aid kits are being inspected and tagged monthly.", "source_page": 78 }, { "number": 15, "text": "Add an update and accountability section to the Safety Rulebook, move the table of contents closer to the beginning, and add chapter tabs or margin labels to encourage ease of navigation.", "source_page": 78 }, { "number": 16, "text": "Develop a lifecycle tracking and replacement program for security equipment.", "source_page": 78 } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "index": 6, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Continue outreach efforts to engage payment troubled customers, leverage pandemic and low- income resources to help reduce the overall level of outstanding customer balances.", "source_page": 93 }, { "number": 18, "text": "Refocus efforts on customer experiences to drive customer service satisfaction through active listening and first call resolution.", "source_page": 93 }, { "number": 19, "text": "Complete implementation of the replacement CIS.", "source_page": 93 }, { "number": 20, "text": "Identify and address the root cause of CSR separations.", "source_page": 93 } ], "themes": [ "Customer service & billing" ], "cost_to_customers": false }, { "index": 7, "title": "Human Resources and Diversity", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Improve Safety Performance.", "source_page": 108 }, { "number": 22, "text": "Reduce the rate of all motor vehicle accidents.", "source_page": 108 } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Customer service & billing", "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Service reliability & vegetation management" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2022-06-16_firstenergy-pennsylvania-companies_pa-mo-audit", "company": "FirstEnergy Pennsylvania Companies (Met-Ed, Penelec, Penn Power, West Penn Power)", "company_raw": "FirstEnergy Pennsylvania Companies (Met-Ed, Penelec, Penn Power, West Penn Power)", "docket": null, "docket_full": null, "issued_date": "2022-06-16", "source_page_url": "https://www.puc.pa.gov/press-release/2022/puc-issues-management-audit-and-implementation-plan-for-firstenergy-pennsylvania-companies", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1748700.pdf", "captured_at": "2026-06-01", "source_note": "Management & Operations Audit of FirstEnergy's four PA electric distribution companies, issued by the PA PUC Bureau of Audits, published 2022-06-16. PDF: puc.pa.gov/pcdocs/1748700.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations (26 recommendations).", "archived_via": null, "page_count": 190, "scanned_pages": [ 1, 190 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 11, "findings": [ { "index": 1, "title": "Executive Management and Organizational Structure", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Complete and retain documentation of a span of control analysis upon projected completion of reorganization in December 2023.", "source_page": 30 }, { "number": 2, "text": "Continue and complete the FE Forward Initiative with the integration of the Audit Bureau’s recommendations for various functional areas in the 2021 Management Audit report.", "source_page": 30 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 2, "title": "Key Audit Matter", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Cooperate fully with all ongoing investigations and implement all approved recommendations for remediation determined by the completed internal and governmental investigations and any settlement terms arising therefrom.", "source_page": 39 }, { "number": 4, "text": "Carefully track and document ongoing activities related to the investigations and litigation, so the costs associated with dealing with the matter are appropriately segregated and to minimize negative impacts to ratepayers.", "source_page": 39 } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Develop and implement approved enhancements to the Compliance Program. Implement appropriate testing criterion for testing the key controls to strengthen FirstEnergy’s internal control environment and ultimately resolve the noted material weakness in internal control over financial reporting", "source_page": 47 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 4, "title": "Affiliated Interests and Cost Allocations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Conduct periodic market studies to confirm FirstEnergy Service Company’s cost of services are at or lower than market, and the FE PA Companies are charging the higher of cost or market for goods/services to affiliates.", "source_page": 64 }, { "number": 7, "text": "Correct administrative oversight controls to ensure every notice and summary information of future debt securities issuances by FE PA Companies are filed with the PUC within 60 days.", "source_page": 64 } ], "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 5, "title": "Affiliated Interests and Cost Allocations (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Begin tracking pole attachment invoice receivables that are 60, 90, 120 and 180 days outstanding while charging late fees at each overdue interval to discourage late payments and improve collection performance for current arrearages at the FE-PA Companies.", "source_page": 64 }, { "number": 9, "text": "Perform comprehensive, periodic updates to FirstEnergy’s CAM to ensure accurate and relevant information and follow it in practice.", "source_page": 64 }, { "number": 10, "text": "Evaluate the current cost allocation factors to assess how accurately they represent the most relevant cost drivers, update the SA after the current reorganization is complete to include robust descriptions of all goods/services provided to the FE-PA Companies, and file the SA with the PUC for approval.", "source_page": 65 }, { "number": 11, "text": "Maintain transparent records of the additional costs incurred as a result of the investigations and fallout related to bribery charges in Ohio to demonstrate prudent and reasonable operating costs in any future rate case proceeding.", "source_page": 65 } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 6, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Perform a comprehensive update to ensure all key elements are included in all policies/procedures/processes within the Finance and Accounting departments.", "source_page": 75 }, { "number": 13, "text": "Comply with the requirements set forth in the various ongoing investigations to regain the confidence of the credit community.", "source_page": 75 }, { "number": 14, "text": "Test the new internal controls over financial reporting and obtain an opinion from the external auditor without a material weakness.", "source_page": 75 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 7, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Improve electric reliability performance by implementing remedial programs that will effectively address the top outage causes within the FE PA Companies control (e.g., Equipment Failure, Line Failure, Animals) as well as actively identify priority off-ROW trees for removal where possible.", "source_page": 103 } ], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 8, "title": "Electric Operations (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Establish an overtime target based upon a percentage of straight time hours as opposed to dollars and determine the necessary staffing level for field operations personnel to achieve a goal of 15% overtime for the field operations employees.", "source_page": 103 }, { "number": 17, "text": "Review and identify why field operations employees are incurring excessive amounts of overtime and promote and/or exercise the companies’ right to equally distribute emergency callouts.", "source_page": 103 }, { "number": 18, "text": "Review and redesign the training and learning management system(s) to create a centralized system to properly manage and report on employee training requirements and certification status.", "source_page": 103 }, { "number": 19, "text": "Review the Met-Ed remediation measures for Penelec, Penn Power, and West Penn Power and implement as needed to standardize procedures to reduce the likeliness of a similar incident occurring at all FE-PA Companies.", "source_page": 103 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 9, "title": "Materials Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 20, "text": "Determine the cause for the significant increases in average inventory balances; and create an action plan to decrease balances and improve inventory turnover performance to match internal goals.", "source_page": 114 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 10, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Survey customers on their satisfaction with the IVR technology, and implement remedial actions based on the survey results.", "source_page": 131 }, { "number": 22, "text": "Establish collection agency goals based upon net collection performance, track collection agency performance based upon actual dollars placed with each agency and hold the agencies accountable for their performance by eliminating agencies that can't achieve the established goals.", "source_page": 131 }, { "number": 23, "text": "Study potential solutions to reduce arrearages including an analysis of customer segmentation as part of the FE Forward initiative.", "source_page": 131 } ], "themes": [ "Customer service & billing" ], "cost_to_customers": false }, { "index": 11, "title": "Human Resources and Diversity", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Evaluate the safety performance goal setting strategies for effectiveness and efficiency. The companies should set challenging yet attainable goals, individualized for each operating company, to encourage reasonable improvement while continuing to nurture the underlying safety culture.", "source_page": 162 }, { "number": 25, "text": "Enter into an agreement with the EEI to allow generalized composite benchmark data to be provided for regulatory review during future audits or participate in other safety benchmarking activities which allow for adequate review and verification.", "source_page": 162 }, { "number": 26, "text": "Continue to identify exposures and to develop and implement adequate training on the appropriate procedures to proactively mitigate the risks associated with the identified exposures to ultimately improve safety performance.", "source_page": 162 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates", "Customer service & billing", "Internal audit & internal controls", "Inventory, materials & fleet", "Service reliability & vegetation management", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-06-01_enterprise-crude-pipeline-llc_fa20-5", "company": "Enterprise Crude Pipeline LLC", "company_raw": "Enterprise Crude Pipeline LLC (FA20-5)", "docket": "FA20-5", "docket_full": "FA20-5-000", "issued_date": "2022-06-01", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220601-3039&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220601-3039", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 79, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2014 to December 31, 2018", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Interstate Allocation Percentage", "summary": "ECPL incorrectly included barrel-miles for intrastate transportation movements, pump-over services, and a pipeline segment it did not own in its interstate allocation percentage. These errors caused ECPL to overstate its total cost of service, barrels, and barrel-miles, reported on Page 700 of its FERC Form No. 6. The impact on the annual total cost of service ranged from $11.9 million to $78.1 million during the audit period. Besides these errors, ECPL should have excluded, to the extent practicable, costs associated with its terminal and pipeline system facilities that were used solely to support intrastate transportation service and other FERC non-jurisdictional services, before applying the interstate allocation percentage.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise and strengthen policies and procedures to ensure that Page 700 is prepared and reported in a manner consistent with Order Nos. 620 and 620-A and the FERC Form No. 6 instructions. Specifically, ECPL should only include interstate barrel-miles in the numerator and total system barrel-miles in the denominator. ECPL’s procedures should also where practicable exclude barrel-miles, cost of assets, and expenses associated with its terminal and storage facilities and 100 percent intrastate transportation pipeline systems in the development and application of the interstate allocation percentage.", "source_page": null }, { "number": 2, "text": "Train staff on the revised computation, policies, and procedures for calculating ECPL’s interstate allocation percentage, which is used to derive input balances reported on Page 700, Lines 1-5. The training should also include discussion of the findings of this audit report. Provide the training periodically as needed.", "source_page": null }, { "number": 3, "text": "Provide an analysis that shows the resulting changes to Page 700 from making the corrections described in this finding, including workpapers reflecting the underlying calculations made. Submit this analysis to DAA within 90 days of the issuance of this audit report. 2 On July 1, 2019, ECPL transferred its interstate assets to EIC; therefore, all of the recommendations contained in this report apply to EIC. At that time, ECPL was no longer a FERC jurisdictional entity as its business involved only intrastate transportation and FERC non-jurisdictional terminal and storage activities subsequent to the transfer.", "source_page": null }, { "number": 4, "text": "Restate and footnote Page 700 of ECPL’s FERC Form No. 6 for the year(s) affecting the Commission’s next five-year index review. For those year(s), refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page", "source_page": null }, { "number": 700, "text": "Further, ensure future FERC Form No. 6 submissions reflect all corrective actions resulting from ECPL’s analysis and revised procedures.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Pipeline Loss Allowance and Gravity Shrinkage Revenues", "summary": "ECPL incorrectly omitted pipeline loss allowance (PLA) and gravity shrinkage deduction (GSD) revenues recorded in Account 230, Allowance Oil Revenues, from Page 700, Line 10, Interstate Operating Revenues. This resulted in ECPL understating its annual interstate operating revenues on Page 700. The understatements ranged from $19,726,306 to $46,812,994 during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Revise and strengthen financial reporting policies and procedures to ensure that PLA and GSD revenues are appropriately reported as interstate operating revenues on Page 700, Line 10.", "source_page": null }, { "number": 6, "text": "Train staff on revised policies and procedure for reporting interstate operating revenues on Page 700, Line 10, and provide periodic training, as needed.", "source_page": null }, { "number": 7, "text": "Ensure all future FERC Form No. 6 submissions reflect ECPL’s revised PLA and GSD procedures.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Idled Pipeline Segments", "summary": "ECPL incorrectly accounted for and reported idled property as carrier, which affected the accuracy of the balances reported in ECPL’s FERC Form No. 6 reports, including the balances on Page 700. This resulted in ECPL overstating it cost of service on Page 700 by $57,242 to $2,706,526 during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise accounting policies and procedures to ensure that all components of ECPL’s property, including idled pipeline segments, are properly accounted for and reported in accordance with Commission requirements. The procedures should include established communication protocols and implementation of a review process to ensure proper account classification of idled pipeline segments, including proper accounting for asset impairments at the time that the impairment determination is made.", "source_page": null }, { "number": 9, "text": "Reclassify all idled pipeline segments recorded in Account 30 that are not held for future carrier service within a reasonable time under a definite plan for pipeline operations to Account 34, and accrued depreciation from Account 31 to Account 35. Submit proposed accounting entries supporting adjustments within the carrier and noncarrier property accounts to DAA for review within 30 days of issuance of this final audit report. Upon receiving approval from DAA, make the approved accounting entries supporting this adjustment within 30 days.", "source_page": null }, { "number": 10, "text": "Perform an analysis to determine the full scale of Page 700 impacts, including Line 1, Operating and Maintenance Expense; Line 2, Depreciation Expense; Lines 5a-5d, Rate Base; and other lines on Page 700, and provide this analysis to DAA audit staff for further review.", "source_page": null }, { "number": 11, "text": "Restate and footnote Page 700 of ECPL’s FERC Form No. 6 for the year(s) affecting the Commission’s next five-year index review. For those year(s), refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page", "source_page": null }, { "number": 700, "text": "Further, ensure future FERC Form No. 6 submissions reflect all corrective actions resulting from ECPL’s analysis and revised procedures.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting and Reporting of Depreciation", "summary": "ECPL did not use Commission approved depreciation rates, incorrectly applied the composite method to calculate depreciation expense, over accrued depreciation reserve balances for some accounts, and incorrectly derived depreciation expense. These errors caused ECPL to improperly calculate depreciation expense and accumulated depreciation reserve balances for carrier property assets and resulted in ECPL including incorrect amounts in its cost of service reported on Page 700 since 2010.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Strengthen procedures and controls to ensure that it uses Commission- approved depreciation rates and the composite method to derive depreciation expense for all carrier property asset accounts and ceases accruing depreciation when asset accounts become fully accrued.", "source_page": null }, { "number": 13, "text": "Conduct a depreciation study that reflects current economic conditions and other factors, including net salvage and interim retirements. Based on this study, determine whether to continue using ECPL’s current depreciation rates to calculate the depreciation expense pursuant to Part 347, or make a filing to request a change in depreciation rates pursuant to GI 1-8.", "source_page": null }, { "number": 14, "text": "Submit a copy of this depreciation study to the Commission within 30 days of completion. ECPL should use the composite method of depreciation as required by GI 1-8, unless it receives Commission approval to use another method of depreciation. ECPL should also make appropriate changes to its existing depreciation rates only when proposed rates are approved or modified by the Commission.", "source_page": null }, { "number": 15, "text": "Perform an analysis of Account 31, Accumulated Depreciation – Carrier Property, to determine the impacts these errors had on the balance in this account. This analysis should include any adjustments made to correct this account balance for ECPL’s use of unapproved depreciation rates, component method of depreciation, over accrual of asset accounts, and improper calculation of depreciation expense. Submit this evaluation and any proposed adjusting entries to DAA within 90 days of the issuance of this audit report.", "source_page": null }, { "number": 16, "text": "File for approval of accounting entries for a prior period adjustment if deemed material in accordance with 18 C.F.R. Part 352, GI 1-6. Upon approval from the Commission, make accounting entries supporting this adjustment within 30 days.", "source_page": null }, { "number": 17, "text": "Provide worksheet(s) showing the effect and adjustment made to each component on Page 700 of the FERC Form No. 6 as a result of the analysis performed in Recommendation No. 15.", "source_page": null }, { "number": 18, "text": "Restate and footnote Page 700 of ECPL’s FERC Form No. 6 for the year(s) affecting the Commission’s next five-year index review. For those year(s), refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page", "source_page": null }, { "number": 700, "text": "Further, ensure future FERC Form No. 6 submissions reflect all corrective actions resulting from ECPL’s analysis and revised procedures.", "source_page": null } ], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting for Non-Operating Expenses", "summary": "ECPL incorrectly classified (1) administrative and general expenses, (2) a civil penalty, and (3) lobbying expenses as operating expenses rather than as non-operating expenses. While these errors did not affect net income, they resulted in ECPL overstating Page 700, Line 1, Operating and Maintenance Expenses, during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Update policies and procedures to ensure that administrative and general expenses of affiliated pipelines recorded on ECPL’s books, civil penalties, and lobbying expenses are accounted for as non-operating expenses consistent with Commission accounting requirements. These procedures should also cover other non-operating expenditures besides those identified.", "source_page": null }, { "number": 20, "text": "Train staff on the revised accounting for non-operating expenses and updated policies and procedures, and provide periodic training as needed.", "source_page": null }, { "number": 21, "text": "Submit a copy of a recent journal entry supporting the reclassification of administrative and general expenses, civil penalties, and lobbying expenses from operating to non-operating expense accounts to DAA within 30 days of issuance of this audit report.", "source_page": null }, { "number": 22, "text": "Restate and footnote Page 700 of ECPL’s FERC Form No. 6 for the year(s) affecting the Commission’s next five-year index review. For those year(s), refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page", "source_page": null }, { "number": 700, "text": "Further, ensure future FERC Form No. 6 submissions reflect all corrective actions resulting from ECPL’s analysis and revised procedures.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 6, "title": "FERC Form No. 6 Reporting", "summary": "ECPL incorrectly reported and calculated the Allowance for Funds Used During Construction (AFUDC) input on Page 700 and misreported barrels and barrel-miles for one pipeline segment on Pages 600-603. These errors reduced the accuracy, transparency, and usefulness of ECPL’s FERC Form No. 6 submissions. D. List of", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Revise and strengthen policies and procedures to ensure that Page 700 is prepared and reported in a manner consistent with Opinion No. 154-B and the instructions of the FERC Form No. 6. These instructions include developing procedures to calculate AFUDC on monthly expenditures and for the actual length of construction periods; maintaining records of the monthly construction expenditures; and excluding ineligible costs. These policies and procedures should also revise and strengthen the reporting of barrels and barrel-miles on Page 600-603 to ensure accurate reporting.", "source_page": null }, { "number": 24, "text": "Provide to audit staff the revised FERC Form No. 6 Pages 600-603 and Page 700 policies and procedures and provide periodic training, as needed.", "source_page": null }, { "number": 25, "text": "Restate and footnote Page 700 of ECPL’s FERC Form No. 6 for the year(s) affecting the Commission’s next five-year index review. For those year(s), refile the FERC Form No. 6 (only restating Page 700) after audit staff reviews and approves all analyses and revised procedures affecting Page", "source_page": null }, { "number": 700, "text": "Further, ensure future FERC Form No. 6 submissions reflect all corrective actions resulting from ECPL’s analysis and revised procedures. E.", "source_page": null } ], "themes": [ "AFUDC / cost of capital", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "OR", "source": "Public Utility Commission of Oregon", "doc_type": "power cost update order", "id": "2022-05-31_idaho-power_or-ue-398-order-22-191-apcu", "company": "Idaho Power Company", "company_raw": "Idaho Power Company", "docket": "UE-398", "docket_full": null, "issued_date": "2022-05-31", "source_page_url": "https://apps.puc.state.or.us/edockets/orders.asp?OrderNumber=22-191", "pdf_download_url": "https://apps.puc.state.or.us/orders/2022ords/22-191.pdf", "captured_at": "2026-06-07", "source_note": "Oregon PUC Order No. 22-191 (entered May 31, 2022), Docket UE 398, in the matter of Idaho Power Company's 2022 Annual Power Cost Update (APCU) (15 pp) — the Commission's annual update of Idaho Power's Oregon net power supply expense in rates. Listed for reference (metadata-only). Source: Oregon PUC orders archive (apps.puc.state.or.us/orders/2022ords/22-191.pdf).", "archived_via": null, "page_count": 15, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "Settlement: terms", "summary": "inistrative and General (\"OHAG\") expenses in accordance with the terms 20 of the 2016 and 2017 APCU settlement stipulations. 7 Per the terms of the 2016 APCU 2 See Idaho Power/100-110. 3 Idaho Power/100, Brady/5. 4 See Idaho Power/100, Brady/15. 5 Idaho Power/100, Brady/5. 6 Idaho Power/10", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Settlement: Agreement", "summary": "pulating Parties resolved all the issues in this case through these 8 conferences, resulting in the settlement stipulation as described in this Agreement. 9 AGREEMENT 10 23. The Stipulating Parties agree to a revenue requirement increase of $3.98 million 11 or 6.97 percent overall. The Stipulating P", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "ID", "source": "Idaho Public Utilities Commission", "doc_type": "power cost adjustment order", "id": "2022-05-31_idaho-power_id-ipc-e-22-11-order-35421-pca", "company": "Idaho Power Company", "company_raw": "Idaho Power Company", "docket": "IPC-E-22-11", "docket_full": null, "issued_date": "2022-05-31", "source_page_url": "https://puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2211", "pdf_download_url": "https://puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2211/OrdNotc/20220531Final_Order_No_35421.pdf", "captured_at": "2026-06-07", "source_note": "Idaho PUC Order No. 35421 (Final Order, service date May 31, 2022), Case No. IPC-E-22-11, on Idaho Power Company's annual Power Cost Adjustment (PCA) effective June 1, 2022 through May 31, 2023 — an overall revenue increase of ~$103.4 million (8.27%) (10 pp). Listed for reference (metadata-only). Source: Idaho PUC fileroom (puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2211/OrdNotc/20220531Final_Order_No_35421.pdf).", "archived_via": null, "page_count": 10, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-05-20_northwestern-corporation_fa20-7", "company": "NorthWestern Corporation", "company_raw": "NorthWestern Corporation (FA20-7)", "docket": "FA20-7", "docket_full": "FA20-7-000", "issued_date": "2022-05-20", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220520-3001&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220520-3001", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 45, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 to October 31, 2021", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Allowance for Funds Used During Construction", "summary": "NorthWestern’s method for calculating its AFUDC rate was inconsistent with the Commission’s accounting regulations. Specifically, NorthWestern inappropriately used prior month balances instead of prior year balances in the long-term debt and equity components for the purpose of computing its AFUDC rate and inappropriately included undistributed subsidiary earnings as a part of the equity component for the purpose of computing its AFUDC rate. Additionally, when applying AFUDC, NorthWestern improperly compounded its AFUDC on a monthly basis rather than compounding on a semi-annual basis and inap", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise its policies and procedures to ensure that its AFUDC base and rate calculation is consistent with Electric Plant Instruction (EPI) No. 3(A)(17) and other applicable Commission requirements. Revisions should include procedures to: use prior year ending balances as reported in NorthWestern’s FERC Form No. 1 filings for the long-term debt and equity components; prevent balances in Account 216.1 from being included in the equity component; ensure AFUDC is compounded, at most, semi-annually; and prevent inclusion of unpaid contract retention amounts in the CWIP base in AFUDC calculations.", "source_page": null }, { "number": 2, "text": "Provide training to staff on the revised policies and procedures described in the previous recommendation. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Recalculate AFUDC for the period 2018 through 2021 in accordance with the requirements of EPI No. 3(A)(17) and the other pertinent guidance discussed in this finding. Based on the calculations, for periods in which AFUDC was over- accrued, submit a yearly estimate of over accruals to DAA within 60 days of receiving this audit report, with proposed corrected accounting entries and supporting documentation that reflects corrections to remove over-accrued AFUDC balances from plant and associated accounts, such as depreciation, income tax expense, accumulated provision for depreciation, and accumulated deferred income taxes (ADIT).", "source_page": null }, { "number": 4, "text": "Revise electric plant, accumulated provision for depreciation, ADIT, and other account balances impacted by over-accrual of AFUDC after receiving DAA’s approval of the proposed accounting entries, and restate and footnote the balances reported in the FERC Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions.", "source_page": null }, { "number": 5, "text": "Submit a refund report, within 60 days of receiving DAA’s approval of the proposed accounting entries, to DAA for review that explains and details the following: (1) calculation of refunds that include the amounts of inappropriate recoveries that resulted from improper AFUDC computations during the audit period; (2) determinative components of the refund; (3) refund method; (4) the customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 6, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 7, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19(a) of Commission’s regulations.", "source_page": null } ], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Revolving Credit Facility Upfront and Commitment Fees", "summary": "NorthWestern inappropriately recorded in Account 181, Unamortized Debt Expense, upfront fees it paid when establishing its revolving line of credit, and inappropriately recorded in Account 921, Office Supplies and Expenses, commitment fees it paid for its revolving credit facility.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise existing accounting policies, procedures, and practices relating to accounting for credit agreement expenses used for general liquidity, such as upfront, commitment, revolving line of credit, and letter of credit fees, to be consistent with Commission accounting requirements.", "source_page": null }, { "number": 9, "text": "Train relevant staff on the revised accounting policies and provide periodic training, as needed.", "source_page": null }, { "number": 10, "text": "Submit proposed accounting entries and supporting documentation to DAA to reflect the transfer of credit agreement-related balances improperly recorded in Account 181 to Account 186, Miscellaneous Deferred Debits.", "source_page": null }, { "number": 11, "text": "Revise miscellaneous deferred debit balances to appropriately account for and report credit agreement-related balances after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the balances reported in the FERC Form No. 1 in the current and comparative years of the report, as necessary, to reflect and disclose the revisions.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Membership Dues", "summary": "NorthWestern misclassified $19,188, constituting part of the lobbying portion of membership dues it paid during the audit period and therefore associated with nonoperating activities, in Account 930.2, Miscellaneous General Expenses, and Account 921, Office Supplies and Expenses, instead of in Account 426.4, Expenditures for Certain Civic, Political and Related Activities. This led to a reporting error in its 2018 FERC Form No. 1.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Strengthen policies, procedures, and controls to account for the lobbying portion of membership dues consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 13, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 14, "text": "Perform an analysis to identify other membership dues that were improperly accounted for during the audit period. Provide the results of the analysis to audit staff within 60 days of receiving this report.", "source_page": null }, { "number": 15, "text": "Submit a refund report, within 60 days of receiving this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amounts of inappropriate recoveries that resulted from improper accounting of lobbying costs in transmission formula rates during the audit period; (2) determinative components of the refund; (3) refund method; (4) customers to receive the refunds, and (5) period(s) refunds will be made.", "source_page": null }, { "number": 16, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 17, "text": "Refund the amounts disclosed in the refund report to FERC-jurisdictional transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Lobbying Expenses", "summary": "NorthWestern misclassified $341,902 of lobbying expenses in various administrative and general expense accounts instead of Account 426.4, Expenditures for Certain Civic, Political and Related Activities. This resulted in NorthWestern inappropriately including these costs in transmission formula rate service cost determinations. As a result, FERC-jurisdictional transmission customers were overbilled $32,509 in Montana and $2,584 in South Dakota.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Develop and implement procedures and policies to track, report, review, and account for lobbying and other expenses of activities associated with influencing legislation and with other political activity consistent with Commission accounting requirements.", "source_page": null }, { "number": 19, "text": "Train relevant staff on the procedures and policies and provide periodic training in this area, as needed.", "source_page": null }, { "number": 20, "text": "Perform an analysis to identify other lobbying costs that were improperly accounted for during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 21, "text": "Submit a refund report, within 60 days of receiving this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amounts of inappropriate recoveries that resulted from improper accounting of lobbying costs in transmission formula rates during the audit period; (2) determinative components of the refund; (3) refund method; (4) customers to receive the refunds, and (5) period(s) refunds will be made.", "source_page": null }, { "number": 22, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 23, "text": "Refund the amounts disclosed in the refund report to FERC-jurisdictional transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 5, "title": "Miscellaneous Accounting Classification Errors", "summary": "NorthWestern misclassified various costs in its books and records. As a result, the amounts reported on FERC Form No. 1 for Administrative and General Expenses were incorrect, which impacted development of the annual transmission revenue requirements used for determining charges for NorthWestern’s FERC-jurisdictional transmission customers in Montana and South Dakota. Specifically, misclassification of certain general advertising expenses in Account 923, Outside Services Employed, resulted in overbillings to FERC-jurisdictional transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Strengthen policies, procedures, and controls to ensure that NorthWestern records the different administrative and general expenses in the proper accounts consistent with Commission accounting requirements.", "source_page": null }, { "number": 25, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 26, "text": "Perform an analysis to identify other administrative and general expenses that were improperly accounted for during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 27, "text": "If the net results of the analysis from Recommendation 26 and the errors identified in this finding impacted formula rate billings, submit a refund report, within 60 days of receiving this report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries that resulted from improper accounting of administrative and general expense impacting charges under transmission formula rates during the audit period; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 28, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 29, "text": "Refund the amounts disclosed in the refund report to FERC-jurisdictional transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations. E. Implementation of Recommendations Audit staff further recommends that NorthWestern submit the following for audit staff’s review:  A plan for implementing corrective actions that address each recommendation within 30 days after the issuance of this audit report;  Quarterly reports to DAA describing NorthWestern’s progress in completing each corrective action taken for each recommendation. NorthWestern should submit these nonpublic quarterly reports no later than 30 days after the end of each calendar quarter, beginning with the first quarter after the issuance of this audit report, and continuing each calendar quarter until NorthWestern completes all recommended corrective actions; and  Copies of any written policies and procedures developed or updated in response to the audit report’s recommendations; copies of journal entries made to correct accounting errors and deficiencies; and other information supporting the corrective actions made. NorthWestern should submit these documents for audit staff’s review in the first nonpublic quarterly report after it completes them.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "KS", "source": "Kansas Corporation Commission", "doc_type": "winter-storm cost investigation stipulation", "id": "2022-04-22_evergy-kansas_ks-21-ekme-329-gie-winter-storm-uri-stipulation", "company": "Evergy Kansas Metro, Inc. and Evergy Kansas Central, Inc.", "company_raw": "Evergy Kansas Metro, Inc. and Evergy Kansas Central, Inc.", "docket": "21-EKME-329-GIE", "docket_full": null, "issued_date": "2022-04-22", "source_page_url": "https://estar.kcc.ks.gov/", "pdf_download_url": "https://estar.kcc.ks.gov/estar/ViewFile.aspx/S202204221602125925.pdf?Id=54e98b5e-d9e2-4627-8355-b0c65b057bd9", "captured_at": "2026-06-07", "source_note": "Joint Motion to Approve Non-Unanimous Stipulation and Agreement (filed April 22, 2022) in the Kansas Corporation Commission's Investigation into Evergy Kansas Metro and Evergy Kansas Central regarding the February 2021 Winter Weather Events (Winter Storm Uri), Docket No. 21-EKME-329-GIE (contemplated by Docket 21-GIMX-303-MIS) — addressing the recovery and prudence of the extraordinary fuel and purchased-power costs Evergy incurred during the storm (21 pp). Listed for reference (metadata-only). Source: Kansas Corporation Commission eSTAR (estar.kcc.ks.gov/estar/ViewFile.aspx, document Id 54e98b5e-d9e2-4627-8355-b0c65b057bd9).", "archived_via": null, "page_count": 21, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery", "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-04-15_florida-power-light-company_fa21-6", "company": "Florida Power & Light Company", "company_raw": "Florida Power & Light Company (FA21-6)", "docket": "FA21-6", "docket_full": "FA21-6-000", "issued_date": "2022-04-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220415-3012&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220415-3012", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 34, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 through December 31, 2021", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Environmental Cleanup Costs", "summary": "FPL improperly recorded environmental cleanup costs in Account 930.2, Miscellaneous General Expenses, and Account 105, Electric Plant Held for Future Use, instead of in Account 186, Miscellaneous Deferred Debits. As a result of the improper accounting, FPL misstated administrative and general (A&G) and Electric Plant Held for Future Use account balances reported in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise and implement accounting policies and procedures to ensure that it properly accounts for environmental cleanup costs consistent with Commission accounting requirements.", "source_page": null }, { "number": 2, "text": "Provide training to its staff on the revised procedures for properly accounting for environmental cleanup costs in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the environmental cleanup costs improperly accounted for in Account 930.2 and Account 105 within 60 days of the date of the audit report.", "source_page": null }, { "number": 4, "text": "Revise the cost of the land reported in Account 105, the refunds and expenses recorded in Account 930.2, and entries in other accounts impacted by the improper accounting for the environmental cleanup costs after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 3. Restate and footnote the FERC Form No. 1 for the current year.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 2, "title": "Prepayments", "summary": "FPL improperly recorded certain advance payments that were applicable to future accounting periods in A&G and Operations and Maintenance (O&M) accounts, instead of in Account 165, Prepayments. As a result, FPL did not accurately recognize certain expenses in the accounting period in which they were incurred, leading to the misstatement of A&G, O&M, and balance sheet account balances reported on its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Revise its accounting policies and procedures to ensure that it properly records all advance payments that are applicable to future periods in accordance with the Commission’s regulations.", "source_page": null }, { "number": 6, "text": "Provide training to staff on the revised prepayment accounting policies and procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting Misclassifications", "summary": "FPL improperly recorded various expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, FPL misstated A&G and O&M account balances reported in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise its policies and procedures to ensure that it properly accounts for expenditures consistent with Commission accounting regulations.", "source_page": null }, { "number": 8, "text": "Provide training to its staff on the revised procedures for properly accounting for expenditures in its books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 4, "title": "FERC Form No. 1 Reporting", "summary": "FPL did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. These actions affected the transparency, accuracy, and usefulness of the reports. D. List of", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Revise and strengthen its policies, procedures, and practices to report correct, accurate, complete information in the FERC Form No. 1 consistent with the instructions of each schedule page.", "source_page": null }, { "number": 10, "text": "Provide training to relevant staff on the revised FERC Form No. 1 policies, procedures, and practices. Provide periodic training in these areas, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-03-31_duke-energy-corporation_pa20-3", "company": "Duke Energy Corporation", "company_raw": "Duke Energy Corporation (PA20-3)", "docket": "PA20-3", "docket_full": "PA20-3-000", "issued_date": "2022-03-31", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220331-3004&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220331-3004", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 17, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2017 to October 31, 2021", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-03-23_arizona-public-service-company_pa20-1", "company": "Arizona Public Service Company", "company_raw": "Arizona Public Service Company (PA20-1)", "docket": "PA20-1", "docket_full": "PA20-1-000", "issued_date": "2022-03-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220323-3002&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220323-3002", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 24, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2016 to October 30, 2021", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Transmission Line Outage Postings", "summary": "APS did not timely post transmission line outages on its OASIS on six occasions. As a result, the Available Transfer Capability (ATC)/Total Transfer Capability (TTC) values were not updated to reflect these outages, which then led to the curtailment of 16 transmission service schedules.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise processes and procedures related to the posting of transmission line outage information on OASIS and enhance the process to timely and accurately communicate outage information to the Balancing Authority Area (BAA) operators.", "source_page": null }, { "number": 2, "text": "Provide training to transmission operators on the new policies, processes, and procedures.", "source_page": null } ], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 2, "title": "Non-Firm Redirect Service Requests", "summary": "APS transmission staff improperly directed existing long-term firm Point-to-Point (PTP) customers to execute a short-term transmission service agreement when requesting non-firm redirect service. This process was implemented because an OASIS configuration error prevented existing long-term firm PTP customers from requesting non-firm redirect service on APS’s OASIS and, instead, required customers to manually request redirect service. Not only was the process involving these short-term agreements inconsistent with APS’s OATT, the process also improperly enabled customers to manually select a higher priority for this redirect service request than they otherwise should have received. D. List of", "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Correct OASIS settings to allow short-term non-firm redirect service requests associated with existing long-term firm PTP transmission service.", "source_page": null }, { "number": 4, "text": "Revise policies and procedures regarding short-term non-firm redirect requests and discontinue the practice of requiring short-term transmission service agreements associated with these redirect requests.", "source_page": null }, { "number": 5, "text": "Provide training to transmission personnel regarding the updated policies and procedures. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Informational postings" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-03-21_tampa-electric-company_pa21-1", "company": "Tampa Electric Company", "company_raw": "Tampa Electric Company (PA21-1)", "docket": "PA21-1", "docket_full": "PA21-1-000", "issued_date": "2022-03-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220321-3011&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220321-3011", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 16, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 to August 31, 2021", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-02-04_firstenergy-corporation_fa19-1", "company": "FirstEnergy Corporation", "company_raw": "FirstEnergy Corporation (FA19-1)", "docket": "FA19-1", "docket_full": "FA19-1-000", "issued_date": "2022-02-04", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220204-3012&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220204-3012", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 85, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2015 to September 30, 2021", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "60" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Allocation of Overhead Costs to CWIP", "summary": "FirstEnergy’s subsidiaries capitalized overhead costs to Account 107, Construction Work in Progress-Electric, using an allocation method that was not based on actual time employees were engaged in construction activities based on timecard reports or on a representative time study. This may have led to FirstEnergy’s subsidiaries capitalizing costs to Account 107 that did not have a definite relationship to construction. As a result, the companies may have overstated construction costs recorded in Account 107 and electric plant in service, as well as accumulated depreciation, depreciation expens", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Retain an independent third-party entity, subject to approval by DAA, to conduct a representative labor time study for allocation of overhead costs incurred in 2021 to CWIP, and to assist with the development of procedures FirstEnergy subsidiaries shall use to periodically determine the allocation of overhead labor and labor- related costs capitalized by each FirstEnergy subsidiary into the cost of construction after 2021. The independent consultant should have expertise and experience independently performing time studies used in the determination of overhead capitalization rates of U.S. based utilities subject to the accounting requirements prescribed for public utilities and licensees or for natural gas companies under 18 C.F.R. Part 101 or Part 201, respectively. The time study should involve a representative sample of study participants (employees) that provides for extrapolation of the study results to the full population of FirstEnergy employees, and should include processes for application of the study results from the audit period to the issue date of this audit report, and processes for applying the capitalization rate(s) the study finds for 2021 back to the period January 1, 2015 through December 31, 2020, either with no change to the capitalization rates found in the study or with such modifications to the capitalization rate(s) the independent consultant finds reasonable and supported by evidence. The independent consultant should use its expertise and all relevant information available to it to make recommendations as to what the capitalization rate(s) should be for prior years for each FirstEnergy subsidiary, should set forth the basis for its recommendations, and provide both the recommendations and the basis therefore to FirstEnergy and DAA. If there is no recommendation by the independent consultant for any year or other period between January 1, 2015 and December 31, 2020 for any specific capitalizable cost center, then FirstEnergy should base its capitalization rate and the amount to be capitalized for such year or period on the rates and costs of such specific cost centers for which FirstEnergy can provide to DAA reasonable evidence as to the time employees in such cost centers spent having a definite relation to construction, and exclude from consideration those cost centers for which FirstEnergy cannot provide such evidence, per, for example, 18 C.F.R. Part 101, General Instruction No. 2 and § 41.8. The progress of the study should be reported within 120 days and the time study results provided to DAA for review and consideration within 180 days of the date of issuance of this audit report, and the developed allocation procedures should be submitted when complete, but no later than 60 days after completion of DAA’s review of the labor time study. At a minimum, the developed allocation procedures should provide a method for overhead cost allocation and capitalization to construction based on actual timecard distributions or where this procedure is impractical, based on periodic time studies.", "source_page": null }, { "number": 2, "text": "Revise written policies, practices, procedures, and controls governing the methods used to account for, track, report, and review overhead labor and related costs, and all other costs allocated to construction projects to be consistent with Commission accounting requirements. In addition, adopt procedures to retain formal documentation supporting the amount of overhead costs allocated to electric plant accounts.", "source_page": null }, { "number": 3, "text": "Revise accounting processes and procedures to account for and report capitalized A&G amounts recorded in Accounts 920, Administrative and General Salaries, and 921, Office Supplies and Expenses, using Account 922, Administrative Expenses Transferred – Credit, consistent with Commission regulations.", "source_page": null }, { "number": 4, "text": "Train relevant staff on the revised overhead allocation, control, and A&G accounting procedures and documentation, and provide periodic training in this area, as needed.", "source_page": null }, { "number": 5, "text": "Train staff on the time reporting guidelines and establish a periodic training program in this area.", "source_page": null }, { "number": 6, "text": "Within 30 days of the completion of Recommendation No. 1, submit an estimate to DAA, including the calculations and determinative components, of overhead costs that would have been allocated to CWIP from 2015 through the present consistent with the requirements of Electric Plant Instruction No. 4 and General Instruction No. 9. The estimate should be based on a recalculation of 2015’s and subsequent years’ overhead costs allocated to construction with labor and related costs removed from the cost of plant that were not associated with construction activities based on the methodology developed in response to Recommendation No. 1.", "source_page": null }, { "number": 7, "text": "With the response to Recommendation No. 6, submit proposed accounting entries to DAA that remove the overhead costs that were allocated to CWIP and electric plant in service from 2015 through the present that exceed the amount of costs that would have been allocated to the accounts based on the methodology developed in response to Recommendation No. 1. Also, provide proposed accounting entries to remove associated amounts from other accounts and balances affected by the inappropriately allocated cost such as the accumulated depreciation and ADIT accounts, and AFUDC balances capitalized into CWIP and electric plant in service. If the adjusting entries result in a significant impact to income for the current year, FirstEnergy subsidiaries may account for the transaction as a correction of a prior period error in Account 439, Adjustments to Retained Earnings. Such adjustments to retained earnings with the proposed accounting entries should be submitted to DAA.", "source_page": null }, { "number": 8, "text": "Revise account balances for FirstEnergy subsidiaries’ utility plant, accumulated depreciation, ADIT, and other account balances impacted by the inappropriate allocation of unsupported overhead costs after receiving DAA’s approval of proposed accounting entries submitted per Recommendation No. 7, and restate and footnote the balances reported in the next-filed FERC Form No. 1 reports of the FirstEnergy subsidiaries for both the current and comparative years presented in each subsidiary’s next-filed report, as necessary to reflect and disclose the revisions.", "source_page": null }, { "number": 9, "text": "Submit a refund analysis to DAA that explains and details the following: (1) calculation of refunds that result from correcting the overstatement of transmission plant due to the improperly capitalized labor costs, as determined by the labor time study, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 10, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 11, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Vegetation Management Costs", "summary": "The FirstEnergy FPUs improperly accounted for maintenance expenses incurred to remove vegetation surrounding in service distribution powerlines. Specifically, the FPUs inappropriately capitalized the cost to electric plant in service. This accounting practice caused the companies to overstate electric plant in service, accumulated depreciation, ADIT, depreciation expenses, and other account balances, and understate operating expenses incurred.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise accounting policies and procedures for vegetation management activities in distribution corridors to be consistent with Commission accounting requirements.", "source_page": null }, { "number": 13, "text": "Train relevant staff on the revised vegetation management accounting policy and procedures and provide periodic training.", "source_page": null }, { "number": 14, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the FirstEnergy FPU’s CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by the capitalization of vegetation management expenses for the period from October 1, 2021 through the present within 60 days of issuance of this audit report.", "source_page": null }, { "number": 15, "text": "Revise the FirstEnergy FPUs’ CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over-accrual of AFUDC after receiving DAA’s approval of the proposed accounting entries per Recommendation No. 14 and restate and footnote the FERC Form No. 1 reports for current and comparative years as necessary.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Capitalization vs. expense", "Service reliability & vegetation management" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Amortization of Regulatory Assets", "summary": "FirstEnergy’s subsidiaries deferred certain maintenance expenses, associated with costs incurred to remove vegetation in transmission corridors, and recorded the deferred expenses as regulatory assets in Account 182.3, Other Regulatory Assets, for Commission accounting and reporting purposes. Certain subsidiaries then improperly amortized $3.8 million of the deferred costs as expenses in subsequent periods without obtaining Commission approval to recover these regulatory assets in rates. Moreover, two of the Transmission Companies, ATSI and TrAILCo, included these expenses representing amortiz", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise policies, practices, and procedures to amortize or write off the regulatory assets consistent with Commission accounting requirements.", "source_page": null }, { "number": 17, "text": "Train relevant staff on the revised methods, and provide periodic training in this area, as needed.", "source_page": null }, { "number": 18, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that result from the correction of ATSI’s and TrAILCo’s improper and unauthorized, respective, depreciation and amortization of plant and regulatory assets to the depreciation expense account and inclusion of the expenses in service rate determinations, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 19, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 20, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations. Accounting for Lobbying Expenses, Donations, and Unsupported Costs", "source_page": null }, { "number": 21, "text": "Critically review and strengthen internal controls in FirstEnergy and its subsidiaries. Establish and implement procedures governing methods to be used to appropriately identify, account for, track, report, and review all lobbying costs, donations, and any unsupported expenses, including, but not limited to, expenses of external lobbyists, monies paid to external corporate entities to be used for lobbying, and other external lobbying costs and internal lobbying costs, including employee lobbying time and other internal lobbying costs.", "source_page": null }, { "number": 22, "text": "Train relevant staff on the internal control enhancements and procedures established, including internal controls over vendor creation in the accounts payable system, payments, accounting, and reporting violations; and provide periodic training in this area, as needed.", "source_page": null }, { "number": 23, "text": "Perform an analysis of costs that FirstEnergy and its subsidiaries incurred associated with internal and external lobbying activities, including payments of FirstEnergy funds to outside entities for purposes of those entities using those funds for lobbying, and provide support to identify lobbying-related expenses improperly charged to utility operating accounts, for the audit period and, with respect to the specific issues discussed in this finding, for the entire period affected by or relevant to each such specific issue. Within 60 days of the issuance of this audit report and on a rolling basis within 60 days of conclusion of each internal or external investigation discussed in the finding or any new internal or external investigation arising directly from Ohio House Bill 6 (HB 6) or lobbying activities occurring prior to 2021, provide the results of the investigation, proposed correcting journal entries, and FirstEnergy’s analysis of the findings from each investigation and the related impact on prior and future accounting and rate development to audit staff.", "source_page": null }, { "number": 24, "text": "Submit a refund analysis, within 60 days of issuance of this audit report and on a rolling basis within 60 days of conclusion of each investigation discussed in the finding or any new investigation arising directly from HB 6 or lobbying activities occurring prior to 2021, for DAA’s review, that explains and details the following: (1) calculation of refunds resulting from correcting the improper accounting for external lobbying costs, donations, and unsupported costs in utility operating and plant accounts; and internal lobbying costs as identified pursuant to the analysis performed in response to Recommendation No. 23, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 25, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 26, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Lobbying Expenses, Donations, and Costs that Lacked Proper Supporting Documentation", "summary": "FESC improperly accounted for and improperly reported lobbying expenses, donations, and other costs that lacked proper supporting documentation or were misclassified (unsupported costs). Moreover, FESC allocated and charged the improperly accounted for lobbying, donation, and unsupported costs to FirstEnergy and its subsidiaries. This led the FirstEnergy subsidiaries to improperly account for and report the lobbying expenses, donations, and unsupported costs in their respective books and records, and FERC Form No. 1. The errors resulted in the Transmission Companies including the lobbying expe", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 5, "title": "Allowance for Funds Used During Construction", "summary": "FirstEnergy’s FPUs improperly included undistributed subsidiary earnings and accumulated other comprehensive income in equity balances used for the purpose of computing AFUDC rates. As a result, the companies over-accrued AFUDC during the audit period, which led them to overstate CWIP and plant-in-service balances.", "is_other_matter": false, "recommendations": [ { "number": 27, "text": "Revise and implement the FPUs’ processes and procedures to calculate their respective AFUDC rates consistent with EPI No. 3(A)(17) and other applicable Commission requirements. Revisions should include processes to prevent the inclusion of balances in Accounts 216.1 and 219 in the AFUDC rate calculations.", "source_page": null }, { "number": 28, "text": "Train relevant staff on the revised AFUDC calculation method, and provide periodic training, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 6, "title": "Service Company Billing Procedures", "summary": "Billing information that FESC provided to FirstEnergy’s subsidiaries pertaining to charges for services provided to them was insufficient. Specifically, FESC did not provide detailed information to reflect the services provided and showing the charges classified as direct costs, indirect costs, or compensation for use of capital, with the details of service company accounts by service provided, as required. As a result, the FirstEnergy subsidiaries misclassified costs charged by FESC.", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Revise FESC policies, procedures, and accounting systems so as to provide sufficient billing information to FirstEnergy’s subsidiaries in accordance with the Commission’s regulations.", "source_page": null }, { "number": 30, "text": "Train relevant staff on the revised policies, procedures, and accounting systems and provide periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Fuel – Coal Supply and Other Consulting Services", "summary": "The FirstEnergy FPU, Monongahela Power Company, improperly accounted for fixed monthly consultation fees paid in Account 501, Fuel, as a component cost of coal used in operations. The accounting led to costs being included in fuel used in operations that were not directly assignable and likewise not properly allocable to the cost of coal purchased and used. As a result, Monongahela Power Company may have overcharged wholesale customers, through operation of the fuel cost adjustment formula in its tariff, for the cost of fuel included as a component cost of generating electricity.", "is_other_matter": false, "recommendations": [ { "number": 31, "text": "Revise accounting policies and procedures for cost of fuel by the FPUs to ensure compliance with the Commission’s accounting regulations.", "source_page": null }, { "number": 32, "text": "Train relevant staff on the revised policies and procedures and provide periodic training.", "source_page": null }, { "number": 33, "text": "Perform an analysis of all monthly payments made to consultants, including BCG Resources, LLC, that were included in the cost of fuel used in operations during the audit period and submit the analysis to DAA with supporting documents within 60 days of issuance of this audit report. Based on the analysis, submit proposed adjusting accounting entries to record the consultation costs in the appropriate accounts for DAA’s review and approval.", "source_page": null }, { "number": 34, "text": "Revise the FirstEnergy FPUs’ fuel inventory and other account balances impacted by the improper accounting after receiving DAA’s approval of the proposed accounting entries per Recommendation No. 33 and restate and footnote the FERC Form No. 1 reports for current and comparative years as necessary.", "source_page": null }, { "number": 35, "text": "Review collections received, including but not limited to uplift payments, during the audit period based, in part, on the cost of fuel and submit an analysis to DAA for review of retail and wholesale overcollections due to improper recording of costs in Account 501.", "source_page": null }, { "number": 36, "text": "Submit a refund analysis if there were overcollections from wholesale customers, within 60 days of issuance of this audit report, for DAA’s review, that explains and details the following: (1) calculation of refunds resulting from the improper accounting for fuel costs, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 37, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 38, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations. E. Implementation of Recommendations Audit staff further recommends that FirstEnergy submit the following:  A plan for implementing the audit recommendations within 30 days after the audit report is issued;  Quarterly reports describing progress in completing each corrective action recommended. Quarterly nonpublic submissions should be made no later than 30 days after the end of each calendar quarter, beginning with the first quarter after the audit report is issued, and continuing until all recommended corrective actions are completed; and  Copies of any written policies and procedures developed in response to the recommendations. These documents should be submitted in the first quarterly filing after development of a written policy or procedures.", "source_page": null } ], "themes": [ "Tariff administration & oversight", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Fuel & purchased-power cost recovery", "Property & plant records", "Service reliability & vegetation management", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2022-02-04_connecticut-light-and-power-company_fa19-8", "company": "Connecticut Light and Power Company", "company_raw": "Connecticut Light and Power Company (FA19-8)", "docket": "FA19-8", "docket_full": "FA19-8-000", "issued_date": "2022-02-04", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20220204-3014&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20220204-3014", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 44, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2015 to December 31, 2019", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1", "60" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "CL&P improperly included accumulated other comprehensive income and unamortized debt-related balances in long-term debt and equity balances used to compute its AFUDC rates. As a result, CL&P over-accrued AFUDC amounts included in utility plant accounts, which led it to overstate its annual transmission revenue requirement and overbill transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Compromise Settlements", "summary": "CL&P incorrectly accounted for compromise settlement costs in operating expense accounts instead of Account 426.3, Penalties, or Account 426.5, Other Deductions, as required. The operating expense accounts used were included in CL&P’s transmission formula rate calculations. As a result, CL&P overstated its annual transmission revenue requirement and overbilled transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise existing or establish new policies, procedures, and controls to account for and track legal settlements and associated expenses relating to compromise settlements consistent with Commission accounting requirements.", "source_page": null }, { "number": 9, "text": "Provide training to relevant staff on the methods to account for expenses relating to such compromise settlements. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 10, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from the exclusion of compromise settlement amounts from transmission formula rate calculations during the audit period, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 11, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 12, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Tax Receivables", "summary": "CL&P incorrectly recorded accounts receivable that represented refunds for overpayments of income taxes in Account 165, Prepayments, instead of in Account 143, Other Accounts Receivable. The incorrect accounting led to an overstatement of CL&P’s rate base used in its transmission formula rate calculations. As a result, CL&P overstated its annual transmission revenue requirement and overbilled transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Revise accounting policies and procedures to account for income tax refunds consistent with Commission accounting requirements.", "source_page": null }, { "number": 14, "text": "Provide training to relevant staff on the revised accounting policies and procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 15, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the accounts receivable and prepayment balances within 60 days of issuance of the audit report.", "source_page": null }, { "number": 16, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) the calculation of refunds that results from excluding income tax account receivable balances from transmission rates during the audit period, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 17, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 18, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Merger Transaction Costs", "summary": "CL&P improperly included merger transaction costs in operating accounts, contrary to the Commission’s long-standing policy that such expenses be recorded in nonoperating accounts. As a result, CL&P overstated its annual transmission revenue requirement and overbilled transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Enhance accounting policies and procedures for tracking and accounting for merger-related costs consistent with Commission accounting requirements.", "source_page": null }, { "number": 20, "text": "Provide training to relevant staff on the revised accounting policies and procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 21, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds resulting from correcting the improper inclusion of merger transaction costs in transmission formula rates during the audit period, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 22, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 23, "text": "Refund the amounts disclosed in the refund report to customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 5, "title": "Application of Nonapproved Depreciation Rates", "summary": "CL&P used a depreciation rate for accounting and transmission ratemaking purposes that was not filed with, and approved by, the Commission. As a result, the Commission was not afforded an opportunity to review or decide on the appropriateness of the inclusion of the depreciation rate in the transmission service rate determination. D. Other Matter", "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Revise and implement processes and procedures to ensure that depreciation rates and related studies are filed with the Commission for consideration and decision before being used for transmission ratemaking purposes.", "source_page": null }, { "number": 25, "text": "Provide training to relevant staff on the revised procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 26, "text": "File a depreciation study and associated depreciation rate for the Norwalk Harbor- Northport underground transmission line in a docket relating to its transmission formula rate within 60 days of issuance of the audit report. F.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 6, "title": "Transparency of the Derivation of Service Company Capital Costs in Jurisdictional Rates", "summary": "CL&P included capital cost charges from its service company, Eversource Energy Service Company (EESCO), in jurisdictional rate determinations. CL&P is encouraged to disclose the EESCO cost components and attributes that are considered in the derivation of the capital cost charges and included in CL&P’s transmission rates in its future transmission formula rate annual informational updates and true-up filings. Such disclosure will ensure the filings include information useful in determining how service company capital costs are derived that are included in CL&P’s jurisdictional rates and recovered from its transmission customers. E. List of", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Depreciation" ], "cost_to_customers": true }, { "collection": "prudence_review", "jurisdiction": "KS", "source": "Kansas Corporation Commission", "doc_type": "fuel & purchased-power prudence staff audit report", "id": "2022-01-21_evergy-kansas_ks-21-ekme-329-gie-staff-fuel-prudence-report", "company": "Evergy Kansas Metro and Evergy Kansas Central", "company_raw": "Evergy Kansas Metro and Evergy Kansas Central", "docket": "21-EKME-329-GIE", "docket_full": null, "issued_date": "2022-01-21", "source_page_url": "https://estar.kcc.ks.gov/", "pdf_download_url": "https://estar.kcc.ks.gov/estar/ViewFile.aspx/S202201210923455044.pdf?Id=c3651aba-c4e9-415f-a36c-a1a2c44d8514", "captured_at": "2026-06-19", "source_note": "Staff's Report and Recommendation (KCC Utilities Division, Senior Auditor Bill Baldry) reviewing Evergy's fuel and purchased-power costs from the Feb 2021 winter storm, Docket 21-EKME-329-GIE; 134 pp. Companion to the docket settlement (id 2022-04-22_evergy-kansas_ks-21-ekme-329-gie-winter-storm-uri-stipulation). PDF: estar.kcc.ks.gov/estar/ViewFile.aspx/S202201210923455044.pdf. Listed for reference (metadata-only).", "archived_via": null, "page_count": 134, "scanned_pages": [ 104, 105 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "OH", "source": "Public Utilities Commission of Ohio", "doc_type": "rider audit report (Daymark Energy Advisors, PUCO third-party audit of Rider DMR)", "id": "2022-01-14_firstenergy-ohio_puco-17-2474-el-rdr-rider-dmr-audit", "company": "FirstEnergy 'Ohio Companies' (Ohio Edison, Cleveland Electric Illuminating, Toledo Edison)", "company_raw": "FirstEnergy 'Ohio Companies' (Ohio Edison, Cleveland Electric Illuminating, Toledo Edison)", "docket": "17-2474-EL-RDR", "docket_full": null, "issued_date": "2022-01-14", "source_page_url": "https://puco.ohio.gov/utilities/electricity/resources/hb-6-related-investigations", "pdf_download_url": "https://dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A22A14B01753C02696", "captured_at": "2026-06-08", "source_note": "PUCO third-party audit (Daymark Energy Advisors), Case 17-2474-EL-RDR — Audit of the FirstEnergy Ohio Companies' Rider DMR. 137 pp. Live host F5-WAF-blocked to scripts (fetch=false); content verified via the Internet Archive snapshot in archived_via. Page 1 verified: 'DAYMARK ENERGY ADVISORS ... AN AUDIT REPORT OF THE OHIO COMPANIES' RIDER DMR JANUARY 14, 2022'.", "archived_via": "http://web.archive.org/web/20220114184543if_/https://dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A22A14B01753C02696", "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "LA", "source": "Louisiana Public Service Commission", "doc_type": "direct testimony", "id": "2021-12-09_entergy-louisiana_la-lake-charles-construction-review-jones", "company": "Entergy Louisiana, LLC", "company_raw": "Entergy Louisiana, LLC", "docket": null, "docket_full": null, "issued_date": "2021-12-09", "source_page_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=3SIDvL86aGQ%3D", "pdf_download_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=3SIDvL86aGQ%3D", "captured_at": "2026-06-02", "source_note": "Direct Testimony of Ryan D. Jones on behalf of Entergy Louisiana, LLC, in Entergy Louisiana's Application for Review of the Management of the Construction of Lake Charles Power Station, before the Louisiana Public Service Commission, filed December 2021 (received December 9, 2021; public version, 17 pp). The Lake Charles Power Station (an approximately $872 million natural-gas plant; commercial operation March 28, 2020) was approved as prudent in LPSC Order No. U-34283 (July 20, 2017); this proceeding reviews the prudence of the project's construction management. The review-proceeding docket number is obscured in the public-redacted filing. Listed for reference (metadata-only). Source: LPSC public docket portal, file 3SIDvL86aGQ= (lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=3SIDvL86aGQ%3D).", "archived_via": null, "page_count": 17, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "LA", "source": "Louisiana Public Service Commission", "doc_type": "direct testimony", "id": "2021-12-09_entergy-louisiana_la-lake-charles-construction-review-dickens", "company": "Entergy Louisiana, LLC", "company_raw": "Entergy Louisiana, LLC", "docket": null, "docket_full": null, "issued_date": "2021-12-09", "source_page_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=f1nYMQY9MWc%3D", "pdf_download_url": "https://lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=f1nYMQY9MWc%3D", "captured_at": "2026-06-02", "source_note": "Direct Testimony of Gary C. Dickens (Vice President, Project/Construction Management, New Generation Program Execution) on behalf of Entergy Louisiana, LLC, in Entergy Louisiana's Application for Review of the Management of the Construction of Lake Charles Power Station, before the Louisiana Public Service Commission, Public Redacted Version, December 2021 (49 pp). Addresses the owner's oversight during the development, design-engineering, and procurement phases of the project, which began commercial operation March 28, 2020. Related to construction-approval Order No. U-34283 (July 20, 2017); the review-proceeding docket number is obscured in the public-redacted filing. Listed for reference (metadata-only). Source: LPSC public docket portal, file f1nYMQY9MWc= (lpscpubvalence.lpsc.louisiana.gov/portal/PSC/ViewFile?fileId=f1nYMQY9MWc%3D).", "archived_via": null, "page_count": 49, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "OR", "source": "Public Utility Commission of Oregon", "doc_type": "power cost adjustment order", "id": "2021-12-07_portland-general-electric_or-ue-380-order-21-457-pcam", "company": "Portland General Electric Company", "company_raw": "Portland General Electric Company", "docket": "UE-380", "docket_full": null, "issued_date": "2021-12-07", "source_page_url": "https://apps.puc.state.or.us/edockets/orders.asp?OrderNumber=21-457", "pdf_download_url": "https://apps.puc.state.or.us/orders/2021ords/21-457.pdf", "captured_at": "2026-06-07", "source_note": "Oregon PUC Order No. 21-457 (entered December 7, 2021) in the matter of Portland General Electric Company's 2020 Annual Power Cost Variance / Power Cost Adjustment Mechanism (PCAM) (9 pp) — the Commission's review of the difference between PGE's actual and forecast net variable power costs. Listed for reference (metadata-only). Source: Oregon PUC orders archive (apps.puc.state.or.us/orders/2021ords/21-457.pdf).", "archived_via": null, "page_count": 9, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "OH", "source": "Public Utilities Commission of Ohio", "doc_type": "independent investigative audit (Blue Ridge Consulting, PUCO-ordered)", "id": "2021-11-19_firstenergy-ohio_puco-20-1629-el-rdr-browns-stadium-investigation", "company": "FirstEnergy Corp. (Ohio electric distribution utilities)", "company_raw": "FirstEnergy Corp. (Ohio electric distribution utilities)", "docket": "20-1629-EL-RDR", "docket_full": null, "issued_date": "2021-11-19", "source_page_url": "https://puco.ohio.gov/utilities/electricity/resources/hb-6-related-investigations", "pdf_download_url": "https://dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A21K19B14331F02084", "captured_at": "2026-06-08", "source_note": "PUCO-ordered independent audit (Blue Ridge Consulting), Case 20-1629-EL-RDR — Investigation into Ohio ratepayer funding of FirstEnergy's Cleveland Browns Stadium renaming. 9 pp. Live host dis.puc.state.oh.us is F5-WAF-blocked to scripts (fetch=false); content verified via the Internet Archive snapshot in archived_via. Page 1 verified: 'Case No. 20-1629-EL-RDR ... November 19, 2021 ... Blue Ridge Consulting Services'.", "archived_via": "http://web.archive.org/web/20220521222115if_/https://dis.puc.state.oh.us/ViewImage.aspx?CMID=A1001001A21K19B14331F02084", "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-11-17_ameren-corporation_fa20-6", "company": "Ameren Corporation", "company_raw": "Ameren Corporation (FA20-6)", "docket": "FA20-6", "docket_full": "FA20-6-000", "issued_date": "2021-11-17", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20211117-3000&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20211117-3000", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 71, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2016 through December 31, 2019", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1", "60" ], "finding_count": 9, "findings": [ { "index": 1, "title": "Reporting of Materials and Supplies", "summary": "Ameren Missouri incorrectly reported materials and supplies (M&S) assigned to transmission-related construction on line 8 of page 227, Materials and Supplies, of its 2016-2018 FERC Form No. 1 reports, rather than on line 5 of the same page. As a result of overstating line 8, Ameren Missouri incorrectly increased the working capital component of its formula rate mechanism, which led to an overstatement of its wholesale transmission revenue requirement used to determine billings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies, procedures, and practices to ensure that FERC Form No. 1, page 227 is completed in accordance with the reporting instructions, including reporting the amount of plant materials and operating supplies under the primary functional classifications as indicated in column (a) of page 227.", "source_page": null }, { "number": 2, "text": "Train relevant staff on the revised reporting policies, procedures, and practices and provide periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Perform an analysis that reflects the proper functionalization of plant M&S to construction for 2016-2018. Provide the results of the analysis to audit staff within 60 days of the date of the final audit report.", "source_page": null }, { "number": 4, "text": "Submit a refund analysis, within 60 days of the issuance of this audit report, to DAA for review that explains and details the following: (1) calculations of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper reporting of M&S on page 227 of the FERC Form No. 1 as determined by the analysis performed in response to Recommendation No. 3, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 5, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 6, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations. Remeasurement of Accumulated Deferred Income Taxes Resulting from the Tax Cuts and Jobs Act", "source_page": null }, { "number": 7, "text": "Strengthen policies, procedures, and controls to maintain and retain documentation to support ADIT amounts consistent with Commission record retention requirements.", "source_page": null }, { "number": 8, "text": "Train relevant staff on the revised ADIT policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 9, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculations of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the overstatement of Account 923 due to the improper write-off of unidentified ADIT, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 10, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 11, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations. Accounting for Service Company’s Depreciation, Amortization, Taxes, and Interest Expenses", "source_page": null }, { "number": 12, "text": "Revise policies and procedures to ensure that the Ameren public utilities properly account for depreciation, amortization, tax, and interest expenses allocated from AMS in Account 930.2.", "source_page": null }, { "number": 13, "text": "Train relevant staff on the revised policies and procedures for properly accounting for depreciation, amortization, tax, and interest expenses allocated from AMS, and provide periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 2, "title": "Remeasurement of Accumulated Deferred Income Taxes Resulting from the Tax Cuts and Jobs Act of 2017", "summary": "AMS overstated its accumulated deferred income tax (ADIT) balance on its books when it made adjustments in response to the Tax Cuts and Jobs Act of 2017 (TCJA). AMS could not provide documentation to support an expense totaling $1,197,220 that was included as part of the remeasurement of its ADIT. This unsupported cost was allocated to the Ameren public utilities and incorrectly included in an account that is a wholesale transmission formula rate input. This led the Ameren public utilities to overstate their wholesale transmission revenue requirements and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Service Company’s Depreciation, Amortization, Taxes, and Interest Expenses", "summary": "The Ameren public utilities improperly accounted for AMS’s allocated depreciation, amortization, tax, and interest expenses in Account 923, Outside Services Employed, instead of Account 930.2, Miscellaneous General Expenses. As a result, the Ameren public utilities overstated Account 923 and understated Account 930.2. This improper accounting had no impact on the Ameren public utilities’ wholesale transmission revenue requirements.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Non-Power Goods and Services Provided to Affiliates", "summary": "The Ameren public utilities improperly recorded the costs of providing non- power goods and services to their associated companies in Account 921, Office Supplies and Expenses, rather than recording them in the appropriate accounts for transactions of the same nature. As a result of the misclassifications, the Ameren public utilities overstated their annual transmission revenue requirements, which led to overbillings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Revise policies and procedures to ensure that affiliate transactions are recorded in the appropriate accounts for transactions of the same nature.", "source_page": null }, { "number": 15, "text": "Train relevant staff on the revised policies and procedures and provide periodic training in this area, as needed.", "source_page": null }, { "number": 16, "text": "Perform an analysis of Account 921 to identify any affiliate transactions that were improperly recorded in Account 921 during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 17, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculations of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper accounting of affiliate transactions as identified pursuant to the analysis performed in response to Recommendation No. 16, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 18, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 19, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 5, "title": "Allocation of Non-Regulated Affiliate Expenses", "summary": "AMS improperly allocated costs associated with its non-regulated affiliate to the Ameren public utilities. This led the Ameren public utilities to overstate their wholesale transmission revenue requirements and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 20, "text": "Strengthen policies, procedures, and controls to ensure that costs are properly allocated to non-regulated affiliates.", "source_page": null }, { "number": 21, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 22, "text": "Perform an analysis to identify other costs related to non-regulated affiliates that were improperly allocated to the Ameren public utilities during the audit period. Provide the results of the analysis to audit staff within 60 days of the issuance of this audit report.", "source_page": null }, { "number": 23, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper allocation of costs related to the Ameren Accelerator program and other costs as identified pursuant to the analysis performed in response to Recommendation No. 22, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 24, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 25, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 6, "title": "Allocation of Overhead Labor Costs to Construction Work In Progress", "summary": "Ameren’s subsidiaries capitalized overhead labor to Account 107, Construction Work in Progress – Electric, using an allocation method that was not based on the actual time that employees were engaged in construction activities or on a representative time study. This led Ameren’s subsidiaries to charge costs to Account 107 that may not have a definite relationship to construction. As a result, the Ameren public utilities may have overstated construction costs recorded in Account 107 and electric plant in service, as well as Accumulated Deferred Income Tax (ADIT) account balances, and may have understated operating expenses. Moreover, this accounting may have led Ameren public utilities to overstate their respective wholesale annual transmission revenue requirements and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Retain an independent third-party entity to conduct a representative labor time study for allocation of overhead costs incurred in 2021 to Construction Work in Progress (CWIP), and to assist with the development of procedures that the Ameren public utilities shall use to periodically determine the allocation of overhead labor and labor-related costs capitalized into the cost of construction after 2021. Report the progress of the study within 120 days and provide the time study results to DAA for review and consideration within 180 days of the date of issuance of this audit report and the developed allocation procedures when complete. At a minimum, the developed allocation procedures should provide a method for overhead cost allocation and capitalization to construction based on actual timecard distributions or where this procedure is impractical, based on periodic time studies.", "source_page": null }, { "number": 27, "text": "Revise policies, practices, procedures, and controls governing the methods used to account for, track, report, and review overhead labor and related costs, and all other costs allocated to construction projects to be consistent with Commission accounting requirements. In addition, adopt procedures to retain formal documentation supporting the amount of overhead costs allocated to electric plant accounts.", "source_page": null }, { "number": 28, "text": "Train relevant staff on the revised overhead allocation and control procedures and documentation, and provide periodic training in this area, as needed.", "source_page": null }, { "number": 29, "text": "Submit an estimate, within 30 days of the completion of Recommendation No. 26, to DAA for review, that includes the calculations and determinative components, of overhead costs that would have been allocated to CWIP during the audit period consistent with the requirements of Electric Plant Instruction No. 4 and General Instruction No. 9. The estimate should be based on a recalculation of 2016 and subsequent years’ overhead costs allocated to construction with labor and related costs removed from the cost of plant that were not associated with construction activities based on the methodology developed in response to Recommendation No. 26.", "source_page": null }, { "number": 30, "text": "With the response to Recommendation No. 29, submit proposed accounting entries to DAA for review that remove the overhead costs that were allocated to CWIP and electric plant in service in 2016 and subsequent years that exceed the amount of costs that would have been allocated to the accounts based on the methodology developed in response to Recommendation No. 26. Also, provide proposed accounting entries to remove associated amounts from other accounts and balances affected by the inappropriately allocated cost such as ADIT accounts, and allowance for funds used during construction balances capitalized into CWIP and plant in service accounts. If the adjusting entries result in a significant impact to income for the current year, Ameren public utilities may account for the transaction as a correction of a prior period error in Account 439, Adjustments to Retained Earnings. Such an entry should be submitted with the proposed accounting entries.", "source_page": null }, { "number": 31, "text": "Revise account balances for the Ameren public utilities’ utility plant, accumulated depreciation, ADIT, and other account balances impacted by the inappropriate allocation of unsupported overhead costs after receiving DAA’s assessment of the proposed accounting entries submitted per Recommendation No. 30, and restate and footnote the balances reported in the next-filed FERC Form No. 1 reports of the Ameren public utilities for both the current and comparative years presented in each subsidiary’s next- filed report, as necessary to reflect and disclose the revisions.", "source_page": null }, { "number": 32, "text": "Submit a refund analysis, within 30 days of the completion of Recommendation No. 29, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries in 2016 and subsequent years that resulted from the overstatement of transmission plant due to the improperly capitalized labor costs, as determined by the labor time study, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 33, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 34, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 7, "title": "Miscellaneous Accounting Misclassifications", "summary": "AMS misclassified various costs in its books and records. These costs were allocated to the Ameren public utilities where they were also misclassified. This led the Ameren public utilities to overstate their wholesale transmission revenue requirements, and they may have overcharged wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Strengthen policies, procedures, and controls to account for distribution- related expenses, lobbying expenses, membership dues, and prepayments consistent with Commission accounting requirements.", "source_page": null }, { "number": 36, "text": "Strengthen policies, procedures, and controls to ensure that costs are charged to the proper service request.", "source_page": null }, { "number": 37, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 38, "text": "Perform an analysis to identify other distribution-related expenses, lobbying expenses, membership dues, and prepayments that were improperly accounted for during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 39, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper accounting for distribution-related costs, lobbying expenses, membership dues, and prepayments recorded in the wrong accounts as identified pursuant to the analysis performed in response to Recommendation No. 38, plus interest; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 40, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 41, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, if applicable, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 8, "title": "FERC-61 Filings", "summary": "Ameren did not submit the FERC-61, Narrative Description of Service Company Functions, filings for STARS Alliance, LLC (STARS Alliance) during the audit period, and did not timely submit the 2016 and 2017 FERC-61 filings for Fuelco, LLC (Fuelco) as required by Commission regulations.", "is_other_matter": false, "recommendations": [ { "number": 42, "text": "Submit FERC-61 filings to the Commission for STARS Alliance for the audit period.", "source_page": null }, { "number": 43, "text": "Revise policies, procedures, and controls to ensure that all special-purpose companies in the Ameren holding company system file a FERC-61 filing and that all FERC-61 filings are filed timely.", "source_page": null }, { "number": 44, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Reporting of Premature Loss of Records", "summary": "Ameren did not notify the Commission as required when the company discovered certain records were prematurely destroyed or lost. D. List of", "is_other_matter": false, "recommendations": [ { "number": 45, "text": "Revise policies, procedures, and controls to ensure that a filing is made with the Commission when the company has discovered that records have been prematurely destroyed or lost.", "source_page": null }, { "number": 46, "text": "Train relevant staff on the revised policies, procedures, and controls and provide periodic training in this area, as needed.", "source_page": null }, { "number": 47, "text": "Submit a filing to the Commission, within 60 days of issuance of this audit report, for the records that were prematurely destroyed or lost. E. Implementation of Recommendations Audit staff further recommends that Ameren submit the following: • A plan for implementing the recommendations within 30 days after this audit report is issued; • Quarterly reports describing progress in completing each corrective action recommended. Quarterly nonpublic submissions should be made no later than 30 days after the end of each calendar quarter, beginning with the first quarter after this audit report is issued, and continuing each quarter until all recommended corrective actions are completed; and • Copies of written policies and procedures developed in response to the recommendations. These documents should be submitted in the first quarterly filing after the development of a written policy or procedures.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Capitalization vs. expense", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-09-27_macquarie-energy-llc_pa19-5", "company": "Macquarie Energy LLC", "company_raw": "Macquarie Energy LLC (PA19-5)", "docket": "PA19-5", "docket_full": "PA19-5-000", "issued_date": "2021-09-27", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210927-3001&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210927-3001", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 29, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2016 to May 31, 2021", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "552" ], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-09-23_centurion-pipeline-l-p_fa19-4", "company": "Centurion Pipeline L.P.", "company_raw": "Centurion Pipeline L.P. (FA19-4)", "docket": "FA19-4", "docket_full": "FA19-4-000", "issued_date": "2021-09-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210923-3016&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210923-3016", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 54, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2014 to December 31, 2018", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Idled and Retired Assets", "summary": "Centurion’s reporting of idled and retired assets was inconsistent with the Commission’s requirements. Specifically, Centurion did not remove the original cost of idled and retired assets from rate base in its cost of service reported on Page 700, Annual Cost of Service Based Analysis Schedule. Centurion also incorrectly removed retired assets at the book cost (purchase price) rather than original cost from rate base on Page 700. These errors resulted in misstating its cost of service on Page 700 from 2004 to 2018.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen procedures and controls to ensure assets are timely retired from the fixed asset ledger and in accordance with the Commission’s accounting requirements. These procedures and controls should ensure that idled assets with no definite plan for future use and appropriate costs for retired assets are excluded from the cost-of-service calculation prepared for Page 700.", "source_page": null }, { "number": 2, "text": "Make an accounting entry to remove retired assets and the remaining service life of those assets from the fixed asset ledger. Submit the accounting entry to DAA for review within 30 days of issuance of this audit report.", "source_page": null }, { "number": 3, "text": "Perform an analysis to determine the full scale of Page 700 impacts, including impacts to Line 1, Operating and Maintenance Expense; Line 2, Depreciation Expense; Lines 5a-5d, Rate Base; and other Lines on Page 700. Provide this analysis to DAA staff for review within 90 days of issuance of this audit report.", "source_page": null }, { "number": 4, "text": "Upon DAA staff’s review and response to Centurion’s analysis, restate and footnote the comparative year balances reported in the next FERC Form No. 6 filed, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Pipeline Loss Allowance and Gravity Shrinkage", "summary": "Centurion incorrectly accounted for and reported certain activities associated with pipeline loss allowance (PLA) and gravity shrinkage deduction (GSD).  Centurion incorrectly recorded oil losses as an offset to revenue in Account 230, Allowance Oil Revenues, rather than as an operating expense in Account 340, Oil Losses and Shortages. Centurion understated its annual interstate operating expenses on Page 700, Line 1 of its FERC Form No. 6. As a representative example for the audit period, Centurion understated oil losses in Line 1 by $6.1 million in 2018.  Centurion incorrectly omitted PLA and GSD revenues reported in Account 230 on Page 301 of its FERC Form No. 6 as a jurisdictional operating revenue on Page 700, Line 10. This resulted in Centurion understating its annual interstate operating revenues on Line 10. As a representative example for the audit period, Centurion understated Line 10 by $21 million in 2018.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Update accounting policies and procedures to ensure that operating oil losses during transportation are recorded in the appropriate operating expense account consistent with Commission accounting requirements.", "source_page": null }, { "number": 6, "text": "Revise and strengthen financial reporting policies and procedures to ensure that PLA and GSD are appropriately reported as operating expenses on Page 700, Line 1 and interstate operating revenues on Page 700, Line 10.", "source_page": null }, { "number": 7, "text": "Train staff on the revised accounting and reporting policies and procedures, and provide periodic training, as needed.", "source_page": null }, { "number": 8, "text": "Submit journal entries to support the change has been made in the accounting for PLA and GSD to DAA within 30 days of issuance of this audit report. Specifically, the journal entries should reflect that Centurion continues to record oil acquired and/or retained through tariff allowances in Account 230 and has changed its accounting to reflect oil lost or undelivered due to operating causes in Account 340.", "source_page": null }, { "number": 9, "text": "Restate and footnote the comparative year balances reported in the next FERC Form No. 6 filed, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 3, "title": "Sale of Carrier Property", "summary": "Centurion improperly recorded the cash proceeds for sales of carrier property as incidental revenue rather than as a charge to the carrier property accrued depreciation account. Centurion also did not retire the carrier property from its books when sold. This resulted in Centurion overstating carrier property, revenue, and net income in its financial statements and the rate base and depreciation expense components of its cost of service schedule in its FERC Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Establish policies and procedures to ensure that dispositions of carrier property are accounted for in accordance with Commission regulations, including provisions for requesting special accounting treatment when necessary. These procedures should ensure timely retirement of carrier property, and proper accounting for carrier property retired, including the recording of gains and losses in accrued depreciation.", "source_page": null }, { "number": 11, "text": "Record gains and losses from the sale of carrier property in Account 31, Accumulated Depreciation, prospectively. Provide a journal entry for a recent sale of carrier property, in particular the sale of vehicles (if available), to demonstrate that the accounting procedures have changed and are correct.", "source_page": null } ], "themes": [ "Accounting misclassification", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Lobbying, Regulatory Fees and Association Dues", "summary": "Centurion incorrectly recorded the lobbying portion of industry association dues in an operating expense account rather than a nonoperating expense account. This resulted in Centurion overstating operating expenses reported in the cost of service schedule on Page 700, Line 1. Centurion also improperly recorded the annual fees and dues paid to regulatory agencies and an industry trade association as operating and maintenance expenses rather than as general expenses. Collectively, this reduced the accuracy and overall usefulness of the information reported in Centurion’s FERC Form No. 6 filings.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Update accounting policies and procedures to ensure that annual charges, regulatory fees, and industry association dues, including the lobbying portion of dues, are accounted for consistently with Commission requirements.", "source_page": null }, { "number": 13, "text": "Record FERC annual charges in Account 510, Materials and Supplies, and Department of Transportation (DOT) fees and the non-lobbying portion of Association of Oil Pipe Lines (AOPL) dues in Account 590, Other Expenses. Submit journal entries to support the change in accounting treatment to DAA within 30 days of issuance of this audit report.", "source_page": null }, { "number": 14, "text": "Record the lobbying portion of industry association dues in Account 660, Miscellaneous Income Charges. Submit journal entries to support the change in accounting treatment to DAA within 30 days of issuance of this audit report.", "source_page": null } ], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 5, "title": "FERC Form No. 6 Report", "summary": "Centurion did not provide complete and accurate information required on certain supporting schedules of its FERC Form No. 6. This reduced the overall accuracy and usefulness of the information reported in the FERC Form No. 6, during the audit period. D.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Update policies and procedures to ensure that information in the FERC Form No. 6 is accurate and consistent with the instructions of the report. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-09-23_bridger-pipeline-llc_fa19-10", "company": "Bridger Pipeline LLC", "company_raw": "Bridger Pipeline LLC (FA19-10)", "docket": "FA19-10", "docket_full": "FA19-10-000", "issued_date": "2021-09-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210923-3015&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210923-3015", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 88, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2014 to December 31, 2018", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 9, "findings": [ { "index": 1, "title": "Accounting for Idle Property", "summary": "Bridger improperly accounted for idle property as carrier property, rather than noncarrier property, which affected the accuracy of the balances reported in the FERC Form No. 6. This resulted in Bridger incorrectly reporting several line inputs used to derive cost of service on Page 700, which caused Bridger to overstate its total cost of service by between $739,763 to $930,355 during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise accounting policies and procedures to ensure that idled pipeline assets are accounted for as noncarrier property consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 2, "text": "Reclassify all idled pipeline assets recorded in Account 30, Carrier Property, for which a definite plan for future use does not exist, to Account 34, Noncarrier Property; and reclassify the related accrued depreciation from Account 31, Accrued Depreciation – Carrier Property, to Account 35, Accrued Depreciation – Noncarrier Property. Submit accounting entries supporting adjustments within the carrier and noncarrier property accounts to audit staff for review within 30 days of issuance of this audit report. Make the accounting entries supporting this adjustment within 30 days of receiving approval from DAA.", "source_page": null }, { "number": 3, "text": "Perform an analysis to determine the full scale of Page 700 impacts, including impacts to Line 1, Operating and Maintenance Expense; Line 2, Depreciation Expense; Lines 5a-5d, Rate Base; and other lines on Page 700, and provide this analysis to DAA for review within 30 days of receiving DAA’s approval described in Recommendation No. 2.", "source_page": null }, { "number": 4, "text": "Upon receiving DAA’s response to the analysis in Recommendation No. 3, restate and footnote the comparative year balances reported in the next FERC Form No. 6 filed, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Investments in Affiliated Companies", "summary": "Bridger improperly reported certain financial statement activities for its investments in Butte Pipeline Company (Butte) and Sakakawea Area Spill Response, LLC (Sakakawea), and did not establish and maintain memorandum or worksheet entries for these investments. Bridger also improperly reported its investment in Sakakawea as a miscellaneous asset, rather than as an investment in an affiliated company. As a result, Bridger incorrectly reported investment activities in its FERC Form No. 6 filings since the initial investments in these companies.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Revise policies and procedures to ensure that its investments in Butte and Sakakawea are accounted and reported for under the equity method consistent with Instruction for Balance Sheet Accounts 2-2.", "source_page": null }, { "number": 6, "text": "Create memorandum or worksheet entries detailing its investments in Butte and Sakakawea since the investments’ inceptions, as required under Instruction for Balance Sheet Accounts 2-2(c)(2).", "source_page": null }, { "number": 7, "text": "Reclassify its investment in Sakakawea from Account 43, Miscellaneous Other Assets, to Account 20, Investments in Affiliated Companies. Submit accounting entries supporting this reclassification to DAA for review within 30 days of the issuance of this report.", "source_page": null }, { "number": 8, "text": "Restate and footnote the comparative year balances reported in the next FERC Form No. 6 filed, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Nonoperating and Operating Expenses", "summary": "Bridger misclassified costs incurred for fines and penalties, lobbying activities, and charitable contributions as operating expenses rather than nonoperating expenses. While this did not affect net income, it did result in Bridger overstating operating and maintenance expenses in its annual cost-of- service schedule on Page 700 of the FERC Form No. 6. Additionally, Bridger misclassified association dues in an incorrect operating expense account, which did not impact Page 700.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Create procedures and controls to ensure that operating and nonoperating expenses are recorded and reported in accordance with the Commission’s account instructions and requirements.", "source_page": null }, { "number": 10, "text": "Perform an analysis to ensure that fines and penalties, lobbying expenses, charitable contributions, and other costs of this nature are correctly reported in nonoperating expense accounts in the FERC Form No. 6. For consistency restate and footnote the comparative year balances reported in the next FERC Form No. 6 filed, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 4, "title": "Annual Cost of Service Based Analysis Schedule", "summary": "Bridger’s Annual Cost of Service Based Analysis Schedules reported on Page 700 of its FERC Form No. 6 filings contained input errors and inconsistencies with Opinion No. 154-B and other Commission guidance. These input errors and inconsistencies affected the accuracy of most inputs and balances on Page 700, which caused Bridger to overstate its rate base and overall cost of service in each year of the audit period.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise and strengthen policies, procedures, and controls to ensure that Page 700 is prepared correctly, accurately, and consistently with Opinion No. 154-B and the instructions of the FERC Form No. 6.", "source_page": null }, { "number": 12, "text": "Train staff on these errors and provide periodic training, as necessary, to ensure that each line item on Page 700 is calculated and reported correctly in accordance with Commission regulations.", "source_page": null }, { "number": 13, "text": "Obtain records or an appraisal to support the Poplar System’s costs at the time of acquisition to ensure that these assets are reported at the original cost rather than at the purchase price. Provide these records or appraisal for DAA’s review within 60 days of the issuance of this report.", "source_page": null }, { "number": 14, "text": "Perform an analysis to determine the impact resulting from the errors identified to rate base and total cost of service on Page 700 for the current year and provide this analysis to DAA within 90 days of this report.", "source_page": null }, { "number": 15, "text": "Upon receiving DAA’s response, restate and footnote the comparative year balances reported in the next FERC Form No. 6 filed, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 5, "title": "Pipeline Loss Allowance and Gravity Shrinkage Deduction Revenues", "summary": "Bridger incorrectly accounted for and reported on certain activities associated with its pipeline loss allowance (PLA) and gravity shrinkage deduction (GSD). Specifically:  Bridger incorrectly recorded oil losses as an offset to revenue in Account 230, Allowance Oil Revenues, rather than as an operating expense in Account 340, Oil Losses and Shortages. This resulted in Bridger understating its annual interstate operating expenses on Page 700, Line 1 of its FERC Form No. 6. Bridger also did not track the costs or keep records to identify the amount of oil lost in transportation that should have been recorded in Account 340.  Bridger incorrectly omitted PLA and GSD revenues reported in Account 230 on Page 301 of its FERC Form No. 6, when it reported jurisdictional operating revenue on Page 700, Line 10. This resulted in Bridger understating its annual interstate operating revenues on Line 10. The annual interstate portion of the allowance oil revenues during the audit period ranged from $2.8 million to $25 million.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Update accounting policies and procedures to ensure that operating oil losses are recorded in the appropriate operating expense account consistent with Commission accounting requirements. This should include policies and procedures to ensure Bridger maintains records to separately report the costs associated with oil lost through transportation in Account 340 consistent with the Commission’s accounting instructions.", "source_page": null }, { "number": 17, "text": "Revise and strengthen financial reporting policies and procedures to ensure that PLA and GSD are appropriately reported as operating expenses on Page 700, Line 1 and interstate operating revenues on Page 700, Line 10.", "source_page": null }, { "number": 18, "text": "Train staff on the revised accounting and reporting policies and procedures, and provide periodic training, as needed.", "source_page": null }, { "number": 19, "text": "Submit journal entries to demonstrate that the change has been made in the accounting for PLA and GSD to DAA within 30 days of issuance of this audit report. Specifically, the journal entries should reflect that Bridger continues to record oil acquired and/or retained through tariff allowances in Account 230 and has changed its accounting to reflect oil lost or undelivered due to operating causes in Account 340.", "source_page": null }, { "number": 20, "text": "Restate and footnote the comparative year balances reported in the next FERC Form No. 6 filed, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Capital Structure Used for Rate of Return and Deferred Earnings", "summary": "Bridger’s use of a capital structure comprised of 100 percent equity to derive its weighted cost of capital was inconsistent with Commission policy. This capital structure was atypical, and Bridger should have used a hypothetical capital structure. Bridger’s all equity capital structure resulted in it inflating the weighted cost of capital used to derive the return on rate base on Page 700. Bridger also used an outdated capital structure to derive the amortization of deferred earnings causing Bridger to inaccurately present this information on Page 700.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Revise policies and procedures to ensure that the capital structure used on Page 700 is derived in accordance with Opinion No. 502 and other Commission precedent. Also, strengthen controls to ensure that the same capital structure is applied consistently to each input on Page 700.", "source_page": null }, { "number": 22, "text": "Develop and use an appropriate hypothetical capital structure for preparing Page 700 consistent with Commission policy if its debt to equity ratio remains atypical.", "source_page": null }, { "number": 23, "text": "Restate and footnote the comparative year balances reported on Page 700 in the next FERC Form No. 6 filed to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 7, "title": "Filing of Depreciation Study and Method", "summary": "Bridger did not maintain records to support that a depreciation study had been performed for the depreciation rates it adopted through an acquisition in 2003. Bridger also used the component method, rather than the composite method, of depreciation without receiving approval from the Commission to use the component method. Bridger’s lack of a depreciation study and use of the component method prevented audit staff from verifying whether Bridger used appropriate depreciation rates and reported rate base and depreciation expense correctly on Page 700.", "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Create policies and procedures to ensure that Bridger applies Commission- approved rates to depreciate all carrier property assets.", "source_page": null }, { "number": 25, "text": "Conduct a depreciation study that reflects current economic conditions and other factors, including net salvage and interim retirements. Based on this study, determine whether to continue using Bridger’s current depreciation rates to calculate depreciation expense pursuant to Part 347, or file a request to change depreciation rates pursuant to General Instruction 1-8.", "source_page": null }, { "number": 26, "text": "Submit a copy of this depreciation study to the Commission within 30 days of completion. Bridger should use the composite method of depreciation as required by General Instruction 1-8. Bridger should also make appropriate changes to its existing depreciation rates when proposed rates are approved or modified by the Commission.", "source_page": null }, { "number": 27, "text": "Perform an evaluation of Account 31, Accumulated Depreciation – Carrier Property, to determine the impacts to this account from applying the composite method of depreciation rather than component method since", "source_page": null }, { "number": 2003, "text": "Submit this evaluation and any proposed adjusting entries to DAA within 90 days of the issuance of this audit report.", "source_page": null }, { "number": 28, "text": "File for approval of accounting entries to make a prior period adjustment if deemed material in accordance with 18 C.F.R. Part 352, General Instruction 1-6. Upon approval of analysis and proposed adjustments from DAA, make accounting entries supporting this adjustment within 30 days.", "source_page": null }, { "number": 29, "text": "Provide worksheet(s) showing the effect and adjustment made to each component on Page 700 of the FERC Form No. 6.", "source_page": null }, { "number": 30, "text": "Upon receiving DAA staff’s response, restate and footnote the balances reported in the FERC Form No. 6 in the comparative years of the report, including all schedules affected, to reflect and disclose the revisions.", "source_page": null } ], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 8, "title": "Filing of Journal Entries for Carrier Property Acquisitions", "summary": "Bridger did not file journal entries for consideration and approval for two operating systems it acquired in 2003 and 2017 both with a purchase price that exceeded $250,000. Bridger should have received Commission approval to ensure it applied appropriate accounting for these acquisitions.", "is_other_matter": false, "recommendations": [ { "number": 31, "text": "Create policies and procedures to ensure that acquisitions of properties comprising a distinct operating system, or an integral portion thereof, are accounted for in accordance with Commission accounting instructions, including submitting tentative journal entries to the Commission for approval when the purchase price exceeds $250,000.", "source_page": null }, { "number": 32, "text": "Prospectively, file accounting entries with the Commission to seek approval for the property acquired that constitutes a distinct operating system, or an integral portion thereof, when the purchase price exceeds $250,000.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 9, "title": "FERC Form No. 6 Reporting", "summary": "Bridger did not report complete information as required in certain supporting schedules of its FERC Form No. 6 reports, during the audit period. Bridger also did not accurately account for certain activities in accordance with the Commission’s accounting instructions. While Bridger’s incomplete reporting and inaccurate accounting did not impact Page 700; it did reduce the overall accuracy and usefulness of the information reported in Bridger’s FERC Form No. 6 filings. D.", "is_other_matter": false, "recommendations": [ { "number": 33, "text": "Revise policies and procedures to ensure complete and accurate information is reported in the FERC Form No. 6 in accordance with the instructions of the report and the Commission’s accounting instructions.", "source_page": null }, { "number": 34, "text": "Review the reporting deficiencies with relevant staff to ensure they include on a prospective basis all required information in Bridger’s FERC Form No. 6 filings.", "source_page": null }, { "number": 35, "text": "Prospectively, file an accounting request with the Commission to seek approval to use Account 710, Other Credits to Retained Income, as required by the instructions for this account. F.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 10, "title": "Method to Derive Return on Equity", "summary": "Bridger derived its return on equity (ROE) using a combination of the Discounted Cash Flow (DCF) Model, Capital Asset Pricing Model (CAPM), and Risk Premium Model for Page 700, during the audit period. This did not fully align with the Commission’s previous and current policy statements on determining ROE for oil pipelines. Bridger’s ROE derivation is an important part of ensuring cost- of-service information is not misleading and enables shippers and other interested parties to make informed decisions related to Page 700. Prospectively, Bridger should consider developing its ROE for Page 700 using a method consistent with Commission policy. E.", "is_other_matter": true, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-09-16_versant-power_fa20-9", "company": "Versant Power", "company_raw": "Versant Power (FA20-9)", "docket": "FA20-9", "docket_full": "FA20-9-000", "issued_date": "2021-09-16", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210916-3010&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210916-3010", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 48, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2018 through April 30, 2021", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Allocation of Overhead Costs to CWIP", "summary": "Versant Power capitalized overhead costs to Account 107, Construction Work in Progress (CWIP) – Electric, using an allocation method that was not based on the actual time that employees were engaged in construction activities or on a representative time study. This led to Versant Power charging costs to Account 107 that did not have a definite relationship to construction. As a result, Versant Power may have overstated construction costs recorded in Account 107 and electric plant in service, as well as accumulated depreciation and accumulated deferred income tax, and may have understated operating expenses. Moreover, this accounting may have led Versant Power to overstate its wholesale transmission revenue requirement and overbill wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Retain an independent third-party entity to conduct a representative labor time study for allocation of overhead costs incurred in 2020 to CWIP, and to assist with the development of procedures Versant Power shall use to periodically determine the allocation of overhead labor and labor-related costs capitalized into the cost of construction after 2020. Report the progress of the study within 120 days and provide the time study results to DAA for review and consideration within 180 days of the date of this audit report, and the developed allocation procedures when complete. At a minimum, the developed allocation procedures should provide a method for overhead cost allocation and capitalization to construction based on actual timecard distributions or, where this procedure is impractical, based on periodic time studies.", "source_page": null }, { "number": 2, "text": "Revise written policies, practices, and procedures governing the methods used to account for, track, report, and review overhead labor, labor-related costs, and all other costs allocated to construction projects to be consistent with Commission accounting requirements. In addition, adopt procedures to retain formal documentation supporting the amount of overhead costs allocated to electric plant accounts.", "source_page": null }, { "number": 3, "text": "Provide training to relevant staff on the revised overhead allocation policies, practices, procedures, and documentation. Provide periodic training in this area, as needed.", "source_page": null }, { "number": 4, "text": "Within 30 days of the completion of Recommendation No. 1, submit an estimate to DAA, including the calculations and determinative components, of overhead costs that would have been allocated to CWIP from 2014 and subsequent years consistent with the requirements of Electric Plant Instruction (EPI) No. 4 and General Instruction (GI) No. 9. The estimate should be based on a recalculation of 2014 and subsequent years overhead cost allocated to construction with labor and labor-related costs removed from the cost of plant that were not associated with construction activities based on the methodology developed in response to Recommendation No. 1.", "source_page": null }, { "number": 5, "text": "With the response to Recommendation No. 4, submit proposed accounting entries to DAA that remove the overhead costs that were allocated to electric plant in CWIP and in service during the audit period. The amount of overhead costs removed should be the excess amount of such costs that was allocated to the accounts based on the methodology developed in response to Recommendation No. 1. Also, provide proposed accounting entries to remove associated amounts from other accounts and balances affected by the inappropriately allocated cost such as the accumulated depreciation and ADIT accounts, and AFUDC balances capitalized into CWIP and plant in service. If the adjusting entries result in a significant impact to income for the current year, Versant Power may account for the transaction as a correction of a prior period error in Account 439, Adjustments to Retained Earnings. Such an entry should be submitted with the proposed accounting entries.", "source_page": null }, { "number": 6, "text": "Revise account balances for utility plant, accumulated depreciation, ADIT, and other account balances impacted by the inappropriate allocation of unsupported overhead cost after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 5, and restate and footnote the balances reported in the FERC Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions.", "source_page": null }, { "number": 7, "text": "Submit a refund analysis to DAA that explains and details the following: (1) calculation of refunds that result from correction of the overstatement of electric plant in service due to the improper capitalization of labor costs, as determined by the labor time study, since January 1, 2014, plus interest computed in accordance with section 35.19a of the Commission’s regulations; (2) determinative components of the refund; (3) refund method; (4) wholesale transmission customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 8, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis", "source_page": null }, { "number": 9, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations. Allowance for Funds Used During Construction", "source_page": null }, { "number": 10, "text": "Revise and implement procedures to calculate the AFUDC rate consistent with, EPI No. 3(A)(17), and other applicable Commission requirements.", "source_page": null }, { "number": 11, "text": "Provide training to relevant staff on the revised procedures implemented under Recommendation No 10. Provide periodic training in these areas as needed.", "source_page": null }, { "number": 12, "text": "Recalculate accrued AFUDC, in a manner consistent with EPI No. 3(A)(17) that corrects for the improper inclusion of Account 216.1 from 2014 through the date of the audit report.", "source_page": null }, { "number": 13, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over accrual of AFUDC within 60 days of the date of the audit report.", "source_page": null }, { "number": 14, "text": "Revise CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over accrual of AFUDC after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 13 and restate and footnote the FERC Form No. 1 for current and comparative years as necessary", "source_page": null }, { "number": 15, "text": "Submit a refund analysis, within 60 days of the date of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of excess AFUDC and impacts on related accounts included in the transmission formula rates, since January 1, 2014, plus interest computed in accordance with section 35.19a of the Commission’s regulations; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 16, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 17, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 2, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "Versant Power improperly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, in the equity component when it computed its AFUDC rate. As a result, Versant Power over accrued AFUDC included in utility plant accounts, and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 3, "title": "Income Tax Receivables", "summary": "Versant Power improperly recorded income tax receivables that represented refunds for income tax overpayments in Account 165, Prepayments, instead of in Account 143, Other Accounts Receivable. As a result, Versant Power overstated its transmission rate base used in its wholesale transmission formula rate calculation, and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Revise accounting policies and procedures to properly account for income tax refund receivables consistent with the Commission accounting requirements.", "source_page": null }, { "number": 19, "text": "Provide training to relevant staff on the revised procedures for properly accounting for income tax refund receivables. Provide periodic training in these areas as needed.", "source_page": null }, { "number": 20, "text": "Submit a refund analysis to DAA, within 60 days of the date of this audit report, that explains and details the following: (1) calculation of refunds that results from eliminating income tax refund receivables from its transmission rate base during the audit period, including interest computed in accordance with section 35.19a of the Commission’s regulations; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 21, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 22, "text": "Refund amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19(a) of the Commission’s regulations. Transmission Revenue Credit", "source_page": null }, { "number": 23, "text": "Revise policies and procedures to properly populate transmission revenue credit inputs into the wholesale transmission formula rates consistent with the wholesale transmission formula rate in each open access transmission tariff (OATT).", "source_page": null }, { "number": 24, "text": "Provide training to relevant staff on the revised procedures for properly populating transmission revenue credit inputs into the wholesale transmission formula in each OATT. Provide periodic training in these areas as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Transmission Revenue Credits", "summary": "Versant Power included an incorrect amount for transmission rental revenues in its wholesale transmission formula rate for the BHD. As a result, Versant Power overstated the revenue credits included in its wholesale transmission formula rate calculations for the BHD, which led to understatement of its wholesale transmission revenue requirements and billings to its wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Excess Accumulated Deferred Income Tax", "summary": "Versant Power improperly netted the excess and deficient Accumulated Deferred Income Tax (ADIT) related to the 2017 Tax Cuts and Jobs Act (TCJA) and recorded the amount that resulted from this improper netting in Account 254, Other Regulatory Liabilities. This action affected the transparency and accuracy of the amounts reported in Versant Power’s FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [ { "number": 25, "text": "Revise accounting policies and procedures to properly record and report the effect of changes in tax laws or tax rates consistent with the Commission’s accounting guidance in Docket No. AI93-5.3", "source_page": null }, { "number": 26, "text": "Provide training to relevant staff on the revised policies and procedures for recording and reporting the effect of changes in tax laws or tax rates. Provide periodic training in these areas as needed. Form No. 1 Reporting", "source_page": null }, { "number": 27, "text": "Revise and strengthen policies, procedures, and practices to report correct, accurate, complete information in the FERC Form No. 1 consistent with the page instructions.", "source_page": null }, { "number": 28, "text": "Provide training to relevant staff on the revised FERC Form No. 1 policies, procedures, and practices. Provide periodic training in these areas as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "FERC Form No. 1 Reporting", "summary": "Versant Power did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. These actions affected the transparency, accuracy, and usefulness of the reports. D.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Capitalization vs. expense", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "IN", "source": "Indiana Utility Regulatory Commission", "doc_type": "fuel cost adjustment order", "id": "2021-08-25_aes-indiana_in-38703-fac132", "company": "Indianapolis Power & Light Company d/b/a AES Indiana", "company_raw": "Indianapolis Power & Light Company d/b/a AES Indiana", "docket": "38703 FAC 132", "docket_full": null, "issued_date": "2021-08-25", "source_page_url": "https://iurc.portal.in.gov/searchlegalcase/", "pdf_download_url": "https://www.in.gov/iurc/files/ord_38703-FAC132_082521.pdf", "captured_at": "2026-06-02", "source_note": "Order of the Indiana Utility Regulatory Commission on the application of Indianapolis Power & Light Company d/b/a AES Indiana for approval of a fuel cost factor for the September–November 2021 billing months under I.C. 8-1-2-42, IURC Cause No. 38703 FAC 132, issued August 25, 2021. Listed for reference (metadata-only). PDF at www.in.gov/iurc/files/; case search iurc.portal.in.gov.", "archived_via": null, "page_count": 12, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Approval: $548,548 ", "summary": "y for the purchased power costs that exceeded the Benchmark and the OUCC agreed Applicant should be allowed to recover $548,548 in purchased power costs that exceeded the Benchmark. Accordingly, the Commission finds Applicant’s request for recovery of its purchased power over t", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-07-20_mustang-pipe-line-llc_fa20-4", "company": "Mustang Pipe Line LLC", "company_raw": "Mustang Pipe Line LLC (FA20-4)", "docket": "FA20-4", "docket_full": "FA20-4-000", "issued_date": "2021-07-20", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210720-3012&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210720-3012", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 57, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2014 to December 31, 2018", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Depreciation Rates and Expense", "summary": "Mustang did not use Commission- approved depreciation rates to calculate depreciation expense for certain carrier property assets. Additionally, Mustang’s depreciation expense accrual started on the date that Mustang transferred project costs from its Construction Work in Progress (CWIP) account to its carrier property accounts rather than on the date it placed projects into service. These errors caused Mustang to overstate rate base and understate depreciation expense in its cost of service reported on Page 700 during and prior to the audit period.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen procedures and controls to ensure that it uses Commission- approved depreciation rates for all carrier property assets (or accounts) and that depreciation begins on the date assets are placed in service.", "source_page": null }, { "number": 2, "text": "Update policies and procedures to ensure depreciation studies are filed with the Commission in a timely manner consistent with 18 C.F.R. Part 347 and Part 352, General Instruction 1-8 of the Commission’s regulations.", "source_page": null }, { "number": 3, "text": "File a new depreciation study to request depreciation rate approval for Account 165, Vehicles and other work equipment, as it relates to the assets acquired in 2018.", "source_page": null }, { "number": 4, "text": "Submit accounting entries for necessary adjustments within the accrued depreciation accounts to DAA for review within 30 days of issuance of this audit report. This should reflect the use of the corrected depreciation rates and calculation of depreciation expense based on the in-service date rather than the date project costs are posted to its carrier property accounts . Upon approval from DAA, make the needed accounting entries supporting these adjustments within 30 days.", "source_page": null }, { "number": 5, "text": "Upon receiving DAA staff’s review and response, restate and footnote the comparative year balances reported in the 2020 FERC Form No. 6 to reflect and disclose the revisions, which should include all schedules affected.", "source_page": null } ], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Return on Equity and Capital Structure", "summary": "Mustang used the ROE rate developed by its indirect parent, Mobil, and Plantation, an affiliate, and relied on the capital structure of one of its ultimate parent companies, ExxonMobil, to determine the weighted cost of capital on Page 700. The percentages Mustang used for its ROE and capital structure were unsupported and there was no analysis to support certain inputs of its weighted cost of capital determination. Mustang should have supported its ROE figures with analysis based on a proxy group consisting of pipelines with comparable risks used in a discounted cash flow or similar analysis to support the ROE and capital structure percentages. As a result, audit staff could not validate the accuracy of the ROE and capital structure Mustang used to determine its overall cost of service reported on Page 700 during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Update its internal FERC Form No. 6 Page 700 reporting policies and procedures to ensure that all items reported on Page 700 are sufficiently documented and supported in accordance with the Commission’s regulations.", "source_page": null }, { "number": 7, "text": "Train staff on the updated policies and procedures referred to in the preceding recommendation to Mustang’s staff responsible for preparing Page 700 of the FERC Form No. 6.", "source_page": null }, { "number": 8, "text": "Perform an analysis consistent with the Commission’s Proxy Group Policy Statement (Docket No. PL07-2-000) and ROE Policy Statement (Docket No. PL19-4-000) to develop an appropriate proxy group and either continue use of a 12 percent ROE in preparing Mustang’s Page 700 if supported by such analysis or adjust the ROE to one that is supported by the analysis. Further perform an analysis consistent with Commission Opinion Nos. 7, 268, and 502 to determine whether the 90 percent-equity capital structure used during the audit period was appropriate or whether a different, hypothetical capital structure should be used. Provide a copy of the analysis as evidence of Mustang’s supporting work papers for its Page 700 reporting.", "source_page": null }, { "number": 9, "text": "Determine the impacts to Page 700 based on the analyses performed in response to Recommendation No. 8, including to Line 6, Rate of Return, and to any other applicable lines on Page 700 for 2019 and 2020. Provide these impacts and the analyses described in Recommendation No. 8 to DAA within 90 days of this report.", "source_page": null }, { "number": 10, "text": "After receiving DAA’s approval, incorporate any changes prospectively into the 2020 FERC Form No. 6 and apply them to comparative years. Include footnotes to disclose the revisions made to the capital structure and ROE and the impact on cost of service.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 3, "title": "Cost of Service Based Analysis Schedule", "summary": "Mustang incorrectly calculated certain inputs for its Annual Cost of Service Based Analysis Schedule reported on Page 700. These errors included several inconsistencies in Mustang’s Allowance for Funds Used During Construction (AFUDC) calculation during the audit period. Mustang also included an income tax allowance in its cost of service but did not reduce its rate base by Accumulated Deferred Income Tax (ADIT) in 2014. Collectively, these errors reduced the accuracy, transparency, and usefulness of Page 700.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise and strengthen policies and procedures to ensure that Page 700 is prepared and reported in a manner consistent with Opinion No. 154-B and the instructions of the FERC Form No. 6. These instructions include developing procedures to calculate AFUDC on monthly expenditures and the length of construction periods; maintaining records of the monthly construction expenditures; and excluding ineligible costs.", "source_page": null }, { "number": 12, "text": "Train staff on the revised Page 700 preparation and reporting policies and procedures and provide periodic training, as needed.", "source_page": null }, { "number": 13, "text": "File a FERC Form No. 6 for 2020 that reflects the AFUDC procedural changes described in Recommendation No. 11, restates the Page 700 balances reported in the comparative years of the report, and include footnotes necessary to explain the revisions.", "source_page": null } ], "themes": [ "AFUDC / cost of capital", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "FERC Form No. 6 Reporting", "summary": "Mustang did not report complete and accurate information on certain supporting schedules of the FERC Form No. 6. These errors affected the accuracy of barrel-miles in the Annual Cost of Service Based Analysis Schedule reported on Page 700, and reduced the overall usefulness and transparency of the FERC Form No. 6, during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Strengthen policies and procedures to ensure complete and accurate information is reported in the FERC Form No. 6 in accordance with the Commission’s reporting requirements and instructions.", "source_page": null }, { "number": 15, "text": "Train staff on the revised filing policies and procedures, and provide periodic reminders as necessary.", "source_page": null }, { "number": 16, "text": "Review the reporting deficiencies described in this Finding with relevant Mustang staff to ensure that the deficiencies are corrected and that Mustang includes accurate and complete information in the FERC Form No. 6 on a prospective basis free of the noted deficiencies.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 5, "title": "Cash Management Agreement Filings", "summary": "Mustang did not file its initial and amended cash management agreements with the Commission, which impaired the Commission’s knowledge of Mustang’s cash management program and limited the Commission’s ability to monitor the program. D.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Revise policies, procedures, and controls to ensure that cash management agreements involving Mustang and any amendments thereto are timely filed with the Commission, as required by 18 C.F.R. § 357.5.", "source_page": null }, { "number": 18, "text": "Train staff on the revised filing policies and procedures and provide periodic reminders as necessary.", "source_page": null }, { "number": 19, "text": "File the currently effective agreement or agreements relating to any cash management program in which Mustang participates with the Commission within 30 days of issuance of this audit report, and notify DAA upon such filing. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Affiliate / intercompany transactions", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-06-28_southern-california-edison-company_fa20-1", "company": "Southern California Edison Company", "company_raw": "Southern California Edison Company (FA20-1)", "docket": "FA20-1", "docket_full": "FA20-1-000", "issued_date": "2021-06-28", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210628-3011&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210628-3011", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 57, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2017 through March 31, 2021", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Accounting for Compromise Settlements", "summary": "SCE improperly recorded approximately $7.3 million of compromise settlement payments related, at least in part, to alleged employment discrimination in Account 925, Injuries and Damages. As a result of the improper accounting for compromise settlements, SCE overstated its annual transmission revenue requirement and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen and revise accounting processes and procedures to ensure that SCE properly records compromise settlement payments related to employment discrimination claims in Account 426.5 as consistent with Accounting Release No. 12.", "source_page": null }, { "number": 2, "text": "Provide training to staff on the revised accounting for compromise settlement payments resulting from employment discrimination claims in Account 426.5 for regulatory accounting and annual transmission revenue requirement development. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to SCE’s wholesale transmission customers since January 1, 2017, plus interest, relating to the inclusion of compromise settlement payments resulting from employment discrimination claims; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 4, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 5, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Vendor Discounts", "summary": "SCE improperly recorded approximately $39.9 million of vendor discounts for early payment of various invoices in Account 930.2, Miscellaneous General Expenses. As a result of the improper accounting for vendor discounts, SCE understated Administrative and General (A&G) expense and overstated various Operating and Maintenance as well as Electric Plant in Service accounts.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Revise policies and procedures to properly account for vendor discounts consistent Document Accession #: 20210628-3011 Filed D ate: 06/28/2021 PDF/A non-compatible with Commission accounting requirements.", "source_page": null }, { "number": 7, "text": "Provide training to staff on the revised procedures for accounting for vendor discounts. Also, develop a training program that supports periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Property & plant records" ], "cost_to_customers": false }, { "index": 3, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "SCE’s method for computing and applying its AFUDC rate to construction projects was deficient. Specifically, SCE improperly excluded short-term debt related to energy procurement margin and collateral postings, and improperly excluded $100 million of long-term debt related to nuclear fuel procurement from its AFUDC rate calculation. In addition, SCE improperly accrued $182,586 of AFUDC on a suspended construction project during the audit period. As a result, SCE overaccrued AFUDC included in utility plant accounts and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Fuel & purchased-power cost recovery" ], "cost_to_customers": true }, { "index": 4, "title": "Allowance for Funds Used During Construction", "summary": "Equity Component – The equity component of SCE’s method for computing the AFUDC rate was deficient. Specifically, SCE improperly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, and Account 219, Accumulated Other Comprehensive Income, in determining the equity component used to compute its AFUDC rate.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise and implement procedures to calculate the AFUDC rate consistent with Order Nos. 561 and 561-A, Electric Plant Instruction No. 3(A)(17), and other applicable Commission requirements.", "source_page": null }, { "number": 9, "text": "Revise procedures to timely cease AFUDC accrual on all suspended or cancelled construction projects, consistent with Commission accounting requirements.", "source_page": null }, { "number": 10, "text": "Provide training to relevant staff on the revised procedures implemented under Recommendation Nos. 8 and 9. Provide periodic training in these areas as needed.", "source_page": null }, { "number": 11, "text": "Recalculate accrued AFUDC in a manner consistent with Electric Plant Instruction No. 3(A)(17) that corrects the improper exclusion of short-term debt beginning in 2010 to the present and long-term debt amounts only for 2019.", "source_page": null }, { "number": 12, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over-accrual of AFUDC within 60 days of issuance of the audit report.", "source_page": null }, { "number": 13, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of excess AFUDC included in the transmission formula rate billing charges since 2017, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 14, "text": "Revise CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over-accrual of AFUDC after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 12, and restate and footnote the FERC Form No. 1 for current and comparative years as necessary.", "source_page": null }, { "number": 15, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis. Document Accession #: 20210628-3011 Filed D ate: 06/28/2021 PDF/A non-compatible", "source_page": null }, { "number": 16, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null }, { "number": 17, "text": "Revise and implement procedures to calculate the AFUDC rate consistent with Order Nos. 561 and 561-A, Electric Plant Instruction 3(A)(17), and other applicable Commission requirements.", "source_page": null }, { "number": 18, "text": "Provide training to relevant staff on the revised procedures implemented under Recommendation 17. Provide periodic training in these areas as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting for Administrative and General Expenses", "summary": "SCE improperly recorded various A&G expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting, SCE misrepresented A&G expense account balances reported in its FERC Form No. 1 filings. Document Accession #: 20210628-3011 Filed D ate: 06/28/2021 PDF/A non-compatible", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Revise policies and procedures to properly account for A&G expenditures consistent with Commission accounting requirements.", "source_page": null }, { "number": 20, "text": "Provide training to relevant staff on the revised procedures for properly accounting for A&G expenditures. Also, develop a training program for periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "FERC Form No. 1 Reporting", "summary": "SCE did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. These actions affected the transparency, accuracy, and usefulness of the reports. D.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Revise and strengthen policies, procedures, and practices to report correct, accurate, and complete information in the FERC Form No. 1, consistent with the page instructions.", "source_page": null }, { "number": 22, "text": "Provide training to relevant staff on the revised FERC Form No. 1 policies, procedures, and practices. Also, develop a training program that supports periodic training in this area, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)", "Fuel & purchased-power cost recovery", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2021-05-06_peoples-natural-gas_pa-mo-audit", "company": "Peoples Natural Gas Co. LLC and Peoples Gas Co. LLC", "company_raw": "Peoples Natural Gas Co. LLC and Peoples Gas Co. LLC", "docket": "D-2020-3018773", "docket_full": null, "issued_date": "2021-05-06", "source_page_url": "https://www.puc.pa.gov/press-release/2021/puc-issues-aquapeoples-gas-audit-report-implementation-plan", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1702687.pdf", "captured_at": "2026-06-08", "source_note": "Management & Operations Audit of Aqua Pennsylvania, Peoples Natural Gas Co. LLC and Peoples Gas Co. LLC (joint), PA PUC Bureau of Audits; PUC publication 2021-05-06, Dockets D-2020-3018771/3018773/3018774; 47 recommendations (combined). Seeded for the Peoples gas companies (industry=gas); Aqua is water and out of scope but the audit is published as one report. Findings parsed verbatim from the Exhibit I-2 Summary of Recommendations. PDF: puc.pa.gov/pcdocs/1702687.pdf.", "archived_via": null, "page_count": 195, "scanned_pages": [ 1, 195 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 13, "findings": [ { "index": 1, "title": "Executive Management and Organizational Structure", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Periodically review spans of control for management positions, document justification for supervisory position ratios with narrow or wide spans of control and adjust reporting relationships as appropriate.", "source_page": 32 }, { "number": 2, "text": "Establish a single repository for all policies and procedures across the Essential Utilities organization and establish a coordinated procedures review process.", "source_page": 32 }, { "number": 3, "text": "Reduce or eliminate manual processes within the payroll function.", "source_page": 32 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 2, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Periodically seek competitive bids for external audit services.", "source_page": 40 }, { "number": 5, "text": "Organize the Internal Audit function to report administratively to the CEO, another non-financial senior officer, or directly to the Board of Directors", "source_page": 40 }, { "number": 6, "text": "Establish a foundational understanding of internal audit needs as a result of the Peoples Companies’ acquisition, then resource and staff accordingly.", "source_page": 40 }, { "number": 7, "text": "Conduct a review of completed internal audits to ensure previous recommendations are being properly implemented at the Peoples Companies.", "source_page": 40 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 3, "title": "Affiliated Interests and Cost Allocations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Improve internal controls and other practices related to affiliate transactions and cost allocation to ensure the company is following best practices and Commission guidelines. Further, the Peoples Companies should consult with the PUC’s Bureau of Technical Utility Services to perform a thorough review of the current AIAs on file to determine if changes to the AIAs are needed and/or if new AIAs need to be filed to ensure compliance with Title 66 Chapter 21.", "source_page": 63 }, { "number": 9, "text": "Document all lease agreements between Aqua PA and its affiliates and submit them to the Commission for approval.", "source_page": 63 }, { "number": 10, "text": "Implement a policy or procedure that requires the approval of Peoples Companies employees’ timesheets similar to what exists for Aqua Services employees.", "source_page": 64 }, { "number": 11, "text": "Expand Essential’s corporate charges allocation manual to include all transactions between affiliates.", "source_page": 64 } ], "themes": [ "Affiliate / intercompany transactions", "Internal audit & internal controls" ], "cost_to_customers": true }, { "index": 4, "title": "Affiliated Interests and Cost Allocations (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Conduct periodic market studies to confirm that goods and services provided by affiliates to the utilities are at the lower of cost or market, and goods and services provided by the utilities to affiliates are at the higher of cost or market.", "source_page": 64 } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 5, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Perform a cost/benefit analysis to determine the feasibility of implementing an Essential Utilities money pool.", "source_page": 82 }, { "number": 14, "text": "Reduce or eliminate manual processes within the accounts payable function at Aqua PA.", "source_page": 82 }, { "number": 15, "text": "Develop and implement capital and operations and maintenance (O&M) budget manuals/policies that include requirements for detailed written explanations of budget variances in excess of 10% for the Peoples Companies.", "source_page": 82 }, { "number": 16, "text": "Develop and implement new accounting/finance policies and procedures at the Peoples Companies where appropriate and ensure the policies have all the key elements, including accountability and a regular review schedule to remain timely.", "source_page": 82 }, { "number": 17, "text": "Update Aqua PA’s dividend policy.", "source_page": 82 } ], "themes": [ "Dividend policy & capital management" ], "cost_to_customers": false }, { "index": 6, "title": "Water Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Implement a full-scale valve inspection and exercise program designed to identify what valves have not been operated or inspected in the last ten years.", "source_page": 94 }, { "number": 19, "text": "Update all drought contingency plans annually.", "source_page": 94 }, { "number": 20, "text": "Implement measures to reduce company-at-fault hits.", "source_page": 94 }, { "number": 21, "text": "Increase testing and replacement of meters to improve accuracy rates.", "source_page": 94 }, { "number": 22, "text": "Focus efforts on reducing NRW at the Roaring Creek system.", "source_page": 94 } ], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Gas Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Expedite bare steel replacement efforts in the companies’ distribution systems, and conduct ongoing staffing analyses to support any decision- making to fully staff, train, and monitor the workforce needs for all of the engineering, construction, and field operations positions and support positions needed to maintain future accelerated main replacement rates.", "source_page": 108 }, { "number": 24, "text": "Effectively modify, track, and enforce the damage prevention program and initiate preventative solutions to minimize second- and third-party damages in significant construction areas.", "source_page": 108 } ], "themes": [ "Gas safety & pipeline integrity" ], "cost_to_customers": false }, { "index": 8, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 25, "text": "Establish a standard frequency for AED inspections across Aqua PA and require inspections to be tracked for all AEDs.", "source_page": 116 }, { "number": 26, "text": "Establish a unified Emergency Response Plan for Aqua PA and ensure that localized conditions are captured for individual facilities.", "source_page": 116 }, { "number": 27, "text": "Establish a unified control room security standard for Aqua PA, and upgrade existing facilities to adhere to it.", "source_page": 116 }, { "number": 28, "text": "Establish a tiered physical security standard for Aqua PA based on criticality of company facilities.", "source_page": 116 }, { "number": 29, "text": "Correct minor deficiencies in physical security and safety at Aqua PA.", "source_page": 116 }, { "number": 30, "text": "Designate responsible parties, review existing security protocols and measures, and address deficiencies with the physical security needs of IT components at Aqua PA and Essential Utilities.", "source_page": 116 }, { "number": 31, "text": "Perform a physical security drill and/or tabletop exercise annually at Aqua PA.", "source_page": 116 }, { "number": 32, "text": "Supply rescue hooks at all locations with open topped aerated basins and tanks deep enough to submerge employees at Aqua PA.", "source_page": 116 } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "index": 9, "title": "Materials Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 33, "text": "Fully develop and standardize all policies and procedures at Aqua PA.", "source_page": 125 }, { "number": 34, "text": "Incorporate inventory accuracy into key performance indicators at the Peoples Companies and improve accuracy in all storerooms.", "source_page": 125 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 10, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Continue outreach efforts to engage payment troubled customers, leverage low-income resources, grants, and programs to mitigate the overall level of unpaid customer balances, and accelerate first contact with customers who miss a payment.", "source_page": 146 }, { "number": 36, "text": "Develop periodic refresher training, including documentation of instances of theft of service, meter tampering, unauthorized tie-ins, etc. to ensure new and existing staff are kept apprised of recent cases, investigation outcomes, and safety precautions for Aqua PA.", "source_page": 146 }, { "number": 37, "text": "Improve the functionality and workflow progression provided by Aqua Services’ customer information system.", "source_page": 146 } ], "themes": [ "Workforce, training & succession planning", "Information technology & systems", "Customer service & billing" ], "cost_to_customers": false }, { "index": 11, "title": "Customer Service (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 38, "text": "Benchmark with similar utilities to set separate net collection goals for primary and secondary collection agencies at the Peoples Companies and measure each collection agency to the respective collection goal.", "source_page": 146 }, { "number": 39, "text": "Establish goals to achieve for customer satisfaction performance at the Peoples Companies and complete an analysis at the end of 2021 to evaluate the effectiveness of the IVR redesign, including Chat Bot, in improving customer satisfaction metrics.", "source_page": 146 }, { "number": 40, "text": "Perform an analysis of source data being gathered for arrearage level reports and remove any adjustments or inactive accounts that would adversely affect the integrity of arrearage data for the Peoples Companies.", "source_page": 146 } ], "themes": [ "Customer service & billing" ], "cost_to_customers": false }, { "index": 12, "title": "Fleet Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 41, "text": "Perform a periodic vehicle lease vs. buy analysis at Aqua Pennsylvania and the Peoples Companies, to ensure Pennsylvania operations is utilizing the least cost option for acquiring vehicles and equipment.", "source_page": 160 }, { "number": 42, "text": "Implement Dossier as PNG Companies’ fleet management system.", "source_page": 160 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 13, "title": "Human Resources and Diversity", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 43, "text": "Establish an internal OSHA recordable rate goal for the Peoples Companies based upon industry performance and align safety programs to achieve the OSHA goal(s).", "source_page": 176 }, { "number": 44, "text": "Measure employee engagement on a regular basis for the Peoples Companies in order to trend employee enthusiasm and motivation and reveal opportunities for improvement.", "source_page": 176 }, { "number": 45, "text": "Implement a safety management system at the Peoples Companies.", "source_page": 176 }, { "number": 46, "text": "Expedite the succession planning process, alongside with Essential Utilities, to ensure the Peoples Companies develop and recruit key positions.", "source_page": 176 }, { "number": 47, "text": "Update all job descriptions for the Peoples Companies.", "source_page": 176 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Customer service & billing", "Cybersecurity & physical security", "Dividend policy & capital management", "Emergency preparedness & business continuity", "Gas safety & pipeline integrity", "Information technology & systems", "Internal audit & internal controls", "Inventory, materials & fleet", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-04-14_evergy-inc_pa20-2", "company": "Evergy, Inc.", "company_raw": "Evergy, Inc. (PA20-2)", "docket": "PA20-2", "docket_full": null, "issued_date": "2021-04-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210414-3002&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210414-3002", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 37, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "non-financial", "functions": [], "forms": [], "finding_count": 3, "findings": [ { "index": 1, "title": "Accounting for Merger-Related Costs", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Merger-Related Accumulated Deferred Income Taxes", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Merger-Related Regulatory Assets", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-01-28_el-paso-electric-company_pa19-3", "company": "El Paso Electric Company", "company_raw": "El Paso Electric Company (PA19-3)", "docket": "PA19-3", "docket_full": "PA19-3-000", "issued_date": "2021-01-28", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210128-3015&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210128-3015", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 33, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2016 to June 30, 2020", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Posting of Available Transfer Capability (ATC)/Total Transfer Capability (TTC) on Interconnection Paths", "summary": "El Paso did not post the ATC and TTC for nine control area to control area interconnection paths on its OASIS as required by the Commission’s OASIS posting requirements. This practice may potentially hinder customers from obtaining transmission service on these paths.", "is_other_matter": false, "recommendations": [], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 2, "title": "Use of Designated Network Resource (DNR) to Make Firm Off-System Sales", "summary": "El Paso incorrectly used a DNR to make firm off-system sales, which was inconsistent with its OATT requirements.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Joint Owner Billing", "summary": "El Paso did not functionalize portions of third-party billings characterized as administrative and general (A&G) expenses for the operation and maintenance of the Palo Verde Generating Station, the Four Corners Generating Station, and the Palo Verde Transmission Switchyard. As a result, El Paso overstated A&G expenses and understated expenses in the generating and transmission operation and maintenance (O&M) accounts.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Review and revise policies and procedures governing the methods used to account for, track, report, and review general and administrative costs associated with joint owner billings from third parties to comply with the Commission’s accounting regulations.", "source_page": null }, { "number": 8, "text": "Communicate joint owner billing accounting policies and procedures to El Paso employees and provide training as necessary, to ensure that the proper accounting procedures are followed.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Application of Nonapproved Depreciation Rates", "summary": "El Paso applied state- approved depreciation rates to assets included in its wholesale production formula rate from 2016 through 2018, but did not file these updated depreciation rates with the Commission and obtain Commission approval prior to using them in wholesale formula rate determinations. Other Matter El Paso’s transmission function created Transmission Service Numbers (TSN) and assigned these TSNs to its merchant function to facilitate scheduling of transmission service, which is less transparent than assigning Transmission Service Requests (TSR) created in OASIS because TSNs are manually created outside of OASIS. D. Summary of", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Strengthen processes and procedures to ensure the use of only Commission- approved depreciation rates in the calculation of Commission-jurisdictional rates, including training for employees performing accounting functions and formula rate input calculations.", "source_page": null }, { "number": 10, "text": "Strengthen processes and procedures to report changes in, and seek Commission approval to use, new or revised deprecation rates, if El Paso intends to use these rates for Commission-approved formula rates. F.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Depreciation", "Informational postings" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "NE", "source": "Nebraska Public Service Commission", "doc_type": "gas rate case order", "id": "2021-01-26_black-hills-nebraska-gas_ne-ng-109-rate-order", "company": "Black Hills Nebraska Gas, LLC d/b/a Black Hills Energy", "company_raw": "Black Hills Nebraska Gas, LLC d/b/a Black Hills Energy", "docket": "NG-109", "docket_full": null, "issued_date": "2021-01-26", "source_page_url": "https://psc.nebraska.gov/natural-gas/ng-109-black-hills-nebraska-gas-llc-dba-black-hills-energy-rate-case-0", "pdf_download_url": "https://psc.nebraska.gov/sites/psc.nebraska.gov/files/doc/2021-01-26%20NG-109%20Order%20Approving%20Stipulation%20And%20Settlement%20Agreement.pdf", "captured_at": "2026-06-19", "source_note": "Order Approving Stipulation and Settlement Agreement in Black Hills Nebraska Gas general rate increase, NE PSC Application No. NG-109; 14 pp. PDF: psc.nebraska.gov/sites/psc.nebraska.gov/files/doc/2021-01-26 NG-109 Order Approving Stipulation And Settlement Agreement.pdf. Listed for reference (metadata-only).", "archived_via": null, "page_count": 14, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2021-01-14_ugi-utilities-inc_fa20-3", "company": "UGI Utilities, Inc.", "company_raw": "UGI Utilities, Inc. (FA20-3)", "docket": "FA20-3", "docket_full": "FA20-3-000", "issued_date": "2021-01-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20210114-3022&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20210114-3022", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 63, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2017 through July 29, 2020", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 10, "findings": [ { "index": 1, "title": "Excess Accumulated Deferred Income Tax", "summary": "UGIU improperly recorded the excess Accumulated Deferred Income Taxes (ADIT) related to the 2017 Tax Cuts and Jobs Act in Account 282, Accumulated Deferred Income Taxes – Other Property and Account 190, Accumulated Deferred Income Taxes. In addition, UGIU improperly excluded excess and deficient ADIT, created as a result of the 2017 Tax Cuts and Jobs Act, from its wholesale transmission formula rate computation. As a result, UGIU overstated its annual transmission revenue requirement by approximately $357,476 and overbilled wholesale transmission customers in 2018.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Implement procedures to ensure that excess and deficient ADIT asset and liability amounts are included in rate base for the computation of the annual transmission revenue requirement.", "source_page": null }, { "number": 2, "text": "Revise its accounting policies and procedures to ensure that the effect of changes in tax laws or tax rates are implemented in accordance with the Commission’s accounting guidance in Docket No. AI93-5.", "source_page": null }, { "number": 3, "text": "Submit correcting journal entries, within 60 days of issuance of this audit report, with proposed accounting entries and supporting documentation to DAA that reflect corrections to recorded excess and deficient ADIT in the appropriate USofA accounts.", "source_page": null }, { "number": 4, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of excess and deficient ADIT asset and liability amounts excluded from the transmission formula rates in 2018, plus interest; (2) determinative components of the refund; (3) refund method; and (4) period(s) refunds will be made.", "source_page": null }, { "number": 5, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 6, "text": "Refund amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Allowance for Funds Used During Construction", "summary": "UGIU’s method for computing its AFUDC rate was deficient. Specifically, UGIU improperly excluded short- term debt, as the first source of financing construction, in calculating its AFUDC rate. In addition, UGIU improperly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, and Account 219, Accumulated Other Comprehensive Income, in the equity component to compute its AFUDC rate. Also, UGIU improperly used its fiscal year-end book balance for long-term debt and common equity amounts when computing its AFUDC rate rather than the calendar year-end balances reported in its FERC Form No. 1 during the audit period. As a result, UGIU overaccrued AFUDC amounts included in utility plant accounts by approximately $436,000 from 2017 to 2019 and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise and implement procedures to ensure that AFUDC rate calculations are consistent with Order Nos. 561 and 561-A, EPI No. 3(A)(17), and other applicable Commission requirements.", "source_page": null }, { "number": 8, "text": "Revise its procedures to ensure that it includes short-term debt in the computation of the AFUDC rate for its electric utility business.", "source_page": null }, { "number": 9, "text": "Revise its procedures to exclude Account 216.1 and Account 219 balances from the equity components used to derive its AFUDC rate.", "source_page": null }, { "number": 10, "text": "Revise its procedures to ensure that it computes AFUDC rates using the calendar year-end balances reported in its FERC Form No. 1 for common equity, preferred stock, and long-term debt.", "source_page": null }, { "number": 11, "text": "Provide training to its staff on the revised procedures implemented under Recommendation Nos. 7, 8, 9, and 10. Provide periodic training in these areas as needed.", "source_page": null }, { "number": 12, "text": "Recalculate its accrued AFUDC, in a manner consistent with EPI No. 3(A)(17) that corrects for the improper exclusion of short-term debt, improper inclusion of Account 216.1 and 219 balances, and improper use of fiscal year-end book balances for common equity, preferred stock, and long-term debt from 2012 through the date of issuance of the audit report.", "source_page": null }, { "number": 13, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over-accrual of AFUDC within 60 days of issuance of the audit report.", "source_page": null }, { "number": 14, "text": "Submit a refund analysis, within 60 days of issuance of the audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of excess AFUDC included in the transmission formula rates since 2017, plus interest; (2) determinative components of the refund; (3) refund method; and (4) period(s) refunds will be made.", "source_page": null }, { "number": 15, "text": "Revise CWIP, electric plant in service, accumulated depreciation, ADIT, and other accounts impacted by over-accrual of AFUDC after receiving DAA’s assessment of the proposed accounting entries per Recommendation No. 13 and restate and footnote the FERC Form No. 1 for current and comparative years as necessary.", "source_page": null }, { "number": 16, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 17, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of Commission regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 3, "title": "Postretirement Benefits Other Than Pensions", "summary": "UGIU improperly included ADIT related to SFAS 106, Employers’ Accounting for Postretirement Benefits Other Than Pensions, as an input to its wholesale transmission formula rate contrary to the directives of its tariff. As a result, UGIU overstated the ADIT balances included in its wholesale transmission formula rate, which led to overstating its annual transmission revenue requirements and overbilling its wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Revise and implement procedures, policies, and controls to track and review the transmission formula rate inputs and calculations for accuracy, completeness, and compliance with UGIU’s Commission approved formula rate.", "source_page": null }, { "number": 19, "text": "Provide training to staff on the revised wholesale transmission formula rate procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 20, "text": "Submit a refund analysis to DAA, within 60 days of issuance of this audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the inclusion SFAS 106 amounts plus interest; (2) determinative components of the refund; (3) refund method; and (4) period(s) refunds will be made.", "source_page": null }, { "number": 21, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 22, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 4, "title": "Common Plant O&M Expenses", "summary": "UGIU improperly included common plant O&M expenses, that were also included as A&G expenses, in its wholesale transmission formula rate. As a result, UGIU double counted expenses associated with common plant, and consequently, overstated its wholesale transmission revenue requirement by approximately $423,454 during the audit period. This led UGIU to overbill its wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Develop and implement procedures, policies, and controls to ensure expenses included in the transmission formula rate are not included in multiple areas.", "source_page": null }, { "number": 24, "text": "Provide training to staff on the revised transmission formula rate procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 25, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to UGIU’s wholesale transmission customers since 2017, plus interest; (2) determinative components of the refund; (3) refund method; and (4) period(s) for which refunds will be made.", "source_page": null }, { "number": 26, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 27, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Transmission Revenue Credits", "summary": "UGIU understated its revenue credits that were used to reduce the annual transmission revenue requirements calculated by its wholesale transmission formula rate by improperly excluding certain transmission- related revenues recorded in Account 454, Rent from Electric Property. Additionally, UGIU improperly accounted for rental revenue associated with third parties’ usage of its utility assets by recording such revenue in Account 418, Nonoperating Rental Income. As a result, UGIU understated the revenue credits includible in its wholesale transmission formula rate, which led to an overstatement of its annual transmission revenue requirements.", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Develop and implement procedures and policies to track, report, review, and account for wholesale transmission revenues consistent with Commission accounting and ratemaking requirements.", "source_page": null }, { "number": 29, "text": "Provide training to staff on the revised accounting and wholesale transmission revenue procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 30, "text": "Perform an analysis of rental income accounts to identify revenues that were not properly credited to wholesale transmission customers through UGIU’s transmission formula rates for the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 31, "text": "Submit a refund analysis to DAA, within 60 days of receiving the audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the exclusion of revenue credits plus interest; (2) determinative components of the refund; (3) refund method; (4) period(s) refunds will be made.", "source_page": null }, { "number": 32, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 33, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 6, "title": "Accounting for Affiliate Transactions", "summary": "UGIU misclassified various expenses associated with services provided by its parent company in Account 923, Outside Services Employed. Also, UGIU did not consistently apply its internally calculated, cost allocation percentages used to allocate costs between UGIU’s electric utility business and its gas utility business. These allocation errors resulted in improper amounts being included in UGIU’s wholesale transmission formula rate.", "is_other_matter": false, "recommendations": [ { "number": 34, "text": "Revise and implement procedures and policies to track, report, review, and account for UGI Corporation allocated expenses consistent with Commission accounting requirements.", "source_page": null }, { "number": 35, "text": "Revise and implement procedures, polices and controls to ensure the correct allocation factors are used to calculate and allocate common expenses recorded in the A&G accounts for the electric utility business.", "source_page": null }, { "number": 36, "text": "Train staff on the procedures and policies and provide periodic training, as needed.", "source_page": null }, { "number": 37, "text": "Perform an analysis of A&G expense accounts to identify common expenses that were allocated using the incorrect allocation percentages during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 38, "text": "Submit a refund analysis to DAA, within 60 days of receiving the audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper allocation of common expenses recorded in A&G accounts as identified pursuant to the analysis performed in response to Recommendation No. 43, plus interest; (2) determinative components of the refund; (3) refund method; and (4) period(s) refunds will be made.", "source_page": null }, { "number": 39, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 40, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 7, "title": "Accounting for Administrative and General Expenses", "summary": "UGIU improperly recorded various A&G expenses in a manner contrary to the Commission’s accounting regulations. As a result, UGIU overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 41, "text": "Revise policies and procedures to ensure that UGIU properly accounts for expenditures in its books and records.", "source_page": null }, { "number": 42, "text": "Provide training to its staff on the revised procedures for properly accounting for expenditures in UGIU’s books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 43, "text": "Perform an analysis of A&G expense accounts to identify expenses that were inappropriately recovered through UGIU’s transmission formula rate and the related customer billings, such as advertising, donations, lobbying, distribution O&M costs, legal costs, and asset insurance improperly charged to accounts included in the transmission formula rate during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of the audit report.", "source_page": null }, { "number": 44, "text": "Submit a refund analysis to DAA, within 60 days of receiving the audit report, that explains and details the following: (1) calculation of refunds that include the amount of inappropriate recoveries during the audit period that resulted from the improper accounting for expenses recorded in A&G accounts as identified pursuant to the analysis performed in response to Recommendation No. 43, plus interest; (2) determinative components of the refund; (3) refund method; and (4) period(s) refunds will be made.", "source_page": null }, { "number": 45, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 46, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 8, "title": "Filing of Depreciation Rates with the Commission", "summary": "UGIU did not file its depreciation rate schedule with the Commission when depreciation rates were changed. This hindered the Commission’s and other interested parties’ ability to timely review and monitor UGIU’s depreciation rates, which impact prices charged for wholesale transmission services through the formula rate.", "is_other_matter": false, "recommendations": [ { "number": 47, "text": "Develop and implement processes and procedures to ensure that depreciation rates and related studies are filed with the Commission when depreciation rates are changed.", "source_page": null }, { "number": 48, "text": "File current depreciation studies with the Commission relating to UGIU’s current annual transmission revenue requirement within 60 days of issuance of this audit report.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 9, "title": "FERC Form No. 1 Reporting", "summary": "UGIU did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. Other Matter", "is_other_matter": false, "recommendations": [ { "number": 49, "text": "Revise and strengthen documented policies, procedures, and practices to ensure information reported in the FERC Form No. 1 is correct, accurate, and consistent with the instructions of the form.", "source_page": null }, { "number": 50, "text": "Provide training to staff on the revised FERC Form No. 1 policies, procedures, and practices. Also, develop a training program that supports the provision of periodic training in this area, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 10, "title": "Accounting for AFUDC ADIT", "summary": "UGIU did not record or report in its FERC Form No. 1 deferred income taxes associated with debt and equity AFUDC. UGIU did not record deferred income taxes consistent with the Internal Revenue Service (IRS) uniform capitalization rule for tax purposes regarding AFUDC, which resulted in the same amount of debt and equity AFUDC reported on UGIU’s accounting books and Federal tax returns. Had UGIU filed its federal income tax returns in a manner consistent with the IRS’s uniform capitalization rule, the resulting deferred income taxes associated with AFUDC debt and equity may have affected UGIU’s wholesale transmission formula rate computation. D.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Form reporting (Form No. 1/2/6, Page 700)", "Capitalization vs. expense" ], "cost_to_customers": true } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-12-17_dominion-energy-transmission-inc_fa15-16", "company": "Dominion Energy Transmission, Inc.", "company_raw": "FA15-16 Dominion Energy Transmission, Inc.", "docket": "FA15-16", "docket_full": "FA15-16-000", "issued_date": "2020-12-17", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20201217-3130&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20201217-3130", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20201217-3130 (fileID 14751843).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 87, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Calculation of Allowance for Funds Used During Construction (AFUDC) Rates and Accrual", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 2, "title": "Allocation of Overhead Costs to Construction Work In Progress (CWIP)", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Greenlick Storage Fire Gas Loss Regulatory Asset", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Employment Discrimination Settlements or Judgments", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Lobbying Expenses", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 6, "title": "Filing of Proposed Accounting for the Sale of Gas Plant Assets", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-12-04_allete-inc_fa20-2", "company": "ALLETE, Inc.", "company_raw": "ALLETE, Inc. (FA20-2)", "docket": "FA20-2", "docket_full": "FA20-2-000", "issued_date": "2020-12-04", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20201204-3005&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20201204-3005", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 47, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2016 through September 3, 2020", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Transmission Incentives", "summary": "ALLETE’s method for computing Pre-funded Allowance for Funds Used During Construction (AFUDC) for its transmission incentive projects was contrary to the Commission’s orders. As a result, ALLETE overstated the transmission plant balances used to compute its annual transmission revenue requirements, which led to overbillings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Update and implement policies and procedures to ensure the accurate calculation of Pre-funded AFUDC recorded in Account 254 and included in the wholesale transmission formula rate.", "source_page": null }, { "number": 2, "text": "Provide training to staff on the updated Pre-funded AFUDC accounting and wholesale transmission formula rate procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 3, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the Pre-funded AFUDC amounts in Account 254, and other accounts impacted by the under-accrual of Pre-funded AFUDC within 60 days of issuance of the audit report.", "source_page": null }, { "number": 4, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ALLETE’s wholesale transmission customers since January 1, 2016, plus interest, relating to the adjustments made in response to the preceding recommendation; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 5, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 6, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of Commission regulations.", "source_page": null } ], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Environmental Costs", "summary": "ALLETE improperly recorded environmental mitigation project costs of $4.2 million in Account 930.2, Miscellaneous General Expenses. As a result, ALLETE overstated its annual transmission revenue requirement and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise policies and procedures to ensure that ALLETE properly accounts for donations in accordance with Commission accounting regulations.", "source_page": null }, { "number": 8, "text": "Provide training to its staff on the revised procedures for recording donations. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 9, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ALLETE’s wholesale transmission customers since January 1, 2016, plus interest, relating to the improper accounting for donation costs in Account 930.2; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 10, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 11, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Transmission and Distribution Plant Accounting", "summary": "ALLETE improperly recorded distribution assets in transmission plant accounts and transmission assets in distribution plant accounts. As a result of the transmission and distribution asset misclassification, ALLETE overstated its annual transmission revenue requirement which led to overbillings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise and implement policies and procedures to ensure assets are recorded in the proper accounts under the Commission’s accounting regulations.", "source_page": null }, { "number": 13, "text": "Provide training to staff on the revised asset accounting procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 14, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ALLETE’s wholesale transmission customers since January 1, 2016, plus interest, relating to the adjustments made in response to the preceding two recommendations; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 15, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 16, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Long-Term Debt and Interest Expense", "summary": "ALLETE improperly recorded proceeds from long-term debt instruments in Account 186, Miscellaneous Deferred Debits. In addition, ALLETE improperly recorded interest expense associated with the debt instruments in Account 920, Administrative and General Salaries. As a result, ALLETE overstated its annual transmission revenue requirement and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Revise and implement policies and procedures to ensure that long-term debt and interest expense are recorded in the proper accounts under the Commission’s accounting regulations.", "source_page": null }, { "number": 18, "text": "Provide training to staff on the revised accounting procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 19, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the correction of the long-term debt amounts in Account 186 within 60 days of issuance of the audit report.", "source_page": null }, { "number": 20, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ALLETE’s wholesale transmission customers since January 1, 2016, plus interest, relating to the adjustments made in response to the preceding recommendation; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 21, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 22, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting Misclassifications", "summary": "ALLETE improperly recorded various administrative and general (A&G) expenses in a manner contrary to the Commission’s accounting regulations. As a result of the improper accounting for certain A&G expenses, ALLETE overstated its annual transmission revenue requirement and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Revise policies and procedures to ensure that ALLETE properly accounts for expenditures in its books and records.", "source_page": null }, { "number": 24, "text": "Provide training to its staff on the revised procedures for properly accounting for expenditures in ALLETE’s books and records. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 25, "text": "Perform an analysis of A&G accounts to identify additional expenses that were inappropriately recovered through ALLETE’s transmission formula rates, such as lobbying costs, during the audit period. Provide the results of the analysis to audit staff within 60 days of the date of issuance of this audit report.", "source_page": null }, { "number": 26, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ALLETE’s wholesale transmission customers since January 1, 2016, plus interest, relating to the adjustments made in response to the preceding recommendation; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 27, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 28, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 6, "title": "Application of Nonapproved Depreciation Rates", "summary": "ALLETE applied state- approved depreciation rates to assets included in its wholesale transmission formula rate determination but had not previously filed these depreciation rates with the Commission and obtained Commission approval. In addition, ALLETE improperly recorded depreciation expenses associated with plant held for future use in Account 403, Depreciation Expense, instead of Account 421, Miscellaneous Nonoperating Income. As a result of ALLETE’s improper accounting for depreciation expenses associated with plant held for future use, ALLETE overstated its annual transmission revenue requirement which led to overbillings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Develop and implement processes and procedures to ensure that depreciation rates and related studies are filed with the Commission for consideration and decision before being used for ratemaking purposes.", "source_page": null }, { "number": 30, "text": "File current depreciation studies in dockets relating to ALLETE’s Wholesale Transmission Formula Rates within 60 days.", "source_page": null }, { "number": 31, "text": "Provide training to its staff on the revised procedures. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 32, "text": "Submit a refund analysis, within 60 days of issuance of this audit report, to DAA for review that explains and details the following: (1) calculation of refunds to ALLETE’s wholesale transmission customers since January 1, 2016, plus interest, relating to the improper accounting for depreciation associated with electric plant held for future use in Account 403; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 33, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 34, "text": "Refund the amounts disclosed in the refund report to wholesale transmission customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [ "Accounting misclassification", "Depreciation", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 7, "title": "FERC Form No. 1 Reporting", "summary": "ALLETE did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. D.", "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Revise and strengthen documented policies, procedures, and practices to ensure that information reported in the FERC Form No. 1 is correct, accurate, complete, and consistent with the instructions of the form.", "source_page": null }, { "number": 36, "text": "Provide training to staff on the revised FERC Form No. 1 policies, procedures, and practices. Also, develop a training program that supports the provision of periodic training in this area, as needed. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-11-12_maritimes-northeast-pipeline-l-l-c_fa19-9", "company": "Maritimes & Northeast Pipeline, L.L.C.", "company_raw": "Maritimes & Northeast Pipeline, L.L.C. (FA19-9)", "docket": "FA19-9", "docket_full": "FA19-9-000", "issued_date": "2020-11-12", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20201112-3002&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20201112-3002", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 64, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2017 to December 31, 2018", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2", "501-G" ], "finding_count": 8, "findings": [ { "index": 1, "title": "Allocation of Labor Burden and Overhead Costs to Capital Projects", "summary": "Maritimes did not record labor burden and overhead costs to capital projects based on actual costs as required by the Commission. Instead, Maritimes used allocation percentages, for which it did not perform timely studies and maintain appropriate records. This prevented audit staff from verifying whether the allocation percentages used to reimburse affiliates were reasonable and representative of actual costs.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Create policies and procedures to directly assign costs to capital projects or perform periodic studies of actual labor costs to ensure allocation percentages are reasonable and representative of actual costs, in accordance with General Instruction No. 9 (GI No. 9) and Gas Plant Instruction No. 4 (GPI No. 4).", "source_page": null }, { "number": 2, "text": "Revise policies, procedures, and controls to ensure it maintains all records of studies supporting allocation percentages in accordance with General Instruction No. 2 (GI No. 2), if direct assignment of costs is impractical for capital projects.", "source_page": null }, { "number": 3, "text": "Directly assign costs for capital projects; however, if direct assignment of costs is deemed impractical, Maritimes should provide the evaluation it conducted to make this determination. Subsequently, conduct a study to support the allocation percentages that Maritimes determines should be used to reimburse its affiliates for labor burden and overhead costs. Provide study results, including supporting documentation, to DAA within 90 days of receiving the final audit report.", "source_page": null }, { "number": 4, "text": "Based on the study results, if the 100 and 130 percentage factors previously used are determined to be unreasonable or excessive compared to the results of the study, then adjust plant in service and other affected account balances for those amounts in accordance with GI No. 2(E) for the affected periods. Submit journal entries, calculations, and other supporting documentation within 30 days of receiving audit staff approval of the study performed and its results.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 2, "title": "Reporting of O&M Expenses for Incremental Rate Projects", "summary": "Maritimes did not perform a study to support the allocation percentage used to assign operations and maintenance (O&M) expenses to its incremental rate projects. Absent a study, audit staff could not determine whether this allocation percentage was reasonable and representative of the actual O&M expenses assigned to incremental rate projects. Maritimes also improperly aggregated maintenance expenses with operating expenses, rather than separately reporting these expenses for its incremental rate projects in its FERC Form No. 2. This reduced the accuracy and completeness of these expenses reported for Maritimes’ incremental rate projects.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Revise policies and procedures to ensure FERC Form No. 2 Pages 217- 217a are completed in accordance with the reporting instructions, including separately reporting maintenance expenses from operating expenses.", "source_page": null }, { "number": 6, "text": "Conduct a study to support the allocation percentage used for assigning O&M expenses that are not directly assigned to incremental rate projects. Provide the study results, including supporting documentation, to DAA within 90 days of the receiving the audit report.", "source_page": null }, { "number": 7, "text": "Train relevant staff on the revised methods to account for expenses related to incremental rate facilities and provide periodic training, as needed.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Nonoperating and Unrelated Expenses", "summary": "Maritimes’ affiliates allocated to Maritimes certain nonoperating expenses and costs that had no relationship to its interstate pipeline operations, which Maritimes improperly recorded in operating expense accounts. Operating expenses are recoverable, while nonoperating and unrelated expenses are generally nonrecoverable from customers in cost of service rates. Therefore, recording these expenses improperly imposes a risk of including and recovering these expenses in future cost of service rate determinations.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise policies, procedures, and controls to track, review, and account for nonoperating expenses and for expenses unrelated to its business allocated to it by affiliates consistent with Commission requirements.", "source_page": null }, { "number": 9, "text": "Provide a recent journal entry and supporting documentation that demonstrate that the accounting misclassifications identified in this finding have been corrected and the related costs are now recorded in accordance with the Commission’s accounting requirements.", "source_page": null }, { "number": 10, "text": "Perform an analysis of expenses allocated to Maritimes by its affiliates to identify all nonoperating and other expenses unrelated to Maritimes’ business operations that were incorrectly recorded as operating expenses by Maritimes during the audit period. This analysis should capture expenses in addition to those already identified during and subsequent to the audit period. Within 90 days of the date of the final audit report, provide results of the analysis, proposed correcting entries, and all applicable work papers supporting the analysis, to DAA.", "source_page": null }, { "number": 11, "text": "Train relevant staff on the revised methods to account for nonoperating expenses and unrelated expenses and provide periodic training, as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Operating Expenses", "summary": "Maritimes improperly accounted for certain operating expenses, such as transmission operating expenses, regulatory activities, and legal fees, in a manner inconsistent with the Commission’s accounting regulations. While these accounting misclassifications had no impact on total operating expenses, the misclassifications nevertheless reduced the accuracy and transparency of operating expenses as reported in Maritimes’ FERC Form No. 2 filings.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise policies, procedures, and controls to track, report, review, and account for administrative and general (A&G) and operating expenses consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 13, "text": "Provide a recent journal entry, and supporting documentation, which demonstrates that the identified accounting misclassifications are now recorded in accordance with the Commission’s accounting regulations.", "source_page": null }, { "number": 14, "text": "Train relevant staff on the revised methods to account for A&G and operating expenses and provide periodic training as needed.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 5, "title": "FERC Form No. 2 Reporting", "summary": "Maritimes did not report complete information as required in certain supporting schedules of its 2017 and 2018 FERC Form No. 2 reports. This reduced the overall accuracy and usefulness of the information reported in the FERC Form No. 2. FERC Tariff and Rates", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Revise policies and procedures to ensure complete and accurate information is reported in the FERC Form No. 2 in accordance with the instructions of the report.", "source_page": null }, { "number": 16, "text": "Review the reporting deficiencies with relevant staff to ensure they include on a prospective basis all required information in the FERC Form No. 2.", "source_page": null } ], "themes": [ "Tariff administration & oversight", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Fuel Retainage Quantity Filings", "summary": "Maritimes misreported the deferred fuel balance and negative lost and unaccounted for gas (LAUF) in its annual Fuel Retainage Quantity filings. Maritimes also did not separately break out its deferred fuel balance from other activities reported on Page 268, Miscellaneous Current and Accrued Liabilities, in its FERC Form No. 2 reports. These oversights reduced the accuracy and the usefulness of Maritimes’ Fuel Retainage Quantity filings and FERC Form No. 2 reports for shippers and other stakeholders during the audit period.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Revise procedures and controls to ensure that Maritimes calculates, and reports deferred fuel balances consistently with section 20 of its Tariff.", "source_page": null }, { "number": 18, "text": "Update procedures to ensure that positive and negative LAUF are included as a component of Customer Use Gas in the projected fuel retainage percentage (FRP) calculation of its annual fuel filings, on a prospective basis. Also, provide footnote disclosures in the annual fuel filing as needed to increase transparency.", "source_page": null }, { "number": 19, "text": "Discuss the procedural changes that resulted in an over collection in deferred fuel balance with shippers. Maritimes should provide DAA with documentation to support that these discussions occurred and the outcome with shippers before its next fuel retainage quantity filing.", "source_page": null }, { "number": 20, "text": "Inform Maritimes’ staff that prepares the supporting schedule for Account 242 of the FERC Form No. 2 to break out each activity comprising the account balance according to the reporting threshold amount required by the instructions, including breaking out Maritimes’ cumulative deferred fuel balance when it exceeds the reporting threshold.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 7, "title": "Reservation Charge Crediting", "summary": "Section 8 of Maritimes’ Tariff contained general terms and conditions that were inconsistent with the Commission’s reservation charge crediting policy. Maritimes also improperly included references to maintenance activities in the force majeure definition in section 26 of its Tariff. Making these tariff terms and conditions consistent with the Commission’s policy will ensure that shippers are properly credited reservation charges for force majeure and non-force majeure events. D. Other Matter Audit staff identified one other matter, which is summarized below. Section V of this report contains a detailed discussion of this other matter.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Revise policies and procedures to establish and maintain compliance with Commission’s reservation charge crediting requirements.", "source_page": null }, { "number": 22, "text": "File tariff revisions made to its reservation charge crediting provisions for force majeure and non-force majeure events in sections 8.8 and 8.9 of its Tariff, and remove (i) maintenance activities from its definition of a force majeure event and (ii) any restrictions on non-force majeure events from its definition of non-force majeure event, in section 26 of its Tariff. File these tariff revisions with the Commission within 60 days of the issuance of this report.", "source_page": null }, { "number": 23, "text": "Make an informational posting to inform shippers of the revisions made to tariff sections 8.8, 8.9, and 26. F.", "source_page": null } ], "themes": [ "Accounting misclassification", "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 8, "title": "Tariff Penalty Crediting Provisions", "summary": "Maritimes’ tariff provisions for scheduling penalties and park and loan penalties contain some inconsistencies with Commission policy. Although these provisions are in Maritimes’ approved Tariff, updating these provisions will better align them with Commission policy, and provide the appropriate outcomes for assessing penalties to offending shippers and crediting back penalty revenues to non-offending shippers. E.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Form reporting (Form No. 1/2/6, Page 700)", "Fuel & purchased-power cost recovery", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-10-07_chevron-pipe-line-company_fa19-5", "company": "Chevron Pipe Line Company", "company_raw": "Chevron Pipe Line Company (FA19-5)", "docket": "FA19-5", "docket_full": "FA19-5-000", "issued_date": "2020-10-07", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20201007-3010&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20201007-3010", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 48, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2014 to December 31, 2018", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Depreciation Rates and Reserve Balances", "summary": "CPL’s accounting and financial reporting for depreciation included several deficiencies affecting depreciation expense and reserve balances and the accuracy of the Annual Cost of Service Based Analysis Schedule on Page 700 (Page 700) of CPL’s FERC Form No. 6 filings. Specifically, CPL:  Did not use Commission-approved depreciation rates to determine depreciation expense. Instead, CPL used slightly higher depreciation rates than the depreciation rates last approved by the Commission, resulting in increased depreciation expense and depreciation reserve balances.  Incorrectly continued to accrue depreciation expense on five carrier property asset accounts after the underlying asset accounts had been fully depreciated. This resulted in CPL recording $11.4 million of excess depreciation expense as of December 31, 2018.  Maintained two carrier property asset accounts with negative depreciation reserve balances. This resulted in an inflated net book value for these two accounts that exceeded the original cost of the assets by $8.2 million as of December 31, 2018.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Create procedures and controls to ensure depreciation rates remain relevant and applicable, and to make timely revisions when property accounts become fully accrued. Also strengthen procedures and controls to ensure that CPL applies Commission-approved rates to depreciate all carrier property assets and ceases accruing depreciation when assets accounts become fully depreciated.", "source_page": null }, { "number": 2, "text": "Conduct a depreciation study that reflects current economic conditions and includes other factors, including net salvage and interim retirements. Based on this study, determine whether to continue using CPL’s current Commission-approved depreciation rates to calculate the depreciation expense pursuant to Part 347, or to timely file a request to change depreciation rates pursuant to General Instruction 1-8.", "source_page": null }, { "number": 3, "text": "Submit a copy of this depreciation study to the Commission within 30 days of completion. CPL should also make appropriate changes to its existing depreciation rates when proposed revised rates are approved or modified by the Commission.", "source_page": null }, { "number": 4, "text": "Submit any necessary accounting entries supporting any proposed adjustments within the accrued depreciation accounts to DAA for review within 30 days of the Commission accepting CPL’s proposed depreciation rates. Upon approval from DAA, make needed accounting entries within 30 days.", "source_page": null }, { "number": 5, "text": "Provide worksheet(s) showing the effect and adjustment made to each component on Page 700 of the FERC Form No. 6.", "source_page": null }, { "number": 6, "text": "Upon receiving DAA staff’s review and response to CPL’s accounting entries and worksheets, restate and footnote the balances reported in the FERC Form No. 6 in the current and comparative years of the report, including all schedules affected, to reflect and disclose the revisions made.", "source_page": null } ], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Inactive and Idle Property", "summary": "CPL improperly accounted for inactive and idle pipeline assets as carrier property rather than noncarrier property. This affected the accuracy of amounts reported in carrier and noncarrier property and depreciation accounts, and resulted in CPL overstating rate base and depreciation expense on Page 700 in its 2018 FERC Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Update accounting policies and procedures to ensure that inactive and idled pipeline assets are accounted for as noncarrier property consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 8, "text": "Reclassify all inactive and idled pipeline assets recorded in Account 30 that will not be used in CPL’s future pipeline operations to Account 34, and reclassify the related accrued depreciation from Account 31 to Account 35. Submit accounting entries supporting adjustments within the carrier and noncarrier property accounts to audit staff for review within 30 days of issuance of this audit report. Upon approval from DAA, make accounting entries supporting this adjustment within 30 days.", "source_page": null }, { "number": 9, "text": "Perform an analysis to determine the full scale of Page 700 impacts, including impacts to Line 1, Operating and Maintenance Expense; Line 2, Depreciation Expense; Lines 5a-5d, Rate Base; and other lines on Page 700, and provide this analysis to DAA staff for further review.", "source_page": null }, { "number": 10, "text": "Upon receiving DAA staff’s review and response, restate and footnote the balances reported in the FERC Form No. 6 in the current and comparative years of the report, including all schedules affected, to reflect and disclose the revisions made. Noncarrier Property Revenues, Expenses, and Net Income", "source_page": null }, { "number": 11, "text": "Establish policies and procedures to ensure that revenues, expenses, and net income associated with noncarrier property are accounted for and reported in accordance with the Commission’s accounting regulations.", "source_page": null }, { "number": 12, "text": "Strengthen procedures to ensure personnel responsible for completing and reviewing the FERC Form No. 6 follow the instructions for completing the schedules prior to submission, to eliminate errors.", "source_page": null }, { "number": 13, "text": "Reclassify revenues and expenses associated with noncarrier property to Account 620 for the current year. Submit a copy of the journal entries to DAA within 30 days of the issuance of this report.", "source_page": null }, { "number": 14, "text": "Restate and footnote the income statement balances reported in the FERC Form No. 6 in the current and comparative years of the report for Accounts 600, 610, and 620, including all schedules affected, to reflect and disclose revisions made.", "source_page": null } ], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 3, "title": "Noncarrier Property Revenues and Expenses", "summary": "CPL improperly accounted for revenues and expenses related to noncarrier property in operating expense and revenue accounts. This resulted in CPL misstating net income from noncarrier property each year of the audit period, with reporting errors ranging from $3.6 million to $5.7 million. These errors impacted the accuracy of the information reported in the FERC Form No. 6.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Legal Settlements and Regulatory Fees", "summary": "CPL improperly accounted for legal settlements relating to employment discrimination claims as an operating rather than nonoperating expense. CPL also improperly accounted for regulatory fees paid to a federal agency in the wrong operating expense account. These errors impacted the accuracy of the information reported in the FERC Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Update policies and procedures to ensure employee discrimination claim settlement payments and regulatory fees are accounted for consistent with the Commission’s accounting regulations.", "source_page": null }, { "number": 16, "text": "Record employee discrimination claim settlement payments in Account 660, Miscellaneous Income Charges, and record regulatory fees, such as PHMSA user fees, in Account 590, Other Expenses, prospectively.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 5, "title": "Reporting of Interstate Operating Revenues", "summary": "CPL omitted reporting some jurisdictional interstate operating revenues on Page 700 of its 2017 FERC Form No. 6. D.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Develop procedures and controls to ensure pipeline systems sold are appropriately removed from the FERC Form No. 6 Page 700.", "source_page": null }, { "number": 18, "text": "Strengthen processes to ensure employees perform adequate reviews of interstate operating revenues reported on Page 700 data. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on formal challenge", "id": "2020-08-28_delmarva-power-light_er09-1158", "company": "Delmarva Power & Light Company", "company_raw": "Delmarva Power & Light Company", "docket": "ER09-1158", "docket_full": null, "issued_date": "2020-08-28", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200828-3048&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200828-3048", "captured_at": "2026-06-01", "source_note": "FERC order granting in part and denying in part a formal challenge re Delmarva Power & Light Company formula-rate inputs, Docket ER09-1158, issued 2020-08-28. Found via eLibrary full-text search; accession 20200828-3048.", "archived_via": null, "page_count": 25, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-07-30_san-diego-gas-electric-company_fa19-3", "company": "San Diego Gas & Electric Company", "company_raw": "San Diego Gas & Electric Company (FA19-3)", "docket": "FA19-3", "docket_full": "FA19-3-000", "issued_date": "2020-07-30", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200730-3038&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200730-3038", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 85, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2016 through February 4, 2020", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 11, "findings": [ { "index": 1, "title": "Allowance for Funds Used During Construction", "summary": "SDG&E’s methods for calculating its Allowance for Funds Used During Construction (AFUDC) base and rate were deficient. Specifically, SDG&E improperly included unpaid contract retention accruals in its construction work in process (CWIP) balance, and unamortized debt discounts and losses on reacquired debt in the determination of its long-term debt balance. As a result, SDG&E miscalculated its AFUDC base and rate. This led it to over-accrue AFUDC, which resulted in an overstatement of CWIP and plant in service balances. This resulted in SDG&E overbilling wholesale transmission customers because the excessive AFUDC costs were included in utility plant that impacted wholesale formula rate determinations. 3 16 U.S.C. § 824s (2018). 4 Promoting Transmission Investment through Pricing Reform, Order No. 679, 116 FERC ¶ 61,057, order on reh’g, Order No. 679-A, 117 FERC ¶ 61,345 (2006), order on reh’g, 119 FERC ¶ 61,062 (2007). The Commission provided additional guidance regarding the application of its transmission incentive policies in Promoting Transmission Investment through Pricing Reform, 141 FERC ¶ 61,129 (2012). 5 San Diego Gas & Elec. Co., 151 FERC ¶ 61,011 (2015). 3", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Commitment Fees", "summary": "SDG&E improperly accounted for upfront fees it paid that were associated with revolving line of credit agreements in Account 182.3, Other Regulatory Assets, and improperly accounted for quarterly commitment fees associated with the agreements in Account 923, Outside Services Employed. In addition, SDG&E improperly included the amortization of upfront line of credit fees in its calculation of long-term debt interest expense used to compute its AFUDC rate.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 3, "title": "Allocation of Overhead Costs to CWIP", "summary": "SDG&E capitalized overhead costs to Account 107, Construction Work in Progress – Electric, using an allocation method that was not based on the actual time that employees were engaged in construction activities or on a representative time study. This led to SDG&E charging costs to Account 107 that did not have a definite relationship to construction. As a result, SDG&E may have overstated construction costs recorded in Account 107 and electric plant in service, as well as accumulated depreciation and accumulated deferred income tax (ADIT) balances, and may have understated operating expenses. Moreover, this accounting may have led SDG&E to overstate its wholesale transmission revenue requirement and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for EV Charging Stations", "summary": "SDG&E improperly accounted for electric vehicle (EV) charging station distribution assets in Account 398, Miscellaneous Equipment. SDG&E’s accounting resulted in the cost of the assets and associated expenses being incorrectly included in accounts that are wholesale transmission formula rate inputs. This led the company to overstate its wholesale transmission revenue requirement and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Regulatory Commission Expenses", "summary": "SDG&E improperly accounted for regulatory commission expenses. SDG&E’s accounting resulted in regulatory commission expenses being incorrectly included in accounts that are wholesale transmission formula rate inputs. This led the company to overstate its wholesale transmission revenue requirement and overcharge wholesale transmission customers. 4", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Distribution-Related Expenses", "summary": "SDG&E improperly accounted for distribution-related operation costs in a transmission operation expense account. SDG&E’s accounting resulted in expenses being incorrectly included in accounts that were wholesale transmission formula rate inputs. This led the company to overstate its wholesale transmission revenue requirement and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Donations and Lobbying Expenses", "summary": "SDG&E misclassified donation payments and costs incurred to support activities to influence public opinion with regard to legislation. SDG&E’s accounting resulted in such expenses being incorrectly included in accounts that were wholesale transmission formula rate inputs. This led the company to overstate its wholesale transmission revenue requirement and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 8, "title": "Accounting for Outside Services Employed", "summary": "SDG&E improperly accounted for external consultant fees incurred to support general services not applicable to a particular operating function. SDG&E’s accounting resulted in expenses being incorrectly included in an account that is a wholesale transmission formula rate input. This led the company to overstate its wholesale transmission revenue requirement and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 9, "title": "Filing of Tariff Records", "summary": "SDG&E did not properly file all Tariff Records, as required, in the Commission’s electronic tariff (eTariff) database. Specifically, SDG&E’s eTariff filing omitted Attachment 2, its Formula Rate Spreadsheet, from its tariff filed in the eTariff database. This impacted interested parties’ ability to access and review the attachment through the Commission’s eTariff Public Viewer.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 10, "title": "Premature Destruction or Loss of Records", "summary": "SDG&E could not verify the existence of an asset, or provide documentation associated with the asset’s cost, that was recorded in Account 154, Plant Materials and Operating Supplies. SDG&E’s inability to produce the documentation represents an instance of premature destruction or loss of records.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Filing Associated with Electric Plant Purchased", "summary": "SDG&E did not file its proposed journal entries for the purchase of electric plant within six months, as required. This hindered the Commission’s and other interested parties’ ability to timely review and monitor the transaction. 5 D.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Depreciation", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2020-07-16_columbia-gas-of-pennsylvania_pa-mo-audit", "company": "Columbia Gas of Pennsylvania, Inc.", "company_raw": "Columbia Gas of Pennsylvania, Inc.", "docket": "D-2019-3011582", "docket_full": null, "issued_date": "2020-07-16", "source_page_url": "https://www.puc.pa.gov/press-release/2020/puc-releases-columbia-gas-audit-report-and-implementation-plan/", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1670369.pdf", "captured_at": "2026-06-08", "source_note": "Management & Operations Audit of Columbia Gas of Pennsylvania, Inc., PA PUC Bureau of Audits; PUC publication 2020-07-16, Docket No. D-2019-3011582; 18 recommendations. PDF: puc.pa.gov/pcdocs/1670369.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 92, "scanned_pages": [ 1, 92 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 8, "findings": [ { "index": 1, "title": "Executive Management and Organizational Structure", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Perform and retain documentation of span of control analysis upon completion of the reorganization at year-end 2020.", "source_page": 16 }, { "number": 2, "text": "Analyze processes where data is being reported on by a different group than those responsible for the business activities to ensure that appropriate levels of communication and review are maintained.", "source_page": 16 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 2, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Formally record and retain minutes of all NGD and CPA management committee meetings during which corporate governance activities are performed. Alternatively, establish an Executive Committee for the NGD and CPA Boards of Directors, respectively, which would record and retain meeting minutes.", "source_page": 20 } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Affiliated Interests and Cost Allocations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Develop and implement controls to ensure that borrowing activities comply with regulatory approvals and notification requirements.", "source_page": 28 }, { "number": 5, "text": "Develop and implement a review schedule to regularly update the NCSC CAM consulting the NARUC Guidelines for Cost Allocations and Affiliate Transactions.", "source_page": 28 }, { "number": 6, "text": "Review and strengthen internal control subsequent to the NCSC accounting function reorganization.", "source_page": 28 }, { "number": 7, "text": "Develop and implement cost allocation training for employees subsequent to the review and update of the CAM.", "source_page": 28 } ], "themes": [ "Affiliate / intercompany transactions", "Workforce, training & succession planning", "Internal audit & internal controls" ], "cost_to_customers": true }, { "index": 4, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise the Dividend Policy to provide advance notice, including explanation of rationale, to the Commission whenever a dividend payment would exceed 85% of net income.", "source_page": 38 }, { "number": 9, "text": "Include an O&M budget variance section that requires documented explanations when budget variances fall outside of defined variance tolerance levels in the O&M Policy.", "source_page": 38 }, { "number": 10, "text": "Update the delegation of authority table to include approval levels for internal transactions.", "source_page": 39 } ], "themes": [ "Internal audit & internal controls", "Dividend policy & capital management" ], "cost_to_customers": false }, { "index": 5, "title": "Financial Management (Continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise the Treasury Operations Payment Guidelines, the O&M Policy, the Delegation of Authority Table, and Cash Collections Policy to include a responsibility and scope section.", "source_page": 39 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 6, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Develop and implement a review schedule to ensure the metering and billing policies and procedures are kept current.", "source_page": 59 }, { "number": 13, "text": "Implement various strategies to reduce arrearage levels such as increasing CAP enrollment and effective calculation of internal arrearage data to appropriately monitor and manage arrearage performance.", "source_page": 59 }, { "number": 14, "text": "Develop and implement net collection goals with which to manage third-party collection efforts by benchmarking with similar utilities.", "source_page": 59 }, { "number": 15, "text": "Develop and implement a documented TOS program.", "source_page": 59 }, { "number": 16, "text": "Complete an analysis of the third-party retention application to evaluate program efficacy in reducing CSR turnover rates by December 31, 2020.", "source_page": 59 } ], "themes": [ "Customer service & billing" ], "cost_to_customers": false }, { "index": 7, "title": "Human Resources", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Analyze influencing factors when developing future safety performance targets to ensure goals are set at challenging, attainable levels while continuing to prioritize the safety culture to bolster continuous improvement toward long-term safety performance goals.", "source_page": 73 } ], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Fleet Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Develop and regularly review a historical summary report of annual vehicle utilization data to ensure optimal fleet efficiency.", "source_page": 76 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Customer service & billing", "Dividend policy & capital management", "Internal audit & internal controls", "Inventory, materials & fleet", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-07-15_national-fuel-gas-supply-corporation_fa19-6", "company": "National Fuel Gas Supply Corporation", "company_raw": "National Fuel Gas Supply Corporation (FA19-6)", "docket": "FA19-6", "docket_full": "FA19-6-000", "issued_date": "2020-07-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200715-3008&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200715-3008", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 55, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2015 to December 31, 2018", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2", "501-G" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "National Fuel did not correctly derive the average daily short-term debt component of its AFUDC rate calculation, as it only considered a portion of the short-term debt borrowed in the month such debt was incurred. National Fuel also incorrectly applied the annual AFUDC rate it calculated to the period March through February of each year, rather than January through December, as specified in the Commission’s regulations. As a result, the AFUDC rates calculated and used exceeded the maximum annual AFUDC rates allowed by the Commission in years when short-term debt was outstanding for the entire year. For those years, this resulted in an over- accrual of AFUDC, which overstated gas plant in service and associated amounts for depreciation and accumulated deferred income taxes.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Nonoperating and Operating Expenses", "summary": "National Fuel improperly accounted for certain nonoperating expenses in operating expense accounts, including costs for charitable contributions, penalties, and lobbying activities. National Fuel also improperly capitalized membership dues and lobbying expenses as a cost of construction. This accounting treatment resulted in overstating operating expenses and gas plant in service, which could impact future cost recoveries from customers, absent other procedures and controls.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Strengthen accounting procedures and controls to ensure it properly records operating and nonoperating expenses consistent with Commission accounting instructions, including intercompany cost allocations.", "source_page": null }, { "number": 6, "text": "Train employees responsible for account coding and assignment to ensure proper classification upon initial entry into the accounting system.", "source_page": null }, { "number": 7, "text": "Reclassify all nonoperating expense activities (e.g., donations, penalties, lobbying) from operating to nonoperating expense accounts for the current year. Additionally, reclassify all operating and nonoperating expense activities capitalized during the audit period and to the present to the appropriate operating or nonoperating expense accounts. Make appropriate adjustments to National Fuel’s plant accounts and to the depreciation, amortization, tax and other accounts impacted by the reclassification of such previously capitalized nonoperating expenses. Provide proposed adjusting entries and supporting documentation for accounting reclassification to DAA for review within 30 days of issuance of this audit report. Also provide a summary of the steps taken to perform the review and to make the accounting determinations.", "source_page": null }, { "number": 8, "text": "After receiving from DAA the results from its review of the proposed accounting entries and supporting documentation, adjust the comparative financial statements and include footnote disclosures to explain changes in the presentation of nonoperating costs and affiliate transactions in National Fuel’s next FERC Form No. 2. Valuation Method Used for System Gas Activities", "source_page": null }, { "number": 9, "text": "Revise accounting policies and procedures to ensure it values system gas at the current market price consistent with its Tariff and the fixed asset method of accounting.", "source_page": null }, { "number": 10, "text": "Make necessary adjustments to remove any undervaluation of encroachments on system gas for each affected account for the current year. Submit calculations and accounting entries supporting any adjustments made for audit staff’s review. Provide proposed entries and documentation for account revaluations to DAA for review within 30 days of issuance of this audit report.", "source_page": null }, { "number": 11, "text": "After receiving from DAA the results from its review of proposed accounting entries and supporting documentation, adjust the comparative financial statements and include footnote disclosures to explain changes in the valuation of system gas in National Fuel’s next FERC Form No. 2.", "source_page": null } ], "themes": [ "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 3, "title": "Valuation Method Use for System Gas Activities", "summary": "National Fuel improperly valued certain system gas activities at 90 percent of the Cash- Out Index Price, rather than 100 percent of the Cash-Out Index. As a result, National Fuel understated the balances in Account 117.4, Gas Owed to System Gas, and various operating expense accounts used to record system gas activities under the fixed asset method. National Fuel also improperly calculated the October 2018 production Monthly Index Price, which resulted in it using a higher index price and overpaying a non-affiliated shipper when cashing out its imbalance.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Fuel and Lost and Unaccounted for Gas", "summary": "National Fuel improperly recorded amounts for lost and unaccounted for gas (LAUF) and gas used for underground storage compressor stations in a transmission expense account rather than in production and gas storage expense accounts. Additionally, National Fuel recorded the cost of gas purchased to replace system gas encroachments in the incorrect production gas supply expense account. National Fuel’s improper account classifications reduced the transparency of these gas activities reported in the FERC Form No. 2.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise its accounting policies and procedures for these gas activities to ensure consistency with Commission accounting instructions.", "source_page": null }, { "number": 13, "text": "Communicate and provide necessary training for affected personnel, as needed, on these revised policies and procedures.", "source_page": null }, { "number": 14, "text": "Reclassify all amounts associated with these system gas activities to the correct accounts for the current year. Submit a copy of the accounting entries and supporting documentation to DAA for review within 30 days of issuance of this audit report.", "source_page": null }, { "number": 15, "text": "Include a footnote disclosure to explain changes in the presentation of imbalances in its next annual FERC Form No. 2 filing.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Shipper Imbalances and Cash Outs", "summary": "National Fuel improperly netted shipper imbalance payables and receivables in Account 174, Miscellaneous Current and Accrued Assets. National Fuel also improperly netted imbalance cash-out settlement losses and gains in Account 495, Other Gas Revenues and Account 182.3, Other Regulatory Assets. National Fuel’s netting reduced the transparency of these gas activities reported in the FERC Form No. 2. D. Summary of", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise its accounting policies and procedures for imbalances and cash-outs to ensure consistency with Commission requirements.", "source_page": null }, { "number": 17, "text": "Communicate and provide necessary training for affected personnel, as needed, on updated policies and procedures.", "source_page": null }, { "number": 18, "text": "Reclassify amounts associated with imbalances payables and receivables and gains and losses to the correct accounts for the current year. Submit a copy of the accounting entries and supporting documentation to DAA for review within 30 days of issuance of this audit report.", "source_page": null }, { "number": 19, "text": "Include a footnote disclosure to explain changes in the presentation of imbalances in National Fuel’s next annual FERC Form No. 2 filing. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-07-07_pnm-resources-inc_pa18-1", "company": "PNM Resources, Inc.", "company_raw": "PNM Resources, Inc. (PA18-1)", "docket": "PA18-1", "docket_full": "PA18-1-000", "issued_date": "2020-07-07", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200707-3025&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200707-3025", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 67, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2015 to December 31, 2019", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 13, "findings": [ { "index": 1, "title": "Independent Functioning of PNM’s Transmission Function", "summary": "During the audit period, upon its Wholesale Power Merchant (WPM) function’s request, PNM’s transmission function employees procured Point-to-Point (PTP) transmission service on certain paths for WPM function employees, contrary to the Commission’s Independent Functioning Rule. As a result, PNM’s transmission function employees conducted a marketing function and did not function independently of its marketing function employees.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Enhance Standards of Conduct training for all applicable employees.", "source_page": null }, { "number": 2, "text": "Develop and implement controls to limit, monitor and document non-OASIS communications between PNM’s transmission and WPM functions.", "source_page": null }, { "number": 3, "text": "Perform quarterly reviews using controls, monitoring, and documentation developed in response to Recommendation 2 listed above.", "source_page": null }, { "number": 4, "text": "Provide to DAA a summary of the above-described review in a quarterly compliance report for two consecutive quarters after this audit report is issued.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Cost-Based Sales", "summary": "PNM incorrectly used estimated transmission costs to price certain cost-based energy sales. These estimated costs did not reflect the actual transmission costs and resulted in PNM overcharging a transmission customer by approximately $121,500.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Refund the overcharged amount of $121,500 to the affected customer in a timely manner.", "source_page": null }, { "number": 6, "text": "Develop and implement procedures for validating cost-based sale prices to ensure that these prices reflect the actual cost of incremental resources including transmission cost.", "source_page": null }, { "number": 7, "text": "After the new process is adopted, provide validation results in a quarterly compliance report to DAA for two consecutive quarters after this audit report is issued to demonstrate the new process works consistently.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Use of Secondary Network Transmission Service", "summary": "During the audit period, PNM’s transmission function improperly allowed its WPM function to use secondary network transmission service to deliver energy outside of PNM’s control area. For most of these instances, WPM used secondary network transmission service to deliver energy to two generation plants located outside of PNM’s control area in order to facilitate station service at those locations. As a result, PNM did not follow the requirements of its OATT associated with the use of secondary network transmission service.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Enhance controls to ensure that WPM employees only use secondary network transmission service to serve PNM native load.", "source_page": null }, { "number": 9, "text": "Develop and implement processes and procedures to validate secondary network transmission service requests for delivering power to any intermediate points of delivery outside the PNM control area and ensure the requests are ultimately to serve the designated network load prior to confirming the request.", "source_page": null }, { "number": 10, "text": "Develop and implement processes and procedures to review e-tags that have a transmission segment(s) associated with a Network Integration Transmission Service (NITS) request to ensure the proper use of transmission service.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Termination of Network Resources", "summary": "PNM did not fully implement Commission-approved North American Energy Standards Board standards that require network customers to submit terminations (temporary and indefinite) of network resources through OASIS in a timely manner. Instead, PNM continued to allow its network customers to submit terminations of network resources outside of OASIS for more than two years after the Order No. 676-H deadline of March 1, 2017.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Develop and implement processes and procedures to ensure use of NITS on OASIS template requirements adopted in Order 676-H.", "source_page": null }, { "number": 12, "text": "Provide training with respect to the processes and procedures developed in response to Recommendation 11. Asset Retirement Obligations", "source_page": null }, { "number": 13, "text": "Develop and implement processes and procedures to prevent ARO costs from being included in PNM’s annual revenue requirement and being passed on through PNM’s formula rate mechanism to customers without the Commission’s approval. Allowance for Funds Used During Construction", "source_page": null }, { "number": 14, "text": "Revise its procedures to ensure that its AFUDC rate calculation is consistent with Electric Plant Instruction No. 3(17), Order Nos. 561 and 561-A, and other applicable Commission accounting regulations.", "source_page": null }, { "number": 15, "text": "Revise its procedures to exclude the underlying “other interest” from the short- term debt rate determination used when calculating its AFUDC rate.", "source_page": null }, { "number": 16, "text": "Revise procedures to ensure that Account 216.1, Unappropriated Undistributed Subsidiary Earnings, is excluded from equity components used to derive its AFUDC rate.", "source_page": null }, { "number": 17, "text": "Revise procedures to ensure that the long-term debt data reported by PNM on its FERC Form No. 1 submissions are used to compute the long-term debt rate used by PNM for calculating PNM’s AFUDC rate.", "source_page": null }, { "number": 18, "text": "Provide training to PNM’s staff on the revised AFUDC accounting and rate calculation method. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null }, { "number": 19, "text": "Make adjustments within 60 days of receiving the final audit report to all impacted accounts, for the period January 1, 2015 to December 31, 2019, including Account 101, Electric Plant in Service, and the accounts for accumulated depreciation, ADIT, and retained earnings, and submit these adjustments to DAA for review and approval. Also, include in this submission to DAA the impact to PNM’s Annual Transmission Revenue Requirement produced by PNM’s formula rate as a result of changes to these accounts.", "source_page": null }, { "number": 20, "text": "Submit a refund analysis, within 60 days of receiving the final audit report, to DAA for review that explains and details the following: (1) calculation of refunds to PNM’s wholesale customers since January 1, 2015, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to receive refunds; and (5) period(s) for which refunds will be made.", "source_page": null }, { "number": 21, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 22, "text": "Refund the amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Asset Retirement Obligations (ARO)", "summary": "PNM did not obtain Commission approval in advance of recovering asset retirement obligation costs in its transmission formula rate calculations. Also, PNM did not file its accounting entries with the Commission to reclassify approximately $37 million from Account 108, Accumulated Provision for Depreciation of Electric Utility Plant (Major Only) to Account 435, Extraordinary Deductions.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 6, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "PNM’s methods for calculating and accounting for its AFUDC rate were deficient and caused PNM’s AFUDC to exceed the maximum AFUDC permitted by the Commission’s regulations, as follows: • PNM improperly included in its short-term debt rate an amount labeled “other interest,” which represented the interest recorded against transmission and interconnection study advances paid to PNM. • PNM incorrectly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, as part of the equity component for the purpose of computing its AFUDC rate. • PNM combined the costs of all debt issuances, rather than individually computing the costs of each debt issuance, to determine the weighted cost of long-term debt. As a result of these methods, PNM overstated AFUDC by approximately $443,000 for 2015 and approximately $1,151,000 for 2016.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 7, "title": "Accounting for Commitment Fees", "summary": "PNM improperly accounted for upfront and quarterly commitment fees that it paid for a credit facility, in Accounts 428, Amortization of Debt Discount and Expense, and 431, Other Interest Expense, respectively, and included these items in its calculation of short-term debt interest expense used to compute its AFUDC rate.", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Revise its procedures so as to exclude upfront and quarterly commitment fees from the cost of short-term debt when calculating its AFUDC rate.", "source_page": null }, { "number": 24, "text": "Revise its procedures to record the upfront and quarterly commitment fees excluded from AFUDC rate calculations in Account 930.2, Miscellaneous General Expenses.", "source_page": null } ], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 8, "title": "Production-Related Remediation Expenses", "summary": "PNM improperly accounted for remediation expenses related to its Santa Fe and Person Generating Stations in Account 930.2, Miscellaneous General Expenses. Since these expenses are production-related expenses, they should have been recorded in Account 506, Miscellaneous Steam Power Expenses (Major Only).", "is_other_matter": false, "recommendations": [ { "number": 25, "text": "Revise its accounting policies to ensure that production-related remediation expenses are accounted for in production expense accounts, consistent with the Commission’s accounting regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "OASIS Posting of Transmission Schedules", "summary": "PNM improperly posted certain transmission schedules associated with its transmission function and WPM as non-affiliated transactions on OASIS rather than affiliated transactions.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Develop and implement processes and procedures to verify schedules against non-OASIS reservations as part of its e-tag validation process to ensure the accuracy of all attributes, including the “Affiliate” flag.", "source_page": null } ], "themes": [ "Informational postings", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 10, "title": "Short-Term Transmission Capacity Reassignments", "summary": "PNM did not execute transmission service agreements governing 15 non-affiliated transmission capacity reassignments prior to commencing the reassigned transmission service. Also, PNM did not report these reassignments in its Electric Quarterly Report (EQR) filings.", "is_other_matter": false, "recommendations": [ { "number": 27, "text": "Develop and implement processes and procedures to ensure that transmission service agreements are executed prior to confirming reassignments of transmission capacity.", "source_page": null }, { "number": 28, "text": "Refile the affected EQR filings in coordination with the refilings to be undertaken pursuant to Recommendation 31 in Finding 10 of this audit report.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 11, "title": "EQR Filing Requirements", "summary": "PNM’s EQR filings contained numerous reporting errors including the improper reporting of cost-based power sales and unreported capacity reassignments. Other Matters", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Enhance EQR filing procedures to ensure PNM reports data accurately and completely, and consistently complies with Commission EQR filing guidance.", "source_page": null }, { "number": 30, "text": "Provide training on preparing and submitting EQR filings in accordance with Commission EQR filing guidance to personnel responsible for performing and overseeing these functions.", "source_page": null }, { "number": 31, "text": "Begin an internal review process to examine all EQR filings made by PNM during the audit period.", "source_page": null }, { "number": 32, "text": "Correct all the errors identified during the audit as well as those discovered in its subsequent internal review process and refile the amended EQR data in a timely manner. Other Matter – Use of Transmission Service Numbers", "source_page": null }, { "number": 33, "text": "Continue to evaluate and take actions to reduce the use of TSNs.", "source_page": null }, { "number": 34, "text": "Post its TSN practices on OASIS and a list of TSNs (active and inactive) along with the intended business purpose. Other Matter – After-the-Fact (ATF) Reservation and Scheduling Practice", "source_page": null }, { "number": 35, "text": "Document its ATF review as a formal business practice and post the business practice document on OASIS in order to enhance transparency of the ATF review, including PNM’s ATF evaluation process, the approval/denial process, and information on the related transmission and ancillary service charges. E.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Use of non-OASIS Reservations", "summary": "PNM’s transmission function created Transmission Service Numbers (TSN), a subset of non-OASIS reservations, and assigned TSNs to WPM in order to facilitate scheduling of transmission service. Since TSNs are created outside of OASIS, PNM’s scheduling of transmission service using the TSNs was less transparent than typical Transmission Service Requests (TSR) created in OASIS.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "After-the-Fact Reservation and Scheduling Practice", "summary": "PNM performs an “after-the-fact” (ATF) review to determine overuse of transmission service by its transmission customers. However, this ATF review is not documented as a formal business practice and posted on OASIS. Audit staff encourages PNM to document this ATF review as a formal business practice and post the business practice document on OASIS in order to enhance transparency of the ATF review. The formal business practice should include PNM’s ATF evaluation process, the approval/denial process, and information on the related transmission and ancillary service charges. D. Summary of", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Depreciation", "Informational postings" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-07-07_new-york-independent-system-operator-inc_pa19-1", "company": "New York Independent System Operator, Inc.", "company_raw": "New York Independent System Operator, Inc. (PA19-1)", "docket": "PA19-1", "docket_full": "PA19-1-000", "issued_date": "2020-07-07", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200707-3024&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200707-3024", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 28, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2016 through December 2, 2019", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-07-02_midamerican-energy-company_fa19-2", "company": "MidAmerican Energy Company", "company_raw": "MidAmerican Energy Company (FA19-2)", "docket": "FA19-2", "docket_full": "FA19-2-000", "issued_date": "2020-07-02", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200702-3005&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200702-3005", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 20, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2016 through December 31, 2019", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 1, "findings": [ { "index": 1, "title": "Accounting for Compromise Settlements", "summary": "MEC improperly recorded a transaction related to compromise settlements in Account 920, Administrative and General Salaries, instead of Account 426.5, Other Deductions. As a result, MEC included approximately $11,000 in its formula rate computation, and the revenue requirement used to set rates for wholesale customers was overstated.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-07-02_michigan-electric-transmission-company-llc_fa19-7", "company": "Michigan Electric Transmission Company, LLC", "company_raw": "Michigan Electric Transmission Company, LLC (FA19-7)", "docket": "FA19-7", "docket_full": "FA19-7-000", "issued_date": "2020-07-02", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200702-3012&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200702-3012", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 39, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2015 to December 31, 2018", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Accounting for Lobbying Costs", "summary": "METC recorded lobbying costs associated with pensions in Account 926, Employee Pensions and Benefits, instead of in Account 426.4, Expenditures for Certain Civic, Political and Related Activities. Account 926 is included in METC’s formula rate while Account 426.4 is not. As a result, METC overstated its wholesale transmission revenue requirement used to bill transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Settlements Related to Employment Discrimination Claims", "summary": "METC incorrectly recorded $287,435 of allocated settlement costs related to employment discrimination claims from ITC Holdings, its parent holding company, in its operating expense accounts. The operating expense accounts were included in the METC’s wholesale transmission formula rate mechanism. As a result, METC overstated its wholesale transmission revenue requirement used to bill transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Abandoned Transmission Projects", "summary": "METC did not assign any engineering and supervision (E&S) costs to abandoned transmission construction projects; instead, it reallocated the associated E&S costs to ongoing transmission projects and improperly accrued AFUDC on the reallocated amounts. As a result, METC improperly accrued and recovered AFUDC on E&S costs related to abandoned transmission projects capitalized to plant in service and understated the cost of abandoned projects recorded to expense.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Donations", "summary": "METC inappropriately accounted for a donation as an operating expense. This accounting misclassification led to improper amounts being included in the inputs to METC’s wholesale transmission formula rate mechanism which resulted in METC overbilling its wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Asset Retirement Obligations", "summary": "METC failed to use the income statement and used only balance sheet accounts to record Asset Retirement Obligations (AROs) related to its utility plant assets.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "FERC Form No. 1 Reporting", "summary": "METC did not properly follow the instructions of the FERC Form No. 1 and therefore in some cases did not report all the required information in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "MN", "source": "Minnesota Office of Administrative Hearings", "doc_type": "ALJ findings of fact, conclusions of law & recommendation (gas rate case)", "id": "2020-06-30_great-plains-natural-gas_mn-g-004-gr-19-511-alj-report", "company": "Great Plains Natural Gas Co. (Division of Montana-Dakota Utilities Co.)", "company_raw": "Great Plains Natural Gas Co. (Division of Montana-Dakota Utilities Co.)", "docket": "OAH 65-2500-36528 / MPUC G-004/GR-19-511", "docket_full": null, "issued_date": "2020-06-30", "source_page_url": "https://mn.gov/oah/lawyers-and-litigants/administrative-law/opinion-archive.jsp", "pdf_download_url": "https://mn.gov/oah/assets/2500-36528-great-plains-puc-rate-increase-report_tcm19-439099.pdf", "captured_at": "2026-06-08", "source_note": "Minnesota OAH ALJ report in Great Plains Natural Gas (Montana-Dakota Utilities division) rate case, MPUC G-004/GR-19-511 (OAH 65-2500-36528), dated 2020-06-30. PDF: mn.gov/oah/assets/2500-36528-...pdf.", "archived_via": null, "page_count": 104, "scanned_pages": [ 84 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NJ", "source": "NJ Board of Public Utilities", "doc_type": "affiliate-transactions, operational/financial performance & management audit (Liberty Consulting)", "id": "2020-03-11_atlantic-city-electric_nj-affiliate-management-audit", "company": "Atlantic City Electric Company", "company_raw": "Atlantic City Electric Company", "docket": null, "docket_full": null, "issued_date": "2020-03-11", "source_page_url": "https://www.nj.gov/bpu/about/divisions/audits/auditreports.html", "pdf_download_url": "https://www.nj.gov/bpu/pdf/auditpdfs/2020%20ACE%20Final%20Audit%20Report.pdf", "captured_at": "2026-06-08", "source_note": "NJ BPU audit (Liberty Consulting Group): Audit of Affiliated Transactions and Operational and Financial Performance and a Management Audit of Atlantic City Electric. Dated March 11, 2020. 705 pp. Page 1 verified.", "archived_via": null, "page_count": 705, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-02-21_louisville-gas-and-electric-company-and-kentucky_pa19-4", "company": "Louisville Gas and Electric Company and Kentucky Utilities Company", "company_raw": "Louisville Gas and Electric Company and Kentucky Utilities Company (PA19-4)", "docket": "PA19-4", "docket_full": "PA19-4-000", "issued_date": "2020-02-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200221-3036&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200221-3036", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 24, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2016, through October 31, 2019", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2020-01-09_oneok-ngl-pipeline-l-l-c_fa18-1", "company": "ONEOK NGL Pipeline, L.L.C.", "company_raw": "ONEOK NGL Pipeline, L.L.C. (FA18-1)", "docket": "FA18-1", "docket_full": "FA18-1-000", "issued_date": "2020-01-09", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20200109-3025&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20200109-3025", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 43, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2015 to December 31, 2018", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Page 700 Reporting", "summary": "ONEOK NGL improperly reported depreciation expense, AFUDC depreciation, and related rate base balances on its Page 700, Annual Cost- of-Service Based Analysis Schedule. Also, ONEOK NGL improperly included Account 187, Construction Work in Progress (CWIP), balances in the calculation of Rate Base – Original Cost on line 5a.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen processes, procedures, and controls surrounding the preparation and review of its FERC Form No. 6. The policies and procedures should ensure complete and accurate reporting of Page 700 data.", "source_page": null }, { "number": 2, "text": "Develop and implement review procedures to ensure that personnel are performing thorough reviews of FERC Form No. 6 information, including Page 700, prior to submittal to the Commission.", "source_page": null }, { "number": 3, "text": "Provide training on updated processes, procedures, and controls surrounding the preparation and review of its FERC Form No. 6.", "source_page": null }, { "number": 4, "text": "Provide DAA with an analysis assessing the impact of these reporting errors to the FERC Form No. 6 for 2005-2018.", "source_page": null }, { "number": 5, "text": "Upon receiving DAA staff’s review and response, file an updated FERC Form No. 6 for 2015, 2016, 2017, and 2018 that reflects the results of this analysis, including notes that explain the corrections being made.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Carrier Property", "summary": "ONEOK NGL improperly accounted for certain inactive and abandoned pipeline assets as carrier property in Account 30, Carrier Property.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Revise accounting policies and procedures to ensure all components of carrier property, such as abandoned and inactive assets, are properly accounted for in accordance with Commission requirements. The procedures should include established communications protocols among the accounting staff that are responsible for asset retirements and implementation of a secondary review of all changes to carrier property.", "source_page": null }, { "number": 7, "text": "Reclassify all inactive carrier property recorded in Account 30 that will not be used in ONEOK NGL’s future pipeline operations to Account 34.", "source_page": null }, { "number": 8, "text": "Reclassify all abandoned pipeline assets recorded in Account 30 to Account 31.", "source_page": null }, { "number": 9, "text": "Perform an analysis to determine the full scale of Page 700 impacts, including impacts to Line 1, Operating and Maintenance Expense; Line 2, Depreciation Expense; Lines 5a-5d, Rate Base; and other Lines on Page 700, and provide this analysis to DAA staff for further review. 10.Upon receiving DAA staff’s review and response, file an updated FERC Form No. 6 for 2015, 2016, and 2017 that reflects the results of this analysis, including notes that explain the corrections being made.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 3, "title": "Scheduling of Nominations", "summary": "ONEOK NGL improperly transported product on its FERC gathering lines under FERC Tariff No. 9 without nominations, which are required under Item No. 45 - Notice of Tenders.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 4, "title": "Incorrect Tariff Rate Charge", "summary": "ONEOK NGL improperly accounted for interstate transportation revenues on its North Line pipeline when ONEOK NGL incorrectly charged an interstate rate, instead of an intrastate rate, from January 2016 to April", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 5, "title": "As the interstate rate was higher than the intrastate rate, ONEOK NGL overcharged for these deliveries and overstated interstate transportation revenues.", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Pipeline Leases", "summary": "ONEOK NGL improperly recorded revenue for the lease of a pipeline asset owned by its affiliate as rental revenue in Account 250, Rental Revenue. The error resulted in overstatements in Account 250 of $3.1 million, $4.2 million, and $4.3 million in 2015, 2016, and 2017, respectively.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 7, "title": "Use of Incorrect Depreciation Rates", "summary": "ONEOK NGL improperly applied depreciation rates for carrier property assets that were not approved by and on file with the Commission. As a result, ONEOK NGL overstated depreciation expense and misreported amounts on its Page 700 from 2015-2017. D. Summary of", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "state_rate_case", "jurisdiction": "FL", "source": "Florida Public Service Commission", "doc_type": "final order on conservation cost recovery", "id": "2019-11-25_florida-iou_fl-20190002-eg-psc-2019-0504-fof-eg", "company": "Florida investor-owned utilities (energy conservation cost recovery)", "company_raw": "Florida investor-owned utilities (energy conservation cost recovery)", "docket": "20190002-EG", "docket_full": null, "issued_date": "2019-11-25", "source_page_url": "https://www.psc.state.fl.us/document-detail?orderNum=PSC-2019-0504-FOF-EG", "pdf_download_url": "https://www.psc.state.fl.us/library/Orders/2019/11112-2019.pdf", "captured_at": "2026-06-07", "source_note": "Florida PSC Order No. PSC-2019-0504-FOF-EG (Final Order), Docket No. 20190002-EG, 'Energy conservation cost recovery clause', issued November 25, 2019 (11 pp) — the Commission's annual review of energy-conservation / demand-side-management program cost recovery, approving the conservation cost-recovery amounts, tariffs, and factors for 2020 for Florida's investor-owned utilities. Listed for reference (metadata-only). Source: Florida PSC document clerk, document 11112-2019 (psc.state.fl.us/library/Orders/2019/11112-2019.pdf).", "archived_via": null, "page_count": 11, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "FL", "source": "Florida Public Service Commission", "doc_type": "final order on environmental cost recovery", "id": "2019-11-22_florida-iou_fl-20190007-ei-psc-2019-0500-fof-ei", "company": "Florida investor-owned electric utilities (environmental cost recovery)", "company_raw": "Florida investor-owned electric utilities (environmental cost recovery)", "docket": "20190007-EI", "docket_full": null, "issued_date": "2019-11-22", "source_page_url": "https://www.psc.state.fl.us/document-detail?orderNum=PSC-2019-0500-FOF-EI", "pdf_download_url": "https://www.psc.state.fl.us/library/Orders/2019/11080-2019.pdf", "captured_at": "2026-06-07", "source_note": "Florida PSC Order No. PSC-2019-0500-FOF-EI (Final Order), Docket No. 20190007-EI, 'Environmental cost recovery clause', issued November 22, 2019 (11 pp) — the Commission's annual review of the reasonableness of environmental-compliance project costs and the resulting cost-recovery factors for Florida's investor-owned electric utilities (Section 366.8255, Fla. Stat.). Listed for reference (metadata-only). Source: Florida PSC document clerk, document 11080-2019 (psc.state.fl.us/library/Orders/2019/11080-2019.pdf).", "archived_via": null, "page_count": 11, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-11-21_exelon-corporation_pa18-3", "company": "Exelon Corporation", "company_raw": "Exelon Corporation (PA18-3)", "docket": "PA18-3", "docket_full": "PA18-3-000", "issued_date": "2019-11-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20191121-3049&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20191121-3049", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 40, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 through March 26, 2019", "industry": "electric", "audit_type": "non-financial", "functions": [ "transmission" ], "forms": [ "1", "60" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Merger-Related Regulatory Assets", "summary": "BG&E improperly included the amortization of merger-related regulatory assets approved by a retail regulator in wholesale transmission formula rates. As a result, BG&E overstated its wholesale transmission revenue requirements and overbilled its wholesale customers by approximately $1.4 million.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Transmission Formula Rate Allocators", "summary": "Exelon’s public utilities improperly included merger-related costs in their transmission formula rate allocators when they computed wholesale transmission revenue requirements. As a result, Exelon’s public utilities overstated their wholesale transmission revenue requirements, which led to overbilling wholesale transmission customers by approximately $333,056.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Merger Commitment Costs", "summary": "Exelon’s public utilities improperly included merger commitment costs for the Exelon and PHI merger in their transmission revenue requirements. As a result, Exelon’s public utilities overstated their transmission revenue requirements, which led to overbilling wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Amortization of Retail Regulatory Assets", "summary": "Exelon’s public utilities improperly recorded the amortization of certain regulatory assets and improperly included the amortization of the regulatory assets in their wholesale transmission formula rates without Commission approval to recover such amounts. As a result, Exelon’s public utilities overstated their wholesale transmission revenue requirements and overbilled their wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-11-15_national-grid-usa_fa16-2", "company": "National Grid USA", "company_raw": "National Grid USA (FA16-2)", "docket": "FA16-2", "docket_full": null, "issued_date": "2019-11-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20191115-3010&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20191115-3010", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 53, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [], "forms": [ "1", "3-Q", "60" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Depreciation Expense of Service Companies Assets", "summary": "National Grid USA Service Company (NGUSASCo) and National Grid Engineering & Survey Inc. (NGE&S) used improper composite depreciation rates to determine depreciation expense accrued on certain property. This led the two service companies to accrue depreciation expense at rates not consistent with Commission accounting rules. The service companies then allocated and billed the incorrectly calculated depreciation expense to their public utility and nonutility affiliates. As a result, amounts billed to public utility affiliates with transmission formula rates were included in the rates charged to wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 2, "title": "Cost Allocation Methodologies", "summary": "NGUSASCo and NGE&S did not consistently use their documented cost allocation methods, nor timely update their general ledger system to reflect changes in the allocation percentages actually used to bill affiliates. These errors led the service companies to over- allocate costs to certain National Grid public utility subsidiaries, and these public utilities in turn overbilled their respective wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 3, "title": "Industry Association Dues", "summary": "NGUSACo improperly accounted for and allocated a portion of the cost of its gas and electric industry associations’ membership dues to National Grid’s public utility subsidiaries. As a result, National Grid’s public utility subsidiaries improperly included the lobbying component of industry association payments in their wholesale transmission rates.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 4, "title": "Donations", "summary": "NGUSASCo improperly recorded certain donations to Account 921, Office Supplies and Expenses, and Account 930.2, Miscellaneous General Expenses, instead of Account 426.1, Donations, as required by Commission regulations. Amounts recorded in Accounts 921 and 930.2 were allocated to National Grid’s public utility subsidiaries and other affiliates and accounted for by the entities using the same accounts, and for some public utility subsidiaries were included as inputs to their respective wholesale transmission formula rate cost recovery mechanisms. As a result, in some years National Grid’s public utility subsidiaries improperly included the donations in their wholesale transmission rates. 3", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 5, "title": "Service Company Account Misclassifications", "summary": "NGUSASCo improperly accounted for various administrative and general expenses in its books and records. As a result, NGUSASCo overstated certain administrative and general accounts it billed to National Grid public utility subsidiaries, resulting in misclassifications reported in the public utilities’ FERC Form No. 1.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Reporting of Transactions with Associated (Affiliated) Companies", "summary": "National Grid’s public utility subsidiaries did not follow the instructions on page 429, Transactions with Associated (Affiliated) Companies, of the FERC Form No. 1 and as a result reported inaccurate and incomplete information for transactions with associated companies.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 7, "title": "Annual Report of Centralized Service Companies, FERC Form No. 60 (FERC Form No. 60)", "summary": "NGUSASCo and NGE&S did not complete the FERC Form No. 60 reports filed during the audit period in accordance with the general and schedule instructions of the form. D.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2019-11-01_citizens-electric-wellsboro-electric-valley-energy_pa-mo-audit", "company": "Citizens' Electric Company of Lewisburg / Wellsboro Electric Company / Valley Energy, Inc.", "company_raw": "Citizens' Electric Company of Lewisburg / Wellsboro Electric Company / Valley Energy, Inc.", "docket": "D-2019-3007883", "docket_full": null, "issued_date": "2019-11-01", "source_page_url": "https://www.puc.pa.gov/press-release/2019/puc-makes-management-recommendations-to-citizens-electric-wellsboro-electric-and-valley-energy-releases-audit-and-implementation-plan", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1648244.pdf", "captured_at": "2026-06-18", "source_note": "Management & Operations Audit of Citizens' Electric Company of Lewisburg, Wellsboro Electric Company, and Valley Energy, Inc., PA PUC Bureau of Audits; PUC publication November 2019, Docket No. D-2019-3007883. PDF: puc.pa.gov/pcdocs/1648244.pdf. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 68, "scanned_pages": [ 1, 68 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 4, "findings": [ { "index": 1, "title": "Executive Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Execute the proposed plan to assign the Wellsboro CEO position to a qualified individual able to devote the necessary time to provide adequate leadership to Wellsboro by year end 2019.", "source_page": 17 }, { "number": 2, "text": "Review all schedules in Valley Energy’s Annual Report to the PUC for accurate reporting and determine and correct any sources of errors.", "source_page": 17 } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Reduce the number of unknown outages at Wellsboro by providing additional resources to assist in investigating unknown outages and/or through supplemental training for field operations employees.", "source_page": 36 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 3, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Develop a business case to assess the options to create a C&T position to oversee the cybersecurity function for the C&T Companies.", "source_page": 48 } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "index": 4, "title": "Human Resources", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Establish minority employee and MWDBE vendor utilization goals and submit annual diversity reports to the PUC for Wellsboro Electric Company.", "source_page": 52 } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Workforce, training & succession planning" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-09-27_cleco-power-llc_fa18-3", "company": "Cleco Power LLC", "company_raw": "Cleco Power LLC (FA18-3)", "docket": "FA18-3", "docket_full": "FA18-3-000", "issued_date": "2019-09-27", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190927-3042&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190927-3042", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 72, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2014 through June 2019", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "60" ], "finding_count": 1, "findings": [ { "index": 1, "title": "• Transmission Revenue Credits", "summary": "Cleco Power improperly recorded rental revenue from its affiliate in Account 455, Interdepartmental Rents, instead of in Account 454, Rent from Electric Property. As a result, Cleco Power understated the revenue credits included in its wholesale transmission formula rates, which led to an overstatement of its wholesale transmission revenue requirements by approximately $100,000 and overbilled its wholesale transmission customers from 2016 to 2018. • Accounting for Electric Generation Renewable Expenses – Cleco Power improperly recorded operating and maintenance costs associated with an electric generation renewable plant in Account 923, Outside Services Employed, instead of in Account 553, Maintenance of Generating and Electric Equipment (Major Only). Cleco Power improperly included the operating and maintenance costs associated with the electric generation renewable plant in its transmission formula rate for the purpose of computing billings to wholesale transmission customers. As a result, Cleco Power overstated its wholesale transmission revenue requirements by approximately $124,000 and overbilled wholesale transmission customers from 2015 to 2018. • Accounting for Jointly Owned Assets – Cleco Power improperly recorded the cost of a transmission asset it did not own in Account 353, Station Equipment, and improperly included the cost of the transmission asset it did not own in its transmission formula rate for the purpose of computing billings to wholesale transmission customers. As a result, Cleco Power overstated its wholesale transmission revenue requirements by approximately $89,000 and overbilled wholesale transmission customers from 2014 to 2016. • Accounting for Legal Settlements – Cleco Power improperly recorded $100,000 for compromised settlement payments it made for a discriminatory employment practice suit in Account 921, Office Supplies and Expenses, instead of Account 426.5, Other Deductions. As a result, Cleco Power overstated its wholesale transmission revenue requirements and overbilled its wholesale transmission customers for that amount. • Electric Plant Held for Future Use – Cleco Power improperly recovered the cost of generation, distribution and gas pipeline assets recorded in Account 105, Electric Plant Held for Future Use, through its wholesale transmission formula rates. As a result, Cleco Power overstated its wholesale transmission revenue requirement by approximately $158,000 and overbilled wholesale transmission customers from 2014 to 2018. • Other Accounting Misclassifications – Cleco Power improperly accounted for various expenses totaling approximately $481,000 in its books and records from 2014 to 2018. These expenses were included in wholesale transmission formula rate determinations. As a result, Cleco Power overstated its wholesale transmission revenue requirement and overbilled wholesale transmission customers. • Accounting for Regulatory Assets – Cleco Power improperly recorded regulatory assets approved by the Louisiana Public Service Commission (LPSC) in Account 182.1, Extraordinary Property Losses, without Commission approval. • FERC Form No. 1 Reporting – Cleco Power did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its FERC Form No. 1 filings. D. Summary of", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-09-19_avista-corporation_pa18-2", "company": "Avista Corporation", "company_raw": "Avista Corporation (PA18-2)", "docket": "PA18-2", "docket_full": "PA18-2-000", "issued_date": "2019-09-19", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190919-3007&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190919-3007", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 48, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2015 to December 31, 2018", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Secondary Network Transmission Service", "summary": "Avista improperly reserved hourly secondary network transmission service 61 times, representing 5,233 MWh, to support off-system sales to non-network customers. Of the 61 requests, 34 requests remained confirmed, representing 3,353 MWh, while 27 requests were annulled. Of these 34 requests, 11 were scheduled for energy delivery, representing 1,395 MWh. As a result, Avista’s merchant function was not charged point-to-point (PTP) transmission charges and obtained service with a higher service priority.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Develop and implement controls to ensure that Avista neither requests nor approves network transmission service and secondary network transmission service for any purpose other than to serve network customers.", "source_page": null }, { "number": 2, "text": "Enhance training for its marketing function employees responsible for reserving and/or scheduling secondary network service to ensure that secondary network service is only reserved to serve Avista’s native load customers, unless reserved on behalf of another network customer pursuant to an executed agent agreement.", "source_page": null }, { "number": 3, "text": "Enhance training for its transmission function employees responsible for approving transmission schedules to ensure network transmission customers, including Avista’s marketing function, properly use secondary network service.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Allowance for Funds Used During Construction", "summary": "Avista’s methods for calculating and accounting for its AFUDC rate were deficient and caused Avista’s AFUDC to exceed the maximum AFUDC permitted by the Commission’s regulations, as follows: • Avista included revolving credit facility commitment fees (up-front and quarterly) as part of short-term debt interest expense to compute its AFUDC rate. Avista did not have Commission approval, required by Order No. 561-A, to include revolving credit facility commitment fees in the calculation of its AFUDC rate. • Avista incorrectly included Account 216.1, Unappropriated Undistributed Subsidiary Earnings, as part of the equity component for the purpose of computing its AFUDC rate. • Avista incorrectly included Account 219, Accumulated Other Comprehensive Income (AOCI), as part of the equity component for the purpose of computing its AFUDC rate. • Avista used monthly Equity and Long-Term Debt balances in AFUDC rate development instead of the using the balances for Equity and Long-Term Debt existing at the end of the prior year. • Avista excluded Account 234, Notes Payable to Associated Companies, in the computation of its AFUDC rate instead of including Account 234 as a short-term financing source – i.e., in the short-term debt component for purposes of calculating its AFUDC rate. • Avista accounted for the excess arising from higher state-approved AFUDC over AFUDC as computed in accordance with the Commission’s accounting regulations as a cost of plant in Account 101, Electric Plant in Service, through Account 107, Construction Work In Progress, instead of recording the excess in Account 182.3, Other Regulatory Assets. As a result of these methods, Avista overstated AFUDC by approximately $19.7 million for the period 2015 through 2017.", "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Revise and implement procedures to ensure its AFUDC rate calculation is consistent with Electric Plant Instructions No. 3(17), Order Nos. 561 and 561- A, and other applicable Commission accounting regulations.", "source_page": null }, { "number": 5, "text": "Revise and implement procedures to ensure that Account 216.1 and Account 219 are excluded from the equity components used to derive the AFUDC rate.", "source_page": null }, { "number": 6, "text": "Revise and implement procedures to ensure that the year-end amounts reported on Avista’s FERC Form No. 1 filings are used to compute the AFUDC rate in accordance with the Commission’s accounting regulations.", "source_page": null }, { "number": 7, "text": "Revise and implement procedures to ensure that the AFUDC amount capitalized as a cost of plant is computed in accordance with the Commission’s accounting regulations.", "source_page": null }, { "number": 8, "text": "Provide training to appropriate employees on AFUDC computation in accordance with the Commission’s accounting regulations and Avista’s revised procedures.", "source_page": null }, { "number": 9, "text": "Recalculate AFUDC amounts in accordance with the Commission’s accounting regulations from January 1, 2010 (effective date of current fixed transmission rates) to the present, determine the excess amount capitalized by Avista, determine the impacts on other accounts due to over-capitalization, and submit correcting journal entries to the DAA for review and approval.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Deferred Income Taxes", "summary": "AFUDC – Avista’s methods for accounting for Deferred Income Taxes related to the equity component of the AFUDC rate were deficient as follows: • Avista incorrectly recorded a debit in Account 410.1, Provision for Deferred Income Taxes, based on the amount of the equity component of AFUDC included in income Account 419.1, Allowance for Other Funds Used During Construction, and credited Account 282, Accumulated Deferred Income Taxes – Other Property. Avista should have recorded the deferred tax debit amount in Account 182.3, Other Regulatory Assets. • Avista should have recorded a gross up for the income taxes related to the equity component of AFUDC in Account 182.3, Other Regulatory Assets, and a related offset as a deferred income tax liability in Account 283, Accumulated Deferred Income Taxes – Other. As a result of the foregoing improper accounting, Avista overstated the Deferred Income Tax expense included in its Income Statement for 2015 through 2017 by approximately $8.4 million.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Revise and implement Avista’s accounting policies and procedures relating to Deferred Income Taxes to comply with the Commission’s accounting regulations.", "source_page": null }, { "number": 11, "text": "Provide training to appropriate employees on accounting procedures related to AFUDC and related income taxes.", "source_page": null }, { "number": 12, "text": "Provide the amount of Deferred Income Taxes on the AFUDC Equity Component flowed through since January 1, 2010 (effective date of current fixed transmission rates), and the amount that should have been included in Account 182.3, Other Regulatory Assets, as of December 31, 2017, and submit detailed analyses to the DAA for review and approval.", "source_page": null }, { "number": 13, "text": "Report the accounting change in 2018 including the impact on annual balances reported on prior Form No. 1 filings as a note on the next Form No. 1.", "source_page": null }, { "number": 14, "text": "Inform DAA about any state rate treatment addressing Avista’s incorrect accounting for Deferred Income Tax Expense prior to January 1, 2018. Provide details of any such state actions with supporting documentation.", "source_page": null }, { "number": 15, "text": "Submit journal entries, if appropriate, related to any state commissions’ actions to the DAA for review and approval.", "source_page": null } ], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 4, "title": "Capitalization of System Planning Costs", "summary": "Avista improperly capitalized system planning costs of approximately $2.8 million as a cost of plant through its CWIP between 2014 and 2017. When subsequently correcting this error, by removing approximately $2.6 million from the cost of plant, Avista did not remove the related accumulated provision for depreciation, current and deferred income taxes, and AFUDC.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise and implement procedures to effect correction of errors including corrections to accounts which require Commission approval.", "source_page": null }, { "number": 17, "text": "Provide enhanced training to appropriate staff on procedures for corrections including requirements to get Commission approval.", "source_page": null }, { "number": 18, "text": "Submit journal entries to a) remove the remaining over-capitalized system planning costs from the cost of plant, b) remove appropriate accumulated depreciation from accumulated provision for depreciation, and c) correct related Accumulated Deferred Income Tax Account balances, for DAA review and approval.", "source_page": null } ], "themes": [ "AFUDC / cost of capital", "Depreciation", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 5, "title": "Asset Retirement Obligations", "summary": "Avista improperly accounted for certain items related to its Asset Retirement Obligations (ARO). Specifically, Avista did not record Asset Retirement Cost (ARC) depreciation expense in Account 403.1, Depreciation Expense, and ARO accretion expense in Account 411.10, Accretion Expense. Instead, Avista recorded those expenses directly in Account 182.3, Other Regulatory Assets.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Revise and implement policies and procedures to ensure Avista properly accounts for ARO-related costs in accordance with the Commission’s accounting regulations.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 6, "title": "FERC Form No. 1 Reporting", "summary": "Avista did not comply with the instructions on page 398, Purchase and Sale of Ancillary Services, on its FERC Form No. 1 filings. This deficient reporting affected the reliability of information reported in Avista’s FERC Form No. 1 submissions. The Other Matter", "is_other_matter": false, "recommendations": [ { "number": 20, "text": "Revise and strengthen documented policies, procedures, and practices to help ensure information in its FERC Form No. 1 submissions is correct, accurate, and consistent with the instructions of the form.", "source_page": null }, { "number": 21, "text": "Provide training to staff on the revised FERC Form No. 1 policies, procedures, and practices. Also, develop a training program that supports the provision of periodic training in this area, as needed.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 7, "title": "Use of Transmission Service Numbers", "summary": "Avista used Transmission Service Numbers (TSN), in addition to Transmission Service Requests (TSR) created in OASIS, to facilitate scheduling of transmission service under certain circumstances. TSRs created in OASIS provide more transparency than TSNs, which are created outside of OASIS. During the audit, Avista significantly reduced the number of active TSNs, and Avista should continue to evaluate TSN use and reduce the use of TSNs when possible. D. Summary of", "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Continue to evaluate and take actions to reduce the use of TSNs.", "source_page": null }, { "number": 23, "text": "Provide training to transmission employees on OATT requirements and implement an ongoing process to ensure that TSNs are used for limited scheduling purposes where a valid adjacent commercial path TSR is not available in OASIS. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Capitalization vs. expense", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-09-06_ohio-power-company_fa17-2", "company": "Ohio Power Company", "company_raw": "Ohio Power Company (FA17-2)", "docket": "FA17-2", "docket_full": "FA17-2-000", "issued_date": "2019-09-06", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190906-3014&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190906-3014", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 34, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 through December 31, 2017", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "3" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Revenue Credits", "summary": "Ohio Power understated its revenue credits that are used to reduce the revenue requirement of its transmission formula rate by improperly excluding certain transmission-related revenues – specifically pole attachment revenue, causing an overstatement of its revenue requirement. This overstatement resulted in excess billings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Customer Funded Capital Projects", "summary": "Ohio Power did not properly return amounts collected in transmission rates in excess of its total investment on certain customer funded projects.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Sales of Accounts Receivable", "summary": "Ohio Power misclassified non-operating expenses related to its servicing of accounts receivables, which were sold on a non-recourse basis, as operating expenses recorded in Account 903, Customer Records and Collection Expenses. Ohio Power should have recorded these non-operating expenses in Account 426.5, Other Deductions, instead.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 4, "title": "FERC Form No. 1 Reporting", "summary": "Ohio Power did not report certain required information on select pages of its FERC Form No. 1. This reduced the transparency and usefulness of the information provided in the FERC Form No. 1.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Revise and strengthen documented policies, procedures, and practices to help ensure all schedule instructions are followed and all information is accurately reported in the FERC Form No. 1.", "source_page": null }, { "number": 17, "text": "Provide training to staff on the revised FERC Form No. 1 policies, procedures, and practices. Also, develop a training program that supports the provision of periodic training in this area. Other Matter – Accounting for Plant in Service", "source_page": null }, { "number": 18, "text": "Revise and strengthen policies and procedures to improve accounting practices for plant in service and ensure that work order expenses associated with projects that have been placed in service are transferred to appropriate plant in service accounts in a timely manner. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-08-29_xcel-energy-inc_fa17-4", "company": "Xcel Energy Inc.", "company_raw": "Xcel Energy Inc. (FA17-4)", "docket": "FA17-4", "docket_full": "FA17-4-000", "issued_date": "2019-08-29", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190829-3023&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190829-3023", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 33, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2014 through December 31, 2018", "industry": "electric", "audit_type": "financial", "functions": [], "forms": [ "1", "60" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Capitalized Software Allocation", "summary": "XES incorrectly allocated capital costs of corporate software only to the Xcel utilities. Capital costs of software should be allocated to all Xcel companies benefitting from XES’s use of the software. Xcel’s utilities were charged an excessive amount of capital software costs as a result of XES’s improper allocation.", "is_other_matter": false, "recommendations": [], "themes": [ "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 2, "title": "Allocation of Information Technology Costs", "summary": "XES used an improper allocation methodology to assign shared costs for operation, maintenance, and management of the company’s information technology network in 2016 and 2017. Use of this allocation methodology led XES to improperly charge administrative and general costs to Xcel’s utilities and led to improper billings to Xcel’s wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Information technology & systems" ], "cost_to_customers": false }, { "index": 3, "title": "Allocation of XES Income Tax Expense", "summary": "XES allocated its income tax expense only to the Xcel utilities. XES should have allocated its income tax expense to all Xcel companies benefiting from XES’s activities that caused XES to incur income tax expense.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Compromise Settlements", "summary": "XES incorrectly recorded approximately $150,000 of payments resulting from compromise settlements in its operating expense accounts, rather than in Account 426.5, Other Deductions, as required. Further, XES allocated these costs to the Xcel utilities, who also incorrectly recorded the costs in their operating expense accounts. These operating expense accounts were included in the utilities’ wholesale transmission formula rate mechanisms. As a result, Xcel’s utilities overstated their wholesale transmission revenue requirement used to bill transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Reporting of Cost Allocation Methodologies", "summary": "XES did not disclose all allocation methods used to allocate costs in its FERC Form No. 60 filings during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Capitalization vs. expense", "Form reporting (Form No. 1/2/6, Page 700)", "Information technology & systems" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-07-31_northern-states-power-company-minnesota_fa17-5", "company": "Northern States Power Company (Minnesota)", "company_raw": "Northern States Power Company (Minnesota) (FA17-5)", "docket": "FA17-5", "docket_full": "FA17-5-000", "issued_date": "2019-07-31", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190731-3033&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190731-3033", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 56, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Income Tax Receivables", "summary": "NSPM incorrectly recorded an income tax receivable that represented a refund for a tax overpayment in Account 165, Prepayments, instead of in Account 143, Other Accounts Receivable. The incorrect accounting led to an overstatement of NSPM’s rate base used in its wholesale transmission formula rate calculations and overbillings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Prepayments", "summary": "NSPM misclassified certain costs in Account 165, Prepayments, resulting in an overstatement of the account. The misclassifications in Account 165 resulted in an overstatement of NSPM’s rate base used in the wholesale transmission formula rate calculations and overbillings to wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Miscellaneous Expenses", "summary": "NSPM’s accounting classifications for some expenses were not consistent with the requirements of the Uniform System of Accounts. In addition, there were instances when the accounting misclassifications led to improper amounts being included in the wholesale transmission formula rate and NSPM overbilling its wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting Classification for Contingent Liabilities", "summary": "NSPM did not use the proper accounts to classify certain contingent liabilities in accordance with the requirements of the Uniform System of Accounts.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Depreciation Rates", "summary": "During the audit period, NSPM used depreciation rates that were not previously filed with the Commission in the development of its wholesale transmission formula rate.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 6, "title": "Accounting for Retirement Units", "summary": "NSPM inconsistently implemented a change to accounting for the retirement of transmission insulators to a retirement unit from a minor item of property, resulting in the gross balances of plant in service and the accumulated provision for depreciation being inappropriately stated in its financial reports, which adversely impacted the amounts used for billings to wholesale transmission customers. D. Summary of", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Cost of service & rates", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-06-25_transcontinental-gas-pipe-line-company-llc_fa18-2", "company": "Transcontinental Gas Pipe Line Company, LLC", "company_raw": "Transcontinental Gas Pipe Line Company, LLC (FA18-2)", "docket": "FA18-2", "docket_full": "FA18-2-000", "issued_date": "2019-06-25", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190625-3009&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190625-3009", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 60, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2014 through December 28, 2018", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2" ], "finding_count": 10, "findings": [ { "index": 1, "title": "Accounting for Replacement of Minor Items of Property", "summary": "Transco improperly accounted for the cost to replace minor items of property. Transco capitalized the cost to utility plant instead of recording it in maintenance accounts as incurred. Transco’s accounting caused utility plant to be overstated and maintenance expenses to be understated.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise policies, procedures, and practices to track, report, review, and account for transactions to replace minor items of property consistent with Commission requirements.", "source_page": null }, { "number": 2, "text": "Train staff on the revised methods and provide periodic training.", "source_page": null }, { "number": 3, "text": "Perform an analysis from 2014 through the date of the final audit report to identify maintenance expenses improperly capitalized into CWIP and plant in service. Provide the results of the analysis and all applicable work papers supporting the analysis, including factors used to calculate the amount of the error, to DAA within 60 days of receiving the final audit report.", "source_page": null }, { "number": 4, "text": "Submit proposed accounting entries based on the analysis performed pursuant to Recommendation No. 3 to DAA, within 90 days of receiving the final audit report, for the removal of the estimated capitalized cost to replace minor items of property from CWIP and plant in service, and to remove associated amounts from other accounts affected, such as accumulated depreciation and accumulated deferred income taxes (ADIT).", "source_page": null }, { "number": 5, "text": "Revise CWIP, gas plant in service, accumulated depreciation, ADIT, and other accounts impacted by the improperly capitalized cost to replace minor items of property after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the balances in the FERC Form No. 2 for current and comparative years as necessary.", "source_page": null } ], "themes": [ "Capitalization vs. expense" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Operating Expenses", "summary": "Transco improperly accounted for allocated direct and indirect overhead operating expenses, resulting in misstated operating expense balances reported in its FERC Form No. 2.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Revise policies, procedures, and practices to track, report, review, and account for operating expenses consistent with Commission requirements.", "source_page": null }, { "number": 7, "text": "Train staff on the revised methods to account for operating expenses and provide periodic training.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Non-Operating Expenses", "summary": "Transco improperly accounted for allocated direct and indirect overhead non-operating expenses in utility plant and operating expense accounts, resulting in misstated utility plant and operating expense balances reported in its FERC Form No. 2.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Revise policies, procedures, and practices to track, report, review, and account for non-operating costs consistent with Commission requirements.", "source_page": null }, { "number": 9, "text": "Train staff on the revised methods to account for non-operating expenses and provide periodic training.", "source_page": null }, { "number": 10, "text": "Perform an analysis from 2014 through the date of the final audit report to identify non-operating expenses improperly capitalized into CWIP and plant in service. Provide the results of the analysis and all applicable work papers supporting the analysis, including factors used to calculate the amount of the error, to DAA within 60 days of receiving the final audit report.", "source_page": null }, { "number": 11, "text": "Submit proposed accounting entries based on the analysis performed per Recommendation No. 10 to DAA, within 90 days of receiving the final audit report, for the removal of the estimated capitalized non-operating costs from CWIP and plant in service accounts, and to remove associated amounts from other accounts affected, such as accumulated depreciation and ADIT.", "source_page": null }, { "number": 12, "text": "Revise CWIP, gas plant in service, accumulated depreciation, ADIT, and other accounts impacted by the improperly capitalized donations, lobbying, and advertising expenses after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the balances in the FERC Form No. 2 for current and comparative years as necessary.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Unused Materials", "summary": "Transco improperly included unused materials in the cost of plant recorded in Account 106, Completed Construction Not Classified, during the audit period. This led the company to overstate its plant in service.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Revise accounting and work order policies and procedures to remove from capital work orders, Account 107, and Account 106 unused materials and supplies not used in construction, and associated accrued AFUDC consistent with Commission regulations.", "source_page": null }, { "number": 14, "text": "Provide training on the revised policies and procedures, and provide periodic training.", "source_page": null }, { "number": 15, "text": "Submit proposed accounting entries and all applicable work papers to DAA, within 60 days of receiving the final audit report, to reclassify unused materials from Accounts 106 and 107 to Account 154, and remove improperly accrued AFUDC.", "source_page": null }, { "number": 16, "text": "Revise balances in Accounts 106, 107, and 154 after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the balances in the FERC Form No. 2 in the current and comparative years of the report. Allowance for Funds Used During Construction", "source_page": null }, { "number": 17, "text": "Revise policies and procedures for calculating AFUDC rates consistent with Gas Plant Instruction (GPI) No. 3(A)(17) and other applicable Commission requirements. Revisions should include processes to prevent inclusion of balances in Accounts 216.1, 219, and 226 in the AFUDC rate calculations.", "source_page": null }, { "number": 18, "text": "Train staff on the revised AFUDC rate calculation methods and provide periodic training.", "source_page": null }, { "number": 19, "text": "Recalculate AFUDC accrued in accordance with GPI No. 3(A)(17) from 2014 through the date of the final audit report. For periods in which AFUDC was over-accrued due to the inclusion of balances recorded in Accounts 216.1, 219, and 226, submit a report to DAA, within 60 days of receiving the final audit report, of proposed accounting entries and documentation to remove over-accrued AFUDC balances from plant and associated accounts, such as accumulated depreciation and ADIT.", "source_page": null }, { "number": 20, "text": "Revise CWIP, gas plant in service, accumulated depreciation, ADIT, and other accounts impacted by over-accrual of AFUDC after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the FERC Form No. 2 for current and comparative years as necessary.", "source_page": null } ], "themes": [ "Accounting misclassification", "Property & plant records" ], "cost_to_customers": false }, { "index": 5, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "Transco improperly included undistributed subsidiary earnings, accumulated other 1 Transcontinental Gas Pipe Line Co., LLC, 145 FERC ¶ 61,205 (2013). 2 Transcontinental Gas Pipe Line Co., LLC, 164 FERC ¶ 61,236 (2018). comprehensive income, and unamortized discounts on long-term debt in debt and equity for the purposes of computing AFUDC rates. As a result, Transco over-accrued AFUDC, which led it to overstate its construction work in progress (CWIP) and plant in service balances.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Property & plant records" ], "cost_to_customers": true }, { "index": 6, "title": "Preliminary Survey and Investigation Charges", "summary": "Transco improperly accounted for feasibility evaluation costs on contemplated construction projects. As a result, expenses reported in the FERC Form No. 2 were overstated in some periods and understated in others.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Update policies and procedures to account for and report expenses related to feasibility evaluation costs associated with proposed construction projects consistent with Commission regulations.", "source_page": null }, { "number": 22, "text": "Train staff on the updated methods to account for expenses related to feasibility evaluations, and provide periodic training.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Incremental Rate Facilities Expenses", "summary": "Transco improperly reported expenses related to incremental rate facilities. As a result, its FERC Form No. 2 schedule page 217a, Non-Traditional Rate Treatment Afforded New Projects, was not accurate. This also impacted stakeholders’ ability to discern expenses related to incremental rate facilities for rate and accounting purposes.", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Update policies and procedures to account for and report expenses related to incremental rate facilities consistent with Commission regulations.", "source_page": null }, { "number": 24, "text": "Strengthen procedures to complete FERC Form No. 2 schedules, in particular pages 217-217a, Non-Traditional Rate Treatment Afforded New Projects, in accordance with the instructions.", "source_page": null }, { "number": 25, "text": "Train staff on the revised methods to account for and report expenses related to incremental rate facilities and provide periodic training.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 8, "title": "FERC Form No. 2 Reporting", "summary": "Transco did not report required information in its FERC Form No. 2 filings, resulting in reduced transparency, accuracy, and usefulness of the reports.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Revise and strengthen policies, procedures, and practices to help ensure the FERC Form No. 2 is correct, accurate, and consistent with the instructions.", "source_page": null }, { "number": 27, "text": "Train staff on the revised FERC Form No. 2 reporting procedures and provide periodic training.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 9, "title": "Distributing and Accounting for Penalty Revenue", "summary": "Transco erroneously distributed penalty revenue to shippers that incurred the penalties, reducing the amount distributable to non-offending shippers. In addition, Transco improperly accounted for regulatory liabilities associated with penalty revenue collected.", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Submit revised policies and procedures to help ensure penalty revenue is allocated in accordance with Transco’s FERC NGA Gas Tariff provisions, and to account for regulatory liabilities consistent with Commission requirements.", "source_page": null }, { "number": 29, "text": "Train staff on the revised policies and procedures and provide periodic training.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Reservation Charge Credits", "summary": "Transco had three firm storage rate schedules in its FERC NGA Gas Tariff that did not contain a provision for reservation charge credits to shippers with firm service affected by non-force majeure and force majeure events, as required by Commission policy. D. Summary of", "is_other_matter": false, "recommendations": [ { "number": 30, "text": "Enhance policies and procedures to comply with Commission requirements on a timely basis.", "source_page": null }, { "number": 31, "text": "File tariff revisions to its FERC NGA Gas Tariff to include a reservation charge crediting provision for force majeure and non-force majeure events for its Washington Storage Service-Open Access, Leidy Storage Service, and SS-2 Storage Service rate schedules, and notify stakeholders consistent with requirements. E.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-05-14_northern-natural-gas-company_pa16-2", "company": "Northern Natural Gas Company", "company_raw": "Northern Natural Gas Company (PA16-2)", "docket": "PA16-2", "docket_full": "PA16-2-000", "issued_date": "2019-05-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190514-3013&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190514-3013", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 49, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "2" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Accounting for Employee Labor Costs", "summary": "Northern Natural misclassified labor costs of certain departments in administrative and general expense, and operating and maintenance expense accounts. The misclassifications averaging about $2.6 million per year during the audit period, affected the accuracy of expenses reported on Pages 317-325 of Northern Natural’s Form No. 2.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise accounting policies and procedures to account for Gas Control, Right of Way, and Welding and Machining Services labor in accordance with Commission accounting requirements. Also strengthen controls to ensure labor costs are properly recorded for all departments.", "source_page": null }, { "number": 2, "text": "Make correcting entries to reclassify current year costs associated with: (a) Gas Control labor from Account 920 to Account 851; (b) Right of Way Labor from Account 920 to the appropriate operating or maintenance account; (c) labor of machinists in Welding and Machining Services from Account 853 to the appropriate operating or maintenance account; and (d) labor of any other departments the company has identified as incorrectly classified as a result of the audit.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 2, "title": "Allocation of Costs to Market-Based Rate Storage Facilities", "summary": "Northern Natural inaccurately allocated payroll costs and never assigned compressor electricity costs to Redfield market-based storage facilities. As a result, Northern Natural overstated market-based storage operating and maintenance expenses reported on Page 217 of Form No. 2 by about $740,000 for the period reviewed.", "is_other_matter": false, "recommendations": [ { "number": 3, "text": "Strengthen procedures and controls to ensure percentages used to allocate labor and expenses between market- and cost-based storage facilities are reviewed annually and updated, if needed, and adequate documentation of the reviews is retained.", "source_page": null }, { "number": 4, "text": "Reinforce procedures and controls to ensure amounts reported on Page 217 of Form No. 2 are accurate and adequately supported.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 3, "title": "Allocation of Payroll to Operating and Maintenance Accounts", "summary": "Northern Natural did not maintain sufficient records to support payroll allocations to operating and maintenance expense accounts. As a result, Northern Natural could not demonstrate allocations were based on actual time engaged, or on a study of time engaged during a representative period, as Commission regulations require.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Develop and implement written policies, procedures, and controls governing the annual review and updating of allocation percentages for all cost centers.", "source_page": null }, { "number": 6, "text": "Revise procedures to require document retention of the annual reviews, including how they take into consideration asset additions and removals, employee changes, and other applicable information.", "source_page": null }, { "number": 7, "text": "Prepare the review for the current year and provide a copy for audit staff within 120 days of issuance of the final audit report.", "source_page": null }, { "number": 8, "text": "Adjust the affected operations and maintenance (O&M) accounts in the general ledger and in the Form No. 2, based on results of the review.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Allocation of Costs to Construction Overheads", "summary": "Northern Natural did not consistently perform annual surveys and maintain records to support the allocation of employee labor costs to construction overheads. Northern Natural also used an arbitrary percentage from a single budget year to allocate labor costs to overheads, which was inconsistent with Commission accounting instructions and company policy. As a result, Northern Natural could not demonstrate the allocations were based on actual time engaged, or on a study of time engaged during a representative period, as Commission regulations require.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Revise procedures and controls for allocating labor supporting construction. The revised procedures and controls should ensure labor costs are allocated to construction overheads based on actual time card distributions or, where impractical, on periodic representative time studies.", "source_page": null }, { "number": 10, "text": "Establish procedures and controls to require retention of records supporting the allocation of labor and expenses to construction overheads in accordance with Commission regulations.", "source_page": null }, { "number": 11, "text": "Conduct time studies to determine hours spent in support of construction by Accounting, Financial Planning, IT Support, and HR employees for the current year. Based on results, adjust allocation percentages and amounts recorded to construction overheads. Provide study results and correcting entries to DAA within 120 days of the date of the final audit report.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Operational Gas Sales", "summary": "Northern Natural’s accounting for operational gas sales was inconsistent with Commission regulations governing system gas accounting. Due to the inconsistencies, Northern Natural incorrectly reported the transactions in the Form No. 2. D. Summary of", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Revise accounting policies and procedures to properly account for system gas transactions in accordance with Commission accounting regulations.", "source_page": null }, { "number": 13, "text": "Perform a review of its system gas accounting and revise any accounting found to be inconsistent with Commission accounting regulations and Northern Natural’s revised accounting policies. Submit the results for audit staff’s review within 120 days of the issuance of the final audit report.", "source_page": null }, { "number": 14, "text": "Make corrective entries to reclassify: (a) accounts payable for imbalances from Account 142 to Account 242; (b) operational sales of gas from Account 483 to Account 495; (c) any other transactions the company has identified as incorrectly classified as a result of the audit.", "source_page": null }, { "number": 15, "text": "Adjust the comparative financial statements in its next Form No. 2 and disclose the reasons for the changes in the presentation of accounts reclassified. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2019-04-23_american-electric-power-company-inc_fa17-1", "company": "American Electric Power Company, Inc.", "company_raw": "American Electric Power Company, Inc. (FA17-1)", "docket": "FA17-1", "docket_full": "FA17-1-000", "issued_date": "2019-04-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20190423-3010&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20190423-3010", "captured_at": "2026-02-03", "source_note": "Listed on FERC https://www.ferc.gov/audits (listing captured 2026-02-03).", "archived_via": null, "page_count": 38, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 through August 31, 2018", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "60" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Allowance for Funds Used During Construction", "summary": "Certain AEP jurisdictional utilities’ method for computing Allowance for Funds Used During Construction (AFUDC) improperly included Account 219, Accumulated Other Comprehensive Income, in the equity component of the formula and improperly determined the AFUDC rate on a monthly basis. As a result, three jurisdictional utilities over accrued AFUDC on transmission plant by approximately $6.1 million from 2012 through 2017. The three jurisdictional utilities overbilled wholesale transmission customers for the excessive AFUDC costs included in utility plant that was included in transmission formula", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 2, "title": "Merger-Related Costs", "summary": "AEP jurisdictional utilities improperly included approximately $295,000 of merger-related capital costs in transmission formula rate determinations without first making a compliance filing under section 205 of the Federal Power Act. As a result, wholesale transmission customers were overbilled due to the inclusion of merger costs.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Charitable Contributions and Penalties", "summary": "AEPSC improperly recorded charitable contributions and penalties in various administrative and general, and operation and maintenance expense accounts, instead of using the appropriate non-operating expense accounts.16 In addition, AEPSC allocated 15F and billed these costs to the jurisdictional utilities, and these utilities then misclassified and misreported these costs in their FERC Form No. 1 filings. These amounts were included in the jurisdictional utilities’ formula rate mechanisms. As a result, the improper accounting for charitable contributions and penalties amounts led to overbillin", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Administrative and General Expenses", "summary": "AEPSC misclassified various administrative and general labor, membership dues, outside services, and advertising expenses among various administrative and general expense accounts. In addition, AEPSC allocated and billed these costs to the jurisdictional utilities, and these utilities then misclassified these costs in their FERC Form No. 1 filings. As a result, the improper accounting for certain administrative and general expenses led to overbillings to wholesale transmission customers through the jurisdictional utilities’ formula rate mechanisms.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Membership dues & industry associations" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "NY", "source": "NY Public Service Commission", "doc_type": "comprehensive management & operations audit (PSC order releasing audit report, PSL 66(19))", "id": "2019-02-07_nyseg-rge_ny-16-m-0610-mo-audit-order", "company": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "company_raw": "New York State Electric & Gas Corporation and Rochester Gas and Electric Corporation", "docket": "16-M-0610", "docket_full": null, "issued_date": "2019-02-07", "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=16-M-0610", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B4F8D1569-9E69-4DB7-85DA-23BDCED680B7%7D&DocTitle=Order+Releasing+Audit+Report", "captured_at": "2026-06-08", "source_note": "NY PSC Order Releasing Audit Report, Case 16-M-0610 — Comprehensive Management and Operations Audits of NYSEG and RG&E (PSL 66(19)). Issued & effective Feb 7, 2019. Page 1 verified.", "archived_via": null, "page_count": 15, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-12-14_black-hills-corporation_fa16-3", "company": "Black Hills Corporation", "company_raw": "FA16-3 Black Hills Corporation", "docket": "FA16-3", "docket_full": "FA16-3-000", "issued_date": "2018-12-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20181214-3016&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20181214-3016", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20181214-3016 (fileID 15117948).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 39, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 through December 31, 2017", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Payroll Taxes", "summary": "BHP incorrectly accounted for its utility and non-utility operating income payroll taxes. In addition, BHP improperly included payroll taxes in its transmission formula rate calculations. As a result, BHP overstated its transmission formula rate revenue requirement by approximately $862,000 from 2010 to 2015. This resulted in BHP overcharging wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise processes and procedures to ensure BHP properly accounts for payroll taxes consistent with Commission accounting requirements and to properly include payroll taxes in the transmission formula rate.", "source_page": null }, { "number": 2, "text": "Make correcting entries to record payroll taxes in Accounts 408.1 and 408.2. Revise payroll tax expenses and other impacted account balances in BHP’s books and records.", "source_page": null }, { "number": 3, "text": "Restate and footnote the balances reported in the FERC Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions. The footnotes should include the adjustments by year with an explanation of the revisions.", "source_page": null }, { "number": 4, "text": "Submit a refund analysis, within 60 days of receiving the final audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of payroll taxes which were inappropriately included in wholesale formula rates since 2010, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to be refunded; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 5, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 6, "text": "Refund amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations. Document Accession #: 20181214-3016 Filed Date: 12/14/2018 Black Hills Power, Inc.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Computer Software and Hardware Costs", "summary": "BHP improperly accounted for software maintenance costs. In addition, BHP recorded interest accruals on software and hardware that were ready for service, which resulted in BHP overstating their costs. BHP included the costs in its transmission formula rate determinations, which resulted in it overstating its transmission formula rate revenue requirement and overcharging wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Revise its policies and procedures to ensure BHP accounts for software license and maintenance costs consistent with Commission accounting requirements and BHP accrues interest consistent with the Commission’s regulations, as required by AR-5. Also, provide training on the revised policies for relevant employees performing accounting functions.", "source_page": null }, { "number": 8, "text": "Perform an analysis of all capitalized information technology (IT) projects from 2013 through the date of the final audit report to identify all instances of the inappropriate inclusion of IT maintenance costs and over accrual of interest. Provide the results of the analysis to DAA for review.", "source_page": null }, { "number": 9, "text": "Make correcting entries to reclassify IT maintenance costs into proper maintenance accounts and remove over-accrued interest. Adjusted accounts should include, but are not limited to, construction work in progress, electric plant in service, depreciation expense, accumulated provision for depreciation, and maintenance expenses.", "source_page": null }, { "number": 10, "text": "Submit a refund analysis, within 60 days of receiving the final audit report, to DAA for review that explains and details the following: (1) calculation of refunds that include the amount of software and hardware costs which were inappropriately included in wholesale formula rates, plus interest; (2) determinative components of the refund; (3) refund method; (4) customers to be refunded; and (5) period(s) refunds will be made.", "source_page": null }, { "number": 11, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 12, "text": "Refund amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Legal Expenses", "summary": "BHP improperly accounted for the cost of litigation services received in 2013 by double counting certain expenses. BHP’s accounting impacted cost inputs to the 2014 transmission formula rate true-up and led it to overstate its transmission formula rate revenue requirement and overcharge wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Revise existing rate development policies, procedures, and practices to ensure BHP includes in its rate determinations refunds for overbillings to wholesale transmission customers that result from errors corrected in a current rate period that impact past rate periods.", "source_page": null }, { "number": 14, "text": "Submit a refund analysis, within 60 days of receiving the final audit report, to DAA for review that explains and details the following: (1) calculations of the refunds resulting from BHP’s accounting for legal expenses, plus interest; (2) Document Accession #: 20181214-3016 Filed Date: 12/14/2018 Black Hills Power, Inc. determinative components of the refund; (3) refund method; (4) customers to be refunded; and (5) period(s) in which refunds will be made.", "source_page": null }, { "number": 15, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 16, "text": "Refund amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Miscellaneous Accounting Misclassifications", "summary": "BHP improperly accounted for various expenses in its books and records. These expenses were included in transmission formula rate determinations. As a result, BHP overstated its transmission formula rate revenue requirement and overcharged wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Revise policies and procedures to ensure that BHP properly accounts for expenditures in its books and records.", "source_page": null }, { "number": 18, "text": "Submit a refund analysis, within 60 days of receiving the final audit report to DAA that explains and details the following: (1) calculation of expenses that were inappropriately recovered through BHP’s transmission formula rate; (2) components of the refund; (3) refund method; and (4) the period(s) in which refunds will be made.", "source_page": null }, { "number": 19, "text": "File a refund report with the Commission after receiving DAA’s assessment of the refund analysis.", "source_page": null }, { "number": 20, "text": "Refund amounts disclosed in the refund report to wholesale customers, with interest calculated in accordance with section 35.19a of the Commission’s regulations. Accounting for Pensions and Post-Retirement Benefits Costs", "source_page": null }, { "number": 21, "text": "Revise its policies and procedures to ensure that pension and benefit expenses are recorded in Account 926 and noncurrent liabilities for pensions and benefits are recorded in Account 228.3, as required by the Commission accounting regulations.", "source_page": null }, { "number": 22, "text": "Make correcting entries to reclassify noncurrent liabilities for pensions and benefits from Account 253 to Account 228.3. Revise pension and benefit expenses and other impacted account balances in the BHP’s books of account and systems.", "source_page": null }, { "number": 23, "text": "Restate and footnote the balances reported in the FERC Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions. The footnotes should include the adjustments by year with an explanation of the revisions. Document Accession #: 20181214-3016 Filed Date: 12/14/2018 Black Hills Power, Inc.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Pensions and Benefits Costs", "summary": "BHP inappropriately transferred its pension and benefit expenses to various operations and maintenance (O&M) accounts. In addition, BHP improperly accounted for liabilities for the underfunded status of its pension plans in Account 253, Other Deferred Credits, instead of Account 228.3, Accumulated Provision for Pensions and Benefits, as required by the Commission’s regulations. As a result, BHP incorrectly reported its pension and benefit expenses in its FERC Form No. 1.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Cost of Long-Term Debt", "summary": "BHP calculated the cost rate of long-term debt in its 2014 transmission formula rate true-up using a method not consistent with Commission requirements, which resulted in a higher long-term debt cost rate than permitted.", "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Revise policies and procedures to ensure BHP calculates the weighted cost of long-term debt consistent with the Commission’s required methodology. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "OR", "source": "Public Utility Commission of Oregon", "doc_type": "power cost adjustment order", "id": "2018-11-30_pacificorp_or-ue-344-order-18-449-pcam", "company": "PacifiCorp d/b/a Pacific Power", "company_raw": "PacifiCorp d/b/a Pacific Power", "docket": "UE-344", "docket_full": null, "issued_date": "2018-11-30", "source_page_url": "https://apps.puc.state.or.us/edockets/orders.asp?OrderNumber=18-449", "pdf_download_url": "https://apps.puc.state.or.us/orders/2018ords/18-449.pdf", "captured_at": "2026-06-07", "source_note": "Oregon PUC Order No. 18-449 (entered November 30, 2018), Docket UE 344, in the matter of PacifiCorp (dba Pacific Power) 2017 Power Cost Adjustment Mechanism (PCAM) (12 pp) — the Commission's review of PacifiCorp's actual vs. forecast net power costs under its PCAM/TAM. Listed for reference (metadata-only). Source: Oregon PUC orders archive (apps.puc.state.or.us/orders/2018ords/18-449.pdf).", "archived_via": null, "page_count": 12, "scanned_pages": [ 11 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-10-19_trunkline-gas-company_pa16-4", "company": "Trunkline Gas Company", "company_raw": "PA16-4 Trunkline Gas Company", "docket": "PA16-4", "docket_full": "PA16-4-000", "issued_date": "2018-10-19", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20181019-3029&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20181019-3029", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20181019-3029 (fileID 15076706).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 68, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 to December 31, 2017", "industry": "gas", "audit_type": "non-financial", "functions": [], "forms": [], "finding_count": 10, "findings": [ { "index": 1, "title": "Reservation Charge Crediting Tariff Provision", "summary": "Trunkline’s tariff did not contain a provision for reservation charge credits to shippers with firm service affected by non-force and force majeure events, as required by Commission policy. As a result, certain shippers with firm service that qualified for full reservation charge credits did not receive any credits following non-force majeure events. Additionally, Trunkline improperly included a reference to maintenance activities in the force majeure definition of its tariff.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 2, "title": "Operational Balancing Agreements", "summary": "Trunkline’s tariff contained language that was inconsistent with the Commission’s requirement that all interconnecting pipelines enter into Operating Balancing Agreements (OBAs). Audit staff also identified inconsistencies with Trunkline’s administration and management of imbalances in accordance with the terms of its tariff and standard OBA.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 3, "title": "Reporting of Gas Equivalents in the Fuel Reimbursement Filing", "summary": "Trunkline misreported gas equivalents in its annual fuel reimbursement filings. While this did not impact the accuracy of the fuel reimbursement rate charged to shippers, it reduced the transparency of the gas equivalents reported in the deferred fuel reimbursement account component schedule of the filing. Accounting and Reporting", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Cash Management and Affiliate Transactions", "summary": "Trunkline incorrectly recorded cash management and affiliate transactions that it carried for less than a year as long-term investments or cash advances rather than as short- term receivables or payables. As a result, Trunkline incorrectly reported short-term receivables, short-term payables, long-term investments, and long- term cash advances in its FERC Form 2.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Revise policies and procedures to ensure it prospectively records short- and long-term cash management and affiliate transactions in the accounts prescribed by the Commission regulations.", "source_page": null }, { "number": 11, "text": "Adjust the comparative financial statements and include footnote disclosures to explain changes in the presentation of cash management program and affiliate transactions in its next FERC Form 2. Document Accession #: 20181019-3029 Filed Date: 10/19/2018 Trunkline Gas Company, LLC Allowance for Funds Used During Construction (AFUDC)", "source_page": null }, { "number": 12, "text": "Strengthen procedures to ensure AFUDC rates do not exceed the maximum permitted by the Commission. Include procedures for the treatment of borrowings associated with the cash management program in the development of its AFUDC rates.", "source_page": null }, { "number": 13, "text": "Evaluate the AFUDC rate applied and the percentage amount that exceeded the maximum rate permitted by the Commission for the periods affected. Also, include in your evaluation how debt borrowings associated with the cash management program factored into its AFUDC calculation and the effect on the derivation of its maximum AFUDC rate. Submit the results to DAA for review within 30 days of completion.", "source_page": null }, { "number": 14, "text": "Adjust plant in service, accumulated depreciation, and other affected accounts to remove the over accrual of AFUDC for the periods affected.", "source_page": null }, { "number": 15, "text": "Disclose in the FERC Form 2 that the maximum AFUDC rate cannot exceed its overall rate of return in its recourse rate, when applicable.", "source_page": null } ], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 5, "title": "Allowance for Funds Used during Construction (AFUDC)", "summary": "Trunkline applied AFUDC rates that exceeded the maximum rate permitted by the Commission to calculate interest costs on construction. While the Commission requires natural gas companies to develop AFUDC rates based on the Commission’s prescribed formula, it restricts the maximum rate to the overall rate of return in its recourse rates. In using rates that exceeded the maximum, Trunkline over accrued AFUDC by approximately $342,823 from 2013 to 2016. Additionally, Trunkline did not consider the effects of the cash management program in its AFUDC rate calculation, which may have resulted in a rate lower than its overall rate of return of its recourse rate. Document Accession #: 20181019-3029 Filed Date: 10/19/2018 Trunkline Gas Company, LLC", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 6, "title": "Accounting for Transmission and Storage Operating Expenses", "summary": "Trunkline misclassified labor and other costs associated with system gas control employees as an administrative and general expense, rather than as a transmission operating expense. Trunkline also misclassified general supervision associated with its underground gas storage facilities as transmission rather than storage operating expense. The misclassifications reduced the transparency of these activities in the FERC Form 2.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Modify its accounting policies and procedures to ensure expenses associated with system gas control and underground storage are treated as operating expenses consistent with Commission accounting instructions.", "source_page": null }, { "number": 17, "text": "Reclassify all amounts associated with system gas control currently in Accounts 920 and 921 to Account 851 and amounts associated with technical engineering services of underground storage facilities from Account 850 to Account 814 for the current year.", "source_page": null }, { "number": 18, "text": "Include a footnote disclosure that explains changes in the presentation of system gas control and underground storage costs in its next FERC Form 2.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Penalty Revenues and Refunds", "summary": "Trunkline incorrectly accounted for penalty revenues collected from offending shippers and refunded to nonoffending shippers as it did not use Account 495, Other Gas Revenues, and Account 254, Other Regulatory Liabilities. As a result, Trunkline’s financial statements did not properly reflect the nature of these activities for accounting and reporting purposes.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Modify accounting policies and procedures for penalty revenues and refunds to ensure consistency with Commission accounting instructions.", "source_page": null }, { "number": 20, "text": "Reclassify all amounts associated with penalty revenues and refunds in Accounts 142 and 242 with respective entries to Accounts 495 and 254 for the current year. Document Accession #: 20181019-3029 Filed Date: 10/19/2018 Trunkline Gas Company, LLC", "source_page": null }, { "number": 21, "text": "Include a footnote disclosure that explains the changes in the presentation of penalty revenues and refunds in its next FERC Form 2. Accounting for Lost and Unaccounted for Gas", "source_page": null }, { "number": 22, "text": "Modify its accounting policies and procedures for LAUF to ensure consistency with Commission accounting instructions.", "source_page": null }, { "number": 23, "text": "Reclassify all amounts associated with LAUF recorded in Account 854 to Account 813 for the current year.", "source_page": null }, { "number": 24, "text": "Include a footnote disclosure to explain changes in the presentation of LAUF in its next FERC Form 2.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Accounting for Loss and Unaccounted for Gas (LAUF)", "summary": "Trunkline incorrectly accounted for LAUF as compressor fuel rather than in accounts designated for system gas losses. This accounting reduced the transparency of LAUF for financial reporting and fuel reimbursement purposes.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Removal of Assets and Liabilities Sold to an Affiliate", "summary": "Trunkline did not timely remove from its books certain assets and a regulatory liability for an asset retirement obligation associated with the sale of onshore and offshore facilities to its affiliate Sea Robin Pipeline Company in 2012. As a result, Trunkline continued to reflect these activities on its books and accrue depreciation expense on these assets in 2013-2015.", "is_other_matter": false, "recommendations": [ { "number": 25, "text": "Strengthen processes and procedures to ensure assets and related amounts sold are removed timely from its books.", "source_page": null }, { "number": 26, "text": "Remove the remaining assets, accumulated provision for depreciation, and ARO regulatory liability associated with the sale to Sea Robin from its books.", "source_page": null }, { "number": 27, "text": "Make a correcting entry to reverse the depreciation expense improperly accrued in the periods subsequent to the sale.", "source_page": null } ], "themes": [ "Depreciation", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 10, "title": "Reporting of Volumes for Gas Storage Projects", "summary": "Trunkline incorrectly reported volumetric data for its gas storage facility in the FERC Form 2. The error affected the accuracy of the amounts recorded in Account 808.1, Gas Withdrawn from Storage-Debit, and Account 808.2, Gas Injected into Storage-Credit. D. Summary of", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Enhance procedures to ensure it correctly reports gas storage quantities for injections and withdrawals on Page 512 of the FERC Form 2 and the related amounts recorded in Accounts 808.1 and 808.2. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Cost of service & rates", "Depreciation", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-10-19_equitrans-l-p_fa17-6", "company": "Equitrans, L.P.", "company_raw": "FA17-6 Equitrans, L.P.", "docket": "FA17-6", "docket_full": "FA17-6-000", "issued_date": "2018-10-19", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20181019-3030&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20181019-3030", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20181019-3030 (fileID 15076710).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 48, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 through April 2, 2018", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2" ], "finding_count": 8, "findings": [ { "index": 1, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": "Equitrans inappropriately included unpaid contract retention accruals in the calculation of its AFUDC rate. In addition, the company erroneously Document Accession #: 20181019-3030 Filed Date: 10/19/2018 Equitrans L.P. excluded certain other cash outlays from the calculation. This led Equitrans to under-accrue AFUDC capitalized into construction work in progress (CWIP) and plant in service of approximately $694,000 on its Ohio Valley Connector (OVC) pipeline system, and over-accrue $127,000 on its Allegheny Valley Connector (AVC) pipeline system, and $49,000 on other Equitrans pipelines.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Property & plant records", "Capitalization vs. expense" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Unused Materials", "summary": "Equitrans incorrectly included approximately $1.3 million of unused materials in construction work orders and therefore overstated the cost of plant recorded in Account 101, Gas Plant in Service, during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Property & plant records" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Tax Receivable", "summary": "Equitrans improperly accounted for an income tax receivable that represented a refund for an overpayment in Account 165, Prepayments, instead of in Account 146, Accounts Receivable from Associated Companies.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Nonoperating Expenses", "summary": "Equitrans improperly accounted for donations, penalties, and nonutility expenses in utility plant and operating expense accounts. As a result, utility plant and operating expense balances in Equitrans’ FERC Form No. 2 were overstated.", "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 5, "title": "Plant Held for Future Use", "summary": "Equitrans recorded assets in Account 105, Plant Held for Future Use, without a definite plan for their future use in gas service. The accounting resulted in a misclassification of plant balances in its FERC Form No. 2.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Unfiled Service Agreements", "summary": "Equitrans did not file two non-conforming interruptible gathering service agreements with the Commission as required. The agreements included service provisions that deviated materially from the pro forma service agreement in its FERC Gas Tariff.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 7, "title": "Cash Management Program", "summary": "Equitrans did not file its effective cash management agreement with the Commission as required. The failure to file inhibited the financial transparency of Equitrans’ cash management program, and could have hampered the Commission’s ability to perform its oversight and market monitoring obligations.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "FERC Form No. 2 Reporting", "summary": "Equitrans did not report certain information in its FERC Form No. 2 filings as required, resulting in reduced overall transparency, accuracy, and usefulness of the filings. Document Accession #: 20181019-3030 Filed Date: 10/19/2018 Equitrans L.P. D. Summary of", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Capitalization vs. expense", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-09-14_california-independent-system-operator-corporati_pa17-3", "company": "California Independent System Operator Corporation", "company_raw": "PA17-3 California Independent System Operator Corporation", "docket": "PA17-3", "docket_full": "PA17-3-000", "issued_date": "2018-09-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180914-3005&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180914-3005", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180914-3005 (fileID 15038664).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 62, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2014 to the March 2, 2018", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Independence of the Department of Market Monitoring", "summary": "CAISO did not have adequate structures in place to ensure sufficient independence of the market monitoring functions of the DMM from the influence of CAISO's senior management. Specifically, CAISO executives were too closely involved in the DMM Director's performance review and compensation, DMM staff incentive compensation awards, DMM staffing issues, and approval of the DMM budget.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Involve the Oversight Committee when reviewing the performance of the DMM and the DMM Director.", "source_page": null }, { "number": 2, "text": "Separate the awarding of incentive compensation to DMM staff from approval by CAISO and from measurement by performance of tasks in areas other than DMM-specific objectives and goals.", "source_page": null }, { "number": 3, "text": "Grant the Oversight Committee the authority to review and approve the DMM budget, subject only to overall budget approval by the CAISO Board. Physical Separation of the DMM", "source_page": null }, { "number": 4, "text": "Provide the DMM Director adequate notice of, and involvement in, the process by which CAISO evaluates relocation of CAISO staff, particularly adjacent to DMM staff, so that the Director may raise his concerns on the independence of the DMM.", "source_page": null }, { "number": 5, "text": "Ensure the DMM Director has the opportunity to bring any unresolved concerns on matters of potential impacts of staff relocation, and other issues of inadequacies in physical separation before the DMM Oversight Committee, who will have the authority itself to address, or bring them to the full Board to address, regarding actions sufficient to ensure independence around the DMM workspace.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "DMM Involvement in CAISO OATT Formation", "summary": "By filing joint comments with CAISO, the DMM did not adequately ensure its independence in advising all interested parties of its views regarding CAISO's proposed OATT and market rule changes. This is particularly problematic when its views differed from those of CAISO. Had the DMM independently advised the Commission, the CAISO, and other interested entities of its views regarding any needed rule and tariff changes, it would have improved the clarity of DMM's position and better demonstrated its independence from CAISO, both of which are critical in its role of advising the Commission.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Facilitate and encourage the DMM to (i) continue its advisory participation in internal committees involved in issues with significant market impact, (ii) articulate its independent views when there is a Commission filing by CAISO with market implications, particularly when they diverge from those of the CAISO, and (iii) use DMM's own legal representation, as necessary, in making such filings.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 3, "title": "Testing Ancillary Service Providers", "summary": "CAISO did not conduct the range and frequency of testing and auditing required by the CAISO OATT to verify, within 2 reasonable timeframes, that generators paid to provide ancillary services were capable of providing the services.", "is_other_matter": false, "recommendations": [ { "number": 7, "text": "Conduct ancillary service testing and auditing, by the means specified in its OATT.", "source_page": null }, { "number": 8, "text": "Enhance controls to ensure CAISO conducts ancillary service testing and auditing within reasonable timeframes.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Assuring the Accuracy of Data Submitted to CAISO", "summary": "CAISO did not have sufficient controls to ensure certain data submitted by market participants were accurate and could be relied on by CAISO when performing its responsibilities under the OATT. Other Matter", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Continue to conduct risk analyses to identify where inaccurate, incomplete, or untimely submissions of data by market participants to the CAISO may threaten CAISO's ability to ensure reliability and/or proper market functioning.", "source_page": null }, { "number": 10, "text": "Use CAISO's internal audit function to evaluate CAISO's effectiveness in addressing these risk areas under the direction of the Audit Committee. Other Matter: CAISO Internal Audit Function Audit staff suggests that CAISO consider:", "source_page": null }, { "number": 1, "text": "Having the Audit Committee assess the performance and remuneration of the Director of Internal Audit.", "source_page": null }, { "number": 2, "text": "Removing compensation metrics that might conflict with IA's objective of detecting noncompliance during the audit process.", "source_page": null }, { "number": 3, "text": "Adding staff or supplementing the necessary skills in operational areas to empower IA in performing the full range of audits necessary to provide adequate assurance of CAISO's compliance to its OATT. E. Compliance with Implementation of Recommendations Audit staff further recommends that CAISO submit for review: • Plans for implementing audit staffs recommendations within 30 days after the issuance of this report. • Quarterly reports to DAA describing CAISO's progress in completing each corrective action. CAISO should make these nonpublic quarterly filings no later than 30 days after the end of each calendar quarter, beginning with the first quarter after the Commission issues this report, and continuing until it completes all recommended actions. • Copies of written policies and procedures developed in response to the recommendations. These documents should be submitted for audit staffs review in the first nonpublic quarterly filing after CAISO completes them.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "CAISO Internal Audit Function", "summary": "CAISO Internal Audit (IA) could strengthen its level of independence and enhance its staffing with expertise in the critical areas of CAISO's operations and markets to facilitate its role in providing adequate assurance of CAISO's compliance to its OATT. D.", "is_other_matter": false, "recommendations": [], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Internal audit & internal controls", "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-08-24_kansas-city-power-light-company_pa17-4", "company": "Kansas City Power & Light Company", "company_raw": "PA17-4 Kansas City Power & Light Company", "docket": "PA17-4", "docket_full": "PA17-4-000", "issued_date": "2018-08-24", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180824-3012&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180824-3012", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180824-3012 (fileID 15003376).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 27, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1,2014 through December 31, 2017", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "1" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Accounting for Derivative Instruments", "summary": "KCP&L improperly recorded derivative instruments that were not designated as cash flow or fair value hedges in Account 176, Derivative Instrument Assets-Hedges, Account 245, Derivative Instrument Liabilities-Hedges, and Account 253, Other deferred credits. KCP&L also incorrectly recorded gains and losses on the derivative instruments for its Missouri jurisdiction in Account 447, Sales for Resale, and Account 547, Fuel. These misclassifications did not impact wholesale rates, but did reduce the accuracy and transparency of the accounting for these activities as derivative instruments to users of the FERC Form No. 1.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 2, "title": "Electric Quarterly Report Contracts and Transactions", "summary": "KCP&L's EQRs contained errors in the reporting of certain contract and transactional data during the audit period. These errors impact the Commission and other stakeholders' ability to effectively oversee wholesale electric market activities. D.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on remand", "id": "2018-08-20_pacific-gas-and-electric_er16-2320", "company": "Pacific Gas and Electric Company", "company_raw": "Pacific Gas and Electric Company", "docket": "ER16-2320", "docket_full": null, "issued_date": "2018-08-20", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180820-3055&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180820-3055", "captured_at": "2026-06-07", "source_note": "FERC Order on Remand, Granting Motion Consolidating Proceedings, and Establishing Briefing Schedule re Pacific Gas and Electric Company transmission revenue-requirement / return-on-equity proceeding, Docket ER16-2320 (consolidated with ER14-2529), issued 2018-08-20. Metadata-only (free-form legal order). Found via the eLibrary AdvancedSearch API (searchText=ER16-2320); accession 20180820-3055.", "archived_via": null, "page_count": 12, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-07-05_cms-energy-corporation_pa17-5", "company": "CMS Energy Corporation", "company_raw": "PA17-5 CMS Energy Corporation", "docket": "PA17-5", "docket_full": "PA17-5-000", "issued_date": "2018-07-05", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180705-3017&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180705-3017", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180705-3017 (fileID 14964860).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 36, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "552" ], "finding_count": 3, "findings": [ { "index": 1, "title": "Economic Minimum Limits for Consumers’ Coal Units", "summary": "The Hourly Economic Minimum Limits (Ecomin) Consumers offered for its coal units in the Midcontinent Independent System Operator, Inc.’s (MISO) real-time energy markets did not reflect the actual known physical capabilities and characteristics of the generating resources, as the MISO Open Access Transmission, Energy and Operating Tariff (MISO Tariff) requires. By preventing MISO from dispatching the units below Ecomin in real-time, the offers denied MISO the flexibility to optimize dispatch to reflect the actual marginal cost of energy, and to manage transmission congestion.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 2, "title": "Ramp Rates for Consumers’ Coal Units", "summary": "The bi-directional ramp rates Consumers offered for Campbell 2 and Campbell 3 in MISO’s energy markets during the audit period did not reflect the actual known physical capabilities and characteristics of the generating resources, as the MISO Tariff requires.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 3, "title": "Economic Minimum Limits for Dearborn Industrial Generation", "summary": "The Hourly Economic Minimum Limits (Ecomin) Energy Resource Management (ERM) offered for Dearborn Industrial Generation, LLC (DIG) in MISO’s day-ahead energy market did not reflect the actual known physical capabilities and characteristics of the generating resource, as the MISO Tariff requires. By preventing MISO from dispatching DIG below Ecomin, the offers denied MISO the flexibility to optimize dispatch to reflect the actual marginal cost of energy, and to manage transmission congestion.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-06-11_idaho-power-company_pa17-7", "company": "Idaho Power Company", "company_raw": "PA17-7 Idaho Power Company", "docket": "PA17-7", "docket_full": "PA17-7-000", "issued_date": "2018-06-11", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180611-3038&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180611-3038", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180611-3038 (fileID 14943440).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 49, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2015 through April 30, 2018", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 10, "findings": [ { "index": 1, "title": "Posting ATC Offerings on Interconnection Paths", "summary": "Idaho Power did not post ATC offerings on seven control-area-to-control-area interconnection paths when ATCs were, in fact, available on these paths. The impact of not posting ATCs on these paths reduced the transparency for transmission customers and consequently inhibited their ability to identify and request available transmission services.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Identification of Affiliates on OASIS", "summary": "Idaho Power did not identify as an affiliate on its OASIS one of its internal divisions that requested transmission service. Consequently, Idaho Power did not identify all the transactions associated with this internal division as affiliated transactions and consequently did not populate Transmission Service Request (TSR) metrics reports appropriately.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 3, "title": "Timely Processing of Transmission Service Requests", "summary": "Idaho Power did not act upon ten customers' transmission service requests within the 30-minute window required under its OATT Section 18.4. Out of customer requests impacted after the audit started, only in a single instance did Idaho Power's delay result in a customer not receiving the service it originally requested.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Posting of Ancillary Services", "summary": "Idaho Power did not post any of its required ancillary service offerings and prices on its OASIS. As a result, the TSRs posted on Idaho Power's OASIS did not include any information identifying what, if any, ancillary service transactions were associated with the posted TSRs.", "is_other_matter": false, "recommendations": [], "themes": [ "Informational postings" ], "cost_to_customers": false }, { "index": 5, "title": "Reporting of Transmission Study Performance Metrics", "summary": "Idaho Power did not properly report required transmission study performance metrics for several quarters during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Generation Interconnection Queue", "summary": "Idaho Power did not post required information specified in its OATT, Attachment M, Section 3.4 including: the identification of its own interconnection requests in the Generation Interconnection Queue posted on OASIS, every interconnection study report conducted during the audit period, and the required advance notice of scoping meetings between Idaho Power's transmission function and its affiliate.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 7, "title": "Annual Reevaluation of Capacity Benefit Margin Needs", "summary": "Idaho Power did not maintain documentation to demonstrate whether, and how, it met the requirement 5 to reevaluate its capacity benefit margin (CBM) needs at least annually, and post its practices for reevaluating its CBM needs.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Transmission Study List", "summary": "Idaho Power incorrectly excluded a customer's transmission study from its Transmission Study List posted on OASIS.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "OASIS Access Control", "summary": "Idaho Power did not revoke the OASIS access privileges of two employees after these individuals no longer required OASIS access.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Use ofDesignated Network Resource to Make Finn Off-System Sales", "summary": "Idaho Power incorrectly used a DNR to make firm off-system sales. G.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Informational postings" ], "cost_to_customers": true }, { "collection": "prudence_review", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "PGA / gas-adjustment-charge reconciliation prudence order (§9-220)", "id": "2018-05-17_nicor-gas_icc-15-0519-pga-reconciliation", "company": "Northern Illinois Gas Company d/b/a Nicor Gas Company", "company_raw": "Northern Illinois Gas Company d/b/a Nicor Gas Company", "docket": "15-0519", "docket_full": null, "issued_date": "2018-05-17", "source_page_url": "https://icc.illinois.gov/docket/P2015-0519/documents/271451", "pdf_download_url": "https://icc.illinois.gov/docket/P2015-0519/documents/271451/files/474549.pdf", "captured_at": "2026-06-08", "source_note": "Illinois Commerce Commission Final Order reconciling Nicor Gas revenues collected under Rider 6 (Gas Supply Cost / PGA) with actual costs prudently incurred for the year ended Dec 31 2015, Docket 15-0519, issued 2018-05-17 (§9-220). PDF: icc.illinois.gov/docket/P2015-0519/documents/271451/files/474549.pdf.", "archived_via": null, "page_count": 6, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-04-18_midcontinent-independent-system-operator-inc_pa16-5", "company": "Midcontinent Independent System Operator, Inc.", "company_raw": "PA16-5 Midcontinent Independent System Operator, Inc.", "docket": "PA16-5", "docket_full": "PA16-5-000", "issued_date": "2018-04-18", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180418-3060&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180418-3060", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180418-3060 (fileID 14892059).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 28, "scanned_pages": [], "ocr_used": false, "audit_period": "June 1, 2013 through August 11, 2017", "industry": "electric", "audit_type": "non-financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 1, "findings": [ { "index": 1, "title": "Records Management Procedures", "summary": "MISO inappropriately destroyed certain records during the audit contrary to the requirements of the Commissions regulations and direction. The destruction of these records inhibited the performance of certain audit processes and procedures.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-04-18_iso-new-england-inc_pa16-6", "company": "ISO New England, Inc.", "company_raw": "PA16-6 ISO New England, Inc.", "docket": "PA16-6", "docket_full": "PA16-6-000", "issued_date": "2018-04-18", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180418-3061&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180418-3061", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180418-3061 (fileID 14892129).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 25, "scanned_pages": [], "ocr_used": false, "audit_period": "July 10, 2013 through June 30, 2017", "industry": "electric", "audit_type": "non-financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-02-21_entergy-gulf-states-louisiana-llc_fa15-10", "company": "Entergy Gulf States Louisiana, LLC", "company_raw": "FA15-10 Entergy Gulf States Louisiana, LLC", "docket": "FA15-10", "docket_full": "FA15-10-000", "issued_date": "2018-02-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180221-3027&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180221-3027", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180221-3027 (fileID 14826909).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 39, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 to December 31, 2014", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1", "3-Q", "580" ], "finding_count": 3, "findings": [ { "index": 1, "title": "Interim Storage of Spent Nuclear Fuel", "summary": "EGSL incorrectly recorded the costs to purchase and amortize dry casks used for the interim storage of spent nuclear fuel assemblies. As a result, EGSL overbilled its wholesale customers in FAC billings.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Nuclear Fuel Fees", "summary": "EGSL incorrectly recorded legal, financing, and audit fees associated with nuclear fuel in Account 518, Nuclear Fuel Expense (Major Only), instead of Account 524, Miscellaneous Nuclear Power Expenses. As a result, EGSL overbilled wholesale customers under its wholesale FAC.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Lobbying Expenses", "summary": "EGSL incorrectly recorded lobbying costs associated with industry association dues in an operating expense account in 2012. This misclassification resulted in improper recovery of lobbying activity through EGSL’s transmission formula rate.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Fuel & purchased-power cost recovery", "Membership dues & industry associations" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-02-21_entergy-arkansas-inc_fa15-11", "company": "Entergy Arkansas, Inc.", "company_raw": "FA15-11 Entergy Arkansas, Inc.", "docket": "FA15-11", "docket_full": "FA15-11-000", "issued_date": "2018-02-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180221-3030&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180221-3030", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180221-3030 (fileID 14826910).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 38, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2012 to December 31, 2014", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1", "3-Q" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Accounting for Lobbying Expenses", "summary": "EAI incorrectly recorded lobbying costs associated with industry association dues in an operating expense account in 2012. This misclassification resulted in improper recovery of lobbying costs through EAI’s transmission formula rate.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Membership dues & industry associations", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Settlements", "summary": "EAI incorrectly recorded $230,000 to settle an employee discrimination lawsuit in Account 925, Injuries and Damages, instead of Account 426.5, Other Deductions, in 2012 and 2013. This resulted in the inappropriate inclusion of $20,585 in its transmission revenue requirement.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Progress Payments", "summary": "EAI inappropriately classified the progress payments for dry cask storage containers used for the interim storage of spent nuclear fuel assemblies in Account 107, Construction Work in Progress-Electric. EAI also improperly accrued AFUDC on the progress payment associated with dry casks.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Nuclear Fuel Fees", "summary": "EAI incorrectly recorded legal, financing, and audit fees associated with nuclear fuel in Account 518, Nuclear Fuel Expense (Major Only), instead of Account 524, Miscellaneous Nuclear Power Expenses.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Fuel & purchased-power cost recovery", "Membership dues & industry associations" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-02-14_american-transmission-company-llc_fa16-1", "company": "American Transmission Company, LLC", "company_raw": "FA16-1 American Transmission Company, LLC", "docket": "FA16-1", "docket_full": "FA16-1-000", "issued_date": "2018-02-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180214-3031&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180214-3031", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180214-3031 (fileID 14822404).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 31, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 3, "findings": [ { "index": 1, "title": "Inclusion of Construction Work in Progress in Rate Base", "summary": "ATC improperly implemented certain aspects of its settlement order involving incentive rate treatment for Construction Work in Progress (CWIP) included in rate base. Specifically, ATC improperly collected an incentive return from its customers for construction projects that were: (1) never submitted by ATC to MISO for inclusion in the MISO Transmission Expansion Plan (MTEP) and (2) submitted but not yet approved by MISO’s Board of Directors in the MTEP. As a result, ATC overbilled its customers an excessive incentive return amounting to approximately $20,000,000.", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Lobbying Costs", "summary": "ATC did not properly account for costs charged to it associated with ATC Management Inc.’s internal lobbyist. ATC recorded the lobbying costs in an operating account instead of using a nonoperating expense account. As a result, ATC improperly recovered these costs through its transmission formula rate.", "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting and Filings Associated With Electric Plant Sold", "summary": "ATC did not use Account 102, Electric Plant Purchased or Sold, to record two sales of operating units, and did not file with the Commission the journal entries for three sales of operating units. Additionally, ATC improperly recorded the gains and losses for the sales of land in Account 411.6, Gains from disposition of utility plant, and Account 411.7, Losses from disposition of utility plant, instead of Account 421.1, Gain on Disposition of Property, and Account 421.2, Loss on Disposition of Property, as the Commission requires.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-01-12_plains-pipeline-l-p_fa16-6", "company": "Plains Pipeline, L.P.", "company_raw": "FA16-6 Plains Pipeline, L.P.", "docket": "FA16-6", "docket_full": "FA16-6-000", "issued_date": "2018-01-12", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180112-3041&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180112-3041", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180112-3041 (fileID 14796784).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 73, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 to September 30, 2017", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 12, "findings": [ { "index": 1, "title": "Accounting for the Line 901 Oil Spill", "summary": "Plains improperly recorded expenses related to the Line 901 oil spill in Account 610, Operating Expenses, and Account 660, Miscellaneous Income Charges. Based on Commission accounting regulations, Plains should have considered this spill to be material and infrequent, which would have required it to record the expenses in Account 665, Unusual or Infrequent Items. As a result, Plains overstated operating expenses by $70 million and miscellaneous income charges by $15 million in its 2015 Form No. 6.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Implement policies and procedures to ensure the company considers the size of an oil spill and amount of ecological and property damages incurred in determining whether an oil spill is an unusual and/or infrequent event. Document Accession #: 20180112-3041 Filed Date: 01/12/2018 Plains Pipeline, L.P.", "source_page": null }, { "number": 2, "text": "Update accounting policies and procedures to ensure expenditures related to an oil spill, including those that are unusual, infrequent, or extraordinary, are recorded consistent with Commission accounting regulations.", "source_page": null }, { "number": 3, "text": "Reclassify amounts improperly recorded in expense accounts and submit revised journal entries.", "source_page": null }, { "number": 4, "text": "Make a footnote disclosure in the Form No. 6 to disclose the change in account coding for the Line 901 expenses and the impact on the financial statements.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for the Pocahontas Line Oil Spill", "summary": "Plains improperly recorded expenses related to the Pocahontas Station oil spill in Accounts 390, Other Expenses, and 520, Outside Services. Based on Commission accounting regulations, Plains should have recorded these expenses in Account 570, Casualty and Other Losses.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Reclassify amounts improperly recorded in Accounts 390 and 520 to Account 570 and submit revised journal entries.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 3, "title": "Prorationing of Nominations", "summary": "Plains did not reduce a shipper’s prorated volumes for the next month when a shipper was unable to tender crude petroleum equal to its allocated trunk space in the previous month, as required by Oil Tariff Item 85, Apportionment When Nominations are in Excess of Facilities. As a result, some shippers should have received more or less capacity than what Plains allocated.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Provide audit staff an analysis assessing the impact to shippers for all months in proration during the audit period.", "source_page": null }, { "number": 7, "text": "Revise and implement procedures and controls to ensure that jurisdictional transportation service is apportioned equitably among shippers when nominations exceed available capacity on a line segment or system and in accordance with Plains’ tariff on file with the Commission.", "source_page": null }, { "number": 8, "text": "Train employees how to determine each shipper’s equitable basis when a line segment or system is in proration.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Subsidiary Investments", "summary": "In 2013 and 2014, Plains improperly reported its investments in four wholly owned subsidiaries by using the consolidated instead of the equity method of accounting, as required by the Commission. Consequently, Plains’ financial statements did not appropriately reflect its investments in subsidiary companies and multiple accounts on the Form No. 6 were overstated.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Implement procedures to ensure the company follows the equity method of accounting for all investments in subsidiaries over which it exercises significant influence and to ensure all accounting is consistent with Commission accounting regulations.", "source_page": null }, { "number": 10, "text": "Make necessary adjustments to ensure that the equity method of accounting is reflected in the company’s reporting of Plains Southcap Inc., Plains South Texas Gathering LLC, Plains Capline LLC, and Diamond Pipeline LLC including requiring the use of worksheets or memorandum accounts.", "source_page": null }, { "number": 11, "text": "Make a footnote disclosure in the Form No. 6 to disclose the change from the consolidated to the equity method of accounting and the impact on the financial statements. Document Accession #: 20180112-3041 Filed Date: 01/12/2018 Plains Pipeline, L.P.", "source_page": null }, { "number": 12, "text": "Implement procedures to ensure that questions regarding guidance with unclear interpretation are submitted to the Commission for consideration in accordance with General Instruction 1-11 of the USofA.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Gain or Loss on Sale of Asset", "summary": "Plains improperly recorded gains and losses from the sale of property used in carrier operations in Account 640, Miscellaneous Income, instead of Account 31, Accumulated Depreciation – Carrier Property, as required by Commission accounting regulations.", "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Establish policies and procedures to ensure that dispositions of carrier property are accounted for in accordance with Commission regulations. Include provisions for requesting special accounting treatment when necessary.", "source_page": null }, { "number": 14, "text": "Record gains and losses from the sale of carrier property in Account 31, Accumulated Depreciation, prospectively.", "source_page": null } ], "themes": [ "Accounting misclassification", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 6, "title": "Accounting for Inactive and Idle Pipeline Assets", "summary": "Plains improperly accounted for inactive and idle pipeline assets as carrier property.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Revise accounting policies and procedures to ensure idle carrier property is recorded in Account 34, and reclassify all idle carrier property recorded in Account 30 during the audit period that will not be used in Plains’ future pipeline operations to Account 34.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Nonoperating Expenses", "summary": "Plains improperly accounted for donations and charitable contributions, lobbying activities, and fines and penalties as operating expenses. Since these expenses are nonoperating in nature, Plains should have recorded them in Account 660, Miscellaneous Income Charges.", "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Implement written procedures to account for, track, report, and review expenses associated with nonoperating activities.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 8, "title": "Accounting for Affiliate Receivables and Payables", "summary": "Plains improperly accounted for affiliate receivables and payables from 2014 to 2015 by combining the balances in Account 63, Other Noncurrent Liability, instead of separately recording the balances in Account 13, Receivables from Affiliated Companies, and in Account 51, Payables to Affiliated Companies. As a result, the Form No. 6 supporting schedules on pages 200, Receivables from Affiliated Companies, and 225, Payables to Affiliated Companies, were not completed as required by Form No. 6 Instructions.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Update policies and procedures to ensure affiliate account balances are accounted for consistently with the Commission’s regulations.", "source_page": null }, { "number": 18, "text": "Record current affiliate receivables and payables in Accounts 13 and 51, respectively, rather than in Account 63 on a prospective basis.", "source_page": null }, { "number": 19, "text": "Update procedures to ensure that all Form No. 6 schedules, in particular pages 200, Receivables from Affiliated Companies, and 225, Payables to Affiliated Companies, are completed in accordance with Commission instructions.", "source_page": null }, { "number": 20, "text": "Strengthen procedures for completing the Form No. 6 review instructions prior to submission to reduce the number of errors. Document Accession #: 20180112-3041 Filed Date: 01/12/2018 Plains Pipeline, L.P.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 9, "title": "Accounting for Affiliate Expenses on Plains’ Books", "summary": "Plains improperly recorded settlements totaling $212,550 on its books that were actually paid by affiliates, Plains All-American Pipeline, L.P. and Plains Marketing, L.P. The error resulted in operating expenses being overstated on Plains’ Form No. 6 by $100,000 in 2013 and $112,500 in 2014.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Implement policies, procedures, and controls to ensure that only Plains’ activities are recognized on Plains’ books.", "source_page": null }, { "number": 22, "text": "Reclassify the miscoded settlement payments recorded on Plains’ books to the entity incurring or recognizing the settlement.", "source_page": null }, { "number": 23, "text": "Record settlement payments in Account 660, Miscellaneous Income Charges.", "source_page": null } ], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 10, "title": "Use of FERC-Approved Depreciation Rates", "summary": "Plains used depreciation rates for carrier property assets that were not filed with the Commission. Therefore, Plains improperly applied unapproved depreciation rates to calculate depreciation and amortization expenses for those assets, and included them in its annual cost-of-service rate determinations and billings to transportation shippers.", "is_other_matter": false, "recommendations": [ { "number": 24, "text": "Establish procedures and controls to ensure that Plains uses Commission- approved depreciation rates for all carrier property assets (or accounts).", "source_page": null }, { "number": 25, "text": "Use Commission-approved depreciation rates to calculate the depreciation expense included in the annual cost-of-service determinations, or timely file a request pursuant to Part 347 of the Commission’s regulations.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 11, "title": "FERC Form No. 6 Reporting Schedules", "summary": "Plains did not complete certain Form No. 6 reporting schedules during the audit period, as required. In addition, Plains incorrectly recorded net income in Account 73, Additional Paid-In Capital, instead of in Account 700, Net Balance Transferred from Income. Although this led to account misclassifications, it did not impact amounts reported on Page 700 of the Form No. 6. Nonetheless, appropriate account classification is important to ensure accurate and transparent accounting and reporting.", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Update procedures to ensure that all Form No. 6 schedules are completed in accordance with Commission instructions.", "source_page": null }, { "number": 27, "text": "Strengthen procedures for completing the Form No. 6 review instructions prior to submission to eliminate errors.", "source_page": null } ], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 12, "title": "Filing of Approval of Acquisition Journal Entry", "summary": "Plains did not file journal entries with the Commission for consideration and approval related to a property acquisition in the amount of $10 million in 2015, as required by 18 C.F.R. Part 352, Instruction for Carrier Property Accounts 3-11, Acquisition by Merger, Consolidation, or Purchase.", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Establish policies and procedures to ensure that acquisitions of properties comprising a distinct operating system, or an integral portion thereof, are accounted for in accordance with Commission regulations, including submitting tentative journal entries to the Commission for approval when the purchase price exceeds $250,000. Document Accession #: 20180112-3041 Filed Date: 01/12/2018 Plains Pipeline, L.P. Other Matters Cost Allocation", "source_page": null }, { "number": 29, "text": "Perform a study for its shared service cost allocation percentages to ensure that costs are reasonably and equitably allocated among the three reporting segments. Allowance Oil Inventory", "source_page": null }, { "number": 30, "text": "Enhance transparency of the availability of allowance oil inventory volumes. E.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-01-12_marathon-pipe-line-llc_fa16-7", "company": "Marathon Pipe Line, LLC", "company_raw": "FA16-7 Marathon Pipe Line, LLC", "docket": "FA16-7", "docket_full": "FA16-7-000", "issued_date": "2018-01-12", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180112-3042&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180112-3042", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180112-3042 (fileID 14796785).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 63, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 to September 30, 2017", "industry": "oil", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "6" ], "finding_count": 10, "findings": [ { "index": 1, "title": "Accounting for Reimbursable Capital Projects", "summary": "Marathon did not credit cash received from MPC to the appropriate carrier property account for reimbursable construction projects. Rather, Marathon improperly recorded the cash received from MPC for reimbursable construction projects in Account 640, Miscellaneous Income. As a result, Marathon overstated its carrier property, depreciation, and revenue accounts reported in the Form 6.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Third Party Expenses", "summary": "Marathon did not credit the appropriate operating expense accounts originally charged for reimbursable operating expenses. As a result, Marathon overstated operating expenses and miscellaneous income reported in its Form 6.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Affiliate Transaction Markup", "summary": "Marathon improperly accounted for affiliate transaction markups, which represent the difference between cost and fair market value, as operating expenses instead of as nonoperating expenses, as required by Commission accounting regulations. As a result, Marathon overstated operating expenses and carrier property amounts reported on its Form 6.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Property & plant records" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Nonoperating Expenses", "summary": "Marathon improperly accounted for donations and charitable contributions, lobbying activities, and fines and penalties as operating expenses. As a result, Marathon overstated operating expenses reported in its Form 6.", "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting for Carrier Property", "summary": "Marathon improperly accounted for various carrier property assets. Specifically, Marathon improperly accounted for retirements, idle pipeline assets, and cancelled capital projects.", "is_other_matter": false, "recommendations": [], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Interest During Construction", "summary": "Marathon improperly accounted for interest during construction for the Patoka Tank Farm Expansion project in Account 155, Pipeline Construction, instead of recording the associated interest costs to Account 161, Oil Tanks, which was the same carrier property account as the construction costs upon placing those facilities into service, as required by Commission accounting regulations. While this accounting affected the accuracy of the balances in these specific carrier property accounts, it did not affect total carrier property since all carrier property accounts consolidate into Account 30, Ca", "is_other_matter": false, "recommendations": [], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 7, "title": "Miscellaneous Accounting Misclassifications", "summary": "Marathon misclassified certain operating expenses during the audit period in the wrong account. While this accounting led to account misclassifications, it did not affect the total operating expenses reported in the Form 6.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 8, "title": "Miscellaneous Form 6 Reporting Errors", "summary": "Marathon misreported certain items on supporting schedules and various accounts included in its Form 6. Specifically, Marathon misreported information related to miles of pipeline operated, noncarrier property, accumulated deferred income taxes, and oil losses and shortages.", "is_other_matter": false, "recommendations": [], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 9, "title": "Allocation of Intrastate Activities on Page 700", "summary": "Marathon did not remove intrastate amounts when reporting certain line items on page 700 of its 2015 Form 6.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 10, "title": "Request for Approval to Use Account 705", "summary": "In 2013, Marathon improperly recorded a balance of $9.4 million in Account 705, Prior Period Adjustment to Beginning Retained Earnings, absent Commission approval. In accordance with Commission accounting regulations, Marathon should have filed with the Commission for approval prior to recording amounts in Account 705.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2018-01-12_explorer-pipeline-company_fa16-5", "company": "Explorer Pipeline Company", "company_raw": "FA16-5 Explorer Pipeline Company", "docket": "FA16-5", "docket_full": "FA16-5-000", "issued_date": "2018-01-12", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180112-3040&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20180112-3040", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20180112-3040 (fileID 14796817).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 81, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2013 to December 31, 2016", "industry": "oil", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "6" ], "finding_count": 13, "findings": [ { "index": 1, "title": "Shipper Historical Capacity for Prorationing", "summary": "Explorer did not correctly calculate shippers’ historical capacity used for prorationing when it included capacity from both the original and revised delivery tickets, rather than the capacity from only the revised ticket, to calculate shippers’ historical capacity. This resulted in incorrect allocation percentages that over allocated capacity to some shippers and under allocated capacity to other shippers during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Prorationing of Bid Capacity", "summary": "Explorer did not assign bid capacity between shippers having equal price offers according to its proration policy for the October 2013 and April 2014 capacity auctions. This resulted in Explorer under awarding capacity to one unaffiliated shipper and over awarding capacity to another in two of the 48 monthly bid capacity auctions during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 3, "title": "Awarding of Bid Capacity", "summary": "Explorer did not properly award bid capacity under its tariff to a shipper with a higher price offer than another shipper in the November 2015 bid capacity auction. As a result, Explorer incorrectly awarded 50,000 barrels of bid capacity between two shippers. Also, Explorer’s tariff did not clearly describe the procedures it used to award bid capacity on each pipeline segment, which reduced the transparency of this process to shippers.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 4, "title": "Transportation Rates for Refined Products", "summary": "On one occasion, Explorer did not charge an unaffiliated shipper its approved tariff rate of $1.096 for the delivery of 25,004 barrels of refined product. On three other occasions, it charged a rate to the same unaffiliated shipper inconsistent with the Commission’s intermediate point requirements. The rate charged was higher than the approved tariff rate causing an over collection of revenues from this shipper of $1,458. These oversights led to inaccurate billings to the shipper and misreporting of operating revenues in its income statement.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight", "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 5, "title": "Form of Tariff", "summary": "Explorer omitted the index of commodities schedule and an appropriate reference to the shipper manual from its tariffs. While this did not adversely affect shippers, it caused a lack of transparency to potential users of Explorer’s local and joint tariffs.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Revise its tariffs to include an index of commodities and the appropriate reference to the shipper manual, to be consistent with the Commission’s regulations in 18 C.F.R. § 341.3.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Subsidiary Investments", "summary": "Explorer improperly reported certain activities related to its investment in its wholly owned subsidiary, the Service Company, under the consolidated method of accounting instead of using the equity method of accounting required by the Commission. Explorer also did not keep worksheets or memorandum accounts to support its investment activity in the Service Company since its creation in January 1997. As a result of consolidation, Explorer incorrectly reported investment activities of the Service Company in its financial statements.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Update policies and procedures to ensure its investment in the Service Company are accounted and reported for under the equity method consistent with Instruction for Balance Sheet Accounts 2-2.", "source_page": null }, { "number": 12, "text": "Create a memorandum account or worksheet detailing its investment in the Service Company since its creation, as required under Instruction for Balance Sheet Accounts 2-2.", "source_page": null }, { "number": 13, "text": "Make appropriate adjustments to the comparative financial statements and include footnote disclosure explaining these adjustments to financial statement presentation associated with the equity method of accounting in its next Form 6.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Accounting for Affiliate Transaction Markups", "summary": "Explorer improperly recorded the markup above costs for services received from its wholly owned subsidiary, the Service Company, as operating expenses instead of recording the markup as a nonoperating expense. As a result, Explorer overstated operating expenses since 1997.", "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Update accounting policies and procedures to ensure transactions with the Service Company are accounted for consistent with the Commission’s accounting requirements.", "source_page": null }, { "number": 15, "text": "Implement procedures to record the affiliate’s profit markup to Account 660, a nonoperating expense account, prospectively. Document Accession #: 20180112-3040 Filed Date: 01/12/2018 Explorer Pipeline Company", "source_page": null }, { "number": 16, "text": "Make appropriate adjustments to the comparative financial statements and include footnote disclosure explaining these adjustments to financial statement presentation in its next Form 6.", "source_page": null } ], "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 8, "title": "Accounting for Interest Rate Swap", "summary": "Explorer improperly accounted for accrued interest and fair value adjustments related to an interest rate swap during the period it held this derivative instrument. Explorer also improperly deferred and amortized the gain from the sale of the interest rate swap over a five year period, rather than recognizing it in income in the accounting period it was sold. This resulted in an understatement of net income from inception, up to and including the period in which the swap was sold. Subsequent to the sale of the interest rate swap the balance sheet and net income were overstated.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Develop appropriate policies and procedures to address Explorer’s accounting for derivative instruments.", "source_page": null }, { "number": 18, "text": "Retain proper documentation for interest rate swaps and other derivative instruments to support their designation as hedge transactions as appropriate.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Carrier Property Depreciation Accruals", "summary": "Explorer accrued depreciation expense for vehicles and other work equipment after these assets were fully depreciated. This resulted in Explorer recording depreciation expense in excess of the book cost of vehicles and other work equipment from 2012 through 2016.", "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Refrain from accruing depreciation on assets that are fully depreciated and periodically monitor the depreciation rates used for carrier property to ensure that carrier property is being depreciated over the respective assets’ useful lives.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 10, "title": "Depreciation on Completed Construction Projects", "summary": "Explorer did not transfer construction project costs in a timely manner from Account 187, Construction Work In Progress to primary plant accounts when it completed and put projects into service. Explorer also did not recognize depreciation expense in the proper period for these projects. As a result, Explorer understated depreciation expense and overstated the net book value of carrier property.", "is_other_matter": false, "recommendations": [ { "number": 20, "text": "Strengthen policies and procedures to ensure projects are transferred timely from Account 187 to the primary plant accounts and depreciation is recognized in the proper period.", "source_page": null }, { "number": 21, "text": "Make appropriate adjustments to the comparative financial statements and include footnote disclosure explaining the change to accumulated depreciation reserve. Submit accounting entries supporting this adjustment to DAA within 30 days of issuance of this report.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 11, "title": "FERC Form No. 6 Accounting and Reporting", "summary": "Explorer did not map its general ledger accounts to FERC prescribed accounts consistently as required by the instructions of the Commission’s Uniform System of Accounts to populate its Form 6. Additionally, Explorer’s Form 6 contained other discrepancies, including incorrect balances and incomplete information for certain supporting pages to the financial statements. These inconsistencies and deficiencies reduced the overall transparency, accuracy, and usefulness of the Form 6.", "is_other_matter": false, "recommendations": [ { "number": 22, "text": "Revise and strengthen policies, procedures, and practices to ensure information in the Form 6 is accurate and consistent with the Commission’s accounting and reporting requirements.", "source_page": null }, { "number": 23, "text": "Strengthen accounting procedures to ensure transactions are mapped and classified to the appropriate accounts according to Commission instructions and regulations.", "source_page": null }, { "number": 24, "text": "Establish regular evaluations of accounting and reporting decisions and adequate checks and balances over employees performing these duties. Document Accession #: 20180112-3040 Filed Date: 01/12/2018 Explorer Pipeline Company", "source_page": null }, { "number": 25, "text": "Consider engaging an outside party for guidance to strengthen its compliance with Commission accounting and reporting requirements. Also consider reaching out to the Regulatory Accounting Branch within DAA for accounting inquiries and Division of Energy Market Oversight for Form 6 reporting guidance.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 12, "title": "Statement of Cash Flows", "summary": "Payment for Retirement of Long Term Debt Page 121, Line Explorer could not explain or provide records or documents to support the difference between the retirement of long term debt reported on page 121, Line 73 and page 227, Line 30, Column (g) in its 2014 Form 6. Carrier Property Page 213, Column (g) Explorer could not explain or provide records or documents to support the amount recorded as an adjustment to carrier property for the audit period. Accrued Depreciation – Carrier Property Page 216, Column (d), Lines 21 and 26 Explorer could not provide records or documents to support the amount", "is_other_matter": false, "recommendations": [ { "number": 26, "text": "Update procedures to ensure it prepares the statement of cash flows consistent with Order 505 and the instructions of the Form 6.", "source_page": null }, { "number": 27, "text": "Make appropriate adjustments to the comparative statement of cash flows and include a footnote disclosure explaining changes made to the previous year’s activities in its next Form 6.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 13, "title": "Preservation of Records", "summary": "Balance Sheet - Derivative Instrument Liabilities (Hedge) Page 113 Explorer did not maintain records and documents to support the carrying value and subsequent monthly valuations from the initial recording of the interest rate swap in 2002 to the balance reported in Explorer’s 2013 Form 6. Statement of Cash Flows – Untitled Page 120, Line Explorer could not explain or provide records or documents to support the manual adjustment reported on this line for 2013 and 2014. This line consisted of several activities, including a change in other deferred charges, accumulated deferred income tax credi", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Update record retention policies, procedures, and controls to ensure all records are retained and stored consistent with the Commission’s preservation of records requirements. E.", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Affiliate / intercompany transactions", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "IL", "source": "Illinois Commerce Commission", "doc_type": "ICC investigation order incorporating Liberty management audit (gas System Modernization Program)", "id": "2018-01-10_peoples-gas-light-coke_icc-16-0376-system-modernization-investigation", "company": "The Peoples Gas Light and Coke Company", "company_raw": "The Peoples Gas Light and Coke Company", "docket": "16-0376", "docket_full": null, "issued_date": "2018-01-10", "source_page_url": "https://icc.illinois.gov/docket/P2016-0376/documents/262806", "pdf_download_url": "https://icc.illinois.gov/docket/P2016-0376/documents/262806/files/462056.pdf", "captured_at": "2026-06-08", "source_note": "Illinois Commerce Commission Final Order (215 pp) in the §8-501/10-101 investigation of Peoples Gas's natural-gas System Modernization Program (formerly Accelerated Main Replacement), issued 2018-01-10; incorporates the Liberty Consulting management-audit findings (~95 recommendations). Listed for reference (metadata-only; ICC order format, not the Exhibit I-2 parser). PDF: icc.illinois.gov/docket/P2016-0376/documents/262806/files/462056.pdf.", "archived_via": null, "page_count": 215, "scanned_pages": [ 2, 4 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-11-09_chevron-u-s-a-inc_pa16-1", "company": "Chevron U.S.A., Inc.", "company_raw": "PA16-1 Chevron U.S.A., Inc.", "docket": "PA16-1", "docket_full": "PA16-1-000", "issued_date": "2017-11-09", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20171109-3042&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20171109-3042", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20171109-3042 (fileID 14753835).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 23, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2014 through August 31, 2017", "industry": "gas", "audit_type": "non-financial", "functions": [], "forms": [ "552" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Price Index Reporting", "summary": "CUSA excluded 27 reportable transactions from its price index reporting submissions during the audit period. The exclusion was an error due to misidentification of reportable and nonreportable transactions.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Form 552 Reporting", "summary": "CUSA improperly reported four transactions on its 2014 Form 552 filing. Also, CUSA improperly applied a reporting threshold used to exclude individual transactions from Form 552 reporting when the volume of the transaction was smaller than 0.05 TBtu per year (or 137 MMBtu per day). E. Summary of", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NY", "source": "NY Public Service Commission", "doc_type": "comprehensive management & operations audit (PSC order releasing audit report, PSL 66(19))", "id": "2017-10-24_central-hudson_ny-16-m-0001-mo-audit-order", "company": "Central Hudson Gas & Electric Corporation", "company_raw": "Central Hudson Gas & Electric Corporation", "docket": "16-M-0001", "docket_full": null, "issued_date": "2017-10-24", "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=16-M-0001", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B70EE0090-9CDA-450B-9614-71C4BEB734BF%7D", "captured_at": "2026-06-08", "source_note": "NY PSC Order Releasing Audit Report, Case 16-M-0001 — Comprehensive Management and Operations Audit of Central Hudson (PSL 66(19)). Issued & effective Oct 24, 2017. Page 1 verified.", "archived_via": null, "page_count": 16, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-09-26_mississippi-power-company_fa15-8", "company": "Mississippi Power Company", "company_raw": "FA15-8 Mississippi Power Company", "docket": "FA15-8", "docket_full": "FA15-8-000", "issued_date": "2017-09-26", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170926-3019&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170926-3019", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170926-3019 (fileID 14692530).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 97, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "580", "60" ], "finding_count": 10, "findings": [ { "index": 1, "title": "Unused Investment Tax Credits", "summary": "Mississippi Power only used balance sheet accounts to record unused investment tax credits (ITC) and its related deferred income tax effects instead of using balance sheet and income statement accounts, as required by the Commission’s accounting regulations. Mississippi Power also improperly transferred the debit balance for unused ITCs from Account 236 to Account 165 on December 31st for 2012 through 2014, and incorrectly billed wholesale customers for this misclassified debit balance. Then, Mississippi Power reclassified the debit balance back to Account 236 the following months from 2013 th", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Income Tax Receivables", "summary": "issue similar to the findings and recommendations in the draft audit report) x Inception of a rate refund with respect to the Income Tax Receivable issue Based on our understanding of the sequence of the expected events that would occur if the FERC maintains its position regarding the Income Tax Receivables issue, we believe that there is significant risk that the IRS would assert that a deferred tax normalization violation occurs upon issuance of the final audit reports, but we believe that the Southern Operating Companies could credibly assert that the effective date of sanctions for a defer", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Wholesale Storm Damage Revenues", "summary": "From 2012 through 2014, Mississippi Power did not retain $199,775 in excessive storm damage revenues collected from its wholesale customers in the appropriate liability account in accordance with the Commission accounting regulations. Also, Mississippi Power did not provide its wholesale customers with the time value of money associated with excessive storm damage revenues.", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 4, "title": "Commitment Fees", "summary": "Mississippi Power’s accounting practices for legal fees and upfront and quarterly commitment fees were deficient. Specifically, Mississippi Power: • Inappropriately recorded legal fees associated with establishing and maintaining bank lines of credit with lending institutions in Account 921, Office Supplies and Expenses, instead of Account 431, Interest Expense. • Improperly accounted for upfront commitment fees associated with establishing lines of credit with various institutions in Account 165, Prepayments, before amortizing amounts to Account 431. • Incorrectly included commitment upfront", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Asset Retirement Obligations", "summary": "Mississippi Power did not adjust the balance in Account 108, Accumulated Provision for Depreciation of Electric Utility Plant, to remove $986,591 debited to this account during the implementation of Financial Accounting Standards Board (FASB) Interpretation No. 4711, Accounting for Conditional Asset Retirement Obligations, in 2005. As a result, Mississippi Power used incorrect net plant allocators in formula rate development since 2005, which had an impact on billings to its wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 6, "title": "Formula Rate Errors", "summary": "Mississippi Power made several errors in determining formula rate billings to wholesale customers. This occurred because Mississippi Power’s formula rate true-up filings inappropriately contained data inputs and calculations not provided for by its formula rate recovery mechanism. As a result of these errors, Mississippi Power overbilled its wholesale customers during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Prior Period Adjustments", "summary": "Mississippi Power improperly used materiality thresholds as justification for not recording adjustments stemming from accounting errors previously recorded in its books and records and reported in its FERC Form No. 1. Also, it did not have adequate procedures to address these accounting matters in a timely fashion. Moreover, Mississippi Power did not consider the formula rate impact of the errors on billings to wholesale customers. As a result, the amounts recorded in Mississippi Power’s books and records and reported in the FERC Form No. 1 were incomplete and billings to wholesale customers w", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 8, "title": "FERC Form No. 1 Reporting", "summary": "Mississippi Power did not properly follow the FERC Form No. 1 instructions and, therefore, did not report all required information in its 2014 FERC Form No. 1 filing.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 9, "title": "Coal Handling Expenses", "summary": "Mississippi Power has five coal supply contracts24 to buy coal to be used in its coal-fired generating facilities. At least some if not all of the coal purchased under these contracts is transported to the ASPA terminal via railcars, ships, and barges (i.e., transportation equipment). Under the master agreement, Southern Company agreed to pay a fixed capacity assessment fee for its share of the construction cost associated with the ASPA terminal conversion. Southern Company pays its share of the capacity assessment fee over the term of the master agreement. The capacity assessment fee is a cha", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Accounting for Estimated Final Land Reclamation", "summary": "Mississippi Power incorrectly determined the depreciation component of the estimated final land reclamation erroneously included in Account 151 on the straight-line method instead of the unit of production method.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-09-26_gulf-power-company_fa15-5", "company": "Gulf Power Company", "company_raw": "FA15-5 Gulf Power Company", "docket": "FA15-5", "docket_full": "FA15-5-000", "issued_date": "2017-09-26", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170926-3016&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170926-3016", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170926-3016 (fileID 14692208).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 87, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "60" ], "finding_count": 10, "findings": [ { "index": 1, "title": "Income Tax Receivables", "summary": "issue similar to the findings and recommendations in the draft audit report) x Inception of a rate refund with respect to the Income Tax Receivable issue Based on our understanding of the sequence of the expected events that would occur if the FERC maintains its position regarding the Income Tax Receivables issue, we believe that there is significant risk that the IRS would assert that a deferred tax normalization violation occurs upon issuance of the final audit reports, but we believe that the Southern Operating Companies could credibly assert that the effective date of sanctions for a defer", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Wholesale Storm Damage Revenues", "summary": "From 2012 through 2014, Gulf Power did not retain $138,245 in excessive storm damage revenues collected from its wholesale customers in the appropriate liability account in accordance with the Commission accounting regulations. Also, Gulf Power did not provide its wholesale customers with the time value of money associated with excessive storm damage revenues.", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 3, "title": "Other Special Funds Related To Storm Damages", "summary": "Gulf Power incorrectly overstated the wholesale transmission rate base by retail related storm damage investments and associated earnings on such investments. As a result, Gulf Power overstated its revenue requirement and overbilled its wholesale customers in years prior to and during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "index": 4, "title": "Commitment Fees", "summary": "Gulf Power improperly accounted for upfront bank fees paid associated with revolving lines of credit agreements in Account 165, Prepayments, and improperly amortized the fees to Account 930.2, Miscellaneous General Expenses, over the term of the line of credit agreements. In addition, Gulf Power improperly accounted for the related quarterly commitment fees in Account 930.2. As a result of these errors, Gulf Power overstated its revenue requirement and increased billings to wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Asset Retirement Obligations", "summary": "Gulf Power inappropriately excluded accumulated depreciation balances from wholesale transmission formula rate determinations that it removed from Account 108, Accumulated Provision for Depreciation of Electric Utility Plant, in the years following an accounting adjustment related to asset retirement obligations (AROs) in 2005. As a result, Gulf Power understated accumulated depreciation balances in its wholesale transmission formula rate by approximately $9.9 million since 2005, which had an impact on billings to its wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 6, "title": "Calculation of an Allowance for Funds Used During Construction", "summary": "Gulf Power incorrectly determined its allowance for funds used during construction (AFUDC) rate using the Florida Public Service Commission’s (Florida Commission) method which was inconsistent with the Commission’s AFUDC requirements. The Florida Commission’s method used resulted in an AFUDC rate that exceeded the maximum rate permitted in accordance with the Commission AFUDC requirements. As a result, Gulf Power overbilled its wholesale customers for the excessive AFUDC costs included in utility plant that was included in formula rate determinations through rate base and depreciation charges.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital", "Depreciation", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 7, "title": "Formula Rate Errors", "summary": "Gulf Power’s formula rate true-up filings contained erroneous formula implementations for Gulf Power. This occurred because Gulf Power’s wholesale formula rate filings inappropriately contained data inputs and calculations not provided for by its formula rate recovery mechanism. As a result, Gulf Power overstated its return on transmission rate base during the audit period, resulting in overbillings to its wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 8, "title": "Prior Period Adjustments", "summary": "Gulf Power improperly used materiality thresholds as justification for not recording adjustments stemming from accounting errors previously recorded in its books and records and reported in its FERC Form No. 1. In addition, Gulf Power did not have adequate procedures to timely address these accounting errors. Gulf Power also did not have procedures in place to reflect the formula rate impact of the accounting errors on billings to wholesale customers. This resulted in Gulf Power recording incomplete amounts in its books and records and in its FERC Form No. 1, as well as, improper billings to i", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 9, "title": "Coal Handling Expenses", "summary": "Gulf Power has coal supply contracts to buy coal to be used in its coal-fired generating facilities. At least some if not all of the coal purchased under these contracts is transported to the ASPA terminal via railcars, ships, and barges (i.e., transportation equipment). Under the master agreement, Southern Company agreed to pay a fixed capacity assessment fee for its share of the construction cost associated with the ASPA terminal conversion. Southern Company pays its share of the capacity assessment fee over the term of the master agreement. The capacity assessment fee is a charge that ASPA", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "FERC Form No. 1 Reporting", "summary": "Gulf Power did not properly follow FERC Form No. 1 instructions and, therefore, did not report all the required information in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Cost of service & rates", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-09-26_georgia-power-company_fa15-6", "company": "Georgia Power Company", "company_raw": "FA15-6 Georgia Power Company", "docket": "FA15-6", "docket_full": "FA15-6-000", "issued_date": "2017-09-26", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170926-3017&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170926-3017", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170926-3017 (fileID 14692532).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 104, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "60" ], "finding_count": 14, "findings": [ { "index": 1, "title": "Income Tax Receivables", "summary": "issue similar to the findings and recommendations in the draft audit report) x Inception of a rate refund with respect to the Income Tax Receivable issue Based on our understanding of the sequence of the expected events that would occur if the FERC maintains its position regarding the Income Tax Receivables issue, we believe that there is significant risk that the IRS would assert that a deferred tax normalization violation occurs upon issuance of the final audit reports, but we believe that the Southern Operating Companies could credibly assert that the effective date of sanctions for a defer", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Wholesale Storm Damage Revenues", "summary": "From 2012 through 2014, Georgia Power did not retain $1,061,285 in excessive storm damage revenues collected from its wholesale customers in the appropriate liability account in accordance with the Commission accounting regulations. Also, Georgia Power did not provide its wholesale customers with the time value of money associated with excessive storm damage revenues.", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 3, "title": "Commitment Fees", "summary": "Georgia Power improperly accounted for upfront fees paid associated with revolving line of credit agreements in Account 165, Prepayments, and quarterly commitment and letter of credit fees on the agreements in Account 930.2, Miscellaneous General Expenses. In addition, Georgia Power inappropriately amortized the upfront fees paid to Account 930.2. The accounting misclassifications of the fees overstated the transmission revenue requirement and resulted in overbillings to Georgia Power’s wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Asset Retirement Obligations", "summary": "Georgia Power inappropriately included accumulated depreciation balances in wholesale transmission formula rate determinations that it recorded in Account 108, Accumulated Provision for Depreciation of Electric Utility Plant, following an accounting adjustment related to asset retirement obligations (AROs) in 2005. As a result, Georgia Power overstated accumulated depreciation balances in its wholesale transmission formula rate by approximately $9.5 million since 2005, which had an impact on billings to its wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 5, "title": "Formula Rate Errors", "summary": "Georgia Power made several errors in determining billings to wholesale transmission customers. This occurred because Georgia Power’s wholesale formula rate filings inappropriately contained data inputs and calculations not provided for by its formula rate recovery mechanism. As a result of these errors, Georgia Power overbilled its wholesale customers during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Southern Nuclear Transactions", "summary": "Georgia Power improperly accounted for certain production-related costs allocated from its affiliate services company, Southern Nuclear Operating Company (Southern Nuclear), in administrative and general expense accounts instead of the appropriate nuclear production operation and maintenance expense accounts. This accounting error resulted in increased billings to Georgia Power’s wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 7, "title": "Regulatory Assets", "summary": "Georgia Power inappropriately included regulatory assets associated with retail- related storm damage costs and unpaid vacation pay in wholesale formula rate determinations without specific Commission authorization. As a result, Georgia Power improperly billed its wholesale customers a return on the regulatory asset for: (1) storm damage costs that were not incurred to repair or restore transmission facilities and (2) unpaid vacation pay that resulted in no outlay of cash.", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 8, "title": "Cancelled Production Projects", "summary": "Georgia Power improperly wrote-off the costs of cancelled production projects accounted for in Account 183, Preliminary Survey and Investigation Charges to Account 930.2, Miscellaneous General Expenses. As a result, Georgia Power inappropriately overbilled its wholesale customers due to the inclusion of unauthorized production- related cost included in the wholesale transmission rates.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Construction Work in Progress", "summary": "Georgia Power inappropriately accounted for the costs of vegetation management and certain tools and test equipment directly in Account 107, Construction Work in Progress – Electric, instead of expensing these costs to the appropriate operations and maintenance expense accounts. Also, Georgia Power improperly accrued AFUDC on the vegetation management costs incorrectly included in CWIP. As a result, Georgia Power incorrectly billed its wholesale customers due to the inclusion of excessive AFUDC costs in electric plant in service that it included in wholesale formula rate determinations through", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital", "Property & plant records", "Service reliability & vegetation management" ], "cost_to_customers": true }, { "index": 10, "title": "Calculation of Allowance of Funds Used During Construction", "summary": "Georgia Power incorrectly determined the equity cost component in its calculation of the Allowance for Funds Used During Construction (AFUDC) rate. Georgia Power also included accumulated deferred income tax (ADIT) balances in the determination of the construction base using the Georgia Commission method which was inconsistent with the Commission’s AFUDC requirements. As a result of these errors, Georgia Power applied to construction work in progress (CWIP) an AFUDC rate that exceeded the maximum rate allowed by the Commission. Thus, Georgia Power overbilled its wholesale customers due to the", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 11, "title": "Accumulated Provision of Depreciation of Electric Plant", "summary": "Georgia Power inappropriately removed $350.8 million of accumulated depreciation expenses related to production, transmission, distribution, and general plant from Account 108, Accumulated Provision for Depreciation of Electric Utility Plant, without obtaining approval from the Commission. This accounting led Georgia Power to misrepresent the net book balance of plant assets reported in its FERC Form No. 1 and resulted in decreased billings to its wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 12, "title": "Prior Period Adjustments", "summary": "Georgia Power’s accounting and rate considerations associated with prior period adjustments were deficient. Specifically, Georgia Power did not: • Have adequate procedures to address in a timely manner prior period adjustments stemming from errors, misstatements, or corrections to estimates previously recorded in its books and records. • Correct prior period adjustments ranging from one to four years after the prior period adjustments were originally discovered. • Record correcting accounting entries in the current period in some situations when it deemed certain prior period adjustments immat", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "FERC Form No. 1 Reporting", "summary": "Georgia Power did not properly follow the FERC Form No. 1 reporting instructions and therefore did not report all the required information in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 14, "title": "Separation of Nuclear Decommissioning Trust Fund Monies", "summary": "Georgia Power did not separately account for monies in its nuclear decommissioning trust funds (NDTFs) that were collected from wholesale and retail customers to provide for the decommissioning of its nuclear plant. As a result, monies collected from wholesale and retail customers were comingled rather than separately accounted for in Georgia Power’s NDTFs.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Service reliability & vegetation management", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-09-26_alabama-power-company_fa15-7", "company": "Alabama Power Company", "company_raw": "FA15-7 Alabama Power Company", "docket": "FA15-7", "docket_full": "FA15-7-000", "issued_date": "2017-09-26", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170926-3018&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170926-3018", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170926-3018 (fileID 14692531).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 98, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "60" ], "finding_count": 13, "findings": [ { "index": 1, "title": "Income Tax Receivables", "summary": "issue similar to the findings and recommendations in the draft audit report) x Inception of a rate refund with respect to the Income Tax Receivable issue Based on our understanding of the sequence of the expected events that would occur if the FERC maintains its position regarding the Income Tax Receivables issue, we believe that there is significant risk that the IRS would assert that a deferred tax normalization violation occurs upon issuance of the final audit reports, but we believe that the Southern Operating Companies could credibly assert that the effective date of sanctions for a defer", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Wholesale Storm Damage Revenues", "summary": "From 2012 through 2014, Alabama Power did not retain $40,204 in excessive storm damage revenues collected from its wholesale customers in the appropriate liability account in accordance with the Commission accounting regulations.", "is_other_matter": false, "recommendations": [], "themes": [ "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 3, "title": "Commitment Fees", "summary": "Alabama Power improperly accounted for upfront set-up fees paid associated with revolving line of credit agreements in Account 165, Prepayments. In addition, Alabama Power inappropriately amortized the fees to Account 431, Interest Expense, over the term of the line of credit agreements. Furthermore, Alabama Power improperly included the amortized fees in the calculation of the cost of short-term debt in its AFUDC rate calculations without Commission approval. The accounting misclassification of the fees in Account 165 and inappropriate amortization of the fees overstated the transmission reve", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 4, "title": "Asset Retirement Obligations", "summary": "Alabama Power inappropriately excluded accumulated depreciation balances from wholesale transmission formula rate determinations that it removed from Account 108, Accumulated Provision for Depreciation of Electric Utility Plant, following an accounting adjustment related to AROs in 2005. As a result, Alabama Power understated accumulated depreciation balances in its wholesale transmission formula rate by approximately $19.3 million since 2005, which had an impact on billings to its wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 5, "title": "Formula Rate Errors", "summary": "Alabama Power made several errors in determining formula rate billings to wholesale customers. This occurred because Alabama Power’s wholesale formula rate true-up filings inappropriately contained data inputs and calculations not provided for by its formula rate recovery mechanism. As a result of these errors, Alabama Power overbilled its wholesale customers during the audit period.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Southern Nuclear Transactions", "summary": "Alabama Power improperly accounted for certain production-related costs allocated from its affiliate services company, Southern Nuclear, in administrative and general expense accounts instead of the appropriate nuclear production operation and maintenance accounts. This accounting error resulted in increased billings to Alabama Power’s wholesale customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 7, "title": "Separation of Nuclear Decommissioning Trust Fund Monies", "summary": "Alabama Power did not separately account for monies in its nuclear decommissioning trust funds (NDTFs) that it collected from wholesale and retail customers to provide for the decommissioning of its nuclear plant. As a result, monies collected from wholesale and retail customers were comingled rather than separately accounted for in Alabama Power’s NDTFs.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Accounting for Abandoned Transmission Projects", "summary": "Alabama Power did not assign any engineering and supervision (E&S) to abandoned transmission construction projects; instead, it reallocated the associated E&S costs to ongoing transmission projects and improperly accrued AFUDC on the reallocated amounts. As a result, Alabama Power improperly accrued AFUDC on E&S costs related to abandoned transmission projects.", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 9, "title": "Regulatory Assets", "summary": "and Liabilities note disclosure does not match Pages 232 and 238. Electric Operating Revenues Page 301, Line 12 Unbilled revenue disclosure note does not match Page 304, Sales of Electricity by Rate Schedule, Line 42, Column C Unbilled revenue. Transmission Line Statistics Page 423, Column (i) Missing required schedule detail on size of conductor and materials. Document Accession #: 20170926-3018 Filed Date: 09/26/2017 Alabama Power Company", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Accounting for Subsidiary Investment", "summary": "Alabama Power inappropriately accounted for its investment in a subsidiary, Alabama Property Company, on a consolidated basis in its FERC Form No. 1 reports, contrary to the Commission’s long-standing accounting policy.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 11, "title": "Prior Period Adjustments", "summary": "Alabama Power improperly used materiality thresholds as justification for not recording adjustments stemming from accounting errors previously recorded in its books and records and reported in its FERC Form No. 1. In addition, Alabama Power did not have adequate procedures to timely address these accounting errors. Alabama Power also did not have procedures in place to reflect the formula rate impact of the accounting errors on billings to wholesale customers. This resulted in Alabama Power recording incomplete amounts in its books and records and in its FERC Form No. 1, as well as improperly", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 12, "title": "Coal Handling Expenses", "summary": "Alabama Power has coal supply contracts to buy coal that was used in its coal- fired generating facilities. Coal purchased under these contracts was typically transported to the ASPA via railcars, ships, and barges (i.e., transportation equipment). Under the master agreement, Southern Company agreed to pay a fixed capacity assessment fee for its share of the construction cost associated with the ASPA terminal conversion. Southern Company pays its share of the capacity assessment fee over the term of the master agreement. The capacity assessment fee is a charge that ASPA invoiced Alabama Power", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "FERC Form No. 1 Reporting", "summary": "Alabama Power did not properly follow the instructions of the FERC Form No. 1 and therefore did not report all the required information in its FERC Form No. 1 filings.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Affiliate / intercompany transactions", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-08-29_pacificorp_fa16-4", "company": "PacifiCorp", "company_raw": "FA16-4 PacifiCorp", "docket": "FA16-4", "docket_full": "FA16-4-000", "issued_date": "2017-08-29", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170829-3016&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170829-3016", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170829-3016 (fileID 14668331).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 69, "scanned_pages": [], "ocr_used": false, "audit_period": "of January 1, 2013 to December 31, 2015", "industry": "electric", "audit_type": "financial", "functions": [ "generation", "transmission" ], "forms": [ "1" ], "finding_count": 9, "findings": [ { "index": 1, "title": "Storm Damage Accounting and Costs Recovery", "summary": "PacifiCorp’s accounting and wholesale formula rate billings for storm damage costs during the period of 2012 through 2015 were deficient as follows:  PacifiCorp improperly overbilled storm damage costs to its merchant function and third-party wholesale customers that procured transmission services under PacifiCorp’s OATT. This occurred because PacifiCorp improperly included actual plus estimated costs associated with the same storms in billings to its merchant and third-party wholesale customers. As a result, PacifiCorp overstated its wholesale transmission revenue requirement by approximatel", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 2, "title": "Mining Assets", "summary": "PacifiCorp inappropriately recovered from its wholesale customers the cost of production related mining assets through its wholesale formula rates. As a result, PacifiCorp overstated its wholesale transmission revenue requirement by approximately $3.7 million, which led to overbillings to third-party wholesale customers by approximately $600,000.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Amortization of Regulatory Assets", "summary": "PacifiCorp inappropriately included amortization of regulatory assets in its wholesale formula rates. As a result, PacifiCorp overstated its wholesale transmission revenue requirement by approximately $800,000, which led to overbillings to third-party wholesale customers of approximately $100,000.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Injuries and Damages Accounting and Costs Recovery", "summary": "PacifiCorp improperly classified injuries and damages accruals and recovered those costs through its wholesale formula rates when it had insurance policies to cover the cost of those damages. As a result, PacifiCorp overstated its wholesale transmission revenue requirement by approximately $2.9 million, which led to overbillings to third- party wholesale customers by approximately $400,000.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Allowance for Funds Used During Construction", "summary": "PacifiCorp’s methods for calculating Allowance for Funds Used During Construction (AFUDC) rate was deficient as follows:  PacifiCorp inappropriately included letter of credit fees (up-front and quarterly) as part of short term debt interest expense to compute AFUDC rate.  PacifiCorp inappropriately included Unappropriated Undistributed Subsidiary Earnings as part of the equity component for the purpose of computing AFUDC rate.  PacifiCorp inappropriately included Accumulated Other Comprehensive Income (AOCI) as part of the equity component for the purpose of computing AFUDC rate in 2013. As", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 6, "title": "Asset Retirement Obligations", "summary": "PacifiCorp’s accounting and rate treatment of Asset Retirement Obligations (ARO) were deficient as follows:  PacifiCorp inappropriately excluded accumulated depreciation amounts removed from Account 108, Accumulated Provision for Depreciation of Electric Utility Plant, to implement ARO accounting in the wholesale formula rates determinations. As a result, PacifiCorp understated its wholesale transmission revenue requirement which led to under-billings to its wholesale customers through its wholesale formula rates.  PacifiCorp inappropriately included estimated future asset retirement costs r", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 7, "title": "Accounting for Coal Settlement Costs", "summary": "PacifiCorp incorrectly accounted for amortization of two coal settlement payments in Account 151, Fuel Stock, instead of Account 501, Fuel.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Accounting for Liquidated Damages", "summary": "PacifiCorp incorrectly accounted for amortization of production related regulatory assets associated with liquidated damages as an administrative and general expense in Account 930.2, Miscellaneous General Expense.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Accounting for Pensions, PBOP and Other Benefits", "summary": "PacifiCorp recorded the cost of pensions, post-retirement benefits other than pensions (PBOP) and other employee benefits in various functional operating and maintenance expense accounts, instead of in Account 926, Employee Pensions and Benefits.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Depreciation", "Storm cost recovery & securitization" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-08-21_sesco-enterprises-llc_pa16-3", "company": "SESCO Enterprises, LLC", "company_raw": "PA16-3 SESCO Enterprises, LLC", "docket": "PA16-3", "docket_full": "PA16-3-000", "issued_date": "2017-08-21", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170821-3003&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170821-3003", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170821-3003 (fileID 14662548).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 19, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-03-15_northwestern-corporation_pa15-1", "company": "NorthWestern Corporation", "company_raw": "PA15-1 NorthWestern Corporation", "docket": "PA15-1", "docket_full": "PA15-1-000", "issued_date": "2017-03-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170315-4016&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170315-4016", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170315-4016 (fileID 14519641).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 41, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 through December 31, 2016", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 6, "findings": [ { "index": 1, "title": "Assignment of Redirect Priority", "summary": "NorthWestern Montana’s transmission function improperly approved 79 nonfirm transmission redirect requests that were assigned a higher priority than was permitted under its OATT. This represented less than 1 percent of the over 33,000 redirect requests that were made during the audit period. Out of these 79 redirect requests, 17 requests, made by NorthWestern’s merchant function, resulted in improperly displacing the service scheduled by other customers when curtailments occurred, which was inconsistent with OATT Section 22.1. This resulted in a total loss of 1,238 MWhs of transmission service", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Use of Secondary Network Transmission Service", "summary": "by Non-network Customers In 34 instances, NorthWestern approved secondary network transmission service requests made by two non-network customers purportedly serving as agents of network service customers without verifying that the reserved network transmission service would be used to serve network loads. Audit staff is concerned that permitting such a practice inhibits NorthWestern’s ability to properly grant transmission requests, which could result in misallocation of transmission capacity and affect transmission service for other transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Communications Between Transmission and Merchant Functions", "summary": "On two occasions, NorthWestern Montana’s transmission function employees improperly disclosed nonpublic transmission information to NorthWestern merchant function employees, which is contrary to the Commission’s Standards of Conduct. Audit staff determined that these disclosures did not provide the merchant function with a competitive advantage because the schedules of NorthWestern’s merchant were not approved on these two occasions and, therefore, there were no transmission curtailments to other transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Temporary Termination/Redesignation Procedures", "summary": "The standard form that NorthWestern provided to its network customers for temporarily terminating a network resource and redesignating the same resource did not include certain information required by section 30.3 of its OATT.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Filing and Reporting of Jurisdictional Service Agreements", "summary": "NorthWestern did not file 15 large generator interconnection agreements (LGIAs) containing nonconforming terms and conditions with the Commission prior to commencing service and receiving customer payments under those agreements, as required by Commission regulations. NorthWestern also did not report four service agreements, including three interconnection agreements and one network operating service agreement, in its Electric Quarterly Report filing.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Reports of Issued Securities", "summary": "NorthWestern did not file reports of issued securities in a timely and accurate manner. These filing errors were caused by several issues, including a lack of controls to monitor and ensure timely and accurate reporting of security and debt issuances and a lack of administrative oversight.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "WA", "source": "Washington Utilities and Transportation Commission", "doc_type": "policy & interpretive statement on LDC natural-gas hedging practices (compliance/prudence review)", "id": "2017-03-13_wa-gas-ldcs_wa-ug-132019-hedging-policy-statement", "company": "Washington natural-gas LDCs (PSE, Avista, Cascade, NW Natural)", "company_raw": "Washington natural-gas LDCs (PSE, Avista, Cascade, NW Natural)", "docket": "UG-132019", "docket_full": null, "issued_date": "2017-03-13", "source_page_url": "https://www.utc.wa.gov/casedocket/2013/132019/docsets", "pdf_download_url": "https://apiproxy.utc.wa.gov/cases/GetDocument?docID=79&year=2013&docketNumber=132019", "captured_at": "2026-06-08", "source_note": "WA UTC Policy and Interpretive Statement on Local Distribution Companies' Natural Gas Hedging Practices, Docket UG-132019, service date March 13, 2017. 16 pp. Page 1 verified.", "archived_via": null, "page_count": 16, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2017-02-01_nv-energy-inc_pa15-2", "company": "NV Energy, Inc.", "company_raw": "PA15-2 NV Energy, Inc.", "docket": "PA15-2", "docket_full": "PA15-2-000", "issued_date": "2017-02-01", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170201-3016&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170201-3016", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20170201-3016 (fileID 14480359).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 58, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 through September 30, 2016", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "1", "580" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Accounting for Merger Costs", "summary": "Nevada Power and Sierra Pacific accounted for merger transaction costs in operating accounts, contrary to the directives of the Merger Order and long-standing Commission policy that such costs be recorded in nonoperating accounts. This accounting resulted in the companies misrepresenting utility operating income and expenses reported in their respective Form No. 1 reports.", "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 2, "title": "Accounting for Asset Retirement Obligations", "summary": "Summary of Proposed Finding and", "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Revise accounting policies and procedures to properly account for measurement changes related to asset retirement obligations (ARO).", "source_page": null }, { "number": 5, "text": "Perform an evaluation of the ARO-related regulatory assets to determine whether the items continue to meet the criteria for deferral as regulatory assets, and provide the evaluation to DAA within 60 days of receiving the final audit report. Regulatory assets associated with negative ARO assets that are no longer probable for recovery in future rates due to write-downs of the related ARO liabilities and assets should be reduced by the negative ARO asset balance and offset by increasing the ARO asset balance to zero.", "source_page": null }, { "number": 6, "text": "Within 60 days of receiving the final audit report, submit proposed accounting entries and supporting documentation to DAA that reflect the removal of ARO asset- and liability-related depreciation and accretion expense amounts from the regulatory asset accounts no longer probable for recovery in future rates. Also, remove corresponding amounts of the negative ARO asset balances from the plant accounts.", "source_page": null }, { "number": 7, "text": "Revise ARO and regulatory asset balances in the companies’ respective books of account and systems after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the balances reported in the Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Trust Funds", "summary": "Summary of Proposed Finding and", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Establish and implement procedures to account for temporary renewable energy development (TRED) trust fund deposits in accordance with Commission regulations.", "source_page": null }, { "number": 9, "text": "Submit proposed accounting entries and supporting documentation to DAA that reflect the transfer of the special-purpose TRED funds deposited in the external trust from Account 165, Prepayments, to Account 128, Other Special Funds, for review within 60 days of receiving the final audit report.", "source_page": null }, { "number": 10, "text": "Revise prepayment and other special-fund balances in the companies’ respective books of account and systems after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the balances reported in the Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "AFUDC Rate Calculation and Application to Construction Costs", "summary": "Summary of Proposed Finding and", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Revise policies and procedures, and reconfigure accounting systems used to calculate AFUDC rates consistent with the requirements of Electric Plant Instruction (EPI) No. 3.A.(17), Allowance for Funds Used During Construction. Among other things, the revisions should include processes to prevent inclusion of unpaid contract retention accruals and of goodwill in AFUDC rate calculations.", "source_page": null }, { "number": 12, "text": "Implement procedures to monitor differences between the maximum AFUDC rate calculated based on the requirements of EPI No. 3.A.(17) and the AFUDC rate as calculated with the inclusion of customer deposits. When inclusion of customer deposits in the calculation results in an AFUDC rate higher than the maximum allowed, the company must exclude the customer deposit balances from the AFUDC rate applied to construction cost.", "source_page": null }, { "number": 13, "text": "Perform an analysis of construction-related work orders and invoices from 2010 through the date of the final audit report to locate all instances of the inappropriate inclusion of unpaid contract retention accruals for all work orders, and also all errors applying AFUDC to construction costs incurred by Great Basin Transmission, LLC (Great Basin). Provide the results of the analysis to DAA for review.", "source_page": null }, { "number": 14, "text": "Recalculate the AFUDC rate since 2005 in accordance with the requirements of EPI No. 3.A.(17). Include the results of the work order and invoice analysis performed for 2010 through the date of the final audit report for the calculation required by Recommendation No. 13. Based on the calculations, in periods that the AFUDC rate used exceeded the maximum rate allowed pursuant to EPI No. 3.A.(17), submit a yearly estimate, with proposed accounting entries and support documentation to DAA that reflects corrections to remove over- accrued AFUDC balances from plant and associated accounts, such as accumulated depreciation and accumulated deferred income taxes in the companies’ respective books of account and systems.", "source_page": null }, { "number": 15, "text": "Revise plant, accumulated depreciation, accumulated deferred income taxes, and other impacted account balances that resulted from the over-accrual of AFUDC in the companies’ respective books of account and systems after receiving DAA’s assessment of the proposed accounting entries, and restate and footnote the balances reported in the Form No. 1 in the current and comparative years of the report, as necessary to reflect and disclose the revisions. The footnotes should include the adjustments by year with an explanation of the revisions. Accounting for Lobbying Expenses", "source_page": null }, { "number": 16, "text": "Establish and implement written procedures to properly account for, track, report, and review lobbying costs incurred through external party billings.", "source_page": null }, { "number": 17, "text": "Develop and implement policies, procedures, and controls to ensure proper accounting and reporting of payroll taxes and pension expenses associated with lobbying activities.", "source_page": null } ], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting for Lobbying Costs", "summary": "Summary of Proposed Finding and", "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 6, "title": "Filing FERC Form No. 580 Reports", "summary": "Summary of Proposed Finding and", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Revise and strengthen documented policies, procedures, and controls for timely completion and reporting of the FERC Form No. 580 in accordance with the instructions of the form.", "source_page": null }, { "number": 19, "text": "Develop and implement written policies, procedures, and controls to maintain compliance with regulatory reporting requirements of the Commission.", "source_page": null }, { "number": 20, "text": "Establish a documented succession plan that establishes procedures to transfer regulatory compliance responsibilities of departing staff on a timely basis.", "source_page": null }, { "number": 21, "text": "Provide training to staff on the revised policies, procedures, and controls to complete and file timely reports to the Commission. Also, develop a training program that supports the provision of periodic training in this area. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission opinion on initial decision", "id": "2017-01-19_potomac-appalachian-transmission-highline_er12-2708-opinion-554", "company": "Potomac-Appalachian Transmission Highline, LLC and PJM Interconnection, L.L.C.", "company_raw": "Potomac-Appalachian Transmission Highline, LLC and PJM Interconnection, L.L.C.", "docket": "ER12-2708", "docket_full": null, "issued_date": "2017-01-19", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20170119-3062&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20170119-3062", "captured_at": "2026-06-02", "source_note": "FERC Opinion No. 554, Order on Initial Decision, on the prudence of the Potomac-Appalachian Transmission Highline (PATH) project's transmission abandonment cost claim (formal challenges, ROE, and legal/advertising/lobbying costs) — affirming in part and reversing in part the ALJ initial decision. Potomac-Appalachian Transmission Highline, LLC and PJM, Dockets ER12-2708 / ER09-1256, issued January 19, 2017 (158 FERC para. 61,050). Distinct from the 2015 ALJ initial decision already in this collection. Found via the eLibrary AdvancedSearch API; accession 20170119-3062.", "archived_via": null, "page_count": 124, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-12-23_plantation-pipe-line-company_fa15-12", "company": "Plantation Pipe Line Company", "company_raw": "FA15-12 Plantation Pipe Line Company", "docket": "FA15-12", "docket_full": "FA15-12-000", "issued_date": "2016-12-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20161223-3023&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20161223-3023", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20161223-3023 (fileID 14451918).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 58, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 to December 31, 2015", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 8, "findings": [ { "index": 1, "title": "Carrier Property Depreciation Rates and Accruals", "summary": "Plantation did not adjust depreciation rates when they were no longer applicable and continued to accrue depreciation expense on certain carrier property accounts after they became fully depreciated. This resulted in Plantation recording $16.4 million of depreciation expense in excess of the book cost of the assets in these accounts, as of December 31, 2014.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Create procedures and controls to ensure depreciation rates remain relevant and applicable, and to make timely revisions when property accounts become fully accrued.", "source_page": null }, { "number": 2, "text": "Perform a new depreciation study that accounts for changes in assumptions for service lives.", "source_page": null }, { "number": 3, "text": "Submit a copy of this depreciation study to the Commission within 30 days of completion. Plantation should make appropriate changes to its existing depreciation rates pursuant to Commission action.", "source_page": null }, { "number": 4, "text": "Submit accounting entries supporting adjustments within the accrued depreciation accounts to reverse accrued depreciation expenses recorded in error to DAA for review within 30 days of issuance of this final audit report. Upon approval from DAA, make accounting entries supporting this adjustment within 60 days.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 2, "title": "Retirement of Carrier Property Assets", "summary": "Plantation did not timely remove the book cost of several assets from its carrier property accounts upon replacing and removing them from service. This resulted in the overstating of depreciation expense and the accrued depreciation reserve in the carrier property accounts. Additionally, Plantation did not maintain its records to readily provide, upon request, full information for some of the assets not properly removed from carrier property upon their retirement from service.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Modify its accounting policies and procedures to ensure retirements are promptly booked into its accounting systems, which should include establishing communication protocols among the various groups that work on asset retirements.", "source_page": null }, { "number": 6, "text": "Update its carrier property records to ensure information used to determine book cost is readily available and assets can be retired in a timely manner.", "source_page": null }, { "number": 7, "text": "Make appropriate adjustments within the accrued depreciation accounts to reverse accrued depreciation expenses recorded in error. Submit accounting entries supporting this adjustment to DAA within 60 days of issuance of this final audit report.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Fines and Penalties", "summary": "Plantation incorrectly accounted for fines and penalties paid to regulatory agencies in Account 570, Casualty and Other Losses, instead of Account 660, Miscellaneous Income Charges. Recording these activities in Account 570 overstated operating expenses and understated nonoperating expenses from 2012-2014.", "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Update accounting policies and procedures to ensure fines and penalties are accounted for consistently with Commission requirements.", "source_page": null }, { "number": 9, "text": "Record fines and penalties in Account 660, instead of Account 570, on a forward going basis. Submit journal entries to support the change in accounting treatment for these operating activities to DAA within 60 days of issuance of this final audit report.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Regulatory Fees and Industry Dues", "summary": "Plantation incorrectly accounted for regulatory fees and industry dues in Account 660, Miscellaneous Income Charges, instead of Account 510, Materials and Supplies, and Account 590, Other Expenses. Recording these activities in Account 660 overstated nonoperating expenses and understated operating expenses from 2012-2014.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Update its accounting policies and procedures to ensure annual charges, regulatory fees, and industry association dues are accounted for consistently with Commission accounting requirements.", "source_page": null }, { "number": 11, "text": "Record FERC annual charges in Account 510, and DOT-PHMSA fees, Commonwealth of Virginia fees, and Association of Oil Pipeline (AOPL) dues in Account 590, instead of Account 660. Submit journal entries to support the change in accounting treatment for these operating activities to DAA within 60 days of issuance of this final audit report.", "source_page": null } ], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 5, "title": "Accounting for Operating Expenses", "summary": "Plantation improperly accounted for certain operating expenses in Account 310, Materials and Supplies, instead of Accounts 320, Outside Services, and 390 and 590, Other Expenses. As a result of the improper classification of these expenses, Plantation reduced the accuracy of its accounting and reporting for operating expense activities.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Review and modify its account mapping for operating expenses to ensure activities recorded in internal cost centers are properly aligned with primary FERC accounts. Submit changes in account mapping to DAA within 60 days of issuance of this final audit report.", "source_page": null }, { "number": 13, "text": "Update accounting policies and procedures to ensure expenses are recorded in the appropriate operating expense account consistent with Commission accounting requirements.", "source_page": null }, { "number": 14, "text": "Reclassify amounts improperly recorded in Account 310 to Account 320, 390, and 590, to ensure these activities are recorded in the correct operating expense accounts. Review other operating expense accounts to ensure those expenses are mapped to the proper internal cost centers and FERC accounts.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Accounting and Reporting of Deferred Income Taxes", "summary": "Plantation had several deficiencies in its accounting and reporting for deferred income taxes from 2012-2014. These deficiencies included: o Improper netting of current and noncurrent deferred tax balances in Account 64, Accumulated Deferred Income Tax Liability, instead of recording the current deferred income tax asset balance in Account 19-5, Deferred Income Tax Assets, and the noncurrent deferred tax liability in Account 64. o Misclassification of a tax refund receivable as a current deferred income tax asset in Account 19-5 instead of Account 19, Other Current Assets. o Incorrect balance", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Revise its procedures to ensure current and noncurrent deferred income tax balances are accounted for and reported consistently with Commission accounting requirements.", "source_page": null }, { "number": 16, "text": "Make a correcting entry to adjust balances in Account 19, Account 19-5, Account 64, Account 670, Income Taxes on Income From Continuing Operations, and Account 671, to ensure balances for the current year are correctly stated. Submit correcting entry and support to DAA within 60 days of issuance of this final audit report.", "source_page": null }, { "number": 17, "text": "Include appropriate footnote disclosure in the Form 6 for adjustments made to deferred income taxes that are reported in column (d) of page 230 of the Form 6 on a forward going basis.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 7, "title": "Interest During Construction", "summary": "Plantation improperly accrued Interest During Construction (IDC) on two construction projects beyond the completion and in-service dates of the project. As a result, Plantation over-accrued IDC on these construction projects, which increased costs recorded in carrier property accounts.", "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Strengthen its procedures to ensure the accrual of IDC stops upon completing project construction and placing assets into service.", "source_page": null }, { "number": 19, "text": "Strengthen communication between accountants and field engineers to ensure timely closure of project work orders. Reporting of Interstate Volumes", "source_page": null }, { "number": 20, "text": "Strengthen its financial reporting procedures to ensure interstate barrel volumes are properly reported in its Form 6. E.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 8, "title": "Misreporting of Interstate Barrel Volumes", "summary": "Plantation over-reported interstate barrel volumes it transported under a joint tariff with Parkway on pages 600-601 of its 2014 Form 6. This error affected the accuracy of interstate barrel volumes used to determine the costs associated with interstate movements reported on page 700 of the Form 6 in 2014.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-12-02_calpine-corporation_pa15-5", "company": "Calpine Corporation", "company_raw": "PA15-5 Calpine Corporation", "docket": "PA15-5", "docket_full": "PA15-5-000", "issued_date": "2016-12-02", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20161202-3004&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20161202-3004", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20161202-3004 (fileID 14414594).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 35, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 through April 30, 2016", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [], "finding_count": 3, "findings": [ { "index": 1, "title": "Uplift Payments", "summary": "Calpine submitted inaccurate data to PJM resulting in overpayments of approximately $1.18 million for Lost Opportunity Cost (LOC) uplift credits as well as-yet undetermined Day-Ahead Scheduling Reserve (DASR) overpayments.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "PJM Offer Requirements", "summary": "Calpine included Regional Greenhouse Gas Initiative (RGGI)-related emission costs in its offers from eight RGGI-associated New Jersey combustion turbine (CT) units after those costs were no longer allowable. This resulted in unwarranted increases in certain Operating Reserve (OR)11 credits to these units during this period. However, the units also received Lost Opportunity Cost (LOC) credits, which were lower than they otherwise would have been, due to inclusion of RGGI-related emission costs in their offers. Analysis performed indicate that these foregone lower LOC credits would have effectiv", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "EQR Filing Requirements", "summary": "Calpine made EQR filings containing numerous errors, including: inaccurate uplift payment reporting, missing transactions, and improper class names for the increment denominated “peaking.” These errors inhibit the ability of the Commission and other interested parties to monitor wholesale electricity market activities.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "ALJ initial decision", "id": "2016-11-07_entergy-services_el01-88", "company": "Louisiana Public Service Commission v. Entergy Services, Inc.", "company_raw": "Louisiana Public Service Commission v. Entergy Services, Inc.", "docket": "EL01-88", "docket_full": null, "issued_date": "2016-11-07", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20161107-3024&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20161107-3024", "captured_at": "2026-06-07", "source_note": "FERC ALJ Initial Decision re Louisiana Public Service Commission v. Entergy Services, Inc., Docket EL01-88, issued 2016-11-07 — a long-running challenge to cost allocation and rough-production-cost equalization under the Entergy System Agreement. Metadata-only (free-form legal order). Found via the eLibrary AdvancedSearch API (searchText=EL01-88); accession 20161107-3024.", "archived_via": null, "page_count": 49, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-10-14_dynegy-inc_pa15-3", "company": "Dynegy, Inc.", "company_raw": "PA15-3 Dynegy, Inc.", "docket": "PA15-3", "docket_full": "PA15-03-000", "issued_date": "2016-10-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20161014-3018&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20161014-3018", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20161014-3018 (fileID 14376678).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 28, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 through April 30, 2016", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "EQR Filing Requirements", "summary": "Dynegy’s EQR filings contained numerous errors, some of which were significant, including: uplift payments in the wholesale organized markets and misclassification of transactions as energy sales, as well as unreported and inaccurately reported capacity sales, particularly in the MISO markets. These errors inhibit the ability of the Commission and other interested entities to monitor wholesale electricity market activities.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-09-29_westar-energy-inc_fa15-9", "company": "Westar Energy, Inc.", "company_raw": "FA15-9 Westar Energy, Inc.", "docket": "FA15-9", "docket_full": "FA15-9-000", "issued_date": "2016-09-29", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160929-3027&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160929-3027", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160929-3027 (fileID 14365485).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 39, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2005 to December 31, 2015", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 6, "findings": [ { "index": 1, "title": "Classification of Utility Plant", "summary": "Westar improperly recorded distribution plant amounts in transmission accounts that are included in the wholesale transmission formula rate. As a result, Westar overstated various transmission accounts and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Strengthen processes and procedures to ensure that Westar’s transmission and distribution assets are properly classified, and that amounts included in Westar’s transmission formula rate calculations are properly includible in those calculations. At a minimum, processes and procedures should be strengthened to include training for employees performing accounting functions and formula rate input calculations.", "source_page": null }, { "number": 2, "text": "Reclassify distribution plant and associated amounts into the proper accounts. Adjusted accounts should include, but are not limited to, transmission and distribution plant in service, depreciation expense, accumulated reserve for depreciation, deferred taxes, and transmission and distribution operations and maintenance expenses.", "source_page": null }, { "number": 3, "text": "Determine the impact of the misclassifications on Westar’s transmission formula rate. To the extent that the misclassified amounts affected Westar’s transmission formula rate, submit refund calculations to DAA for review that explains and details Westar’s calculation of the refunds and determinative components. Following submittal of the refund calculations to DAA, submit a refund report to the Commission in Docket No. ER11-2395. The refunds should include the net amount of inappropriate recoveries that resulted from the misclassifications, including interest calculated in accordance with section 35.19a of Commission regulations.", "source_page": null }, { "number": 4, "text": "Refund amounts over-collected consistent with the applicable provisions of Westar’s OATT.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Westar Energy Foundation Activities", "summary": "Westar improperly recorded nonoperating expenses in operating expense accounts that are included in the wholesale transmission formula rate. Specifically, Westar improperly recorded labor expenses associated with Westar’s employees performing nonoperating activities on behalf of the Westar Energy Foundation (WEF). Westar improperly recorded the labor expenses due to insufficient controls over the employees who work on WEF activities. As a result, Westar overstated various operating expense accounts and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 5, "text": "Strengthen accounting procedures to ensure it properly tracks and records time spent by Westar employees on WEF activities according to Commission accounting regulations. At a minimum, processes and procedures should be strengthened to include training for employees performing accounting functions and formula rate input calculations.", "source_page": null }, { "number": 6, "text": "Conduct a review of time and resources spent on foundation activities to identify expenses used to support WEF activities.", "source_page": null }, { "number": 7, "text": "Determine the impact of misclassified costs associated with WEF activities on Westar’s transmission formula rate. To the extent that the misclassified amounts affected Westar’s transmission formula rate, submit refund calculations to DAA for review that explains and details Westar’s calculation of the refunds and determinative components. Following submittal of the refund calculations to DAA, submit a refund report to the Commission in Docket No. ER11-2395. The refunds should include the net amount of inappropriate recoveries that resulted from the misclassifications, including interest calculated in accordance with section 35.19a of Commission regulations.", "source_page": null }, { "number": 8, "text": "Refund amounts over-collected consistent with the applicable provisions of Westar’s OATT.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Discriminatory Employment Practices", "summary": "Westar improperly recorded costs associated with discriminatory employment practices in various administrative and general (A&G) accounts, instead of using Account 426.5, Other Deductions. As a result, Westar overstated various A&G expense accounts, which are included in the wholesale transmission formula rate, and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Strengthen processes and procedures to ensure that Westar properly accounts for expenses related to discriminatory employment practices, and excludes such amounts from its transmission formula rate calculations. At a minimum, processes and procedures should be strengthened to include training for employees performing accounting functions and formula rate input calculations.", "source_page": null }, { "number": 10, "text": "Determine the impact of misclassified costs associated with discriminatory employment practices on Westar’s transmission formula rate. To the extent that the misclassified amounts affected a transmission formula rate, submit refund calculations to DAA for review that explains and details Westar’s calculation of the refunds and determinative components. Following submittal of the refund calculations to DAA, submit a refund report to the Commission in Docket No. ER11-2395. The refunds should include the net amount of inappropriate recoveries that resulted from the misclassifications, including interest calculated in accordance with section 35.19a of Commission regulations.", "source_page": null }, { "number": 11, "text": "Refund amounts over-collected consistent with the applicable provisions of Westar’s OATT.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Corporate Owned Life Insurance (COLI) Policies", "summary": "Westar improperly recorded COLI expenses for officers and other employees for policies in which Westar is the beneficiary in Account 926, Employee Pensions and Benefits, instead of Account 426.2, Life Insurance. As a result, Westar overstated Account 926, which is included in the wholesale transmission formula rate, and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Strengthen processes and procedures to ensure that Westar properly accounts for expenses related to corporate-owned life insurance policies, and excludes such amounts from its transmission formula rate calculations. At a minimum, processes and procedures should be strengthened to include training for employees performing accounting functions and formula rate input calculations.", "source_page": null }, { "number": 13, "text": "Determine the impact of corporate-owned life insurance amounts on Westar’s transmission formula rate. To the extent that these COLI amounts affected Westar’s transmission formula rate, submit refund calculations to DAA for review that explains and details Westar’s calculation of the refunds and determinative components. Following submittal of the refund calculations to DAA, submit a refund report to the Commission in Docket No. ER11-2395. The refunds should include the net amount of inappropriate recoveries that resulted from the misclassifications, including interest calculated in accordance with section 35.19a of Commission regulations.", "source_page": null }, { "number": 14, "text": "Refund amounts over-collected consistent with the applicable provisions of Westar’s OATT.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Completed Construction Not Classified", "summary": "Westar did not transfer the balances to Account 101, Electric Plant in Service, from Account 106, Completed Construction Not Classified – Electric, in a timely manner despite the fact that those projects could be readily classified according to prescribed account classifications. Westar represented that balances remained in Account 106 due to process inefficiencies in Westar’s construction and engineering departments, system- related issues, and employee turnover in the property accounting department.", "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Strengthen processes and written procedures to ensure that items are cleared out of Account 106 and into Account 101 so that the balances in Accounts 101 and 106 are classified as accurately as practicable according to prescribed account classifications. At a minimum, processes and procedures should be strengthened to include training for employees performing accounting functions.", "source_page": null }, { "number": 16, "text": "Conduct a review of assets currently classified in Account 106 to determine if any assets can be accurately transferred from Account 106 to Account 101 and into the proper functional utility plant accounts. Make all necessary accounting entries to transfer assets.", "source_page": null } ], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting for Asset Retirement Obligations", "summary": "Westar improperly accounted for asset retirement obligations (AROs) related to its utility plant assets by:  Improperly recording asset retirement cost depreciation expense in Account 182.3 rather than properly recording this expense in Account 403.1, Depreciation Expense for Asset Retirement Costs; and  Improperly recording accretion expense in Account 182.3, Other Regulatory Assets, rather than properly recording this expense to Account 411.10, Accretion Expense. Based on this improper accounting, Westar only recorded ARO amounts in balance sheet accounts and not income statement accounts.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Strengthen processes and procedures to ensure that Westar accounts for asset retirement obligations in accordance with Commission accounting rules and regulations. At a minimum, processes and procedures should be strengthened to include training for employees performing accounting functions.", "source_page": null }, { "number": 18, "text": "Going forward, classify accretion of ARO liabilities in Account 411.10, Accretion Expense.", "source_page": null }, { "number": 19, "text": "Going forward, classify the depreciation of asset retirement costs in Account 403.1, Depreciation Expense for Asset Retirement Costs. E.", "source_page": null } ], "themes": [ "Depreciation" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-09-29_kansas-gas-and-electric-company_fa15-15", "company": "Kansas Gas and Electric Company", "company_raw": "FA15-15 Kansas Gas and Electric Company", "docket": "FA15-15", "docket_full": "FA15-15-000", "issued_date": "2016-09-29", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160929-3028&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160929-3028", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160929-3028 (fileID 14365372).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 43, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2005 to December 31, 2015", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 7, "findings": [ { "index": 1, "title": "Classification of Utility Plant", "summary": "KGE improperly recorded distribution plant amounts in transmission accounts that are included in the wholesale transmission formula rate. As a result, KGE overstated various transmission accounts and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 2, "title": "Westar Energy Foundation Activities", "summary": "KGE improperly recorded nonoperating expenses in operating expense accounts that are included in the wholesale transmission formula rate. Specifically, KGE improperly recorded labor expenses associated with Westar employees performing nonoperating activities on behalf of the Westar Energy Foundation (WEF). KGE improperly recorded the labor expenses due to insufficient controls over the employees who work on WEF activities. As a result, KGE overstated various operating expense accounts and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Asset Retirement Obligations", "summary": "KGE improperly accounted for asset retirement obligations (AROs) related to its utility plant assets by: • Improperly recording asset retirement cost depreciation expense in Account 182.3 rather than properly recording this expense in Account 403.1, Depreciation Expense for Asset Retirement Costs; and • Improperly recording accretion expense in Account 182.3, Other Regulatory Assets, rather than properly recording this expense to Account 411.10, Accretion Expense. Based on this improper accounting, KGE only recorded ARO amounts in balance sheet accounts and not income statement accounts. Also,", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Discriminatory Employment Practices", "summary": "KGE improperly recorded costs associated with discriminatory employment practices in Account 920, Administrative and General Salaries, instead of using Account 426.5, Other Deductions. As a result, KGE overstated Account 920, which is included in the wholesale transmission formula rate, and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Accounting for Corporate Owned Life Insurance (COLI) Policies", "summary": "KGE improperly recorded COLI expenses for officers and other employees for policies in which Westar is the beneficiary in Account 926, Employee Pensions and Benefits, instead of Account 426.2, Life Insurance. As a result, KGE overstated Account 926, which is included in the wholesale transmission formula rate, and overbilled wholesale transmission customers.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 6, "title": "Application of Non-Approved Depreciation Rates", "summary": "KGE applied state-approved depreciation rates to transmission assets of the Wolf Creek Generating Station from 2012 through 2015, instead of FERC-approved depreciation rates.", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 7, "title": "Completed Construction Not Classified", "summary": "KGE did not transfer the balances to Account 101, Electric Plant in Service, from Account 106, Completed Construction Not Classified – Electric, in a timely manner despite the fact that those projects could be readily classified according to prescribed account classifications. The balances remained in Account 106 due to process inefficiencies in KGE’s construction and engineering departments, system-related issues, and employee turnover in the property accounting department.", "is_other_matter": false, "recommendations": [], "themes": [ "Property & plant records" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-08-16_empire-district-electric-company_pa15-7", "company": "Empire District Electric Company", "company_raw": "PA15-7 Empire District Electric Company", "docket": "PA15-7", "docket_full": "PA15-7-000", "issued_date": "2016-08-16", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160816-3031&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160816-3031", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160816-3031 (fileID 14330892).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 29, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2010 through December 31, 2015", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "1", "552" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Reporting of Energy and Capacity Sales in the EQR", "summary": "Empire did not report its wholesale sales to four municipalities within Empire’s service territory or wholesale sales made from its hydro facility. As a result, Empire under-reported its sales in its EQRs by $121,910,668 and 2,089,983 MWh during the audit period. These omissions hampered the Commission and interested parties’ ability to review and evaluate Empire’s wholesale sales activity.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Accuracy of Data Reported in the EQR", "summary": "Empire’s EQRs during the audit period contained various errors in the contracts and transactions it reported, including incorrect prices, quantities, customers, points of delivery, and affiliate identifications. These errors resulted from the Company’s inadequate oversight of its EQR processes and procedures, hampering the Commission and interested parties’ ability to review and evaluate Empire’s wholesale sales activity.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-07-15_southwest-power-pool-inc_pa15-6", "company": "Southwest Power Pool, Inc.", "company_raw": "PA15-6 Southwest Power Pool, Inc.", "docket": "PA15-6", "docket_full": "PA15-6-000", "issued_date": "2016-07-15", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160715-3007&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160715-3007", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160715-3007 (fileID 14309533).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 61, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 through June 22, 2016", "industry": "electric", "audit_type": "non-financial", "functions": [ "transmission" ], "forms": [ "1" ], "finding_count": 5, "findings": [ { "index": 1, "title": "SPP RTO Involvement with MMU Operations", "summary": "SPP RTO executives attended MMU meetings with the Oversight Committee, thereby having inappropriate access to information associated with MMU operations. In addition, SPP RTO executives were inappropriately involved in the performance evaluation of the MMU Director, approval of the MMU budget, and compensation adjustments for MMU staff. SPP RTO executives’ participation in the MMU Oversight Committee meetings and involvement in certain MMU operations resulted in an inadequate separation between the MMU and SPP RTO.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Separation of Functions", "summary": "The MMU inappropriately relied on the SPP RTO for legal services, IT resources, and staffing. The MMU’s reliance on SPP RTO for these functions neither fostered the appropriate level of independence nor demonstrated a sufficient separation of functions between the MMU and SPP RTO.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "MMU Shared Staff", "summary": "The MMU did not have a rigorous process in place to ensure that MMU staff members focused on MMU-related activities rather than performing SPP RTO activities unrelated to MMU operations. This practice contributed to a loss of clear separation between the MMU staff and the SPP RTO.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Operational Separation", "summary": "Since the MMU and SPP RTO shared the same physical facilities, the MMU lacked sufficient physical safeguards to preserve the MMU’s independence and ensure adequate separation between itself and SPP RTO to protect against the potential access by SPP RTO of MMU confidential workproducts.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "MMU Involvement with SPP RTO Tariff Formation", "summary": "The MMU did not limit its participation in SPP RTO tariff formation to the advisory role prescribed by the Commission. This resulted in conflicts that led to inefficient MMU and SPP RTO operations.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-05-09_enbridge-energy-partners-lp_fa15-4", "company": "Enbridge Energy Partners, LP", "company_raw": "FA15-4 Enbridge Energy Partners, LP", "docket": "FA15-4", "docket_full": "FA15-4-000", "issued_date": "2016-05-09", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160509-3026&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160509-3026", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160509-3026 (fileID 13682310).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 65, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2011 to December 31, 2015", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6" ], "finding_count": 12, "findings": [ { "index": 1, "title": "Provision of, and Billing for, Service to Intermediate Points", "summary": "Between March 2013 and June 2013, NDPL charged shippers rates for service to and from intermediate points on its pipeline system that were not specified in its tariff on file with the Commission. Additionally, NDPL did not make its tariff filing for the new origin/destination points (including the intermediate point paths) within the 30 days after the start of such service, as required by the Commission. As a result, NDPL was out of compliance with Commission regulations and its tariff. These unfiled rates did not cause harm to the shippers, since NDPL ultimately billed them for what would hav", "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Revise and implement procedures and controls to ensure that all its jurisdictional pipelines charge shippers rates in accordance with their applicable tariffs, and that all its jurisdictional pipelines submit accurate invoices to shippers.", "source_page": null }, { "number": 2, "text": "Develop and implement appropriate procedures and controls to ensure that all its jurisdictional pipelines’ tariffs remain applicable to their current operations, ensuring that, prior to implementing any changes in operations, the potential impacts upon the tariff are carefully considered to determine whether tariff revisions are needed.", "source_page": null }, { "number": 3, "text": "Train employees responsible for pipeline operations on the potential impacts that operational changes have upon tariff compliance.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 2, "title": "Invoicing for Services Rendered", "summary": "NDPL billed its shippers for oil movements not nominated by the shippers, which was contrary to their tariff language. These billing practices resulted in some shippers paying more and others less than what was appropriate under the filed tariff rates. The result was an overcollection of $536,555. Audit staff points out that NDPL subsequently corrected these billing errors such that no outstanding refunds are required.", "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Revise and implement procedures and controls to ensure that all its jurisdictional pipelines charge shippers rates in accordance with their applicable tariffs, and issue invoices for the services contracted for and provided to shippers.", "source_page": null }, { "number": 5, "text": "Refund any overcollections to shippers with interest.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 3, "title": "Reporting Intrastate Amounts on Page 700 of the Form 6", "summary": "Enbridge did not follow Commission instructions to remove intrastate amounts when reporting certain line items on page 700 of the Form 6. As a result, Enbridge overstated the interstate barrels and barrel-miles for NDPL’s Form 6 reports for the years 2009 through 2013. These errors could potentially affect: the shippers’ use of the data as a preliminary screening tool to protest indexed rate changes or to file complaints against existing rates, and the Commission’s calculation of the five-year index adjustment that is used to calibrate the indexed rates used by jurisdictional oil pipelines.", "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Enhance its review procedures to ensure the page 700 is accurate and complete.", "source_page": null }, { "number": 7, "text": "Update its policies and procedures to ensure that intrastate activities are removed from page 700, and that only interstate activities are reported.", "source_page": null }, { "number": 8, "text": "Resubmit its 2009-2013 Form 6 with the corrected page 700 amounts.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 4, "title": "Accounting for Charitable Contributions", "summary": "NDPL incorrectly recorded $191,030 in donations and charitable contributions in Account 590, Other Expenses (General), instead of in Account 660, Miscellaneous Income Charges, during the audit period. This resulted in an overstatement of operating expenses reported in the Form 6, affecting data used as a preliminary screen to evaluate pipeline rates and indexed rate changes, and potentially affecting the Commission’s calculation of the five- year oil pipeline index adjustment.", "is_other_matter": false, "recommendations": [ { "number": 9, "text": "Update accounting policies and procedures to ensure nonoperating expenses are properly recorded in nonoperating accounts.", "source_page": null }, { "number": 10, "text": "Review operating expense accounts and make correcting entries to reclassify amounts for donations and charitable contributions from Account 590, Other Expenses, to Account 660, Miscellaneous Income Charges, for the audit period.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 5, "title": "Changes in Reporting on Page 700 of the Form 6", "summary": "NDPL revised 18 of the 22 line item amounts on page 700 for 2013 and did not refile the corrected Form 6 with the Commission. NDPL presented this revised information in the prior-year column on page 700 of its 2014 Form 6 without adequately disclosing the reasons for the changes, in the 2014 Form 6 page 700 and accompanying footnotes. As a result there was no transparency for the reporting changes.", "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Enhance its review procedures to ensure page 700 is accurate and complete.", "source_page": null }, { "number": 12, "text": "Update its policies and procedures to ensure that footnotes for page 700 provide transparency for any changes in its methods or corrections in its calculations, and that only interstate activities are reported.", "source_page": null }, { "number": 13, "text": "Resubmit its 2013 Form 6 with the corrected page 700 amounts and sufficient explanations in the footnotes.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "index": 6, "title": "Accounting and Reporting for Derivative Instruments", "summary": "NDPL improperly recorded amounts related to derivative instruments that were not classified as either “cash flow” or “fair value” hedges in Account 47, Derivative Instrument Assets – Hedges, instead of Account 46, Derivative Instrument Assets. NDPL also incorrectly deferred gains and losses on the changes in fair value of the derivative instruments, and misclassified the realized gains or losses in Account 230, Allowance Oil Revenue, instead of the nonoperating miscellaneous income or expense accounts. As a result, the income statements, balance sheets, and page 700 revenues were misstated as", "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Develop the appropriate policies and procedures to properly address NDPL’s accounting for derivative instruments and hedging activities.", "source_page": null }, { "number": 15, "text": "Provide additional training as needed to improve NDPL’s accounting for derivative instruments.", "source_page": null }, { "number": 16, "text": "NDPL should record correcting entries to reclassify the accounting for derivatives and hedging activities for 2015 from Account 47 to Account 46, and reclassify gains and losses from Account 230 to Account 640 (gains), and Account 660 (losses). NDPL shall notify the Division of Audits when such adjustments are made.", "source_page": null } ], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true }, { "index": 7, "title": "Accounting for Retirements of Carrier Property", "summary": "NDPL improperly accounted for the retirement of carrier property removed from service by neither estimating the value nor having adequate records to justify the book cost of the assets. This treatment inflates carrier property and the accrued depreciation—carrier property by understating the retirements that should be reported on page 216 of the Form 6 and leads to overstated depreciation expense.", "is_other_matter": false, "recommendations": [ { "number": 17, "text": "Record appropriate adjusting journal entries to properly reflect the costs of the assets previously retired at only $0.01.", "source_page": null }, { "number": 18, "text": "Develop the appropriate policies and procedures that address NDPL’s accounting for retirements.", "source_page": null }, { "number": 19, "text": "Develop and implement appropriate procedures and controls to ensure its recordkeeping is adequate in supporting financial data.", "source_page": null }, { "number": 20, "text": "Ensure that due diligence is performed for future assets acquired by purchase to ensure that records were provided to support valuation of assets recorded on the books and any subsequent retirement.", "source_page": null } ], "themes": [ "Depreciation", "Property & plant records" ], "cost_to_customers": true }, { "index": 8, "title": "Accounting for Amortization Expense", "summary": "NDPL improperly included $168,667 of amortization expense in Account 541, Depreciation Expense for Asset Retirement Costs instead of Account 540, Depreciation and Amortization. This led to a lack of transparency in the reporting of NDPL’s Form 6 data.", "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Provide additional employee training on accounting for amortization of intangible assets.", "source_page": null }, { "number": 22, "text": "Strengthen policies and procedures that address NDPL’s accounting for amortization of intangible assets.", "source_page": null } ], "themes": [ "Accounting misclassification", "Depreciation" ], "cost_to_customers": true }, { "index": 9, "title": "Classification of Delivery Revenues", "summary": "NDPL did not record amounts in Account 220, Delivery Revenues, despite the fact that NDPL’s tariff has charge provisions that have identical language to the account instructions of Account 220. NDPL recorded these amounts in Account 200, Gathering Revenues. This creates an improper functionalization of revenues.", "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Develop the appropriate policies and procedures to properly classify and report NDPL’s various types of revenues in accordance with FERC requirements.", "source_page": null }, { "number": 24, "text": "Record appropriate adjusting entries to reclassify any Delivery Revenues currently recorded in the Gathering Revenues account.", "source_page": null } ], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 10, "title": "Account Mapping for Utilities Expense", "summary": "NDPL misclassified “utilities expense” in Account 310, Materials and Supplies instead of Account 590, Other Expenses. This misclassification results in insufficient transparency with respect to the pipeline’s operating expenses.", "is_other_matter": false, "recommendations": [ { "number": 25, "text": "Implement procedures to ensure that NDPL’s natural accounts in Oracle are mapped to the appropriate FERC regulatory account.", "source_page": null }, { "number": 26, "text": "Develop the appropriate policies and procedures that address NDPL’s accounting for utilities expenses.", "source_page": null }, { "number": 27, "text": "Record correcting entries to reclassify the utilities expenses not directly allocable to operations expense for 2015 from Account 310 to Account 590. NDPL shall notify the Division of Audits when such adjustments are made.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 11, "title": "Filing of Cash Management Agreements", "summary": "Enbridge did not file a cash management agreement in a timely manner when it changed its cash management program on December 20, 2013. Such documentation should have been filed within 10 days of the effective date of the new cash management agreement. While no financial concerns resulted from NDPL’s late filing of its cash management agreement, the issue highlights the need for internal controls to ensure compliance with all applicable Commission filing requirements.", "is_other_matter": false, "recommendations": [ { "number": 28, "text": "Establish written policies and procedures that ensure appropriate personnel are assigned the responsibility, and carry out the duties, of monitoring compliance with all filing requirements, including filing current cash management agreements.", "source_page": null } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 12, "title": "Treatment of Confidential Pipeline Shipper Information", "summary": "During the course of the audit, Enbridge informed the Commission of an inadvertent disclosure of confidential shipper information in a filing made with the Commission. The controls over the release of confidential information did not prevent the release of this business-sensitive information by the shared staff that processes the filing of regulatory documents. Enbridge discovered the issue shortly after the filing was made and posted on the Commission’s eLibrary and made a full disclosure of this breach of confidentiality to the Commission. Nevertheless, stronger internal controls to ensure a", "is_other_matter": false, "recommendations": [ { "number": 29, "text": "Establish written policies and procedures that ensure appropriate personnel are assigned the responsibility for, and perform the functions of, monitoring the contents of filings to ensure compliance and the proper treatment of confidential shipper information that may be part of filing requirements.", "source_page": null }, { "number": 30, "text": "Develop a training program and conduct training of shared employees that are responsible for preparing and drafting filings on the FERC rules and policies for the protection of confidential shipper information. E.", "source_page": null } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Depreciation", "Form reporting (Form No. 1/2/6, Page 700)", "Internal audit & internal controls", "Property & plant records", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-04-19_itc-holdings-corporation_fa15-14", "company": "ITC Holdings Corporation", "company_raw": "FA15-14 ITC Holdings Corporation", "docket": "FA15-14", "docket_full": "FA15-14-000", "issued_date": "2016-04-19", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160419-3023&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160419-3023", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160419-3023 (fileID 14209363).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 20, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2011 to December 31, 2015", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1", "65" ], "finding_count": 1, "findings": [ { "index": 1, "title": "Merger-Related Costs", "summary": "The ITC Operating Companies recorded merger-related costs in operating accounts included in the determination of transmission formula rate billings, rather than in Account 426.5, Other Deductions, as required by Commission precedent. The improper accounting led to inappropriate recovery of the merger-related costs in transmission formula rate billings.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-04-19_entergy-services-inc_fa15-13", "company": "Entergy Services, Inc.", "company_raw": "FA15-13 Entergy Services, Inc.", "docket": "FA15-13", "docket_full": "FA15-13-000", "issued_date": "2016-04-19", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160419-3024&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160419-3024", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160419-3024 (fileID 14209364).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 22, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2011 to December 31, 2015", "industry": "electric", "audit_type": "financial", "functions": [ "transmission" ], "forms": [ "1", "65" ], "finding_count": 1, "findings": [ { "index": 1, "title": "Merger-Related Costs", "summary": "The Entergy Operating Companies recorded merger-related costs in operation and maintenance (O&M) and administrative and general (A&G) expense accounts rather than in Account 426.5, Other Deductions, as required by Commission precedent. The improper accounting led to overstatements of O&M and A&G expenses in the Entergy Operating Companies’ FERC Form No. 1 filings. Additionally, the Entergy Operating Companies inappropriately included some merger-related costs in transmission formula rate calculations.", "is_other_matter": false, "recommendations": [], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-04-01_duke-energy-corporation_pa14-2", "company": "Duke Energy Corporation", "company_raw": "PA14-2 Duke Energy Corporation", "docket": "PA14-2", "docket_full": "PA14-2-000", "issued_date": "2016-04-01", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160401-3008&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160401-3008", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160401-3008 (fileID 14187734).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 70, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2011 through January 31, 2016", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation", "transmission" ], "forms": [ "65" ], "finding_count": 1, "findings": [ { "index": 1, "title": "As a result, inappropriate costs were included in wholesale power and transmission formula rate service cost determinations and charged to customers. D. Summary of", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-03-30_destin-pipeline-company_fa15-1", "company": "Destin Pipeline Company", "company_raw": "FA15-1 Destin Pipeline Company", "docket": "FA15-1", "docket_full": "FA15-1-000", "issued_date": "2016-03-30", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160330-3003&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160330-3003", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160330-3003 (fileID 13682311).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 50, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2012 to July 31, 2015", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2" ], "finding_count": 9, "findings": [ { "index": 1, "title": "Reservation Charge Credits", "summary": "Destin’s tariff did not include language consistent with the Commission’s reservation charge crediting policy.", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Imbalances", "summary": "Destin improperly accounted for its gas imbalances by recording imbalances payable in Account 254, Other Regulatory Liabilities.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Fuel Used in Compressor Stations", "summary": "Destin did not account for gas volumes furnished to the pipeline by its shippers for compressor fuel and other pipeline system use.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Calculating and Accounting for Lost and Unaccounted-for Gas Quantities", "summary": "Destin neither calculated nor accounted for amounts related to lost and unaccounted-for gas since inception of operations.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Accounting and Reporting of Accumulated Deferred Income Taxes", "summary": "Destin improperly recorded deferred income taxes on its regulatory assets recognized for the equity portion of AFUDC in Account 282, Accumulated Deferred Income Taxes – Other Property, instead of Account 283, Accumulated Deferred Income Taxes – Other. Also, in 2013, Destin improperly removed the balance associated with the deferred income taxes on the equity portion of AFUDC from Account 282. This amount was appropriately recorded and should have remained in Account 282.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 6, "title": "Accounting and Reporting Accrued Taxes", "summary": "Destin recorded accrued income taxes in Account 236, Taxes Accrued, but did not record any offsetting entries to reflect income taxes paid by its member companies.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Accounting and Reporting Accruals and Third-Party Reimbursements", "summary": "Destin improperly recorded cost accruals related to construction work in progress in Account 253, Other Deferred Credits. Also, Destin improperly recorded certain nonrefundable reimbursements/advances of costs related to two projects under construction by customers in Account 253, instead of recording these amounts as reductions to Account 107, Construction Work in Progress – Gas.", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 8, "title": "BP Management Fees", "summary": "Destin did not recognize an accounts receivable or prepayment at the time it overpaid for services related to a management agreement between it and BP Pipelines (North America), Inc.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Form 2 Reporting", "summary": "Destin did not properly comply with select filing instructions on pages 508-509 and 520 of its Form 2.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on formal challenge", "id": "2016-03-11_itc-midwest_er15-1250", "company": "ITC Midwest LLC", "company_raw": "ITC Midwest LLC", "docket": "ER15-1250", "docket_full": null, "issued_date": "2016-03-11", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160311-3026&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160311-3026", "captured_at": "2026-06-01", "source_note": "FERC order on a formal challenge re ITC Midwest LLC transmission formula rate, Docket ER15-1250, issued 2016-03-11. Found via eLibrary full-text search; accession 20160311-3026.", "archived_via": null, "page_count": 26, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2016-01-04_emera-maine_pa15-4", "company": "Emera Maine", "company_raw": "PA15-4 Emera Maine", "docket": "PA15-4", "docket_full": "PA15-4-000", "issued_date": "2016-01-04", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20160104-3018&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20160104-3018", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20160104-3018 (fileID 14088674).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 31, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2013 through December 31, 2014", "industry": null, "audit_type": "non-financial", "functions": [ "transmission" ], "forms": [], "finding_count": 4, "findings": [ { "index": 1, "title": "Merger-Related Capital Costs", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Merger-Related Expenses", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Allowance for Funds Used During Construction (AFUDC)", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 4, "title": "Misclassification of Canceled Stock", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification" ], "cost_to_customers": false } ], "structured": true, "themes": [ "AFUDC / cost of capital", "Accounting misclassification" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-10-23_yankee-atomic-energy-company_fa15-3", "company": "Yankee Atomic Energy Company", "company_raw": "FA15-3 Yankee Atomic Energy Company", "docket": "FA15-3", "docket_full": "FA15-3-000", "issued_date": "2015-10-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20151023-3035&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20151023-3035", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20151023-3035 (fileID 14022526).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 15, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2012 through August 31, 2015", "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "1" ], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-10-23_portland-general-electric-company_fa15-2", "company": "Portland General Electric Company", "company_raw": "FA15-2 Portland General Electric Company", "docket": "FA15-2", "docket_full": "FA15-2-000", "issued_date": "2015-10-23", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20151023-3034&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20151023-3034", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20151023-3034 (fileID 14022523).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 14, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2012 through July 31, 2015", "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "1" ], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "ALJ initial decision", "id": "2015-09-14_potomac-appalachian-transmission-highline_er09-1256", "company": "Potomac-Appalachian Transmission Highline, LLC et al.", "company_raw": "Potomac-Appalachian Transmission Highline, LLC et al.", "docket": "ER09-1256", "docket_full": null, "issued_date": "2015-09-14", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150914-4006&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150914-4006", "captured_at": "2026-06-01", "source_note": "FERC ALJ Initial Decision re Potomac-Appalachian Transmission Highline, LLC (PATH) transmission-incentive cost recovery / abandoned-plant prudence, Docket ER09-1256, issued 2015-09-14. Found via eLibrary full-text search; accession 20150914-4006.", "archived_via": null, "page_count": 61, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-07-30_entergy-corporation_fa14-2", "company": "Entergy Corporation", "company_raw": "FA14-2 Entergy Corporation", "docket": "FA14-2", "docket_full": "FA14-2-000", "issued_date": "2015-07-30", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150730-3041&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150730-3041", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20150730-3041 (fileID 13944747).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 25, "scanned_pages": [], "ocr_used": false, "audit_period": "January 1, 2011 through December 31, 2014", "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "1" ], "finding_count": 1, "findings": [ { "index": 1, "title": "Nuclear Decommissioning Trust Fund Reports", "summary": "Entergy filed trust fund financial reports annually with the Commission, but the reports did not include some trust funds containing monies collected from wholesale customers. Moreover, for the trust funds reported, the company did not include all required information.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-07-02_nrg-energy-inc_pa14-1", "company": "NRG Energy, Inc.", "company_raw": "PA14-1 NRG Energy, Inc.", "docket": "PA14-1", "docket_full": null, "issued_date": "2015-07-02", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150702-3031&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150702-3031", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20150702-3031 (fileID 13920116).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 28, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2011 to December 31,2014", "industry": "electric", "audit_type": "non-financial", "functions": [ "generation" ], "forms": [ "552" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Plant Outage Data", "summary": "NRG reported outage data incorrectly either in the Generator Availability Data System (GADS) or when reporting the outage data to the relevant RTO/ISO. Some regions use GADS data to develop reserve requirements for purchasing in the capacity market. Therefore, accurate and complete data must be gathered to understand unit life cycle performance and obtain a complete historical assessment.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Premature Destruction ofRecords", "summary": null, "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-06-17_enterprise-product-partners_fa14-1", "company": "Enterprise Product Partners", "company_raw": "FA14-1 Enterprise Product Partners", "docket": "FA14-1", "docket_full": "FA14-1-000", "issued_date": "2015-06-17", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150617-3057&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150617-3057", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20150617-3057 (fileID 13906964).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 65, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2011 to January 30, 2015", "industry": "oil", "audit_type": "financial", "functions": [], "forms": [ "6", "6-Q" ], "finding_count": 1, "findings": [ { "index": 1, "title": "This accounting error affected certain equity accounts on the balance sheet as reported in the Form No. 6, but affected neither, the income statement or Document Accession #: 20150617-3057 Filed Date: 06/17/2015 Enterprise Products Partners L.P. balance sheet totals in the Form No. 6, nor the calculation of the five-year index adjustment. It did, however, create an issue where balances were moving between two equity accounts in a fashion that required FERC accounting approval. • Accounting for Prepaid Leases", "summary": "MAPL misclassified a prepaid lease asset in its books and records in the amount of $1,152,358. MAPL also imposed an unauthorized dollar threshold limitation when amortizing prepaid lease payments. While these accounting treatments do not have a significant impact on its Form No. 6 reporting, its books and records, or its current rates, nevertheless, corrections need to be made to bring MAPL into compliance with Commission accounting guidance. • Cash Management Filing Issue - MAPL did not file a cash management agreement when it established its cash management program. Such documentation should have been filed within 10 days of the effective date of the rule or entry into the program. While no financial concerns resulted from MAPL’s not filing its cash management agreement, the issue highlights the need for policies and procedures to ensure transparency and compliance with all applicable Commission filing requirements. D. Summary of", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-06-17_conocophillips_fa14-5", "company": "ConocoPhillips", "company_raw": "FA14-5 ConocoPhillips", "docket": "FA14-5", "docket_full": "FA14-5-000", "issued_date": "2015-06-17", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150617-3055&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150617-3055", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20150617-3055 (fileID 13906962).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 25, "scanned_pages": [], "ocr_used": false, "audit_period": "from January 1, 2011 through present", "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "552" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Aggregation of Next-Day Gas Deals", "summary": "COP did not report some physical next-day gas transactions to price index publishers due to deal entry practices used by COP’s gas traders. These practices were enabled by lapses in internal controls in COP’s deal capture system and processes.", "is_other_matter": false, "recommendations": [], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 2, "title": "FERC Form No. 552 Reporting", "summary": "COP aggregated natural gas volumes purchased and sold by affiliate companies on its 2010, 2011, and 2012 Form 552s, but did not disclose the name of an affiliate company in those filings due to a lack of controls in its Form 552 preparation process. Although COP’s reported volumes on the 2010, 2011, and 2012 Form 552 filings were accurate, the omission of the affiliate company’s name resulted in a lack of transparency to users of the Form 552.", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Form reporting (Form No. 1/2/6, Page 700)", "Internal audit & internal controls" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-06-17_colonial-pipeline-company_fa14-4", "company": "Colonial Pipeline Company", "company_raw": "FA14-4 Colonial Pipeline Company", "docket": "FA14-4", "docket_full": "FA14-4-000", "issued_date": "2015-06-17", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150617-3056&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150617-3056", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20150617-3056 (fileID 13906963).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 42, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "oil", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "6" ], "finding_count": 5, "findings": [ { "index": 1, "title": "Consolidated Method of Accounting", "summary": "Colonial improperly reported its investment in Colonial Pipeline Company of Pennsylvania, CP Dogwood LLC, and Energy Logistics Solutions LLC under the consolidated method of accounting instead of using the equity method of accounting, as required by the Commission. By consolidating, Colonial’s financial statements did not appropriately reflect its investments in subsidiary companies.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Accounting for Interest During Construction", "summary": "Colonial incorrectly accounted for interest during construction in Account 166, Other Property, instead of recording the interest in the carrier property Accounts 153-161, which are the accounts used to record the related property costs. While this accounting affected the accuracy of the balances in these specific accounts, it did not affect total carrier property since Account 166 and Accounts 153-161 were used to derive the balance in Account 30, Carrier Property.", "is_other_matter": false, "recommendations": [], "themes": [ "Property & plant records" ], "cost_to_customers": false }, { "index": 3, "title": "Accounting for Nonoperating Expenses", "summary": "Colonial improperly recorded amounts for donations, charitable contributions, fines and penalties, and lobbying activities as operating expenses in Accounts 390, Other Expenses, 580, Pipeline Taxes, and 590, Other Expenses. Colonial should have recorded these activities in Account 660, Miscellaneous Income Charges, as these activities are nonoperating in nature. Recording these activities as operating expenses increased amounts that factored into its annual cost of service schedule on page 700 of the Form 6, which provides stakeholders a gauge of Colonial’s cost of service. However, since Colo", "is_other_matter": false, "recommendations": [], "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true }, { "index": 4, "title": "Accounting for Regulatory Fees to Federal Agencies", "summary": "Colonial incorrectly accounted for regulatory fees payable to Federal agencies in Account 56, Taxes Payable, instead of Account 52, Accounts Payable. Also, Colonial accounted for the payment of regulatory fees to the U.S. Department of Transportation (DOT) in Account 580, Pipeline Taxes, instead of Account 590, Other Expenses. While this accounting led to account misclassifications, it had no impact on total payables and operating expenses reported in the Form 6.", "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Record amounts payable for regulatory fees to Federal agencies in Account 52, Accounts Payable, rather than Account 56, Taxes Payable, prospectively.", "source_page": null }, { "number": 11, "text": "Record expense amounts paid to DOT for user fees in Account 590, Other Expenses, rather than Account 580, Pipeline Taxes, prospectively.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 5, "title": "Reporting Intrastate Amounts on Page 700 of the Form 6", "summary": "Colonial did not remove intrastate amounts when reporting certain line items on page 700 of the Form 6. As a result, Colonial overstated the total cost of service by approximately $7.6 million for 2013 on page 700, which provides stakeholders a gauge of Colonial’s cost of service. However, since Colonial has indexed- and market-based rates, this accounting treatment did not affect the rates shippers paid for transportation service on Colonial’s pipeline.", "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Enhance its review procedures to ensure the page 700 prepared by the third- party consultant is accurate and complete.", "source_page": null }, { "number": 13, "text": "Update its policies and procedures to ensure that intrastate activities are removed from page 700, and only interstate activities are reported.", "source_page": null }, { "number": 14, "text": "Restate 2013 page 700 with the corrected amounts in the 2014 Form 6. E.", "source_page": null } ], "themes": [ "Form reporting (Form No. 1/2/6, Page 700)", "Cost of service & rates" ], "cost_to_customers": true } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)", "Cost of service & rates", "Form reporting (Form No. 1/2/6, Page 700)", "Property & plant records" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-06-04_kinder-morgan_fa14-10", "company": "Kinder Morgan", "company_raw": "FA14-10 Kinder Morgan", "docket": "FA14-10", "docket_full": "FA14-10-000", "issued_date": "2015-06-04", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150604-3010&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150604-3010", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20150604-3010 (fileID 13895448).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 34, "scanned_pages": [], "ocr_used": false, "audit_period": "of January 1, 2011 through December 2014", "industry": "gas", "audit_type": "financial", "functions": [], "forms": [ "2" ], "finding_count": 4, "findings": [ { "index": 1, "title": "Accounting for Maintenance Expenses", "summary": "After the merger, EPC legacy entities adopted the accounting classification procedures used by KMI legacy entities for certain maintenance expenses that were inconsistent with the Commission's accounting regulations under 18 C.F.R. Part 201. This resulted in the KMI jurisdictional entities inappropriately using operating expense Account 824, Other Expenses, and Account 859, Other Expenses, to classify pipeline assessment expenses and other maintenance costs.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Merger-related Internal Labor Costs", "summary": "The KMI jurisdictional entities did not record the cost of labor devoted towards merger consummation activities to the appropriate nonoperating expense account in accordance with the Commission's rules and regulations.", "is_other_matter": false, "recommendations": [], "themes": [ "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "index": 3, "title": "Accounting for Abandoned Projects", "summary": "Based on audit staff examination of KMI's merger activity and related costs, audit staff observed that the EPC legacy entities incorrectly wrote off costs for software development projects supporting pipeline operations. These software development projects were abandoned due to the merger and the related costs were recorded in administrative and general expense accounts rather than appropriate operating expense accounts. As a result, these costs were misclassified in the books and financial records of the EPC legacy entities.", "is_other_matter": false, "recommendations": [ { "number": 921, "text": "Depending on the intended use of the projects, their expenses should have been recorded to the appropriate transmission or storage expense accounts. Recommendations Audit staff recommends EPC Legacy companies: 5. Modify its existing accounting practice to ensure that costs for canceled or abandoned capital projects are expensed to the functional accounts related to the intended function of the abandoned project. 6. Submit to DAA their documented accounting practice implementing the proper accounting for canceled or abandoned capital projects. Kinder Morgan, Inc. 4.", "source_page": null } ], "themes": [ "Accounting misclassification" ], "cost_to_customers": false }, { "index": 4, "title": "Miscellaneous Accounting Classification Errors", "summary": "The KMI jurisdictional entities accounted for certain costs inconsistent with the Commission rules and regulations under 18 C.F.R. Part 201.", "is_other_matter": false, "recommendations": [ { "number": 920, "text": "23 Account 923, Outside Services Employed, states: A. This account shall include the fees and expenses of professional consultants and others for general services which are not applicable to a particular operating function or to other accounts. It shall include also the pay and expenses of persons engaged for a special or temporary administrative or general purpose in circumstances where the person so engaged is not considered as an employee of the utility. 24 Account 924, Property Insurance, states in part: 21 18 C.F.R. pt. 201, Account 426.1. 22 Id. at Account 426.5. 23 Id. at Account 921. 24 Id. at Account 923. Kinder Morgan, Inc. A. This account shall include the cost of insurance or reserve accruals to protect the utility against losses and damages to owned or leased property used in its utility operations . . . . 25 Account 925, Injuries and Damages, states in part: A. This account shall include the cost of insurance or reserve accruals to protect the utility against injuries and damages claims of employees or others, losses of such character not covered by insurance, and expenses incurred in settlement of injuries and damages claims. 26 Account 931, Rents, states: This account shall include rents properly includible in utility operating expenses for the property of others used, occupied, or operated in connection with the customer accounts, customer service and informational, sales, and general and administrative functions of the utility. 27 Account 816, Wells Expenses, states: This account shall include the cost of labor, materials used and expenses incurred in operating storage gas wells.28 Account 832, Maintenance of Reservoirs and Wells, states: This account shall include the cost of labor, materials used and expenses incurred in the maintenance of storage wells, the book cost of which is included in account 352, Wells, and the maintenance of reservoirs, the book cost of which is included in account 352.2, Reservoirs.29 25 Id. at Account 924. 26 Id. at Account 925. 27 1d. at Account 931. 28 Id. at Account 816. 29 Id. at Account 832. Kinder Morgan, Inc. Background Audit staff tested a sample of charges made to certain expense accounts to attest to the types of merger-related costs the KMI jurisdictional entities recorded, and evaluated whether they were recorded consistent with Commission accounting requirements. Audit staff testing identified several accounting misclassification errors in the sample that related to the cost types in the table below: . cco i Use il 1 Liability Insurance Premiums Office Building Rent 930.2 Storage Well Maintenance Stora:e Field Shut in Ex senses Donations 426.1 Outside Tax Services Environmental Legal Reserve 426.5 Civil Penalties 426.3 Audit staff believes that the KMI jurisdictional entities should have classified these charges in the appropriate accounts as Commission rules and regulations have prescribed. Further, the KMI jurisdictional entities should strengthen their procedures to ensure that accounting misclassifications identified do not reoccur. Recommendations Audit staff recommends that the KMI jurisdictional entities: 7. Modify their accounting system and policy so KMI costs allocated to its jurisdictional entities can be accounted for appropriately. 8. Establish and implement procedures to ensure proper coding and accounting of expenses under Commission regulations. 9. Revise their procedures to properly classify the costs identified in the", "source_page": null } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Accounting misclassification", "Below-the-line costs (lobbying, charitable, etc.)" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2015-03-27_kansas-gas-and-electric-company_fa14-3", "company": "Kansas Gas and Electric Company", "company_raw": "FA14-3 Kansas Gas and Electric Company", "docket": "FA14-3", "docket_full": "FA14-3-000", "issued_date": "2015-03-27", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20150327-3035&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20150327-3035", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20150327-3035 (fileID 13817513).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 30, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": "financial", "functions": [ "generation" ], "forms": [ "1" ], "finding_count": 2, "findings": [ { "index": 1, "title": "Commission-Jurisdictional Trust Fund Assets", "summary": "KGE did not clearly distinguish Commission-jurisdictional assets from non- Commission-jurisdictional assets in the Wolf Creek trust fund. Specifically, KGE: • Did not establish and maintain clearly identifiable accounts within a single trust fund. As a result, KGE could not readily identify the amount of Commission-jurisdictional from non-Commission-jurisdictional assets in the trust fund. • Erroneously directed its trustee to record zero contributions to the Commission-jurisdictional portion of the trust fund since 2010. As a result, KGE understated Commission-jurisdictional contributions by", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Filing of Nuclear Decommissioning Trust Fund Reports", "summary": "KGE did not file annual nuclear decommissioning trust fund reports with the Commission from 2004-2013. In response to the audit, KGE filed a trust fund report for 2013 with the Commission in March 2014. While KGE took immediate action to file this report, the report did not include all required information. Also, absent filing reports for nearly 10 years, audit staff had no historical records to verify the accuracy of the balances in the 2013 trust fund report.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "FL", "source": "Florida Public Service Commission", "doc_type": "final order on nuclear cost recovery", "id": "2014-10-27_florida-nuclear_fl-140009-ei-psc-14-0617-fof-ei", "company": "Florida Power & Light Company and Duke Energy Florida (nuclear cost recovery)", "company_raw": "Florida Power & Light Company and Duke Energy Florida (nuclear cost recovery)", "docket": "140009-EI", "docket_full": null, "issued_date": "2014-10-27", "source_page_url": "https://www.psc.state.fl.us/document-detail?orderNum=PSC-14-0617-FOF-EI", "pdf_download_url": "https://www.psc.state.fl.us/library/Orders/2014/06043-2014.pdf", "captured_at": "2026-06-07", "source_note": "Florida PSC Order No. PSC-14-0617-FOF-EI (Final Order Approving...), Docket No. 140009-EI, 'Nuclear cost recovery clause', issued October 27, 2014 (49 pp) — the Commission's annual prudence review and true-up of nuclear power-plant project costs recovered by Florida utilities under Section 366.93, Fla. Stat. and Rule 25-6.0423, F.A.C. Listed for reference (metadata-only). Source: Florida PSC document clerk, document 06043-2014 (psc.state.fl.us/library/Orders/2014/06043-2014.pdf).", "archived_via": null, "page_count": 49, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 38, "findings": [ { "index": 1, "title": "Approval: $14,679,680 ", "summary": "ing costs of $5,479,030, for a total of $6,688,942 (jurisdictional). The total amount that shall be approved for determining the 2015 NCRC recovery is $14,679,680 ($7,990,738 + $6,688,942 = $14,679,680). Conclusion The Levy Project exit and wind-down costs and other sunk costs DEF has presented for ", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $14,679,680\n", "summary": "ce that such costs were not reasonably quantified. Based upon our review of the record evidence, we approve DEF’s Levy Project exit and wind-down costs of $14,679,680 for recovery in 2015. Long Lead Equipment Milestone Payments for Cancelled Turbine Generators and Reactor Vessel Internal Components ", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $100 million", "summary": "e resolution of the federal lawsuit awaits years of litigation and appeals, this Commission will be allowing Duke to recover $100 million on an annual, on-going basis for costs that have not been approved by this Commission. Terminating the $3.45 sometime during 2015, based on the known", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Approval: $3.45 ", "summary": "be allowing Duke to recover $100 million on an annual, on-going basis for costs that have not been approved by this Commission. Terminating the $3.45 sometime during 2015, based on the known Commission-reviewed and Commission- ORDER NO. PSC-14-0617-FOF-EI DOCKET NO. 140009-EI PAGE 13 approved costs", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Approval: $54\nmillion", "summary": "known Commission-reviewed and Commission- ORDER NO. PSC-14-0617-FOF-EI DOCKET NO. 140009-EI PAGE 13 approved costs and taking into consideration the 2015 impact of Duke’s $54 million refund claim, will avoid this unfair result while not precluding Duke from asking this Commission to establish or re-", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Approval: $63,204,163 ", "summary": "stipulated issues, we approve as DEF’s 2015 NCRC cost recovery an amount consistent with the rates approved in the 2013 Settlement Agreement for the Levy project and $63,204,163 for the EPU project. The estimated amount consistent with the 2013 Settlement Agreement, for use in establishing DEF’s 201", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Approval: $28,209,654 ", "summary": "sts that included a calculation of its requested 2013 recovery amount. In Exhibit 34, FPL witnesses Grant-Keene and Scroggs indicated that the jurisdictional expense amount was $28,209,654 and the associated carrying costs totaled $4,835,406. FPL’s total 2013 jurisdictional amount, including carryin", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Approval: $14,287,862 ", "summary": "es not add due to rounding. ORDER NO. PSC-14-0617-FOF-EI DOCKET NO. 140009-EI PAGE 37 Conclusion We approve a total jurisdictional amount of $14,287,862 as FPL's 2015 NCRC recovery amount. This amount shall be used in establishing FPL's 2015 Capacity Cost Recovery Clause factor. Based on the foregoi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: Agreement", "summary": "2013, DEF filed a Petition for Limited Proceeding to Approve a Revised and Restated Stipulation and Settlement Agreement (2013 Settlement Agreement) that was signed by OPC, FRF, FIPUG, FEA, and PCS Phosphate. DEF also filed a motion to defer its issues in the 2013 proce", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Settlement: Agreement", "summary": "for Limited Proceeding to Approve a Revised and Restated Stipulation and Settlement Agreement (2013 Settlement Agreement) that was signed by OPC, FRF, FIPUG, FEA, and PCS Phosphate. DEF also filed a motion to defer its issues in the 2013 proceeding pending approval of t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: Agreement", "summary": "te. DEF also filed a motion to defer its issues in the 2013 proceeding pending approval of the 2013 Settlement Agreement, which was approved as part of preliminary matters during the 2013 Nuclear Cost Recovery Clause (NCRC) hearing.6 We approved the 2013 Settlement Agre", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Settlement: Agreement", "summary": "liminary matters during the 2013 Nuclear Cost Recovery Clause (NCRC) hearing.6 We approved the 2013 Settlement Agreement by Order No. PSC-13-0598-FOF-EI.7 This 2013 Settlement Agreement was a comprehensive settlement addressing issues from multiple dockets. Requirements", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: Agreement", "summary": "RC) hearing.6 We approved the 2013 Settlement Agreement by Order No. PSC-13-0598-FOF-EI.7 This 2013 Settlement Agreement was a comprehensive settlement addressing issues from multiple dockets. Requirements from the 2013 Settlement Agreement that affected this docket inc", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Settlement: Agreement", "summary": "was a comprehensive settlement addressing issues from multiple dockets. Requirements from the 2013 Settlement Agreement that affected this docket include:  DEF’s recovery amount for the Levy Project reflects the use of a prescribed fixed factor set by rate class. 5 Or", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Settlement: agreement", "summary": ". 130208-EI, In re: Petition for limited proceeding to approve revised and restated stipulation and settlement agreement by Duke Energy Florida, Inc. d/b/a Duke Energy. ORDER NO. PSC-14-0617-FOF-EI DOCKET NO. 140009-EI PAGE 5  DEF’s recovery of Levy Project costs is li", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 16, "title": "Settlement: Agreement", "summary": "Project costs is limited to only those costs associated with the activities identified in the 2013 Settlement Agreement unless otherwise agreed to by the signatory parties.  DEF is allowed to recover its CR3 Uprate Project costs through the NCRC consistent with Sectio", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Settlement: Agreement", "summary": "t of Acronyms and Abbreviations 2013 Settlement Agreement 2013 Revised and Restated Stipulation and Settlement Agreement AFUDC Allowance for Funds Used During Construction CCRC Capacity Cost Recovery Clause COL Combined Operating License Commission Florida Public Servic", "is_other_matter": false, "recommendations": [], "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "index": 18, "title": "Settlement: Agreement", "summary": "ounted for all 2013 costs associated with pursuit of a COL in accordance with the terms of the 2013 Settlement Agreement. DEF witness Foster’s testimony explained that DEF utilizes project accounting and cost oversight controls which are consistent with best practices f", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Settlement: Agreement", "summary": "ode was used in 2013 and will continue in 2014 and going forward. However, consistent with the 2013 Settlement Agreement, costs incurred in 2014 and beyond will not be included in DEF’s NCRC Schedules or be presented for nuclear cost recovery. DEF witness Fallon also te", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 20, "title": "Settlement: Agreement", "summary": "2015, DEF will not seek to recover these costs from customers through the NCRC pursuant to the 2013 Settlement Agreement. No party challenged DEF’s position. DEF has provided testimony and exhibits to support its position that COL costs for 2013 have been reasonably acc", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: Agreement", "summary": "its position that COL costs for 2013 have been reasonably accounted for in accordance with the 2013 Settlement Agreement. Witness Fallon testified that DEF was continuing work necessary to obtain a COL from the NRC and environmental permitting work necessary to obtain a", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: Agreement", "summary": "the NCRC. These costs will continue to be tracked for accounting purposes consistent with the 2013 Settlement Agreement. Joint Intervenors’ cross examination of witness Fallon did not identify any inappropriate COL- related activities or expenditures in DEF’s recovery", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 23, "title": "Settlement: Agreement", "summary": "th its pursuit of the COL for the Levy Project, and that it has done so in accordance with the 2013 Settlement Agreement. No party has disputed the adequacy of DEF’s accounting procedures and our review of the evidence confirms that DEF has reasonably accounted for COL", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 24, "title": "Settlement: Agreement", "summary": "ind that DEF has reasonably accounted for COL pursuit costs pursuant to paragraph 12(b) of the 2013 Settlement Agreement. Levy Project Exit and Wind Down Costs Witness Fallon testified that DEF has actual/estimated costs in 2014 as a result of Levy wind-down activities.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 25, "title": "Settlement: Agreement", "summary": "ery or review in this docket are in compliance with the NCRC statute, Commission rules and the 2013 Settlement Agreement. In addition, none of the intervenors have disputed the costs or presented evidence that such costs were not reasonably quantified. Based upon our re", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 26, "title": "Settlement: Agreement", "summary": "ested by DEF and agreed to by WEC. In August 2013, the Joint Intervenors and DEF presented the 2013 Settlement Agreement for Commission approval that in section 12(a) stated: At the earliest reasonable and prudent time, DEF will be terminating the EPC contract for the L", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 27, "title": "Settlement: agreement", "summary": ". 130208-EI, In re: Petition for limited proceeding to approve revised and restated stipulation and settlement agreement by Duke Energy Florida, Inc. d/b/a Duke Energy, at page 30. ORDER NO. PSC-14-0617-FOF-EI DOCKET NO. 140009-EI PAGE 11 perjury, or intentional withhol", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 28, "title": "Settlement: Agreement", "summary": "$54,127,100 to its projected 2015 expenses. Such an adjustment is well within the scope of the 2013 Settlement Agreement and does not constitute any review of our prior decisions concerning the prior approval of milestone payments made by DEF in prior years. DEF will co", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 29, "title": "Settlement: Agreement", "summary": "nation of the Levy Project NCRC Fixed Charge As noted in the Joint Intervenors' arguments, the 2013 Settlement Agreement includes an explicit provision to end the fixed monthly rates for the Levy Project through a final true-up before the expiration date of the Agreemen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 30, "title": "Settlement: Agreement", "summary": "Fallon. We find that if a large credit were recorded at any time before the termination of the 2013 Settlement Agreement, then the possibility of a final true-up consistent with the requirements of the Agreement could likely occur before 2017. While the Joint Intervenor", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 31, "title": "Settlement: Agreement", "summary": "nclude that all Levy Project costs have been recovered consistent with the requirements of the 2013 Settlement Agreement. Consequently, we do not require the termination of the Levy Project NCRC fixed monthly charge as requested by the Joint Intervenors in this proceedi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 32, "title": "Settlement: Agreement", "summary": "st deal possible for its customers, and believes DEF has obligated itself to do so through the 2013 Settlement Agreement. However, we find that the Joint Intervenors have provided no support for the particular relief they recommend, requiring prior notification and 12 S", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 33, "title": "Settlement: Agreement", "summary": "additional restrictions on DEF’s attempts to dispose of LLE than those already included in the 2013 Settlement Agreement. Conclusion Based on our review of the record in this proceeding, we are not imposing any additional restrictions at this time on DEF’s attempts to d", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 34, "title": "Settlement: Agreement", "summary": "ents does not affect the establishment of the 2015 NCRC cost recovery amount. We find that the 2013 Settlement Agreement requires the use or application of specified fixed factors per rate class until the final true-up event.15 We further note that all issues affecting", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 35, "title": "Settlement: Agreement", "summary": "e approve as DEF’s 2015 NCRC cost recovery an amount consistent with the rates approved in the 2013 Settlement Agreement for the Levy project and $63,204,163 for the EPU project. The estimated amount consistent with the 2013 Settlement Agreement, for use in establishing", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 36, "title": "Settlement: Agreement", "summary": "the Levy project and $63,204,163 for the EPU project. The estimated amount consistent with the 2013 Settlement Agreement, for use in establishing DEF’s 2015 Capacity Cost Recovery Clause factor shall be $167,195,304. DECISION – FPL PROJECTS Pursuant to the Commission-ap", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 37, "title": "Settlement: agreement", "summary": ". 130208-EI, In RE: Petition for limited proceeding to approve revised and restated stipulation and settlement agreement by Duke Energy Florida, Inc. d/b/a Duke Energy, at page 31. ORDER NO. PSC-14-0617-FOF-EI DOCKET NO. 140009-EI PAGE 17 feasibility of completing the p", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 38, "title": "Settlement: Agreement", "summary": "zed to include the estimated nuclear cost recovery amount of $167,195,304, consistent with the 2013 Settlement Agreement, for establishing its 2015 capacity cost recovery factor. ORDERED that Florida Power & Light Company is hereby authorized to include the nuclear cost", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "AFUDC / cost of capital" ], "cost_to_customers": true }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2014-10-24_occidental-energy-marketing-inc_fa14-8", "company": "Occidental Energy Marketing, Inc.", "company_raw": "FA14-8 Occidental Energy Marketing, Inc.", "docket": "FA14-8", "docket_full": null, "issued_date": "2014-10-24", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20141024-3018&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20141024-3018", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20141024-3018 (fileID 13666269).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 12, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": "financial", "functions": [], "forms": [ "552" ], "finding_count": 0, "findings": [], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "ferc_audit", "jurisdiction": "FERC", "source": "FERC Office of Enforcement, Division of Audits & Accounting", "doc_type": null, "id": "2014-10-24_cargill_fa14-6", "company": "Cargill", "company_raw": "FA14-6 Cargill", "docket": "FA14-6", "docket_full": null, "issued_date": "2014-10-24", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20141024-3019&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20141024-3019", "captured_at": "2021-12-07", "source_note": "Listed on FERC ferc.gov/audits via Internet Archive Wayback Machine (snapshot 2021-12-07; origin www.ferc.gov); report PDF from FERC eLibrary, accession 20141024-3019 (fileID 13666270).", "archived_via": "https://web.archive.org/web/20211207020015/https://www.ferc.gov/audits", "page_count": 17, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": "financial", "functions": [], "forms": [ "552" ], "finding_count": 1, "findings": [ { "index": 1, "title": "Nonreportable Purchase and Sales Volumes", "summary": "Cargill incorrectly reported certain nonreportable purchase and sales volumes as transactions contracted: at fixed prices, at prices that refer to published daily and monthly indices, and at prices set upon a physical basis transaction value. This resulted in Cargill over-reporting purchase and sales volumes by 202.2 TBtu and 218.6 TBtu, respectively, in its 2012 Form 552.", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "DE", "source": "Delaware Public Service Commission", "doc_type": "base-rate case order", "id": "2014-08-05_delmarva-power-light_de-13-115-order-8589", "company": "Delmarva Power & Light Company", "company_raw": "Delmarva Power & Light Company", "docket": "13-115", "docket_full": null, "issued_date": "2014-08-05", "source_page_url": "https://depsc.delaware.gov/commission-orders/2014-orders/", "pdf_download_url": "https://depsc.delaware.gov/wp-content/uploads/sites/54/2017/03/8589.pdf", "captured_at": "2026-06-19", "source_note": "Findings, Opinion and Order No. 8589 in Delmarva Power & Light's electric distribution rate change, DE PSC Docket No. 13-115; 163 pp. PDF: depsc.delaware.gov/wp-content/uploads/sites/54/2017/03/8589.pdf. Listed for reference (metadata-only).", "archived_via": null, "page_count": 163, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "ALJ initial decision", "id": "2014-02-27_bp-pipelines-alaska_is09-395", "company": "BP Pipelines (Alaska) Inc. et al. (Trans-Alaska Pipeline System)", "company_raw": "BP Pipelines (Alaska) Inc. et al. (Trans-Alaska Pipeline System)", "docket": "IS09-395", "docket_full": null, "issued_date": "2014-02-27", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20140227-3052&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20140227-3052", "captured_at": "2026-06-07", "source_note": "FERC ALJ Initial Decision re BP Pipelines (Alaska) Inc. et al. interstate oil-pipeline rates for the Trans-Alaska Pipeline System (TAPS), lead Docket IS09-395 (consolidated TAPS Carrier rate cases), issued 2014-02-27. An oil-pipeline cost/rate prudence proceeding (eLibrary mis-tags the library as Gas; the IS docket prefix and TAPS carriers are oil). Metadata-only (free-form legal order). Found via the eLibrary AdvancedSearch API (searchText=IS09-395); accession 20140227-3052.", "archived_via": null, "page_count": 542, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "oil", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "FERC", "source": "FERC (eLibrary)", "doc_type": "Commission order on abandonment cost recovery", "id": "2013-02-28_pepco-delmarva-mapp_er13-607", "company": "Potomac Electric Power Company and Delmarva Power & Light Company (PHI / MAPP)", "company_raw": "Potomac Electric Power Company and Delmarva Power & Light Company (PHI / MAPP)", "docket": "ER13-607", "docket_full": null, "issued_date": "2013-02-28", "source_page_url": "https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20130228-3064&optimized=false", "pdf_download_url": "https://elibrary.ferc.gov/eLibraryWebAPI/api/File/DownloadPDF?accesssionNumber=20130228-3064", "captured_at": "2026-06-02", "source_note": "FERC order on the Mid-Atlantic Power Pathway (MAPP) abandonment cost recovery filing of Potomac Electric Power Company and Delmarva Power & Light Company (PHI), Docket ER13-607, issued February 28, 2013 (142 FERC para. 61,156) — accepting abandonment cost recovery and setting prudent-cost amounts for hearing, but removing the previously-granted ROE incentive adders once the project was abandoned. Found via the eLibrary AdvancedSearch API (searchText=docket); accession 20130228-3064.", "archived_via": null, "page_count": 27, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "FL", "source": "Florida Public Service Commission", "doc_type": "final order on fuel cost recovery", "id": "2012-12-21_florida-iou_fl-120001-ei-psc-12-0664-fof-ei", "company": "Florida investor-owned electric utilities (FPL, Progress Energy Florida, Tampa Electric, Gulf Power)", "company_raw": "Florida investor-owned electric utilities (FPL, Progress Energy Florida, Tampa Electric, Gulf Power)", "docket": "120001-EI", "docket_full": null, "issued_date": "2012-12-21", "source_page_url": "https://www.psc.state.fl.us/document-detail?orderNum=PSC-12-0664-FOF-EI", "pdf_download_url": "https://www.psc.state.fl.us/library/Orders/2012/08286-2012.pdf", "captured_at": "2026-06-07", "source_note": "Florida PSC Order No. PSC-12-0664-FOF-EI (Final Order), Docket No. 120001-EI, 'Fuel and purchased power cost recovery clause with generating performance incentive factor', issued December 21, 2012 (39 pp) — the Commission's annual review setting fuel/capacity cost-recovery factors and generating-performance incentive rewards/penalties for Florida's investor-owned electric utilities. Listed for reference (metadata-only). Source: Florida PSC document clerk, document 08286-2012 (psc.state.fl.us/library/Orders/2012/08286-2012.pdf).", "archived_via": null, "page_count": 39, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 24, "findings": [ { "index": 1, "title": "Settlement: agreement", "summary": "the evidentiary hearing in Docket No. 120015-EI, FPL, FIPUG, FEA, and SFHHA entered into a proposed settlement agreement which they presented to us as a proposed settlement of all issues in Docket No. 120015-EI. The RTR-l rider is also included in the proposed settlemen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Settlement: agreement", "summary": "settlement of all issues in Docket No. 120015-EI. The RTR-l rider is also included in the proposed settlement agreement between FPL, FEA, FIPUG and SFHHA as Tariff Sheet 8.203. We have not reached a decision and issued a final order in Docket No. 120015-EI prior to our", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 3, "title": "Settlement: agreement", "summary": "5-EI prior to our decision in this Docket No. 120001-EI. However, both the stipulation and proposed settlement agreement contemplate that the RTR-l rider will become effective after FPL's billing system has been modified to accommodate the rider, which FPL ORDER NO. PSC", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Settlement: agreement", "summary": "ice under that rider. It is acknowledged that the OPC, FRF and others have objected to the proposed settlement agreement signed by FPL, FIPUG, SFHHA and FEA in Docket No. 120015­ EI and that agreement to the stipulation language on this issue does not constitute waiver", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: agreement", "summary": "issue does not constitute waiver by OPC, FRF, or other parties of their objections to the proposed settlement agreement and to any orders impacted by our consideration of the proposed settlement agreement in Docket No. 120015-EI. Progress Energy Florida. Inc. Hedging A", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Settlement: agreement", "summary": "o the proposed settlement agreement and to any orders impacted by our consideration of the proposed settlement agreement in Docket No. 120015-EI. Progress Energy Florida. Inc. Hedging Activities for August 2011 through July 2012 We reviewed PEF's hedging activities for", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: Agreement", "summary": "Hedging Guidelines. ORDER NO. PSC-12-0664-FOF-EI DOCKET NO. 120001-EI PAGE 5 Refund Pursuant to the Settlement Agreement The parties raised an issue of whether PEF correctly reflected the $129 million refund pursuant to the Settlement Agreement approved in Order No. PSC", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Settlement: Agreement", "summary": "parties raised an issue of whether PEF correctly reflected the $129 million refund pursuant to the Settlement Agreement approved in Order No. PSC-12-0104-FOF-EI in the calculation of the 2013 factor. Testimony and evidence was entered into the record. Upon the conclusi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: Agreement", "summary": "alculation and will reduce 2013 fuel factors. 2 See also Paragraphs 9 and 10 in the Stipulation and Settlement Agreement approved by Order No. PSC-12-0104­ FOF-EI, issued March 8, 2012, in Docket No. 120022-EI, In re: Petition for limited proceeding to approve stipulati", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 10, "title": "Settlement: agreement", "summary": "8, 2012, in Docket No. 120022-EI, In re: Petition for limited proceeding to approve stipulation and settlement agreement by Progress Energy Florida, Inc. 3 See page 4 of Order No. PSC-II-0579-FOF-EI, issued December 16,2011, in Docket No. IIOOOI-EI, In re: Fuel and purc", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: agreement", "summary": ". 4Id. ORDER NO. PSC-12-0664-FOF-EI DOCKET NO. 120001-EI PAGE 6 In January 2012, PEF entered into a settlement agreement with OPC, FIPUG, FRF, PCS, and FEA.5 This agreement addressed issues involving nuclear cost recovery, base rates, the CR3 outage, fuel cost recovery", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 12, "title": "Settlement: Agreement", "summary": "Docket 120001-EI, incremental security rates shall be treated per the terms of the Stipulation and Settlement Agreement approved in the prior FPL rate case, Docket No. 080677-EI. Once we have made our decision in Docket No. 12001S-EI or in the event FPL implements a ba", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: agreement", "summary": "id-course correction. It is acknowledged that the OPC, FRF and others have objected to the proposed settlement agreement signed by FPL, FIPUG, SFHHA and FEA in Docket No. 120015-EI, and that agreement to the stipulation language on this issue does not constitute waiver", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Settlement: agreement", "summary": "anguage on this issue does not constitute waiver by OPC and FRF of those objections to the proposed settlement agreement or orders impacted by our consideration of the proposed settlement agreement. West County Energy Center Unit 3 Cost Recovery FPL, the parties, and ou", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Settlement: agreement", "summary": "ctions to the proposed settlement agreement or orders impacted by our consideration of the proposed settlement agreement. West County Energy Center Unit 3 Cost Recovery FPL, the parties, and our staff raised the issue of what amount should be included in the capacity co", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 16, "title": "Settlement: Agreement", "summary": "ation and Settlement approved in Docket No. 080677-EI, the prior FPL rate case. The Stipulation and Settlement Agreement approved in Docket No. 080677-EI contemplated the cost recovery of the revenue requirements associated 15 We approved the Proposed Settlement Agreeme", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Settlement: Agreement", "summary": "I contemplated the cost recovery of the revenue requirements associated 15 We approved the Proposed Settlement Agreement, as modified, in Docket 12001S-EI on December 13,2012. However, we have not issued an Order. I6 Id. ORDER NO. PSC-12-0664-FOF-EI DOCKET NO. 120001-EI", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 18, "title": "Settlement: agreement", "summary": "id-course correction. It is acknowledged that the OPC, FRF and others have objected to the proposed settlement agreement signed by FPL, FIPUG, SFHHA and FEA in Docket No. 12001S-EI and that agreement to the stipulation language on this issue does not constitute waiver b", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Settlement: agreement", "summary": "anguage on this issue does not constitute waiver by OPC and FRF of those objections to the proposed settlement agreement or orders impacted by the our consideration of the proposed settlement agreement. Canaveral Modernization Project FPL, the parties, and our staff rai", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 20, "title": "Settlement: agreement", "summary": "ns to the proposed settlement agreement or orders impacted by the our consideration of the proposed settlement agreement. Canaveral Modernization Project FPL, the parties, and our staff raised the issue of what amount should be included in the capacity cost recovery cla", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: Agreement", "summary": "Case Settlement Agreement that was filed in Docket No. 12001S-EI on August IS, 2012 (the \"Proposed Settlement Agreement\"), should we approve FPL's proposed GBRA factor of 3.527 percent for the Canaveral Modernization Project. The parties briefed the issue. Subsequent t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: agreement", "summary": "Docket No. 12001S-EI. It is acknowledged that the OPC, FRF and others have objected to the proposed settlement agreement signed by FPL, FIPUG, SFHHA and FEA in Docket No. 12001S-EI, and that agreement to the stipUlation language on this issue does not constitute waiver", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 23, "title": "Settlement: agreement", "summary": "anguage on this issue does not constitute waiver by OPC and FRF of those objections to the proposed settlement agreement or orders impacted by our consideration of the proposed settlement agreement. 17 Id. ORDER NO. PSC-12-0664-FOF-EI DOCKET NO. 120001-EI PAGE 32 GENERI", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 24, "title": "Settlement: agreement", "summary": "ctions to the proposed settlement agreement or orders impacted by our consideration of the proposed settlement agreement. 17 Id. ORDER NO. PSC-12-0664-FOF-EI DOCKET NO. 120001-EI PAGE 32 GENERIC CAPACITY COST RECOVERY FACTOR ISSUES Based on the testimony and exhibits in", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Fuel & purchased-power cost recovery", "Tariff administration & oversight" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "TX", "source": "Public Utility Commission of Texas", "doc_type": "fuel cost reconciliation order", "id": "2005-12-19_southwestern-public-service_puct-29801-fuel-reconciliation-order", "company": "Southwestern Public Service Company", "company_raw": "Southwestern Public Service Company", "docket": "29801", "docket_full": null, "issued_date": "2005-12-19", "source_page_url": "https://interchange.puc.texas.gov/search/filings/?ControlNumber=29801", "pdf_download_url": "https://interchange.puc.texas.gov/Documents/29801_432_499091.PDF", "captured_at": "2026-06-19", "source_note": "Commission Order reconciling Southwestern Public Service Company's (SPS) fuel and purchased-power costs for 2002-2003, PUCT Docket 29801 (SOAH 473-04-6558), Item 432, issued December 19, 2005; 21 pp. A concluded contested fuel-cost reconciliation (complements the still-open El Paso Electric 57149). PDF: interchange.puc.texas.gov/Documents/29801_432_499091.PDF. Listed for reference (metadata-only).", "archived_via": null, "page_count": 21, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "CA", "source": "California Public Utilities Commission", "doc_type": "ERRA reasonableness/prudence decision", "id": "2005-11-18_pacific-gas-and-electric_ca-a05-02-014-d05-11-007-erra", "company": "Pacific Gas and Electric Company", "company_raw": "Pacific Gas and Electric Company", "docket": "A.05-02-014", "docket_full": null, "issued_date": "2005-11-18", "source_page_url": "https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/what-is-an-energy-resource-recovery-account-proceeding", "pdf_download_url": "https://docs.cpuc.ca.gov/published/Final_decision/51417.htm", "captured_at": "2026-06-07", "source_note": "CPUC Decision D.05-11-007 (adopted November 18, 2005), Application A.05-02-014 — the Energy Resource Recovery Account (ERRA) reasonableness review for Pacific Gas and Electric Company, finding PG&E's power-purchase-agreement administration and least-cost-dispatch procurement for Jan 1–Dec 31, 2004 'reasonable and prudent' ($74.9M undercollection). ERRA is California's annual fuel & purchased-power prudence determination. Listed for reference (metadata-only); the decision is published as HTML on the CPUC document portal, so it is captured by reference rather than machine-fetched. Source: CPUC (docs.cpuc.ca.gov/published/Final_decision/51417.htm).", "archived_via": null, "page_count": 1, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "WV", "source": "Public Service Commission", "doc_type": null, "id": "wv_0000_009_2025-management-summary-report", "company": "2025 Management Summary Report", "company_raw": "2025 Management Summary Report", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.psc.state.wv.us", "pdf_download_url": "https://www.psc.state.wv.us/Mgmt_Sum/MSR2025_Report.pdf", "captured_at": "2026-06-14", "source_note": "Public Service Commission (WV)", "archived_via": null, "page_count": 58, "scanned_pages": [ 2 ], "ocr_used": false, 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[211538/1] 22 [211538/1] APPENDIX A SETTLEMENT AGREEMENT APPENDIX B CITATION DETAIL FOR FOOTNOTE 57 57 Jason Donabauer (eDocket No. 202311-200665-01); Ben Fladager (eDocket No. 20241-201723-01); Sandr", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MN", "source": "Minnesota Public Utilities Commission", "doc_type": "administrative law judge report", "id": "northern-states-power_mn-e002-aa-22-179-fuel-forecast-alj", "company": "Northern States Power Company d/b/a Xcel Energy", "company_raw": "Northern States Power Company d/b/a Xcel Energy", "docket": "E-002/AA-22-179", "docket_full": null, "issued_date": null, "source_page_url": "https://mn.gov/oah/assets/21-2500-40336-itm-xcel-energys-petition-for-approval-2023-annual-fuel-forecast-and-monthly-fuel-cost-charges_tcm19-731253.pdf", "pdf_download_url": "https://mn.gov/oah/assets/21-2500-40336-itm-xcel-energys-petition-for-approval-2023-annual-fuel-forecast-and-monthly-fuel-cost-charges_tcm19-731253.pdf", "captured_at": "2026-06-02", "source_note": "Findings of Fact of the Administrative Law Judge (Minnesota Office of Administrative Hearings, OAH 21-2500-40336) in the matter of Xcel Energy's (Northern States Power Company) Petition for Approval of its 2023 Annual Fuel Forecast and Monthly Fuel Cost Charges, before the Minnesota Public Utilities Commission, MPUC Docket No. E-002/AA-22-179 (54 pp) — a review of the utility's fuel-cost recovery. 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Source: Minnesota OAH (mn.gov/oah/assets/21-2500-40336-...fuel-cost-charges_tcm19-731253.pdf).", "archived_via": null, "page_count": 54, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "WI", "source": "Public Service Commission of Wisconsin", "doc_type": "direct testimony", "id": "northern-states-power-wisconsin_wi-4220-ur-127-direct-ascheman", "company": "Northern States Power Company (Wisconsin)", "company_raw": "Northern States Power Company (Wisconsin)", "docket": "4220-UR-127", "docket_full": null, "issued_date": null, "source_page_url": "https://apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=539705", "pdf_download_url": "https://apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=539705", "captured_at": "2026-06-02", "source_note": "Direct Testimony of [NSPW witness] Ascheman in the Application of Northern States Power Company, a Wisconsin Corporation (Xcel Energy), for authority to adjust electric and natural gas rates, before the Public Service Commission of Wisconsin, Docket No. 4220-UR-127 (19 pp). Listed for reference (metadata-only). Source: PSC of Wisconsin Electronic Records Filing, document 539705 (apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=539705).", "archived_via": null, "page_count": 19, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NM", "source": "Public Regulation Commission", "doc_type": null, "id": "nm_0000_000_prce360-compliance-filings", "company": "PRCe360 | Compliance Filings", "company_raw": "PRCe360 | Compliance Filings", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.nm-prc.org", "pdf_download_url": "https://www.prc.nm.gov/prce360/prce360-compliance-filings/", "captured_at": "2026-06-14", "source_note": "Public Regulation Commission (NM)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, 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"doc_type": "cost-recovery application", "id": "montana-dakota-utilities_sd-el25-006-tcr-annual-update", "company": "Montana-Dakota Utilities Co.", "company_raw": "Montana-Dakota Utilities Co.", "docket": "EL25-006", "docket_full": null, "issued_date": null, "source_page_url": "https://puc.sd.gov/Dockets/Electric/2025/EL25-006.aspx", "pdf_download_url": "https://puc.sd.gov/commission/dockets/electric/2025/EL25-006/EL25-006TCR.pdf", "captured_at": "2026-06-07", "source_note": "Montana-Dakota Utilities Co. filing for Approval of the Annual Update to its Transmission Cost Recovery (TCR), before the South Dakota Public Utilities Commission, Docket No. EL25-006 (2 pp). Listed for reference (metadata-only). Source: SD PUC electronic docket, EL25-006 (puc.sd.gov/commission/dockets/electric/2025/EL25-006/EL25-006TCR.pdf).", "archived_via": null, "page_count": 2, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "SD", "source": "South Dakota Public Utilities Commission", "doc_type": "cost-recovery application", "id": "midamerican-energy_sd-el25-004-tcr-reconciliation", "company": "MidAmerican Energy Company", "company_raw": "MidAmerican Energy Company", "docket": "EL25-004", "docket_full": null, "issued_date": null, "source_page_url": "https://puc.sd.gov/Dockets/Electric/2025/EL25-004.aspx", "pdf_download_url": "https://puc.sd.gov/commission/dockets/electric/2025/EL25-004/Application.pdf", "captured_at": "2026-06-07", "source_note": "MidAmerican Energy Company's Application for Approval of its 2024 Reconciliation and 2025 Transmission Cost Recovery (TCR), before the South Dakota Public Utilities Commission, Docket No. EL25-004 (7 pp). Listed for reference (metadata-only). 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Settlement Agreement in the Evergy Kansas Central, Inc. and Evergy Kansas South, Inc. base-rate case, Docket No. 25-EKCE-294-RTS (88 pp) — the utilities' application sought a net revenue-requirement increase of ~$196.4M (~$192M base, 8.64%). Listed for reference (metadata-only). Source: Kansas Corporation Commission eSTAR (estar.kcc.ks.gov/estar/ViewFile.aspx, document Id a0f02909-3351-4599-8d21-75c879fdd16c).", "archived_via": null, "page_count": 88, "scanned_pages": [ 36, 37, 49, 51 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 44, "findings": [ { "index": 1, "title": "Settlement: AGREEMENT", "summary": "proval to Make Certain Changes in ) their Charges for Electric Service. ) ORDER APPROVING UNANIMOUS SETTLEMENT AGREEMENT This matter comes before the State Corporation Commission of the State of Kansas (Commission) for consideration and decision. Having reviewed the ple", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Settlement: Agreement", "summary": "taff’s revenue requirement recommendation totaled $122.2 million. Testimony in Support of Unanimous Settlement Agreement of Chad Unrein (Unrein Supporting Testimony), July 17, 2025, p. 5. 9 Direct Testimony of Mark E. Garrett (Garrett Direct), June 6, 2025, p. 8. 10 Dir", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Settlement: Agreement", "summary": "E. Garrett, June 20, 2025, p. 6. 3 Chamber; and IBEW 304, filed a Joint Motion to Approve Unanimous Settlement Agreement. The Unanimous Settlement Agreement is attached as Attachment A and incorporated by reference.15 Some important provisions of the settlement include:", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Settlement: Agreement", "summary": "hamber; and IBEW 304, filed a Joint Motion to Approve Unanimous Settlement Agreement. The Unanimous Settlement Agreement is attached as Attachment A and incorporated by reference.15 Some important provisions of the settlement include: • Evergy will receive an overall an", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: Agreement", "summary": "udice;21 15 On July 18, 2025, the Parties filed an Errata to Joint Motion for Approval of Unanimous Settlement Agreement, to correct some minor typographical errors. The Unanimous Settlement Agreement attached to the July 18, 2025 errata filing is attached to this Order", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 6, "title": "Settlement: Agreement", "summary": "proval of Unanimous Settlement Agreement, to correct some minor typographical errors. The Unanimous Settlement Agreement attached to the July 18, 2025 errata filing is attached to this Order as Attachment A and incorporated by reference. 16 Unanimous Settlement Agreemen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: Agreement", "summary": "errata filing is attached to this Order as Attachment A and incorporated by reference. 16 Unanimous Settlement Agreement, July 16, 2025, ⁋ 6. 17 Id, ⁋ 7. 18 Id. 19 Id. 20 Id, ⁋ 9. 21 Id., n. 3. 4 • The Parties agree that Evergy’s request for approval of a nuclear PTC tr", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Settlement: Agreement", "summary": "rt of the settlement. 12. On July 21, 2025, the Commission held a hearing on the proposed Unanimous Settlement Agreement. The Parties appeared by counsel. The Commission heard live testimony from David Campbell and Darrin Ives of Evergy, Josh Frantz of CURB, and Chad Un", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: Agreement", "summary": "shall not be burdened with costs created by another class.”32 16. Pursuant to K.A.R. 82-1-230a, the Settlement Agreement is considered a “unanimous settlement agreement.” The law generally favors compromise and settlement of disputes between parties when they enter into", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Settlement: agreement", "summary": "her class.”32 16. Pursuant to K.A.R. 82-1-230a, the Settlement Agreement is considered a “unanimous settlement agreement.” The law generally favors compromise and settlement of disputes between parties when they enter into an agreement knowingly and in good faith to set", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: Agreement", "summary": "n, 28 Kan. App. 2d 313, 316 (2000), rev denied March 20, 2001. 35 Testimony in Support of Unanimous Settlement Agreement of Darrin R. Ives (Ives Supporting Testimony), July 17, 2025, pp. 7-8. 36 Id., p. 8. 37Farmland Indus., Inc. v. Kansas Corp. Comm’n, 25 Kan.App.2d 84", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Settlement: Agreement", "summary": "very request responses that thoroughly examined Evergy’s Application.41 Ives explains the Unanimous Settlement Agreement is the product of rigorous vetting, thorough expert analysis, and informed compromise.42 If this Docket had been fully litigated, the Parties would h", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: Agreement", "summary": "Commission to make an informed decision on the merits.44 Staff believes the terms of the Unanimous Settlement Agreement are commensurate with its expected outcome from a fully-litigated proceeding.45 Having reviewed the record as a whole, the Commission finds the Unani", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Settlement: Agreement", "summary": "y-litigated proceeding.45 Having reviewed the record as a whole, the Commission finds the Unanimous Settlement Agreement is supported by substantial competent evidence. 20. Every electric public utility in Kansas is required to provide reasonably efficient and sufficien", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Settlement: Agreement", "summary": "Supreme Court 38Id. at 851. 39 Ives Supporting Testimony, p. 19; Testimony in Support of Unanimous Settlement Agreement of Josh Frantz (Frantz Supporting Testimony), July 17, 2025, p. 8, Unrein Supporting Testimony, p. 27. 40 Ives Supporting Testimony, p. 19; Unrein Su", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 16, "title": "Settlement: Agreement", "summary": "of which are lower than what Evergy requested in its Application.50 22. The Signatories believe the Settlement Agreement will result in just and reasonable rates.51 Ives explains the evidence and expert analysis presented in this proceeding indicate that the rates estab", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Settlement: Agreement", "summary": "d expert analysis presented in this proceeding indicate that the rates established by the Unanimous Settlement Agreement are: (1) based on a lawful and prudent revenue requirement, (2) allocated equitably among customer classes, (3) structured to promote efficiency and", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 18, "title": "Settlement: Agreement", "summary": "ort, p. 32. 49 Id. 50 Frantz Supporting Testimony, p. 10. 51 Joint Motion for Approval of Unanimous Settlement Agreement, ¶ 4; Ives Supporting Testimony, p. 20; Frantz Supporting Testimony, p. 9, Unrein Supporting Testimony, p. 36. 52 Ives Supporting Testimony, p. 20. 5", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Settlement: Agreement", "summary": "roviding reliable electric service.54 Staff believes the cost recovery afforded under the Unanimous Settlement Agreement accurately reflects Evergy’s cost of providing reasonably sufficient and efficient service.55 Based on the substantial evidence in the record that th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 20, "title": "Settlement: Agreement", "summary": "sonable rates for Evergy and its customers. 25. The Commission finds that approval of the Unanimous Settlement Agreement is in the public interest. The Signatories agree the terms of the Unanimous Settlement Agreement are in the public interest and should be approved by", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: Agreement", "summary": "us Settlement Agreement is in the public interest. The Signatories agree the terms of the Unanimous Settlement Agreement are in the public interest and should be approved by the Commission.56 26. Staff opines the Settlement Agreement is in the public interest because it", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: Agreement", "summary": "reement are in the public interest and should be approved by the Commission.56 26. Staff opines the Settlement Agreement is in the public interest because it: (1) It reduces Evergy’s requested revenue increase closer to Staff’s position; (2) provides Evergy with suffici", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 23, "title": "Settlement: Agreement", "summary": "ng process of a fully-litigated hearing.57 27. Frantz identifies the ERS provision of the Unanimous Settlement Agreement, which he believes promotes the public interest. The ERS enables Evergy to share earnings beyond a designated level with its customers.58 CURB believ", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 24, "title": "Settlement: Agreement", "summary": "opportunity 54 Unrein Supporting Testimony, p. 36. 55 Id. 56Joint Motion for Approval of Unanimous Settlement Agreement, ¶ 4. 57 Unrein Supporting Testimony, p. 39. 58 Frantz Supporting Testimony, p. 11. 10 to earn a fair return on its investments, while benefitting ra", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 25, "title": "Settlement: Agreement", "summary": "service at just and reasonable rates to its customers. After considering the terms of the Unanimous Settlement Agreement, the Commission finds it is in the public interest. The Unanimous Settlement Agreement is a balanced agreement that is fair to all the parties. 29. A", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 26, "title": "Settlement: Agreement", "summary": "he Unanimous Settlement Agreement, the Commission finds it is in the public interest. The Unanimous Settlement Agreement is a balanced agreement that is fair to all the parties. 29. After a careful review and consideration of the evidence, the Commission finds that the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 27, "title": "Settlement: Agreement", "summary": "careful review and consideration of the evidence, the Commission finds that the attached Unanimous Settlement Agreement is supported by substantial competent evidence in the record as a whole, will result in just and reasonable rates, and is in the public interest. The", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 28, "title": "Settlement: Agreement", "summary": "in just and reasonable rates, and is in the public interest. The Commission approves the Unanimous Settlement Agreement in its entirety. 30. The new rates will take effect based on the customer’s billing cycle date beginning October 1, 2025.60 THEREFORE, THE COMMISSION", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 29, "title": "Settlement: Agreement", "summary": "nning October 1, 2025.60 THEREFORE, THE COMMISSION ORDERS: A. The Commission approves the Unanimous Settlement Agreement in its entirety. The terms of the attached Unanimous Settlement Agreement are incorporated into this Order. B. The parties have 15 days from the date", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 30, "title": "Settlement: Agreement", "summary": "on approves the Unanimous Settlement Agreement in its entirety. The terms of the attached Unanimous Settlement Agreement are incorporated into this Order. B. The parties have 15 days from the date of electronic service of this Order to petition for reconsideration.61 59", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 31, "title": "Settlement: Agreement", "summary": "this Order to petition for reconsideration.61 59 Id. 60 See Joint Motion for Approval of Unanimous Settlement Agreement, ⁋ 38; Ives Supporting Testimony, p. 18. 61 K.S.A. 66-118b; K.S.A. 77-529(a)(1). 11 BY THE COMMISSION IT IS SO ORDERED. French, Chairperson; Keen, Co", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 32, "title": "Settlement: AGREEMENT", "summary": "ake Ce1iain Changes in their ) Docket No. 25-EKCE-294-RTS Charges for Electric Service. ) UNANIMOUS SETTLEMENT AGREEMENT As a result of discussions among all parties to this docket, the Staff (\"Staff') of the State Corporation Commission (\"Commission\") of the State of K", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 33, "title": "Settlement: Agreement", "summary": "Pmiies\", hereby submit to the Commission for its consideration and approval the following Unanimous Settlement Agreement (\"Settlement\", \"Agreement\" or \"Settlement Agreement\"). I. EVERGY'S PETITION 1. On January 31, 2025, EKC filed a Joint Application requesting authoriz", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 34, "title": "Settlement: Agreement", "summary": "to the Commission for its consideration and approval the following Unanimous Settlement Agreement (\"Settlement\", \"Agreement\" or \"Settlement Agreement\"). I. EVERGY'S PETITION 1. On January 31, 2025, EKC filed a Joint Application requesting authorization to make certain chan", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 35, "title": "Settlement: Agreement", "summary": "sideration and approval the following Unanimous Settlement Agreement (\"Settlement\", \"Agreement\" or \"Settlement Agreement\"). I. EVERGY'S PETITION 1. On January 31, 2025, EKC filed a Joint Application requesting authorization to make certain changes to its charges for ele", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 36, "title": "Settlement: terms", "summary": "turned to customers; • Approval of modifications to the terms of the prior Western Plains Wind Farm settlement to reflect cmTent considerations and align its regulation with the terms in place for the Persimmon Creek Wind Farm; • Approval of Tracker 2 for Pension and OPEBs to be included in rate bas", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 37, "title": "Settlement: AGREEMENT", "summary": "vide an updated cross-answering revenue requirement amount in the record. Attachment 1 II. TERMS OF SETTLEMENT AGREEMENT A. Revenue Requirement 6. The Parties agree that Evergy Kansas Central's (\"EKC\") overall annual revenue requirement increase should be $128.0 million", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 38, "title": "Settlement: Agreement", "summary": "ries recommend the Commission convert the July 21-25, 2025 evidentimy hearing into a hearing on the Settlement Agreement on July 21, 2025, and waive the filing of post-hearing briefs. F. Miscellaneous Provisions 45. Nothing in this Settlement is intended to impinge or r", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 39, "title": "Settlement: Agreement", "summary": "a separate docket; and/or ( c) in this proceeding should the Commission decide to not approve this Settlement in the instant proceeding. If the Commission accepts this Settlement Agreement in its entirety and incorporates the same into a formal order without material modification, the Signatory Part", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 40, "title": "Settlement: Agreement", "summary": "erms hereof, and will not appeal the Commission's order on these issues. 48. The provisions of this Settlement Agreement have resulted from negotiations among the Signatory Parties and are interdependent. In the event the Commission does not approve and adopt the terms", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 41, "title": "Settlement: terms", "summary": "es and are interdependent. In the event the Commission does not approve and adopt the terms of this Settlement in total or materially changes the Settlement terms, the Settlement shall be voidable and no Signatory Party hereto shall be bound, prejudiced, or in any way affected by any of the agreemen", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 42, "title": "Settlement: Agreement", "summary": "rial change of condition. IN WITNESS THEREOF, the Signatory Parties have executed and approved this Settlement Agreement, effective as of the ---- day of July, 2025, by subscribing their signatures below. Attachment 1 fJ. By: Isl~ 1)~ Cathryn J. Dinges (#20848) Sr. Dire", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 43, "title": "Settlement: Agreement", "summary": "ue Inputs Commissioner Dwight D. Keen Dissenting in Part The Commission’s approval of the Unanimous Settlement Agreement grants Evergy Kansas Central (EKC) an annual $128 million increase in base rates and also authorizes EKC to receive a 9.7% Return on Equity (ROE) for", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 44, "title": "Settlement: Agreement", "summary": "3). 6 Woolridge Testimony, p. 11-13, 16-19. 7 Id., p. 5-6. 8 See Transcript of Hearing on Unanimous Settlement Agreement, July 21, 2025, p. 27. 3 while simultaneously protecting ratepayers from unnecessary or unjustified rate increases. Throughout the country, affordabi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "MO", "source": "Missouri Public Service Commission", "doc_type": "staff prudence review report", "id": "er-2011-0028_union-electric-ameren-missouri_mo-staff-taum-sauk-construction-audit-prudence", "company": "Union Electric Company d/b/a Ameren Missouri", "company_raw": "Union Electric Company d/b/a Ameren Missouri", "docket": "ER-2011-0028", "docket_full": null, "issued_date": null, "source_page_url": "https://efis.psc.mo.gov/Document/Display/99523", "pdf_download_url": "https://efis.psc.mo.gov/Document/Display/99523", "captured_at": "2026-06-02", "source_note": "Missouri Public Service Commission Staff's Construction Audit and Prudence Review of the Taum Sauk Project for costs reported as of October 31, 2010, for Union Electric Company d/b/a Ameren Missouri, Case No. ER-2011-0028 (34 pp; Staff's audit/prudence review of the rebuilt Taum Sauk pumped-storage hydroelectric plant). Listed for reference (metadata-only). Source: Missouri PSC EFIS, document 99523 (efis.psc.mo.gov/Document/Display/99523).", "archived_via": null, "page_count": 34, "scanned_pages": [ 23, 24, 25, 26, 27, 28, 29, 30, 31, 32 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MO", "source": "Missouri Public Service Commission", "doc_type": "staff testimony", "id": "er-2011-0028_union-electric-ameren-missouri_mo-staff-surrebuttal-fac-sharing-mechanism", "company": "Union Electric Company d/b/a Ameren Missouri", "company_raw": "Union Electric Company d/b/a Ameren Missouri", "docket": "ER-2011-0028", "docket_full": null, "issued_date": null, "source_page_url": "https://efis.psc.mo.gov/Document/Display/140150", "pdf_download_url": "https://efis.psc.mo.gov/Document/Display/140150", "captured_at": "2026-06-02", "source_note": "Surrebuttal Testimony of Lena M. Mantle on behalf of the Missouri Public Service Commission Staff on the Fuel Adjustment Clause (FAC) Sharing Mechanism, in the matter of Union Electric Company d/b/a Ameren Missouri, Case No. ER-2011-0028 (137 pp). Listed for reference (metadata-only). Source: Missouri PSC EFIS, document 140150 (efis.psc.mo.gov/Document/Display/140150).", "archived_via": null, "page_count": 137, "scanned_pages": [ 2 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "MO", "source": "Missouri Public Service Commission", "doc_type": "staff prudence review report", "id": "eo-2024-0053_union-electric-ameren-missouri_mo-staff-tenth-fac-prudence-review", "company": "Union Electric Company d/b/a Ameren Missouri", "company_raw": "Union Electric Company d/b/a Ameren Missouri", "docket": "EO-2024-0053", "docket_full": null, "issued_date": null, "source_page_url": "https://efis.psc.mo.gov/Document/Display/772394", "pdf_download_url": "https://efis.psc.mo.gov/Document/Display/772394", "captured_at": "2026-06-02", "source_note": "Missouri Public Service Commission Staff Report — Tenth Prudence Review of Costs Related to the Fuel Adjustment Clause (FAC) for the electric operations of Union Electric Company d/b/a Ameren Missouri, File No. EO-2024-0053 (56 pp; Staff's review of the prudence of fuel and purchased-power costs recovered through Rider FAC). Listed for reference (metadata-only). Source: Missouri PSC EFIS, document 772394 (efis.psc.mo.gov/Document/Display/772394).", "archived_via": null, "page_count": 56, "scanned_pages": [ 13, 19 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MO", "source": "Missouri Public Service Commission", "doc_type": "order", "id": "eo-2022-0027_union-electric-ameren-missouri_mo-commission-order-fac-truup-far", "company": "Union Electric Company d/b/a Ameren Missouri", "company_raw": "Union Electric Company d/b/a Ameren Missouri", "docket": "EO-2022-0027", "docket_full": null, "issued_date": null, "source_page_url": "https://efis.psc.mo.gov/Document/Display/80659", "pdf_download_url": "https://efis.psc.mo.gov/Document/Display/80659", "captured_at": "2026-06-02", "source_note": "Order of the Missouri Public Service Commission (session order) addressing Union Electric Company d/b/a Ameren Missouri's Fuel Adjustment Clause true-up (File No. EO-2022-0027), Fuel Adjustment Rate adjustment (File No. ER-2022-0026), and related rate proceeding (ER-2021-0240) (15 pp). Listed for reference (metadata-only). 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"https://portal.ct.gov/pura/industries/rate-case-information", "pdf_download_url": "https://portal.ct.gov/-/media/PURA/1-Final-Decision--PURA-Issues-Ruling-on-Utilities-Preparation-for-Response-to-Tropical-Storm-Isaias.pdf", "captured_at": "2026-06-07", "source_note": "Connecticut PURA Final Decision, Docket No. 20-08-03 — Investigation into the Electric Distribution Companies' (The Connecticut Light and Power Company d/b/a Eversource Energy and The United Illuminating Company) Preparation for and Response to Tropical Storm Isaias, resulting in civil penalties and management directives for inadequate emergency response (139 pp). Listed for reference (metadata-only). Source: Connecticut PURA (portal.ct.gov/-/media/PURA/).", "archived_via": null, "page_count": 139, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Emergency preparedness & business continuity" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "CT", "source": "Connecticut Public Utilities Regulatory Authority", "doc_type": "rate design investigation decision", "id": "connecticut-edcs_ct-17-12-03re011-rate-design-decision-phase-1a", "company": "Connecticut electric distribution companies (Eversource / United Illuminating)", "company_raw": "Connecticut electric distribution companies (Eversource / United Illuminating)", "docket": "17-12-03RE011", "docket_full": null, "issued_date": null, "source_page_url": "https://portal.ct.gov/pura/industries/rate-case-information", "pdf_download_url": "https://portal.ct.gov/-/media/pura/electric/decision--phase-1a.pdf", "captured_at": "2026-06-07", "source_note": "Connecticut PURA Decision (Phase 1A), Docket No. 17-12-03RE011 — PURA Investigation into Distribution System Planning of the Electric Distribution Companies, New Rate Designs (Eversource / United Illuminating) (23 pp). Listed for reference (metadata-only). Source: Connecticut PURA (portal.ct.gov/-/media/pura/electric/decision--phase-1a.pdf).", "archived_via": null, "page_count": 23, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Cost of service & rates" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "CA", "source": "Public Utilities Commission", "doc_type": "audit report", "id": "ca_0000_000_cpuc-see-docs-cpuc-ca-gov-for-audit-repo", "company": "CPUC: See docs.cpuc.ca.gov for audit reports", "company_raw": "CPUC: See docs.cpuc.ca.gov for audit reports", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.cpuc.ca.gov/documents", "pdf_download_url": "https://docs.cpuc.ca.gov/", "captured_at": "2026-06-14", "source_note": "Public Utilities Commission (CA)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NE", "source": "Nebraska Public Service Commission", "doc_type": "order on gas cost hedge agreement (denied)", "id": "black-hills-nebraska-gas_ne-ng-0086-cost-of-service-gas-hedge-denied", "company": "Black Hills/Nebraska Gas Utility Company, LLC d/b/a Black Hills Energy", "company_raw": "Black Hills/Nebraska Gas Utility Company, LLC d/b/a Black Hills Energy", "docket": "NG-0086", "docket_full": null, "issued_date": null, "source_page_url": "https://psc.nebraska.gov/natural-gas/pending-and-completed-dockets", "pdf_download_url": "https://www.nebraska.gov/psc/orders/natgas/NG-0086.30.pdf", "captured_at": "2026-06-07", "source_note": "Nebraska PSC Order (Application No. NG-0086) in the matter of Black Hills/Nebraska Gas Utility Company, LLC d/b/a Black Hills Energy seeking approval of its Cost of Service Gas Hedge Agreement with affiliate Black Hills Utility Holdings, Inc. — the Commission DENIED the agreement (an affiliate gas-cost / prudence matter) (16 pp). Listed for reference (metadata-only). Source: Nebraska PSC orders repository (nebraska.gov/psc/orders/natgas/NG-0086.30.pdf).", "archived_via": null, "page_count": 16, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AZ", "source": "Corporation Commission", "doc_type": null, "id": "az_0000_000_report-a-railroad-issue", "company": "Report a Railroad Issue", "company_raw": "Report a Railroad Issue", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.azcc.gov", "pdf_download_url": "https://www.azcc.gov/safety/railroad", "captured_at": "2026-06-14", "source_note": "Corporation Commission (AZ)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "AZ", "source": "Arizona Corporation Commission", "doc_type": "rate case order", "id": "arizona-public-service_az-e-01345a-03-0437-rate-case-order", "company": "Arizona Public Service Company", "company_raw": "Arizona Public Service Company", "docket": "E-01345A-03-0437", "docket_full": null, "issued_date": null, "source_page_url": "https://www.azcc.gov/utilities", "pdf_download_url": "https://www.azcc.gov/divisions/utilities/electric/APS-FinalOrder.pdf", "captured_at": "2026-06-07", "source_note": "Arizona Corporation Commission order in the Arizona Public Service Company (APS) general rate case, Docket No. E-01345A-03-0437 (178 pp; scanned cover with a born-digital body — the parties/appearances list and findings carry a text layer). Posted on the ACC Utilities Division site as 'APS-FinalOrder.pdf'. Listed for reference (metadata-only). Source: Arizona Corporation Commission (www.azcc.gov/divisions/utilities/electric/APS-FinalOrder.pdf).", "archived_via": null, "page_count": 178, "scanned_pages": [ 1, 45, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90, 91, 92, 93, 94, 95, 96, 97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, 116, 117, 118, 119, 120, 121, 122, 123, 124, 125, 126, 127, 128, 129, 130, 131, 132, 133, 134, 135, 136, 137, 138, 139, 140, 141, 142, 143, 144, 145, 146, 147, 148, 149, 150, 151, 152, 153, 154, 155, 156, 157, 158, 159, 160, 161, 162, 163, 164, 165, 166, 167, 168, 169, 170, 171, 172, 173, 174, 175, 176, 177, 178 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 121, "findings": [ { "index": 1, "title": "Disallowance: $700", "summary": "$1 billion. 21 As part of the settlement, APS agreed to reflect an original cost rate base value of $700 22 million, representing a $148 million disallowance. The effect of a reduction in rate base is to 23 immediately reduce the revenue requirement, and to preserve that diminished revenue requireme", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 2, "title": "Approval: $100 million", "summary": "fund of that existing bank balance will be addressed at such time. In no event shall the 14 Company allow the bank balance to reach $100 million prior to seeking recovery or refund. 15 Following a proceeding to recover or refund a bank balance between $50 million and $100 million, 16 the bank", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Approval: $100 million", "summary": "efund of that existing bank balance will be addressed at such time. In no event shall the 7 Company allow the bank balance to reach $100 million prior to seeking recovery or refund. 8 Following a proceeding to recover or refund a bank balance between $50 million and $100 million, 9 the bank ba", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Settlement: Agreement", "summary": "ergy Corporation (“PWEC”); permit APS to recover the 10 $234 million write-off taken under the 1999 Settlement Agreement; and provide for the recovery of 11 all prudently incurred costs to comply with the Commission’s Retail Electric Competition Rules, 12 A.A.C. R14-2-1", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Settlement: Agreement", "summary": "11 include its report in this docket. 12 II. PRE-SETTLEMENT POSITIONS OF PARTIES 13 APS Staff RUCO Settlement Agreement 14 Revenue requirement +$175.1 M -$142.7 M -$53.6 M +$75.5 M 15 Return on Equity 11.5 % 9.0% 9.5% 10.25 % 16 Debt cost 5.8 % 5.8% 5.8% 5.8% 17 Capita", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 6, "title": "Settlement: AGREEMENT", "summary": "45 55/45 55/45 18 Cost of Capital 8.67 % 7.3% 7.43% 7.8 % 19 PWEC assets $848 M - -2 $700 M 20 III. SETTLEMENT AGREEMENT 21 a. Introduction 22 On August 18, 2004, a Settlement Agreement signed by 22 parties3 was docketed with the 23 Commission. AWC, SWG, and UES do not", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 7, "title": "Settlement: Agreement", "summary": "assets $848 M - -2 $700 M 20 III. SETTLEMENT AGREEMENT 21 a. Introduction 22 On August 18, 2004, a Settlement Agreement signed by 22 parties3 was docketed with the 23 Commission. AWC, SWG, and UES do not oppose the Settlement Agreement, and the AARP made 24 public comm", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 8, "title": "Settlement: Agreement", "summary": "ment signed by 22 parties3 was docketed with the 23 Commission. AWC, SWG, and UES do not oppose the Settlement Agreement, and the AARP made 24 public comment supporting it. The only party opposed to the Commission’s adoption of the 25 Settlement Agreement that presented", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Settlement: Agreement", "summary": "made 24 public comment supporting it. The only party opposed to the Commission’s adoption of the 25 Settlement Agreement that presented testimony and evidence is the Arizona Cogeneration 26 1 On August 18, 2004, Wickenburg moved to withdraw its intervention. 27 2 Phase", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 10, "title": "Settlement: Agreement", "summary": "ation”; and to determine the company’s future public service obligations. 4 Staff believes that the Settlement Agreement is in the public interest because: it is fair to 5 ratepayers because it precludes inappropriate utility profits and results in just and reasonable r", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Settlement: Agreement", "summary": "for general service customers, encouraging those customers to shop for competitive services; the 16 Settlement Agreement resolves long, complex litigation by resolving issues associated with prior 17 Commission decisions that are on appeal; the Settlement Agreement faci", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 12, "title": "Settlement: Agreement", "summary": "itigation by resolving issues associated with prior 17 Commission decisions that are on appeal; the Settlement Agreement facilitates the provision of 18 electric service at the lowest reasonable rates; it provides additional discounts to low-income APS 19 customers, inc", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 13, "title": "Settlement: Agreement", "summary": "the negotiations. RUCO 25 points to the very substantial, nearly universal consensus reached in the Settlement Agreement as 26 4 New Harquahala Generating Company, LLC and Panda made statements objecting to the rate basing of the PWEC 27 assets. 5 Defined as the ability", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 14, "title": "Settlement: Agreement", "summary": "members can sell their power. According to the Alliance, there are 6 several key provisions in the Settlement Agreement that accomplish that goal: the restrictions on 7 self-build coupled with the high growth rate in APS’ service territory; and the 1,000 megawatt 8 Req", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Settlement: Agreement", "summary": "rate in APS’ service territory; and the 1,000 megawatt 8 Request for Proposal (“RFP”) in 2005. The Settlement Agreement also preserves the financial 9 stability and creditworthiness of the Alliance’s target customer – APS.8 10 b. Revenue Requirements 11 For ratemaking", "is_other_matter": false, "recommendations": [], "themes": [ "Creditworthiness" ], "cost_to_customers": false }, { "index": 16, "title": "Settlement: Agreement", "summary": "rget customer – APS.8 10 b. Revenue Requirements 11 For ratemaking purposes and for purposes of the Settlement Agreement, the parties agree that 12 APS will receive a total increase of $75.5 million over its adjusted 2002 test year (“TY”) revenue of 13 $1,791,584,000. T", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 17, "title": "Settlement: Agreement", "summary": "in the hearing, the Company’s fair value rate base 16 (“FVRB”) is $5,054,426,000.9 According to the Settlement Agreement, this revenue increase will 17 allow the Company the opportunity to earn a fair value rate of return of 5.92 percent. According to 18 the Company and", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 18, "title": "Settlement: Agreement", "summary": "rn of 5.92 percent. According to 18 the Company and Staff, the revenue requirement contained in the Settlement Agreement provides 19 sufficient revenues for APS to provide adequate and reliable service.10 20 c. PWEC Asset Treatment 21 The Settlement Agreement provides t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 19, "title": "Settlement: Agreement", "summary": "ient revenues for APS to provide adequate and reliable service.10 20 c. PWEC Asset Treatment 21 The Settlement Agreement provides that APS will acquire and rate base generation units 22 owned by PWEC.11 Those units include: West Phoenix CC-4; West Phoenix CC-5; Saguaro", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 20, "title": "Settlement: Agreement", "summary": "West Phoenix CC-5; Saguaro CT-3; 23 Redhawk CC-1; and Redhawk CC-2 (“PWEC assets”). Pursuant to the Settlement Agreement, the 24 7 Summary of settlement testimony of Stephen Ahearn. 25 8 Tr. p. 458. 9 Paragraph 4 to the Settlement Agreement states the FVRB is $6,281,885", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 21, "title": "Settlement: Agreement", "summary": ", the 24 7 Summary of settlement testimony of Stephen Ahearn. 25 8 Tr. p. 458. 9 Paragraph 4 to the Settlement Agreement states the FVRB is $6,281,885,000, however, during the hearing, that amount 26 was corrected to $5,054,426,000. Tr. p. 692. 10 Tr. p. 810. 27 11 On N", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 22, "title": "Settlement: Agreement", "summary": "04, PWEC filed a letter with the Commission indicating that it would abide by the provisions of the Settlement Agreement that require PWEC to take or refrain from taking any action in order to carry out the intent of 28 the Settlement Agreement. 8 DECISION NO. _________", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 23, "title": "Settlement: Agreement", "summary": "t require PWEC to take or refrain from taking any action in order to carry out the intent of 28 the Settlement Agreement. 8 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 original cost rate base (“OCRB”) of the PWEC assets will be $700 million which is $148 mi", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 24, "title": "Settlement: Agreement", "summary": "$148 million less 2 than the original cost of the assets as of December 31, 2004. According to the Settlement Agreement, 3 this represents a reasonable estimate of the value of the remaining term of the Track B contract 4 between APS and PWEC.12 APS agrees to forgo any", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 25, "title": "Settlement: Agreement", "summary": "ny present or future claims of stranded costs 5 associated with these PWEC assets. According to the Settlement Agreement, APS is required to seek 6 approval of certain aspects of the asset transfer from the Federal Energy Regulatory Commission 7 (“FERC”). APS agreed to", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 26, "title": "Settlement: Agreement", "summary": "APS agreed to file a request for FERC approval within 30 days of the Commission’s 8 approval of the Settlement Agreement, and the parties have agreed not to oppose the FERC 9 application. The Settlement Agreement provides for a bridge purchased power agreement (“Bridge", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 27, "title": "Settlement: Agreement", "summary": "of the Settlement Agreement, and the parties have agreed not to oppose the FERC 9 application. The Settlement Agreement provides for a bridge purchased power agreement (“Bridge 10 PPA”) to be implemented once new rates are put in place, until the actual date of the tra", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 28, "title": "Settlement: Agreement", "summary": "flecting cost-of-service as if the PWEC assets were rate-based at the $700 million amount in 15 the Settlement Agreement, and with the associated fuel costs and off-system sales revenue flowing 16 through the PSA. The basis point credit established in Decision No. 65796", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates", "Fuel & purchased-power cost recovery" ], "cost_to_customers": true }, { "index": 29, "title": "Settlement: Agreement", "summary": "or 18 amounts deferred after December 31, 2004 will be accounted for in APS’ next rate case. The 19 Settlement Agreement also provides that West Phoenix CC-4 and West Phoenix CC-5 will be 20 deemed “local generation” and during must-run conditions, generation from the W", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 30, "title": "Settlement: Agreement", "summary": "nveyance of the PWEC assets to APS is further support for this proposition. APS’ 14 request and the Settlement Agreement’s provision allowing APS to acquire the PWEC assets and put 15 them in rate base raises the issue of whether such action would undermine the Commissi", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 31, "title": "Settlement: Agreement", "summary": "e the Commission’s stated 16 intent to encourage retail and wholesale competition. The terms of the Settlement Agreement taken 17 as a whole indicate to us that the answer to that question is “no”. 18 During the hearing on the Settlement Agreement, the parties presented", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 32, "title": "Settlement: Agreement", "summary": "17 as a whole indicate to us that the answer to that question is “no”. 18 During the hearing on the Settlement Agreement, the parties presented evidence 19 demonstrating that the PWEC acquisition was the most beneficial option for ratepayers. Staff 20 testified that the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 33, "title": "Settlement: Agreement", "summary": "ot be met, and it would have to procure additional 24 power to meet the needs of its customers. The Settlement Agreement provides that APS will issue an 25 RFP for an additional 1000 megawatts, thereby giving other market participants an opportunity to 26 compete. The o", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 34, "title": "Settlement: Agreement", "summary": "ed, and because of the 8 treatment of the West Phoenix facilities. 9 We believe that nothing in the Settlement Agreement prevents the continued development of 10 electric competition. Any potential anti-competitive effects of the asset transfer will be addressed 11 thro", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 35, "title": "Settlement: Agreement", "summary": "and in the public interest for APS 28 to acquire and rate base the PWEC assets as set forth in the Settlement Agreement. 12 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 d. Cost of Capital 2 The Settlement Agreement adopts a capital structure of 55 percent l", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 36, "title": "Settlement: Agreement", "summary": "ent Agreement. 12 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 d. Cost of Capital 2 The Settlement Agreement adopts a capital structure of 55 percent long-term debt and 45 3 percent equity for ratemaking purposes. The parties agree that a 10.25 percent retur", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 37, "title": "Settlement: Agreement", "summary": "5.8 percent embedded cost of long-term debt is appropriate. 5 e. Power Supply Adjustor (PSA) 6 The Settlement Agreement provides that a PSA be implemented and remain in effect for a 7 minimum of five years, with reviews available during APS’ next rate case, or upon APS", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 38, "title": "Settlement: Agreement", "summary": ". Regardless of the 9 review/report, the PSA cannot be abolished until five years have expired. The Settlement Agreement 10 provides that APS will file a plan of administration as part of its tariff filing that describes how the 11 PSA will operate. According to the Set", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 39, "title": "Settlement: Agreement", "summary": "istration as part of its tariff filing that describes how the 11 PSA will operate. According to the Settlement Agreement, the PSA will have the following 12 characteristics: 13 • Includes both fuel and purchased power; 14 • The adjustor rate will initially be set at zer", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight", "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 40, "title": "Settlement: Agreement", "summary": "ct to refund if the Commission later 5 determines that the costs were not prudently incurred. 6 The Settlement Agreement provides that APS shall provide monthly reports to Staff’s 7 Compliance Section and to RUCO detailing all calculations related to the PSA, and shall", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 41, "title": "Settlement: Agreement", "summary": "ovided in the reports is true and accurate to 10 the best of his or her information and belief. The Settlement Agreement also provides that direct 11 access customers and customers served under rates E-36, SP-1, Solar-1, and Solar-2 are excluded 12 from paying PSA charg", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 42, "title": "Settlement: Agreement", "summary": "ved under rates E-36, SP-1, Solar-1, and Solar-2 are excluded 12 from paying PSA charges. Under the Settlement Agreement, the PSA remains in effect for 5 years, 13 and if after that, the Commission abolishes the PSA, it must provide for any under- or over-recovery 14 an", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 43, "title": "Settlement: Agreement", "summary": "ugh we recently approved the concept of a PSA, we are concerned about the PSA as 15 proposed in the Settlement Agreement. The benefits of this PSA are that over time, the utility’s 16 earnings will be stabilized, thereby preserving its financial integrity and in the lon", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 44, "title": "Settlement: Agreement", "summary": "s the shifting of the risk that fuel costs will increase above the base rates established in the 26 Settlement Agreement. Currently, if fuel costs or any other costs rise above the level embedded in 27 28 14 Tr. p. 1249. 15 DECISION NO. _____________ DOCKET NO. E-01345A", "is_other_matter": false, "recommendations": [], "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "index": 45, "title": "Settlement: Agreement", "summary": "also increases due to growth that is met 9 with generation from a high cost fuel.16 10 Although the Settlement Agreement provides that APS will increase its demand side 11 management and renewables, and we agree that those resources are increasingly important, they will", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 46, "title": "Settlement: Agreement", "summary": "-risk almost seems like a “free pass,” 15 especially when a revenue increase is added. Although the Settlement Agreement provides that all 16 costs will be subject to review for prudency before they can be recovered, prudency reviews, 17 especially transactions in the w", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 47, "title": "Settlement: Agreement", "summary": "on. Should the Company seek to recover or refund a 12 bank balance pursuant to Paragraph 19E of the Settlement Agreement, the timing and manner of 13 recovery or refund of that existing bank balance will be addressed at such time. In no event shall the 14 Company allow", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 48, "title": "Settlement: Agreement", "summary": "to reset base rates if it deems it necessary because that cap is reached. Further, although the 25 Settlement Agreement provides that the PSA will be in effect for 5 years, if APS files a rate case 26 18 For example, under “Average Usage Scenario One”, the line reads “", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 49, "title": "Settlement: Agreement", "summary": "ven our concerns and the modifications we require to the PSA, we will require 13 the parties to the Settlement Agreement to submit a PSA Plan of Administration that reflects the 14 determinations in this Decision, for our approval. 15 f. Depreciation 16 The Settlement A", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 50, "title": "Settlement: Agreement", "summary": "n that reflects the 14 determinations in this Decision, for our approval. 15 f. Depreciation 16 The Settlement Agreement adopts Staff’s recommended service lives, and Appendix A to the 17 Settlement Agreement sets forth the remaining service lives, net salvage allowance", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 51, "title": "Settlement: Agreement", "summary": "tion 16 The Settlement Agreement adopts Staff’s recommended service lives, and Appendix A to the 17 Settlement Agreement sets forth the remaining service lives, net salvage allowance, annual 18 depreciation rates, and reserve allocation for each category of APS deprecia", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 52, "title": "Settlement: Agreement", "summary": "ds (”SFAS”) 143 20 will not be adopted for ratemaking purposes. 21 g. $234 Million Write-Off 22 The Settlement Agreement provides that APS will not recover the $234 million write-off 23 attributable to Decision No. 61973 in this case, nor shall APS seek to recover the w", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 53, "title": "Settlement: Agreement", "summary": "energy 2 consumption (kWh) in a cost-effective manner.”21 3 DSM is addressed in three areas of the Settlement Agreement: in the funding, programs, 4 plans and reporting provisions; in the study of rate design modifications; and in the competitive 5 procurement process.", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 54, "title": "Settlement: Agreement", "summary": "istance.25 APS is obligated to spend $13 million in 10 2005 on DSM projects.26 11 Appendix B to the Settlement Agreement is a preliminary plan (“Preliminary Plan”) for 12 eligible DSM-related items for 2005. The Preliminary Plan includes $6.9 million for commercial, 13", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 55, "title": "Settlement: Agreement", "summary": "t reduce the use of 26 electricity by means of energy-efficiency products, services, or practices.” Settlement Agreement par. 40. 24 Id. par. 45. 27 25 Id. par. 42. 26 Tr. p. 969. 28 27 APS’ share of DSM net economic benefits, capped at 10 percent of total DSM expenditu", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 56, "title": "Settlement: Agreement", "summary": "kW charge. The DSM adjustor will 3 apply to both standard offer and direct access customers. 4 The Settlement Agreement does not provide for the recovery of net lost revenues. The 5 Settlement Agreement provides that if during 2005 through 2007, APS does not spend at l", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 57, "title": "Settlement: Agreement", "summary": "customers. 4 The Settlement Agreement does not provide for the recovery of net lost revenues. The 5 Settlement Agreement provides that if during 2005 through 2007, APS does not spend at least $30 6 million of the base rate allowance for approved and eligible DSM-related", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 58, "title": "Settlement: Agreement", "summary": "Decision, APS must file a Plan of Administration for Staff review and approval. 11 Pursuant to the Settlement Agreement, APS is required to “implement and maintain a 12 collaborative DSM working group to solicit and facilitate stakeholder input, advise APS on program 1", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 59, "title": "Settlement: Agreement", "summary": "iled at the Commission by APS must be certified by an Officer 24 of the Company. 25 Pursuant to the Settlement Agreement, APS is to invite DSM resources to participate in its 26 RFP and other competitive solicitations, and must evaluate them in a consistent and comparab", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 60, "title": "Settlement: Agreement", "summary": "FP and other competitive solicitations, and must evaluate them in a consistent and comparable 27 28 Settlement Agreement par. 50. 28 29 Id. par. 54. 21 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 manner. 2 SWEEP supports the DSM provisions in the Settlement", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 61, "title": "Settlement: Agreement", "summary": "NO. _____________ DOCKET NO. E-01345A-03-0437 1 manner. 2 SWEEP supports the DSM provisions in the Settlement Agreement. Although it originally 3 recommended that the Commission should substantially increase energy efficiency by setting target 4 goals of 7 percent of t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 62, "title": "Settlement: Agreement", "summary": "ded to meet retail load in 2010 from energy efficiency 5 and 17 percent in 2020, it agreed that the Settlement Agreement’s requirement of DSM funding is 6 reasonable and justified given the cost-effective benefits that will be achieved. SWEEP believes that 7 the level o", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 63, "title": "Settlement: Agreement", "summary": "he cost-effective benefits that will be achieved. SWEEP believes that 7 the level of funding in the Settlement Agreement is a valuable and meaningful step towards 8 encouraging and supporting energy efficiency for APS customers, especially since the Commission 9 can app", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 64, "title": "Settlement: Agreement", "summary": "the environmental and health standpoint.31 The 15 Preliminary DSM Plan attached as Exhibit B to the Settlement Agreement is a good start towards 16 developing cost-effective DSM programs. However, we are concerned that our approval of the 17 Settlement Agreement and Exh", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 65, "title": "Settlement: Agreement", "summary": "ds 16 developing cost-effective DSM programs. However, we are concerned that our approval of the 17 Settlement Agreement and Exhibit B may result in stakeholders focusing too narrowly when 18 attempting to comply with the DSM goals of this Order. Particularly, we note t", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 66, "title": "Settlement: Agreement", "summary": "f such DSM 10 programs. 11 i. Environmental Portfolio Standard and other Renewables Programs 12 The Settlement Agreement addresses renewable energy in three areas: a special renewable 13 energy solicitation; the environmental portfolio standard (“EPS”) and in the compet", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 67, "title": "Settlement: Agreement", "summary": "the environmental portfolio standard (“EPS”) and in the competitive procurement 14 of power. 15 The Settlement Agreement requires APS to issue a special RFP in 2005 seeking at least 100 16 MW and at least 250,000 MWh per year of renewable energy resources including sola", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 68, "title": "Settlement: Agreement", "summary": "ial demand programs in this matter. 23 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 The Settlement Agreement also provides that renewable resources acquired through the 2 special RFP or future solicitations shall be subject to the Commission’s customary prud", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 69, "title": "Settlement: Agreement", "summary": "uture solicitations shall be subject to the Commission’s customary prudence review. 3 And while the Settlement Agreement further stipulates that a renewable resource purchase shall not 4 be found imprudent solely because the cost of the renewable resource exceeds market", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 70, "title": "Settlement: Agreement", "summary": "justment mechanism, which will allow for 10 Commission-approved changes to APS’ EPS funding. 11 The Settlement Agreement does not alter the existing EPS or the current level of funding, but 12 it changes the EPS surcharge into an adjustor so that the Commission has the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 71, "title": "Settlement: Agreement", "summary": "nd rates in the future. APS’ current rates and surcharge total $12.5 million and 14 pursuant to the Settlement Agreement, $6 million of this amount will be recovered in base rates and 15 $6.5 million in the EPS adjustor. 16 Under the Settlement Agreement, APS will allow", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 72, "title": "Settlement: Agreement", "summary": "f this amount will be recovered in base rates and 15 $6.5 million in the EPS adjustor. 16 Under the Settlement Agreement, APS will allow and encourage all renewable resources to 17 participate in its competitive power procurement. 18 In response to a request from Commis", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 73, "title": "Settlement: Agreement", "summary": "NO. E-01345A-03-0437 1 resources and renewable energy.” 2 j. Competitive Procurement of Power 3 The Settlement Agreement provides that APS will issue an RFP or other competitive 4 solicitation(s) in 2005 seeking long-term resources of not less than 1000 MW for 2007 and", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 74, "title": "Settlement: Agreement", "summary": "e date prior to January 1, 2015, unless expressly authorized by the 9 Commission. As defined in the Settlement Agreement, “self-build” does not include the acquisition 10 of a generating unit or interest in one from a non-affiliated merchant or utility generator, the 11", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 75, "title": "Settlement: Agreement", "summary": "a generating unit from any 19 merchant or utility generator. Consistent with the definition in the Settlement Agreement, “self- 20 build” will not include the acquisition of temporary generation needed for system reliability, 21 distributed generation of less than fift", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 76, "title": "Settlement: Agreement", "summary": "be accorded to 27 35 Competitive solicitation includes a RFP issued pursuant to Paragraph 78 of the Settlement Agreement or any solicitation issued by APS in using its Secondary Procurement Protocol pursuant to Paragraph 80 of the Settlement 28 Agreement. 25 DECISION NO", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 77, "title": "Settlement: Agreement", "summary": "red by APS. APS will 2 continue to use its Secondary Procurement Protocol except as modified by the Settlement Agreement 3 or by Commission decision. The Commission’s Staff will schedule workshops on resource planning, 4 focusing on developing needed infrastructure and", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 78, "title": "Settlement: Agreement", "summary": "buffer zone property 24 around many of the existing coal plants. 25 k. Regulatory Issues 26 In the Settlement Agreement, the parties acknowledge that APS has the obligation to plan for 27 and serve all customers in its certificated service area and to recognize through", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 79, "title": "Settlement: Agreement", "summary": "ncrease funding for marketing its E-3 and E-4 tariffs to a total of $150,000 as set 14 forth in the Settlement Agreement. The parties’ intent is to insulate eligible low income customers 15 from the effects of the rate increase resulting from the Settlement Agreement. O", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 80, "title": "Settlement: Agreement", "summary": "insulate eligible low income customers 15 from the effects of the rate increase resulting from the Settlement Agreement. On December 17, 16 2004, the ACAA filed a response to Commissioner Mayes’ question about automatic enrollment in 17 utility discount programs, indic", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 81, "title": "Settlement: Agreement", "summary": "ities within APS’ 7 service territory. 8 n. Returning Customer Direct Access Charge (“RCDAC”) 9 The Settlement Agreement provides that APS can recover from Direct Access customers the 10 additional cost that would otherwise be imposed on other Standard Offer customers i", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 82, "title": "Settlement: Agreement", "summary": "of Administration as part of its tariff 15 compliance filing. 16 o. Service Schedule Changes 17 The Settlement Agreement adopts several of APS’ proposed changes to service schedules, 18 including Schedule 3, but with the retention of the 1,000 foot construction allowanc", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 83, "title": "Settlement: Agreement", "summary": "24 The decommissioning costs as recommended by APS are adopted as set forth in Appendix I to 25 the Settlement Agreement. 26 q. Transmission Cost Adjustor (“TCA”) 27 The Settlement Agreement establishes a transmission cost adjustor (“TCA”) to ensure that 28 any potentia", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 84, "title": "Settlement: Agreement", "summary": "forth in Appendix I to 25 the Settlement Agreement. 26 q. Transmission Cost Adjustor (“TCA”) 27 The Settlement Agreement establishes a transmission cost adjustor (“TCA”) to ensure that 28 any potential direct access customers pay the same for transmission as Standard Of", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 85, "title": "Settlement: Agreement", "summary": "e on natural gas (demand and cost); leverage of resources; and 11 sustainable installations. 12 The Settlement Agreement provides that Staff shall schedule workshops to consider 13 outstanding issues affecting distributed generation and shall refer to the results of the", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 86, "title": "Settlement: Agreement", "summary": "rocess to bring contested issues to the 18 Commission for resolution. None of the proponents of the Settlement Agreement oppose 19 Commission adoption of these objectives. 20 In its post-hearing brief, ACA/DEAA listed the following guidelines as “overriding criteria”: 2", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 87, "title": "Settlement: Agreement", "summary": "opt an experimental rate for partial requirement customers. The proposal 27 36 Paragraph 106 of the Settlement Agreement contains a typo; the amount “$0.000476” should actually be “$0.00476,” 28 Tr. p. 1168. 29 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 wo", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 88, "title": "Settlement: Agreement", "summary": "should also be discussed and developed during the course of the workshop. 12 The proponents of the Settlement Agreement recommend that specific issues concerning DG 13 should be addressed in workshops devoted to distributed generation. Paragraphs 108 and 109 direct 14", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 89, "title": "Settlement: Agreement", "summary": "eive service under Schedule E-32, and according to the proponents, it is an integral part 22 of the Settlement Agreement. The proponents believe that ACA/DEAA’s proposal to put the rate 23 increase in the energy portion would create a massive subsidy from higher load fa", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 90, "title": "Settlement: Agreement", "summary": "ts, and will 15 determine the appropriate amortization period. 16 t. Rate Design 17 Attached to the Settlement Agreement is Appendix J, which sets forth the rates adopted in the 18 Settlement Agreement. The rates are designed to permit APS to recover an additional $67.5", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 91, "title": "Settlement: Agreement", "summary": "17 Attached to the Settlement Agreement is Appendix J, which sets forth the rates adopted in the 18 Settlement Agreement. The rates are designed to permit APS to recover an additional $67.5 million 19 in base revenues, including an additional 3.94 percent for the reside", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 92, "title": "Settlement: Agreement", "summary": "explore the possibility of offering a discount to those customer who participate in 3 Surepay. The Settlement Agreement adopts APS’ proposed experimental time-of-use periods for ET- 4 1 and ECT-1R. For general service customers, the existing on-peak time periods will r", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 93, "title": "Settlement: Agreement", "summary": "Testimony was offered at the hearing that there was an inadvertent 14 omission in Appendix J to the Settlement Agreement for Rate E-32-TOU in that the delivery-related 15 demand charge for Rate E-32-TOU should have been reduced after the first 100 kW of demand for 16 re", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 94, "title": "Settlement: Agreement", "summary": "on from Commissioner Mundell regarding 3 the break-over points for tiered rates, the parties to the Settlement Agreement indicated that rate E-12 4 has the most customers. The response also stated that the average use by a customer on rate E-12 is 5 770 kWh per month. R", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 95, "title": "Settlement: Agreement", "summary": "hree tiers with break-over points at 400 kWh per month and 800 6 kWh per month. Paragraph 57 of the Settlement Agreement requires APS to conduct a rate design 7 study analyzing rate design modifications to promote energy efficiency, conservation, and reduce 8 peak deman", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 96, "title": "Settlement: Agreement", "summary": "docket and at the time that APS files its next rate case. 22 u. Litigation and other issues 23 The Settlement Agreement provides that APS will dismiss with prejudice all appeals of 24 Decision No. 65154, the Track A Order, and APS and its affiliates will dismiss litiga", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 97, "title": "Settlement: Agreement", "summary": "ered in Decision No. 65796 shall be 28 concluded with no further action by the Commission, once the Settlement Agreement is approved in 33 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 accordance with Section XXI of the Settlement Agreement by a Commission De", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 98, "title": "Settlement: Agreement", "summary": "d in 33 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 accordance with Section XXI of the Settlement Agreement by a Commission Decision that is final 2 and no longer subject to judicial review. 3 The Commission is also concerned that service reliability on rur", "is_other_matter": false, "recommendations": [], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 99, "title": "Settlement: Agreement", "summary": "participate 7 in any future dockets related to enhancing reliability statewide. 8 v. Summary 9 This Settlement Agreement resolves numerous significant, complex, and conflicting issues 10 affecting many parties with very different perspectives and interests. As with ever", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 100, "title": "Settlement: Agreement", "summary": "ogether as a whole, and in such a way that will 14 promote the public interest. We believe that the Settlement Agreement reached by these 22 parties, 15 with the modifications that we make herein, reaches such a result. Our agreement to rate base the 16 PWEC assets does", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 101, "title": "Settlement: Agreement", "summary": "expect APS and its affiliates to fully comply with all the pro- 18 competition requirements in the Settlement Agreement and other Commission decisions and rules. 19 Additionally, our adoption of a PSA will be a significant change for APS customers, and we expect 20 APS", "is_other_matter": false, "recommendations": [], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 102, "title": "Settlement: Agreement", "summary": "14. At the August 18, 2004 Procedural Conference, the parties announced that they had 10 reached a settlement, and the Settlement Agreement was docketed on that date. 11 15. On August 20, 2004, an Amended Rate Case Procedural Order was issued setting the 12 hearing on the Settlement Agree", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 103, "title": "Settlement: Agreement", "summary": "On August 20, 2004, an Amended Rate Case Procedural Order was issued setting the 12 hearing on the Settlement Agreement to commence on November 8, 2004. 13 16. The hearing was held as scheduled on November 8, 9, 10, 29, 30 and December 1, 2, 14 and 3, 2004. Public comm", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 104, "title": "Settlement: Agreement", "summary": "ly .44 percent, which will collect $7.9 million. 23 20. A Power Supply Adjustor as set forth in the Settlement Agreement and as modified 24 herein, is in the public interest. 25 21. APS is authorized to acquire the PWEC generation assets and rate base those assets at 26", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 105, "title": "Settlement: Agreement", "summary": "alue of $700 million as of December 31, 2004, under the terms and conditions as set forth in the 27 Settlement Agreement and herein. 28 22. The Settlement Agreement will allow APS the opportunity to earn a reasonable rate of 36 DECISION NO. _____________ DOCKET NO. E-01", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 106, "title": "Settlement: Agreement", "summary": ", under the terms and conditions as set forth in the 27 Settlement Agreement and herein. 28 22. The Settlement Agreement will allow APS the opportunity to earn a reasonable rate of 36 DECISION NO. _____________ DOCKET NO. E-01345A-03-0437 1 return on its investment, wil", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 107, "title": "Settlement: Agreement", "summary": "n on its website 9 within 30 days of the effective date of this Decision. 10 24. The parties to the Settlement Agreement shall submit a PSA Plan of Administration 11 that reflects the determinations in this Decision for Commission approval within 60 days of the 12 effec", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 108, "title": "Settlement: Agreement", "summary": "ion. 13 25. The depreciation rates and the costs for nuclear decommissioning as set forth in the 14 Settlement Agreement are reasonable and appropriate. 15 26. Testimony was offered at the hearing that there was an inadvertent omission in 16 Appendix J to the Settlement", "is_other_matter": false, "recommendations": [], "themes": [ "Depreciation" ], "cost_to_customers": true }, { "index": 109, "title": "Settlement: Agreement", "summary": "Testimony was offered at the hearing that there was an inadvertent omission in 16 Appendix J to the Settlement Agreement for Rate E-32-TOU in that the delivery-related demand 17 charge for Rate E-032-TOU should have been reduced after the first 100 kW of demand for resi", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 110, "title": "Settlement: Agreement", "summary": "on from Commissioner Mundell 4 regarding the break-over points for tiered rates, the parties to the Settlement Agreement indicated that 5 rate E-12 has the most customers. The response also stated that the average use by a customer on rate 6 E-12 is 770 kWh per month. R", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 111, "title": "Settlement: Agreement", "summary": "hree tiers with break-over points at 400 kWh per month 7 and 800 kWh per month. Paragraph 57 of the Settlement Agreement requires APS to conduct a rate 8 design study analyzing rate design modifications to promote energy efficiency, conservation, and 9 reduce peak deman", "is_other_matter": false, "recommendations": [], "themes": [ "Cost of service & rates" ], "cost_to_customers": true }, { "index": 112, "title": "Settlement: Agreement", "summary": "future which may require sizeable investments to improve emissions 8 control performance. 9 35. The Settlement Agreement also provides that renewable resources acquired through 10 the special RFP or future solicitations shall be subject to the Commission’s customary pru", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 113, "title": "Settlement: Agreement", "summary": "ture solicitations shall be subject to the Commission’s customary prudence 11 review. And while the Settlement Agreement further stipulates that a renewable resource purchase 12 shall not be found imprudent solely because the cost of the renewable resource exceeds marke", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 114, "title": "Settlement: Agreement", "summary": "that it cannot meet the goal for 18 renewable energy resources as set forth in Paragraph 69 of the Settlement Agreement, through in- 19 state resources, it shall bring its proposal to purchase out-of-state resources to Staff and obtain 20 Commission approval before mak", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 115, "title": "Settlement: Agreement", "summary": "ion. Should the Company seek to recover or refund a 5 bank balance pursuant to Paragraph 19E of the Settlement Agreement, the timing and manner of 6 recovery or refund of that existing bank balance will be addressed at such time. In no event shall the 7 Company allow th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 116, "title": "Settlement: Agreement", "summary": "f the application. 3 3. Notice of the application was provided in accordance with the law. 4 4. The Settlement Agreement, with the modifications and additional provisions contained 5 herein, resolves all matters raised by APS’ rate application in a manner that is just a", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 117, "title": "Settlement: Agreement", "summary": "re just and 10 reasonable. 11 7. APS should be directed to file revised tariffs consistent with the Settlement Agreement 12 and the findings contained in this Order. 13 VI. ORDER 14 IT IS THEREFORE ORDERED that the Settlement Agreement attached hereto as 15 Attachment A", "is_other_matter": false, "recommendations": [], "themes": [ "Tariff administration & oversight" ], "cost_to_customers": false }, { "index": 118, "title": "Settlement: Agreement", "summary": "ement 12 and the findings contained in this Order. 13 VI. ORDER 14 IT IS THEREFORE ORDERED that the Settlement Agreement attached hereto as 15 Attachment A as modified herein is approved. 16 IT IS FURTHER ORDERED that Arizona Public Service Company is hereby directed to", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 119, "title": "Settlement: Agreement", "summary": "THER ORDERED that Arizona Public Service Company shall implement and 9 comply with the terms of the Settlement Agreement including filing all reports, studies, and plans as 10 set forth in the Settlement Agreement and as modified herein. 11 IT IS FURTHER ORDERED that th", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 120, "title": "Settlement: Agreement", "summary": "of the Settlement Agreement including filing all reports, studies, and plans as 10 set forth in the Settlement Agreement and as modified herein. 11 IT IS FURTHER ORDERED that the parties to the Settlement Agreement shall submit a PSA 12 Plan of Administration that refle", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 121, "title": "Settlement: Agreement", "summary": "n the Settlement Agreement and as modified herein. 11 IT IS FURTHER ORDERED that the parties to the Settlement Agreement shall submit a PSA 12 Plan of Administration that reflects the determinations in this Decision for Commission approval 13 within 60 days of the effec", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates", "Creditworthiness", "Depreciation", "Fuel & purchased-power cost recovery", "Service reliability & vegetation management", "Tariff administration & oversight" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "AK", "source": "Regulatory Commission", "doc_type": null, "id": "ak_0000_006_report-fraud", "company": "Report Fraud", "company_raw": "Report Fraud", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.state.ak.us/rca", "pdf_download_url": "https://doa.alaska.gov/drm/oru/", "captured_at": "2026-06-14", "source_note": "Regulatory Commission (AK)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AK", "source": "Regulatory Commission", "doc_type": null, "id": "ak_0000_005_report-a-fish-wildlife-violation", "company": "Report a fish/wildlife violation?", "company_raw": "Report a fish/wildlife violation?", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.state.ak.us/rca", "pdf_download_url": "https://dps.alaska.gov/AWT/safeguard.aspx", "captured_at": "2026-06-14", "source_note": "Regulatory Commission (AK)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AK", "source": "Regulatory Commission", "doc_type": null, "id": "ak_0000_004_report-child-abuse", "company": "Report Child Abuse", "company_raw": "Report Child Abuse", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.state.ak.us/rca", "pdf_download_url": "https://dfcs.alaska.gov/ocs/Pages/Report-Child-Abuse.aspx", "captured_at": "2026-06-14", "source_note": "Regulatory Commission (AK)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AK", "source": "Regulatory Commission", "doc_type": null, "id": "ak_0000_003_report-a-cruise-ship-concern", "company": "Report a Cruise Ship Concern", "company_raw": "Report a Cruise Ship Concern", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.state.ak.us/rca", "pdf_download_url": "https://www.dec.alaska.gov/water/cruise-ships", "captured_at": "2026-06-14", "source_note": "Regulatory Commission (AK)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AK", "source": "Regulatory Commission", "doc_type": null, "id": "ak_0000_002_report-a-spill", "company": "Report a Spill", "company_raw": "Report a Spill", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.state.ak.us/rca", "pdf_download_url": "https://www.dec.alaska.gov/spar/ppr/spill-information/reporting", "captured_at": "2026-06-14", "source_note": "Regulatory Commission (AK)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AK", "source": "Regulatory Commission", "doc_type": null, "id": "ak_0000_001_report-an-environmental-crime", "company": "Report an Environmental Crime", "company_raw": "Report an Environmental Crime", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.state.ak.us/rca", "pdf_download_url": "https://dec.alaska.gov/das/ecu/", "captured_at": "2026-06-14", "source_note": "Regulatory Commission (AK)", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": null, "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NV", "source": "Public Utilities Commission of Nevada", "doc_type": "rate case notice", "id": "2025_nevada-power_nv-25-02016-grc-notice", "company": "Nevada Power Company d/b/a NV Energy", "company_raw": "Nevada Power Company d/b/a NV Energy", "docket": "25-02016", "docket_full": null, "issued_date": null, "source_page_url": "https://pucweb1.state.nv.us/PUC2/Dktinfo.aspx?Util=Electric", "pdf_download_url": "https://pucweb1.state.nv.us/pdf/CS27269.pdf", "captured_at": "2026-06-07", "source_note": "Public Utilities Commission of Nevada filing in Docket No. 25-02016 — Application of Nevada Power Company d/b/a NV Energy for authority to adjust its annual revenue requirement for general rates charged to all classes of electric customers (NV Energy 2025 general rate case) (3 pp). Listed for reference (metadata-only). Source: PUCN document store (pucweb1.state.nv.us/pdf/CS27269.pdf).", "archived_via": null, "page_count": 3, "scanned_pages": [ 3 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "AR", "source": "Arkansas Public Service Commission", "doc_type": "direct testimony", "id": "2025_entergy-arkansas_ar-16-036-fr-evaluation-report-testimony", "company": "Entergy Arkansas, LLC", "company_raw": "Entergy Arkansas, LLC", "docket": "16-036-FR", "docket_full": null, "issued_date": null, "source_page_url": "https://apps.apsc.arkansas.gov/olsv2/Docket_Search_Documents.asp?Docket=16-036-FR&DocNumVal=1107", "pdf_download_url": "https://apps.apsc.arkansas.gov/pdf/16/16-036-FR_1107_1.pdf", "captured_at": "2026-06-02", "source_note": "Supporting Testimony of Middleton Ray on the 2025 Evaluation Report in the Formula Rate Plan filings of Entergy Arkansas, LLC, before the Arkansas Public Service Commission, Docket No. 16-036-FR (filed in the 2025 Rider FRP review; 14 pp). Listed for reference (metadata-only). Source: APSC Online Services, document 16-036-FR_1107 (apps.apsc.arkansas.gov/pdf/16/16-036-FR_1107_1.pdf).", "archived_via": null, "page_count": 14, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Approval: $1,671,378.\n", "summary": "filing 3 to $97,325,308 in Staff’s Attachment A.2. This has the effect of increasing the 4 maximum allowed increase in revenues (A.2 L6) by $1,671,378. 5 MODIFIED BALANCE SHEET APPROACH 6 Q. What is the methodology used to determine Working Capital Assets 7 (“WCA”) and Current, Accrued, and Other Li", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MO", "source": "Missouri Public Service Commission", "doc_type": "direct testimony", "id": "2025_empire-district-electric-liberty_mo-er-2024-0261-staff-lange", "company": "The Empire District Electric Company d/b/a Liberty", "company_raw": "The Empire District Electric Company d/b/a Liberty", "docket": "ER-2024-0261", "docket_full": null, "issued_date": null, "source_page_url": "https://efis.psc.mo.gov/Case/Display/85589", "pdf_download_url": "https://efis.psc.mo.gov/Document/Display/840218", "captured_at": "2026-06-02", "source_note": "Direct Testimony of Sarah L.K. Lange on behalf of the Missouri Public Service Commission Staff in the electric rate case of The Empire District Electric Company d/b/a Liberty, Case No. ER-2024-0261 (issues: Limited Large Customer Service Recommendation, Class Cost of Service, Rate Design; 97 pp). Listed for reference (metadata-only). Source: Missouri PSC EFIS, document 840218 (efis.psc.mo.gov/Document/Display/840218; docket sheet: efis.psc.mo.gov/Case/Display/85589).", "archived_via": null, "page_count": 97, "scanned_pages": [ 81, 96 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Cost of service & rates", "Customer service & billing" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "MO", "source": "Missouri Public Service Commission", "doc_type": "direct testimony", "id": "2025_empire-district-electric-liberty_mo-er-2024-0261-staff-giacone", "company": "The Empire District Electric Company d/b/a Liberty", "company_raw": "The Empire District Electric Company d/b/a Liberty", "docket": "ER-2024-0261", "docket_full": null, "issued_date": null, "source_page_url": "https://efis.psc.mo.gov/Case/Display/85589", "pdf_download_url": "https://efis.psc.mo.gov/Document/Display/838475", "captured_at": "2026-06-02", "source_note": "Direct Testimony of Jared Giacone on behalf of the Missouri Public Service Commission Staff in the electric rate case of The Empire District Electric Company d/b/a Liberty, Case No. ER-2024-0261 (issues: PISA, property tax, Riverton 12 O&M tracker, severance, solar rebates, VOLL study costs, wind farm construction, wind O&M and non-FAC wind project expense, PAYGO tracker; 52 pp). Listed for reference (metadata-only). Source: Missouri PSC EFIS, document 838475 (efis.psc.mo.gov/Document/Display/838475; docket sheet: efis.psc.mo.gov/Case/Display/85589).", "archived_via": null, "page_count": 52, "scanned_pages": [ 20, 31 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NY", "source": "New York State Department of Public Service", "doc_type": "rate case summary", "id": "2025-07_nyseg_ny-25-e-0375-rate-case-summary", "company": "New York State Electric & Gas Corporation", "company_raw": "New York State Electric & Gas Corporation", "docket": "25-E-0375", "docket_full": null, "issued_date": null, "source_page_url": "https://dps.ny.gov/pending-and-recent-electric-rate-cases", "pdf_download_url": "https://dps.ny.gov/system/files/documents/2025/07/nyseg-electric-rate-case-25-e-0375.pdf", "captured_at": "2026-06-07", "source_note": "New York DPS electric rate-case summary for New York State Electric & Gas Corporation (NYSEG), Case 25-E-0375 — published under Public Service Law §66(12)(l). NYSEG's June 30, 2025 filing requested an increase in annual electric revenues of ~$464.4M (35.0% to delivery revenues) for the rate year ending April 30, 2027. Listed for reference (metadata-only). Source: NY DPS (dps.ny.gov/system/files/documents/2025/07/nyseg-electric-rate-case-25-e-0375.pdf).", "archived_via": null, "page_count": 1, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Approval: $189.7 ", "summary": "te Drivers Inc/(Dec) Delivery Rev Total Rev Primary Drivers ($ M) Change (%) Change (%) Major Storm Allowance $189.7 14.5% 7.6% Capital Investments $189.0 14.5% 7.6% Labor & Benefits $55.6 4.3% 2.2% Net Operating Loss Deferred Tax Asset $34.5 2.6% 1.4% Vegetation Man", "is_other_matter": false, "recommendations": [], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false } ], "structured": false, "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "NY", "source": "New York State Department of Public Service", "doc_type": "rate case summary", "id": "2025-02_consolidated-edison_ny-25-e-0072-rate-case-summary", "company": "Consolidated Edison Company of New York, Inc.", "company_raw": "Consolidated Edison Company of New York, Inc.", "docket": "25-E-0072", "docket_full": null, "issued_date": null, "source_page_url": "https://dps.ny.gov/pending-and-recent-electric-rate-cases", "pdf_download_url": "https://dps.ny.gov/system/files/documents/2025/02/con-ed-electric-rate-case-25-e-0072-february-2025_1.pdf", "captured_at": "2026-06-07", "source_note": "New York DPS electric rate-case summary for Consolidated Edison Company of New York, Inc., Case 25-E-0072 (February 2025) — published under Public Service Law §66(12)(l). Con Edison requested an increase in annual electric delivery revenues of ~$1,612M (18.0%); the PSC ultimately adopted a Joint Proposal (Jan 22, 2026) cutting this by ~87%. Listed for reference (metadata-only). Source: NY DPS (dps.ny.gov/system/files/documents/2025/02/con-ed-electric-rate-case-25-e-0072-february-2025_1.pdf).", "archived_via": null, "page_count": 1, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "ND", "source": "North Dakota Public Service Commission", "doc_type": "direct testimony", "id": "2024_northern-states-power_nd-pu-24-376-direct-testimony", "company": "Northern States Power Company d/b/a Xcel Energy", "company_raw": "Northern States Power Company d/b/a Xcel Energy", "docket": "PU-24-376", "docket_full": null, "issued_date": null, "source_page_url": "https://www.psc.nd.gov/public/cases/", "pdf_download_url": "https://www.psc.nd.gov/webdocs/case/24-0376/086-010.pdf", "captured_at": "2026-06-07", "source_note": "Direct Testimony and Schedules of Nicholas N. Paluck (Exhibit 13) before the North Dakota Public Service Commission in the Application of Northern States Power Company (Xcel Energy) electric rate proceeding, Case No. PU-24-376 (initiated December 2024) (65 pp). Listed for reference (metadata-only). Source: ND PSC public case records, document 086-010 (psc.nd.gov/webdocs/case/24-0376/086-010.pdf).", "archived_via": null, "page_count": 65, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "GA", "source": "Georgia Public Service Commission", "doc_type": "Vogtle construction-monitoring report (semi-annual cost/schedule prudence monitoring)", "id": "2024-02_georgia-power_ga-29849-vogtle-30th-vcm-report", "company": "Georgia Power Company", "company_raw": "Georgia Power Company", "docket": "29849", "docket_full": null, "issued_date": null, "source_page_url": "https://psc.ga.gov/search/facts-docket/?docketId=29849", "pdf_download_url": "https://services.psc.ga.gov/api/v1/External/Public/Get/Document/DownloadFile/217538/98678", "captured_at": "2026-06-08", "source_note": "Georgia PSC Thirtieth Semi-annual Vogtle Construction Monitoring Report (Georgia Power, Vogtle Units 3 & 4), Docket 29849; cover 'February 2024' (month-only -> issued_date null). PDF: services.psc.ga.gov/.../DownloadFile/217538/98678.", "archived_via": null, "page_count": 17, "scanned_pages": [ 1, 16 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AR", "source": "Arkansas Public Service Commission (APSC)", "doc_type": "management and operations audit", "id": "2023-otter-tail-power_ar-audit", "company": "Otter Tail Power Company", "company_raw": "Otter Tail Power Company", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.apsc.arkansas.gov/filings/", "pdf_download_url": "https://www.apsc.arkansas.gov/filings/?company=otter-tail-power", "captured_at": "2026-06-16", "source_note": "Otter documents from APSC. Requires manual docket/order lookup.", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "AR", "source": "Arkansas Public Service Commission (APSC)", "doc_type": "rate case order with audit findings", "id": "2023-entergy-arkansas_ar-rate-case", "company": "Entergy Arkansas, Inc.", "company_raw": "Entergy Arkansas, Inc.", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.apsc.arkansas.gov/filings/", "pdf_download_url": "https://www.apsc.arkansas.gov/filings/?company=entergy-arkansas", "captured_at": "2026-06-16", "source_note": "Entergy documents from APSC. Requires manual docket/order lookup.", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "AR", "source": "Arkansas Public Service Commission (APSC)", "doc_type": "management and operations audit", "id": "2023-empire-district-ar_ar-audit", "company": "The Empire District Electric Company", "company_raw": "The Empire District Electric Company", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.apsc.arkansas.gov/filings/", "pdf_download_url": "https://www.apsc.arkansas.gov/filings/?company=empire-district", "captured_at": "2026-06-16", "source_note": "The documents from APSC. Requires manual docket/order lookup.", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "GA", "source": "Georgia Public Service Commission", "doc_type": "Vogtle construction-monitoring report (semi-annual cost/schedule prudence monitoring)", "id": "2023-02_georgia-power_ga-29849-vogtle-28th-vcm-report", "company": "Georgia Power Company", "company_raw": "Georgia Power Company", "docket": "29849", "docket_full": null, "issued_date": null, "source_page_url": "https://psc.ga.gov/search/facts-docket/?docketId=29849", "pdf_download_url": "https://services.psc.ga.gov/api/v1/External/Public/Get/Document/DownloadFile/193355/74970", "captured_at": "2026-06-08", "source_note": "Georgia PSC Twenty-eighth Semi-annual Vogtle Construction Monitoring Report (Georgia Power, Vogtle Units 3 & 4), Docket 29849; cover 'February 2023' (month-only -> issued_date null). PDF: services.psc.ga.gov/.../DownloadFile/193355/74970.", "archived_via": null, "page_count": 32, "scanned_pages": [ 1, 31 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "TN", "source": "Tennessee Public Utility Commission", "doc_type": "general rate case filing", "id": "2022_kingsport-power-aep_tn-21-00107-general-rate-case", "company": "Kingsport Power Company d/b/a AEP Appalachian Power", "company_raw": "Kingsport Power Company d/b/a AEP Appalachian Power", "docket": "21-00107", "docket_full": null, "issued_date": null, "source_page_url": "https://www.tn.gov/tpuc.html", "pdf_download_url": "https://tpucdockets.tn.gov/archive/filings/2021/2100107bd.pdf", "captured_at": "2026-06-07", "source_note": "Petition of Kingsport Power Company d/b/a AEP Appalachian Power for a general rate case before the Tennessee Public Utility Commission, Docket No. 21-00107 (74 pp). Listed for reference (metadata-only). Source: TPUC dockets archive (tpucdockets.tn.gov/archive/filings/2021/2100107bd.pdf).", "archived_via": null, "page_count": 74, "scanned_pages": [ 44, 45, 59 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 1, "findings": [ { "index": 1, "title": "Settlement: Agreement", "summary": "ility property and are 17 summarized below on Table 10. 18 19 20 35 Order Approving Stipulation and Settlement Agreement, Exhibit A – Stipulation & Settlement Agreement, Attachment A, Schedule 13, TPUC Docket No. 16-00001 (October 19, 2016). 36 Consumer Advocate Revenue", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "GA", "source": "Georgia Public Service Commission", "doc_type": "PSC Staff & Independent Construction Monitor prudence testimony (Vogtle 22nd VCM report)", "id": "2022_georgia-power_ga-29849-vogtle-22nd-staff-icm-testimony", "company": "Georgia Power Company", "company_raw": "Georgia Power Company", "docket": "29849", "docket_full": null, "issued_date": null, "source_page_url": "https://psc.ga.gov/search/facts-docket/?docketId=29849", "pdf_download_url": "https://services.psc.ga.gov/api/v1/External/Public/Get/Document/DownloadFile/181460/63470", "captured_at": "2026-06-08", "source_note": "Georgia PSC direct testimony of Staff/Independent Construction Monitor (Steven D. Roetger; William R. Jacobs, Jr., PhD) on Georgia Power’s Twenty-second Semi-annual Vogtle Construction Monitoring Report, Docket 29849 (Vogtle construction prudence). Page 1 carries no date -> issued_date null. PDF: services.psc.ga.gov/.../DownloadFile/181460/63470.", "archived_via": null, "page_count": 52, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NJ", "source": "NJ Board of Public Utilities", "doc_type": "affiliate-transactions audit & management audit (Overland Consulting)", "id": "2022-12_pseg_nj-affiliate-management-audit", "company": "Public Service Electric and Gas Company (PSE&G)", "company_raw": "Public Service Electric and Gas Company (PSE&G)", "docket": null, "docket_full": null, "issued_date": null, "source_page_url": "https://www.nj.gov/bpu/about/divisions/audits/auditreports.html", "pdf_download_url": "https://www.nj.gov/bpu/pdf/auditpdfs/2023%20PSEG%20Final%20Audit%20Report.pdf", "captured_at": "2026-06-08", "source_note": "NJ BPU audit (Overland Consulting): Audit of Affiliated Transactions between PSE&G, PSEG and affiliates, plus a Management Audit of PSE&G. 868 pp (public redacted). Title page prints 'December 2022' (month only) -> issued_date null. Page 1 verified. Findings parsed verbatim from the Overland Consulting Comprehensive Listing of All Recommendations (Attachment 1-1).", "archived_via": null, "page_count": 868, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 16, "findings": [ { "index": 1, "title": "Non-Power Affiliate Relationships and Transactions", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "In conjunction with Recommendation 1, we recommend PSEG explore development of transaction-type-based budgets and budget variance reporting for large, recurring intercompany transactions involving fund transfers between affiliates. PSEG should report to the BPU whether it is possible to develop and implement these capabilities cost effectively prior to the replacement of the Company’s SAP system. Budgeting for expected funds transfers by type of transaction is no less necessary for large intercompany transactions than for transactions between unrelated parties. Budgeting occurs for each operating company and plans vs. actuals are reviewed and may trigger more in depth analysis for any given variance. However, by setting expected levels of charges and funds flow, budgeting can help maintain control over large, recurring charges between affiliates. Examples of recurring charges that should be budgeted include large, recurring transmission agreement payments made to Power but owed to PSE&G, large corporate life insurance payouts received by PSEG Enterprise that are owed to PSE&G, and retiree prescription subsidy program payments received by Enterprise but owed to PSE&G. When significant variances occur, it should prompt follow up review, at least by the affiliate to which funds are owed. Implementation of this recommendation requires maintaining information to classify intercompany transactions by type; as such it is related to the previous recommendation.", "source_page": null }, { "number": 2, "text": "We recommend PSEG clarify its position regarding compliance with New Jersey Affiliate Standards in its Annual Compliance Plan and clarify and document controls in place between PSE&G and affiliates regardless of the Company’s position that certain regulations are inapplicable. PSEG takes the position that, as a matter of law, it is required to comply with New Jersey Affiliate Standards only with respect to its relationships with two, in our opinion very minor, “affected affiliates” (PSEG Solar Hackettstown and PSEG Energy Solutions). It is our opinion as auditors that there are many provisions of Affiliate Standards that should apply to the material relationships between PSE&G and its more significant operating affiliates (PSEG Services, Power, Energy Holdings and PSEG LI). In addition, there are provisions in Affiliate Standards, including those in N.J.A.C 14:3-3.3 and 14:3-3.4, that, in our opinion should apply to PSE&G’s Appliance Services Business, notwithstanding the fact that the ASB is a separate PSE&G business unit rather than a legally distinct affiliate. While we found that, in practice, PSEG applied Affiliate Standards requirements to PSE&G’s relationships and transactions with PSEG Services, PSEG Power and other significant operating affiliates, we recommend PSEG consider the “Relevant [Affiliate] Standards” covered in its Annual Compliance Plan and clarify, in each of the Plan’s “Compliance Procedures” sections, the affiliates and / or ASB business unit to which specific regulations apply. We also recommend PSEG clarify, regardless of applicability of these regulations, the procedures PSEG uses either to ensure compliance where required, or to enhance affiliate controls where technically not required. The NJBPU should review these Compliance Plan clarifications to ensure they properly recognize PSEG’s controls with respect to PSE&G’s relationships and transactions with its major operating affiliates, and between PSE&G’s regulated utility business and the ASB.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": true }, { "index": 2, "title": "Centralized Service Cost Allocation Methods and Procedures", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 3, "text": "PSEG should reform the Enterprise Corporate allocator to implement a uniform set of inputs for all PSEG operating subsidiaries and document the calculation methodology in the CAM. Any adjustments to the inputs and the impacts of such adjustments, or the basis for not making such adjustments, such as to the O&M expense component of the allocator, should be documented in the CAM and submitted for review by the BPU. Specifically:", "source_page": null }, { "number": 4, "text": "The zero-value used for PSEG LI’s assets should be replaced by the utility’s actual net fixed asset (or gross plant) input value. Allocators that rely on measures of size to distribute non- attributable corporate costs are inherently arbitrary in that they cannot be linked to cost objectives based on cost causation. This does not mean they cannot be objective, systematic and rational. However, it is neither systematic or rational to calculate an allocator based on measures of size that, for one reason or another, either do not apply to or are determined not to be useful for all of the allocator’s significant cost objectives. In this particular case, there is no reason that PSEG Long Island’s net fixed assets should not contribute to its “weight” in drawing PSEG’s corporate enterprise costs. PSEG supports the Long Island utility’s assets in all material respects. PSEG manages, operates and maintains the assets and performs asset planning. If PSEG’s stated reason for excluding Long Island’s assets from the allocator’s calculation, that it does not hold the title to the assets, overcomes the asset management, operation, maintenance and other activities supported by PSEG Corporation, then the basis for using assets as a measure of relative corporate support in the allocator is flawed, because it cannot be applied in a balanced fashion to the significant subsidiaries supported. Regardless of the measures selected, the Enterprise Corporate allocator should be based on measures of size that are characteristic of and can be used for all subsidiary cost objectives, with the exception of subsidiaries that are small enough that the difference between using or not using a particular component would be immaterial. Leaving assets out of the allocator lowers PSEG LI’s allocation of corporate enterprise costs by nearly a third, and improperly shifts corporate enterprise costs to PSE&G and Power, but primarily to PSE&G as Power shrinks. Centralized Service Cost Allocation Methods and Procedures Recommendation 3.1a The Plan headcount factors used in the enterprise allocator should be replaced with actual employee headcounts. The Plan-based (authorized) subsidiary headcounts used to calculate the enterprise factor’s headcount component materially exceeded actual headcounts for PSE&G and Power, but not for PSEG LI. For example, PSE&G’s Plan headcount was more that 7% above actual headcount throughout the three-year review period, while PSEG LI’s actual headcount was within about 2% of Plan. This caused the allocator to assign relatively less corporate cost to PSEG LI and relatively more to PSE&G and Power than would have been the case had actual employee counts been used. Actual headcount is an accurate measure of the relative level of support provided by corporate activities to the employees of each subsidiary and is preferable to authorized employee levels, particularly when Plan levels contain several hundred authorized positions that never seem to get filled for one subsidiary, but not for another. Centralized Service Cost Allocation Methods and Procedures Recommendation 3.1b Adjustments to financial statement O&M expense for use in the enterprise allocator should be documented and explained. There are significant adjustments made to financial statement O&M expense for use in the Enterprise Corporate allocator. For example, in 2020 nearly 48% of PSE&G’s O&M expense was adjusted out for allocation purposes, and more than 42% was adjusted out for PSEG LI. Neither the basis nor the reasons for the adjustments are explained anywhere in PSEG Services’ CAM. It is not clear that the adjustments render a better “apple-to- apples” comparison of O&M expense across subsidiaries. To the extent any adjustments to published, verifiable O&M expense amounts are made in the allocator, they should be supported by the objective of making the figures more comparable across all subsidiary cost objectives. The logic behind any adjustments to O&M used for allocation purposes should be fully explained and documented in the CAM. Centralized Service Cost Allocation Methods and Procedures Recommendation 3.1c The service company catalog should be updated and documentation improved. The service company catalog should be reviewed to ensure it covers all services which are or are authorized to be provided. All obsolete services should be removed. An additional column of information should be added to better explain how the services are allocated; for example, descriptions of the transactional bases for services should be added. The service company activities included in services should be better documented in some cases. For example, instead of stating simply that a service is intended to include “enterprise level” activities, the service definition should provide examples of the types of work that qualify as enterprise level in the context of the department providing the service and the activities performed.", "source_page": null }, { "number": 5, "text": "The Cost Allocation Manual should be updated to add, or a supplemental document should be developed to provide, an understandable description of how costs are allocated to business units within PSE&G; in particular, how PSEG Services’ costs are distributed to UbUs that comprise the foundation of state-level electric and gas distribution revenue requirements and rates. The CAM was not designed to explain how service company costs attributable to multiple PSE&G UbUs are distributed to the business units. The CAM does not explain the basis for allocations to UbUs or why some service company Customer Operations, Electric Operations and Asset Management and Centralized Services costs are or are not attributable to UbUs such as Appliance Services or Transmission. Instead, the CAM contains a technical discussion of the means of allocation within the utility (for example, what “surcharging,” “assessment” and “fixed percentage allocators” are and how they are calculated.) While this technical information is fine, as far as it goes, it does not explain the basis for the allocation of various common service company activities or why they are considered attributable to some UbUs, but not others. One way to accomplish a service-level documentation of the basis for cost allocation to UbUs would be to add the information to the service company catalog discussed above. Alternatively, the company should develop supplemental documentation that should be referenced in the CAM that provides this information.", "source_page": null }, { "number": 6, "text": "PSEG Services should conduct and document a review of all significant common cost allocations to UbUs. Overland reviewed a limited number of allocations of service company costs within PSE&G and found mistakes had been made in the application of allocation percentages. In addition, services which appear to have been common to all UbUs served by operating organizations such as Customer Operations and Electric Operations were not allocated to all of the UbUs served by those organizations. It is likely that these problems are due to the “wall” between information available for utility FLoBs in the service company’s accounting system and UbU information available in the utility’s accounting system. We recommend a complete review of the links between service company services and utility UbUs and the basis and selection of UbU cost objectives for all services common to more than one UbU.", "source_page": null }, { "number": 7, "text": "At the time of our audit the Service Agreement between PSEG Services and PSE&G was outdated. The agreement should accurately reflect all current service and allocation relationships. PSEG stated that the agreement we reviewed, which had not updated since 2003, was updated in 2022. Going forward, the Company should periodically review the agreement for material changes and update the agreement to reflect details and applicable changes through an addendum, or as appropriate, to update the entire agreement. The Service Agreement establishes basic terms for service company staffing, service accounting and utility payment, a service company working capital fund, record keeping and PSE&G access to records. It provides for a service company Board of Directors with approval responsibility for cost allocation methods. Overland did not review the 2022 update and it is not clear that it was comprehensive or addressed the problems the led to our recommendation. Although service and charging method descriptions are generic enough that many still apply, certain services and allocation descriptions in Agreement Schedule 1 have been changed pursuant to notice to the BPU. For example, Schedule item 9 describes the allocation basis for General PSEG Management services (corporate enterprise services) as being “assigned using a number of allocation methodologies [which] include but are not limited to . . . Modified Massachusetts formula, Revenue, Earnings and Capital Expenditures and Headcount.” It is Overland’s understanding that enterprise cost allocation formulas other than the currently used three- factor formula composed of net assets, headcount and operating expense were abandoned after 2009.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 3, "title": "Marketing Conditions", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Provide a link to the Board’s “Shop for Energy Suppliers” webpage on PSE&G’s retail choice page to make Supplier browsing easier for customers.", "source_page": null }, { "number": 9, "text": "Provide a link to the Company’s Price to Compare directly from its “Electric and Gas Choice Customer Information” page to allow customers to easily see the Price to Compare versus TPS rates.", "source_page": null }, { "number": 10, "text": "Continue to actively participate in supporting retail choice in New Jersey, especially with the roll-out of Advanced Metering Infrastructure.", "source_page": null }, { "number": 11, "text": "PSE&G should initiate discussions with the New Jersey Board of Public Utilities (the “Board” or “BPU”) to discuss options and strategies to advocate for new sector weighting in PJM to provide more voting power and influence for members owning significant transmission and distribution assets and that have long-term interests in providing reliable service to end-use customers when voting in transmission-related proceedings, especially regarding New Jersey.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Electric Procurement and Supply", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "PSE&G should not implement any changes in current BGS policies and practices until their proposal is approved by the Board.", "source_page": null }, { "number": 13, "text": "The Electric Procurement and Supply function in PSE&G should adopt a more formal documented succession planning process for all of its manager-level and key analyst roles to maintain secure operations in the future.", "source_page": null }, { "number": 14, "text": "The Board should look at the impacts post sale of PSEG Power fossil facilities relative to the financial information provided and justification of ZECs to make sure stranded shared Service Company costs are not included as part of the financial hardship justification included by the nuclear plants in any future ZEC application.", "source_page": null }, { "number": 15, "text": "The Board should conduct an inquiry or audit of PSEG Services allocation methodology to ensure that none of the stranded shared services costs resulting from the sale of PSEG Power’s assets will be charged to the PSE&G ratepayers post-closing of the transaction.", "source_page": null } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 5, "title": "Gas Supply and Procurement", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "The BPU should consider whether the benefits to customer of this arrangement continue to support this arrangement. Management should evaluate whether supply contract ownership and management should be moved to the regulated PSE&G utility, when practical. This would create synergies within the organization and centralize all gas supply processes within the PSE&G organization.", "source_page": null }, { "number": 17, "text": "Since the internal audit function is the primary tool for ensuring ER&T compliance with the Requirements Contract, audits should be scheduled more frequently and explicitly include the contract elements covered under the audit scope.", "source_page": null }, { "number": 18, "text": "ER&T should track the effectiveness of its hedging program to determine the overall impact to customers.", "source_page": null } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 6, "title": "Deferral of Costs", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Given the critical role operating areas play in determining which storm-related costs can be deferred, we recommend that PSE&G formally notify the BPU in advance in writing of any plans to increase or otherwise subdivide its current New Jersey operating areas on a prospective basis. In addition, until the BPU decides that the consequences of this decision on the deferral of future PSE&G storm restoration costs are acceptable, the criteria for determining whether an event is major or not will be based on historical definitions of PSE&G’s operating areas.", "source_page": null }, { "number": 20, "text": "If not already included in its 2022 plan, we recommend that Internal Auditing Services perform audit(s) in the next twelve months of PSE&G’s most significant regulatory assets and liabilities as well as those that have been created since 2017, such as the post-2018 base rate case storm- related cost deferrals and the COVID-19 cost deferral. Thereafter, all of PSE&G’s regulatory assets and liabilities should undergo internal audit at least once every three years, or the Company should justify why they do not warrant such examination. In addition to determining whether the regulatory assets and liabilities are properly presented and disclosed in the Company’s financial statements, the audits should ensure compliance with regulatory policy, precedent, and rules in addition to confirming that internal controls associated with these regulatory assets and liabilities are appropriate and operating effectively. All related audit reports should be made available to BPU staff or their delegates, upon request.", "source_page": null } ], "themes": [ "Internal audit & internal controls", "Storm cost recovery & securitization" ], "cost_to_customers": false }, { "index": 7, "title": "Recommendations and Review of Previous Analysis", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 21, "text": "We recommend that implementation plans and/or actions taken by the company to respond to recommendations made in this affiliate transactions and management audit be tested by PSEG’s Internal Auditing Services group for comprehensiveness and effectiveness on an annual basis until all accepted recommendations have been implemented. The results of this review should be provided to the BPU in a timely manner upon request, and associated workpapers should be made available for review by the BPU, as requested.", "source_page": null } ], "themes": [ "Affiliate / intercompany transactions", "Internal audit & internal controls" ], "cost_to_customers": true }, { "index": 8, "title": "Strategic Planning", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 22, "text": "We recommend that the PSEG board’s Executive Committee members should be compensated by the number of meetings attended rather than by annual retainer at levels equal to that of the board’s standing committees. A payment of $5,000 per meeting attended would more closely align with the actual workload of this as-needed committee than the status quo. If the board is concerned that this would unduly penalize Executive Committee members from a compensation standpoint, given the historical composition of the committee, it could make minor adjustments to Lead Director and committee chair annual retainer amounts. Executive Management and Corporate Governance Recommendations 12.1 We recommend that actual and targeted performance associated with compensable metrics used in the SMICP, MICP, and LTIP be proactively communicated to all participants throughout the performance year so that informed decisions concerning remedial action can be taken by all in a timely manner. If release of this information cannot be disseminated to the Company employees who have been identified as most crucial to the success of the organization, then different metrics that can be shared should be selected. Executive Management and Corporate Governance Recommendations 12.2 We recommend that the Organization and Compensation Committee require a certain level of accomplishment be achieved with respect to PSE&G safety, reliability, and customer satisfaction in order for pay-outs to be paid to executives under the short-term incentive compensation plans as currently designed. If these threshold levels of safety, reliability, and customer satisfaction are not achieved in a given year, then short-term incentive compensation earned by executives should be capped at 50 percent of target performance achievement irrespective of how the Company performs against other metrics such as financial, ESG, etc. Executive Management and Corporate Governance Recommendations 12.3 The destruction of PSEG materials, including those related to the board and the board committee self-evaluations, should conform with the Company’s currently existing record retention policy and verifiable market standard practices. Executive Management and Corporate Governance Recommendations 12.4 The PSEG board of directors should retain a qualified expert on public company board and corporate governance matters to conduct a periodic independent assessment of the board’s and its committees’ effectiveness. At a minimum, the purpose of this assessment would be to identify areas of improvement, instances in which corporate governance best practices are not being followed by the board or its committees, and non-conformance with regulatory requirements. The third party should be retained by the PSEG board or one of its standing committees. The assessment should be conducted at least once every five years. Executive Management and Corporate Governance Recommendations 12.5 The Company should enhance its ERM policy and procedures to address the development of a risk appetite statement that is owned by the Risk Management Committee and subject to approval by the board (or relevant committee).", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Accounting and Property Records", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 23, "text": "Internal Audit should continue to functionally report to the Audit Committee of the PSEG board of directors. However, on an administrative basis, it should ideally report to the CEO of PSEG. Alternatively, we recommend that Internal Audit should revert back to reporting administratively to the CFO, and the Audit Committee of the PSEG board of directors should document its rationale in writing for this reporting structure, including mitigating controls available for situations that could adversely impact the objectivity of the head of Internal Audit and the department as a whole. In such instances, the Audit Committee should periodically, but not less than annually, evaluate whether the head of Internal Audit is impartial and not unduly influenced by the administrative reporting line arrangement. Furthermore, conflicts of interest for the head of Internal Audit and all other audit staff should be monitored at least annually with appropriate restrictions placed on auditing areas where conflicts may arise.", "source_page": null }, { "number": 24, "text": "When a new person is considered for the position of head of Internal Audit on a prospective basis, management and PSEG board’s Audit Committee should select and approve a person with a professional and educational background as an accountant and/or financial auditor. In addition, future periodic external assessments of PSEG’s Internal Audit function should specifically include an assessment of the competence of the head of Internal Audit as well as a commentary on industry and peer best practices concerning the educational and professional qualifications of the head of Internal Audit, adequately supported by benchmarking data.", "source_page": null }, { "number": 25, "text": "The Internal Audit charter and the PSEG board of directors’ Audit Committee charter should state that the Audit Committee has the responsibility to approve the staffing of the Internal Audit department (a key component of resource planning) and the budget of Internal Audit rather than the Company’s executive management.", "source_page": null }, { "number": 26, "text": "The PSEG Audit Committee charter should be modified to explicitly state that the Audit Committee is responsible for reviewing and approving the internal audit plan for the upcoming year.", "source_page": null } ], "themes": [ "Property & plant records", "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 10, "title": "Electric Distribution and Operations Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 27, "text": "The Company should leverage advanced computerized tools to assist with staffing forecasts that optimizes internal hiring and contractor utilization. This should be coordinated with a broader corporate effort to accurately model and forecast staffing needs by leveraging input from leadership through a formalized process. The output of this model should be the generation of a short- and long-term resourcing plan.", "source_page": null }, { "number": 28, "text": "The Company should conduct a time study for all front-line supervision within Electric Operations, then benchmark to other utilities for best practices. Pending the results of the study, the Company should strive to reduce the administrative burden, if applicable, so supervisors can maximize their time overseeing employee safety and productivity.", "source_page": null }, { "number": 29, "text": "The Company should prepare checklists for all ICS roles that capture required activity for all phases of restoration. The checklist should be aligned to the Company’s response plans and with the goal of supporting the effective management of each ICS role.", "source_page": null }, { "number": 30, "text": "The Company should re-evaluate their ETR process to determine whether Damage Assessment can be better incorporated to support ETR development in the earliest phase of major events. Additionally, the Company should indicate their compliance to the ETR standards established by the BPU by implementing a tracking method and reporting their compliance through every submitted Major Event report.", "source_page": null }, { "number": 31, "text": "The actions and initiatives resulting from AARs conducted after each weather event should incorporate project management rigor and governance to ensure accountability, timeliness and transparency.", "source_page": null }, { "number": 32, "text": "In addition to tracking PPCs at a circuit level, the Company should also track the substations that tend to contain a concentration of PPCs to identify trends that could support asset management recommendations at the substation level.", "source_page": null }, { "number": 33, "text": "More advanced DER penetration and EV Charger forecasts should be prepared on a short- and long-term basis. This effort should use more advanced forecasting methods such as economic modeling, industry data, and surveying.", "source_page": null }, { "number": 34, "text": "To ensure the proper oversight and management of the Company’s Smart Grid strategy and implementation, including deploying their Integrated Distribution Plan (IDP), they should implement a PMO and associated program management frameworks to manage.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 11, "title": "Cybersecurity", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 35, "text": "The Company should develop a customized template to drive a consistent approach to reporting for all levels of governance. Content and metrics should be generally similar including, but not be limited to, Progress on Actions from last month, Emergent Topics or issues, latest intelligence, Key Risks, any escalations from other meetings and metrics.", "source_page": null }, { "number": 36, "text": "The Company should have robust meeting minutes, decision, and action tracking logs for all cybersecurity governance meetings. This will ensure that all decisions and actions are trackable and accountability is clear for appropriate follow through.", "source_page": null }, { "number": 37, "text": "The Company should report key staffing risks to leadership through the governance process and highlight actions taken to close these risk areas.", "source_page": null }, { "number": 38, "text": "The Company should prioritize the creation of and implementation of an internally visible schedule of third party cybersecurity compliance audits for medium and high risk vendors and suppliers.", "source_page": null }, { "number": 39, "text": "The incorporation of cybersecurity checkpoints into the SDLC should be a mandatory requirement and not optional, the rationale for not implementing should be detailed and vetted through appropriate leadership.", "source_page": null }, { "number": 40, "text": "While Overland recognizes that the Company is moving forward with implementing a customized program management framework for cybersecurity programs, the effort is still developing and many questions remain. Therefore, Overland recommends that the Company provides regular reporting to the BPU on progress and scope of this effort to ensure it incorporates best practices and is timely.", "source_page": null }, { "number": 41, "text": "The CSRC Incident Response Plan should include process maps where appropriate to assist with plan use. Additionally, where applicable decision trees should also be included to help with more complex decision making processes.", "source_page": null }, { "number": 42, "text": "The Company should implement a more robust After Action Review tracking approach by implementing a project management centric (including progress to date, delivery date, dependencies, key issues, etc.) and reporting approach, which assigns a clear owner for delivery.", "source_page": null } ], "themes": [ "Cybersecurity & physical security" ], "cost_to_customers": false }, { "index": 12, "title": "Gas Delivery", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 43, "text": "To support increased collaboration between Asset Management & Planning and Gas Operations departments, PSE&G should pursue the collaboration initiatives cited in the Utility Culture Action Plan Rollout, dated February 2021, with the goal of creating a shared vision, mutual respect, and in-depth understanding of each other’s role in achieving excellent business outcomes and outstanding customer service. To confirm the two departments are making progress, a focused employee engagement survey should be periodically conducted, and based on survey results the collaboration initiatives employed adjusted.", "source_page": null }, { "number": 44, "text": "Develop a program that prioritizes the replacement of all short sections (less than 50 feet) of smaller diameter (8-inch and smaller) of cast iron pipe operating above utilization pressure in low priority GSMP grids. The program should have a definitive start and end date consistent with prudent distribution system risk management.", "source_page": null }, { "number": 45, "text": "Augment current Gas Distribution Standards training by stressing the need for correct entries with respect to leak cause. Training should emphasize the importance of this information as it provides the basis for determining which mains and services get replaced.", "source_page": null }, { "number": 46, "text": "Perform an open leak cost-benefit study, similar to what other gas utilities have conducted, to determine if there is a potential cost savings as well as reduced methane emissions associated with fixing leaks sooner.", "source_page": null }, { "number": 47, "text": "If conclusions from the open leak cost-benefit study support reducing the number of open leaks, the Company should develop and commit to a plan of significantly reducing the number of open leaks from end of year 2020 levels.", "source_page": null }, { "number": 48, "text": "Future GSMP filings will recommend continued replacement of cast iron and bare steel in PSE&G’s gas distribution system. By continuing to remove these leak prone facilities and assuming normal winter conditions, the Company should experience less leaks per mile in the remaining facilities. Consequently, the Company should continue to commit to the BPU that it will achieve a reduced end of year open leak backlog in concert with any future GSMP filings.", "source_page": null }, { "number": 49, "text": "Develop a written policy and process addressing when and how potential non-pipeline alternatives to traditional long-term system reinforcement projects should be evaluated.", "source_page": null }, { "number": 50, "text": "To demonstrate GSMP success in reducing the Leak Hazard Index per mile of main that remains in its system, PSE&G should develop and annually report to the BPU a suitable metric that emphasizes the inventory of prioritized utilization pressure cast iron main remaining in its system based on the Hazard Index per mile of main per map grid.", "source_page": null } ], "themes": [ "Workforce, training & succession planning", "Customer service & billing" ], "cost_to_customers": false }, { "index": 13, "title": "Contractor Performance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 51, "text": "Expand PSE&G’s Peer Panel Benchmarking to include additional comparisons for gas and electric damage prevention, specifically the markout program, or develop some other enhanced comparative analysis for damage prevention. The comparison should be structured in such a way that the damage prevention program variability between utilities can be identified to allow understanding of the methods utilized by the utilities achieving superior gas and electric damage prevention performance.", "source_page": null }, { "number": 52, "text": "Initiate the documenting and tracking of any procedure or process changes resulting from analysis of major categories of improvement ideas expressed by customers in the Transaction Satisfaction Survey should be initiated.", "source_page": null }, { "number": 53, "text": "Include the Gas Operator Qualifications Program in PSE&G’s audit risk assessment process and perform an internal audit of operator qualifications (OQ) program compliance with US Department of Transportation (DOT) rules and regulations. The audit should focus on determining whether the OQ program adheres to the protocols required by DOT rules. Reassess audit risk after performing the audit and determine whether the OQ program should be subject to periodic audit.", "source_page": null } ], "themes": [ "Internal audit & internal controls", "Gas safety & pipeline integrity" ], "cost_to_customers": false }, { "index": 14, "title": "Human Resources", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 54, "text": "The Labor Relations team within HR, in consultation with the company’s Compensation HR Center of Excellence, should consider more formally benchmarking wage compensation for union employees against peers to assist in negotiating union wages that are both fair and comparable with peers. Overland requested union wage, benefits, job classification and work rules benchmarking data. In response to our request, PSEG stated that “[o]ther than the benchmarking data provided by the other HR Centers for Excellence, records of the research and consultation performed by Labor Relations are utilized in the normal course of business to inform the work of the Labor Relations team but are not formally archived.” Our recommendation applies primarily to union wages, as opposed to employee benefits, given that PSEG obtains benchmarking data for union employee benefits from Aon.", "source_page": null } ], "themes": [], "cost_to_customers": false }, { "index": 15, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 55, "text": "The relatively new 82,000 square foot Newark Customer Contact Center is significantly underutilized considering the annual lease and utilities costs of approximately [BEGIN CONFIDENTIAL] [END CONFIDENTIAL]million and estimated space utilization of only about 15%, due mainly to a continuation of the Covid-era policy of allowing most agents to work from home. As soon as practicable, PSE&G should take steps to reduce its leased space footprint in the new Newark Customer Contact to match the highest utilization the Company expects it will need under its ongoing work-from-home policy.", "source_page": null }, { "number": 56, "text": "Rather than simply having a stated goal of top-quartile or top-decile performance, PSE&G should develop a concrete plan of action to improve, over the medium term (1-3 years), key Contact Center metrics in which it ranks in the third or fourth quartile, specifically the customer inquiry service level and the abandoned call percentage, to at least second quartile performance among peers in the JD Power survey. While the ongoing efforts PSE&G cited in response to our data request concerning performance in these metrics could be part of this plan, we recommend PSE&G document a plan with an overall target performance level for each metric, the timeframe over which it expects to achieve the resulting performance, the specific efforts or projects it expects will bring about the improvement, and assign management accountability for the targeted performance.", "source_page": null }, { "number": 57, "text": "PSE&G’s 16 CSCs currently cost approximately $10 million annually to operate, excluding building costs, while processing only about 2% of PSE&G’s total payments. As part of the ongoing effort to move customer communication to digital channels, we recommend PSE&G develop a specific plan to better utilize the CSCs or simply reduce their overall cost by closing the least productive centers, as permitted by employee attrition or reassignment, and considering geography, customer payment alternatives, and historic trends of utilization. Recognizing PSE&G may be constrained by current agreements with union-represented employees, such steps might include utilizing current CSC employees for additional customer service functions or requirements, or simply closing the least utilized centers permanently. Overland recognizes there are additional mitigating factors, such as the social service assistance provided within some of the centers; however, regarding these we believe PSE&G should determine whether digitized customer channels might, in some cases, provide equivalent or even improved social services assistance. This should not be construed as a recommendation to close all 16 local centers.", "source_page": null }, { "number": 58, "text": "We recommend PSE&G develop a metric to measure the extent to which its procedures result in the establishment of service within two business days of the receipt of a customer’s application for utility service, as required by N.J.A.C. Section 14:3-3.2(g). Consideration should include evaluation of processes, systems, and costs required to implement.", "source_page": null }, { "number": 59, "text": "We recommend PSE&G develop a metric to measure the extent to which its procedures result in the restoration of service within 12 hours upon a customer correcting all of the conditions which caused service to be disconnected, as required by N.J.A.C. Section 14:3-3A.9(a). Consideration should include evaluation of processes, systems, and costs required to implement.", "source_page": null } ], "themes": [ "Customer service & billing" ], "cost_to_customers": false }, { "index": 16, "title": "Support Services", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 60, "text": "PSE&G should implement the inventory optimization analysis currently in development and update the SAP system with optimal material quantities.", "source_page": null } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Customer service & billing", "Cybersecurity & physical security", "Gas safety & pipeline integrity", "Internal audit & internal controls", "Inventory, materials & fleet", "Property & plant records", "Storm cost recovery & securitization", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "NY", "source": "NY Department of Public Service", "doc_type": "DPS Office of Investigations & Enforcement investigation report (customer billing system)", "id": "2022-12_central-hudson_ny-22-m-0645-billing-investigation", "company": "Central Hudson Gas & Electric Corporation", "company_raw": "Central Hudson Gas & Electric Corporation", "docket": "22-M-0645", "docket_full": null, "issued_date": null, "source_page_url": "https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=22-M-0645", "pdf_download_url": "https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7B7410F817-B458-4232-9522-BF3FB9BAB451%7D", "captured_at": "2026-06-08", "source_note": "NY DPS Office of Investigations and Enforcement Investigation Report (Dec 2022), Case 22-M-0645 — investigation into Central Hudson's customer information/billing system and billing-accuracy impacts. 62 pp. Cover prints month only (December 2022) -> issued_date null. Page 1 verified: 'OFFICE OF INVESTIGATIONS AND ENFORCEMENT ... INVESTIGATION REPORT DECEMBER 2022 CASE 22-M-0645'.", "archived_via": null, "page_count": 62, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2019-10_ugi-utilities_pa-mo-audit", "company": "UGI Utilities, Inc.", "company_raw": "UGI Utilities, Inc.", "docket": "D-2018-3002234", "docket_full": null, "issued_date": null, "source_page_url": "https://www.puc.pa.gov/press-release/2023/puc-issues-management-efficiency-investigation-report-for-ugi-utilities", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1644014.pdf", "captured_at": "2026-06-08", "source_note": "Management & Operations Audit of UGI Utilities, Inc. (incl. UGI Central Penn Gas and UGI Penn Natural Gas), PA PUC Bureau of Audits — cover 'Issued October 2019', Docket Nos. D-2018-3002234, D-2018-3002235, D-2018-3002236; 45 recommendations across the Exhibit I-2 table (the 2023 MEI follow-up tracked a 23-rec significant subset). PDF: puc.pa.gov/pcdocs/1644014.pdf. Cover prints only the month, so issued_date is left null. source_page_url is the 2023 MEI follow-up (the original 2019 announcement is not in the current archive). Findings parsed verbatim from Exhibit I-2.", "archived_via": null, "page_count": 127, "scanned_pages": [ 1, 127 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 13, "findings": [ { "index": 1, "title": "Executive Management and Organizational Structure", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Improve the maintenance and tracking of safety training through automation.", "source_page": 18 }, { "number": 2, "text": "Periodically review spans of control for UGI Utilities’ management positions and document justification for supervisory position ratios with narrow or wide spans of control and adjust reporting relationships as appropriate.", "source_page": 18 }, { "number": 3, "text": "Centralize policy management and establish requirements to periodically review and update them.", "source_page": 18 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 2, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Organize the Internal Audit function to report administratively to the UGI Corp. CEO, another non- financial senior officer of UGI Corp., or directly to the Board of Directors.", "source_page": 23 }, { "number": 5, "text": "Revise UGI Utilities’ delegation of authority policy to strengthen governance controls for the new EVP Natural Gas position.", "source_page": 23 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 3, "title": "Affiliated Interests and Cost Allocations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Create a periodic, recurring process to compare the internal cost of services provided between UGI Utilities and its affiliates to market rates.", "source_page": 31 }, { "number": 7, "text": "Update UGI Corp.’s Cost Allocation Manual.", "source_page": 31 }, { "number": 8, "text": "Work with UGI Corp. to improve the level of detail provided in intercompany invoices and reports.", "source_page": 31 }, { "number": 9, "text": "Develop time entry training to address direct charging of labor for intercompany services.", "source_page": 31 }, { "number": 10, "text": "Amend or file new affiliated interest agreements to more accurately detail services provided.", "source_page": 31 } ], "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "index": 4, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 11, "text": "Conduct periodic internal audits of affiliate transactions and shared service costs.", "source_page": 37 }, { "number": 12, "text": "Document or update existing policies or procedures to reflect actual practices.", "source_page": 37 } ], "themes": [ "Affiliate / intercompany transactions", "Internal audit & internal controls" ], "cost_to_customers": true }, { "index": 5, "title": "Gas Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 13, "text": "Continue to reduce the number of third-party damages and increase the damage collection rate at UGI North.", "source_page": 57 }, { "number": 14, "text": "Decrease the inventory of outstanding Class A leaks and continue to reduce the number of main leaks at UGI North.", "source_page": 57 }, { "number": 15, "text": "Maintain focus on safety with the objective of meeting or exceeding safety KPI goals.", "source_page": 57 } ], "themes": [ "Gas safety & pipeline integrity" ], "cost_to_customers": false }, { "index": 6, "title": "Gas Operations (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Continue accelerated efforts to identify and safely remove and dispose of all mercury regulators in UGI South’s service territory.", "source_page": 57 }, { "number": 17, "text": "Follow through on plans to develop a centralized training facility to aid in OQ training", "source_page": 57 }, { "number": 18, "text": "Consider redefining emergent and non-emergent work and train supervisors on the usage of overtime and continue to work to reduce overtime that is not related to an emergency.", "source_page": 57 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 7, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 19, "text": "Establish and track response times by subcategories and take corrective action to continue improving response times for emergency outage calls.", "source_page": 63 }, { "number": 20, "text": "Investigate the costs and related benefits of implementing some EMS features into the existing SCADA system.", "source_page": 63 } ], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 8, "title": "Emergency Preparedness", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 21, "text": "Install sprinkler systems at all regularly occupied facilities, where feasible.", "source_page": 74 }, { "number": 22, "text": "Establish physical security standards that apply at company facilities and devote resources to adequately maintain oversight.", "source_page": 74 }, { "number": 23, "text": "Update the PSP to include relevant physical security efforts and review, update, and test it annually.", "source_page": 74 }, { "number": 24, "text": "Establish a clear chain of command for physical security by placing the Director of Physical Security in charge of all physical security at UGI Utilities.", "source_page": 74 }, { "number": 25, "text": "Perform penetration tests, risk analysis, and vulnerability assessments of physical security routinely, and periodically utilize external/independent resources.", "source_page": 74 }, { "number": 26, "text": "Improve the CSP and relevant procedures, secure all PII, and consider formalizing policies at the UGI Corporation level.", "source_page": 74 }, { "number": 27, "text": "Complete the gas SCADA communication upgrade.", "source_page": 74 }, { "number": 28, "text": "Review and adjust resources to address the business continuity program’s deficiencies.", "source_page": 74 }, { "number": 29, "text": "Continue improvement of the ERP, and address deficiencies in associated training.", "source_page": 74 }, { "number": 30, "text": "Maintain up to date printed copies of SDS near where chemicals are stored or in a relevant control center.", "source_page": 74 } ], "themes": [ "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 9, "title": "Materials Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 31, "text": "Improve company-wide inventory turnover and exclude emergency stock from inventory turnover calculations.", "source_page": 82 }, { "number": 32, "text": "Automate the materials management function.", "source_page": 82 }, { "number": 33, "text": "Develop a detailed material procurement manual and track vendor performance.", "source_page": 82 }, { "number": 34, "text": "Improve cycle count accuracy rates at warehouses in the UGI Central division.", "source_page": 82 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 10, "title": "Information Technology", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 35, "text": "Ensure forward-looking goals and objectives are fully defined within the IT Strategic Plan.", "source_page": 87 }, { "number": 36, "text": "Expand the required IT certifications to drive wanted skill competencies.", "source_page": 87 }, { "number": 37, "text": "Integrate the IT Department as part of the procurement process to review and evaluate cybersecurity issues for communications-capable operations equipment.", "source_page": 87 } ], "themes": [ "Cybersecurity & physical security", "Information technology & systems" ], "cost_to_customers": false }, { "index": 11, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 38, "text": "Reduce long-term accounts receivable balances.", "source_page": 96 }, { "number": 39, "text": "Resolve integration issues between the new customer information system and program used to support billing and collections processes for UGI Utilities’ Customer Assistance Program.", "source_page": 96 }, { "number": 40, "text": "Improve customer service performance metrics.", "source_page": 96 }, { "number": 41, "text": "Improve the retention of Customer Care Representatives within the Customer Information Center.", "source_page": 96 } ], "themes": [ "Information technology & systems", "Customer service & billing" ], "cost_to_customers": false }, { "index": 12, "title": "Fleet Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 42, "text": "Determine optimal vehicle and equipment replacement strategy and update vehicle replacement guidelines.", "source_page": 100 }, { "number": 43, "text": "Develop key performance indicators tailored to effectively manage UGI Utilities’ fleet, reduce costs, and drive efficiency.", "source_page": 100 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 13, "title": "Human Resources/Diversity", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 44, "text": "All documentation provided to new hires should be reviewed periodically and updated as necessary.", "source_page": 107 }, { "number": 45, "text": "Prepare and file annual diversity reports in accordance with Commission guidelines for annual PUC diversity filing.", "source_page": 107 } ], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [ "Affiliate / intercompany transactions", "Cost of service & rates", "Customer service & billing", "Cybersecurity & physical security", "Emergency preparedness & business continuity", "Gas safety & pipeline integrity", "Information technology & systems", "Internal audit & internal controls", "Inventory, materials & fleet", "Service reliability & vegetation management", "Workforce, training & succession planning" ], "cost_to_customers": true }, { "collection": "state_audit", "jurisdiction": "PA", "source": "PA PUC Bureau of Audits", "doc_type": "management & operations audit", "id": "2019-07_duquesne-light-company_pa-mo-audit", "company": "Duquesne Light Company", "company_raw": "Duquesne Light Company", "docket": "D-2018-3000838", "docket_full": null, "issued_date": null, "source_page_url": "https://www.puc.pa.gov/press-release/2023/puc-issues-management-efficiency-investigation-report-for-duquesne-light", "pdf_download_url": "https://www.puc.pa.gov/pcdocs/1630850.pdf", "captured_at": "2026-06-08", "source_note": "Management & Operations Audit, PA PUC Bureau of Audits — cover 'Issued July 2019', Docket No. D-2018-3000838; 18 recommendations. PDF: puc.pa.gov/pcdocs/1630850.pdf. The cover prints only the month, so issued_date is left null to avoid false precision (cf. CPUC month-only precedent). The original 2019 announcement is not in the current PUC press-release archive; source_page_url is the 2023 Management Efficiency Investigation follow-up, which documents this audit by name. Findings & recommendations parsed verbatim from the Exhibit I-2 Summary of Recommendations.", "archived_via": null, "page_count": 96, "scanned_pages": [ 1, 96 ], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 10, "findings": [ { "index": 1, "title": "Executive Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 1, "text": "Establish an annual management committee self- evaluation and/or survey to assess the efficiency and effectiveness of each management committee.", "source_page": 23 }, { "number": 2, "text": "Perform a follow-up to the Span of Control Assessment after completing the current reorganization.", "source_page": 23 }, { "number": 3, "text": "Establish individual goals for the CEO that are specific, measurable, attainable, relevant and time- based, and linked specifically to corporate goals and objectives similar to what existed in 2014.", "source_page": 23 } ], "themes": [ "Workforce, training & succession planning" ], "cost_to_customers": false }, { "index": 2, "title": "Corporate Governance", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 4, "text": "Include within the profile currently being developed to hire an independent director the consideration criterion that a candidate may qualify as an SEC-defined AC financial expert.", "source_page": 28 }, { "number": 5, "text": "Implement a quality assurance and improvement program that meets IIA Standard 1300 and its subcategories as well as prepare written policies and procedures for the IAD that provide guidance on internal audit activity that meets IIA Standard 2040.", "source_page": 28 } ], "themes": [ "Internal audit & internal controls" ], "cost_to_customers": false }, { "index": 3, "title": "Financial Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 6, "text": "Conduct a review of all finance and accounting policies and procedures to ensure administrative controls are standardized and applied uniformly.", "source_page": 47 }, { "number": 7, "text": "Create a formal variance policy that includes a threshold (percentage and/or amount) for variances to be tracked and explained through documentation.", "source_page": 47 } ], "themes": [], "cost_to_customers": false }, { "index": 4, "title": "Electric Operations", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 8, "text": "Establish overtime level goals for each functional group with a goal not to exceed 20% and develop craftworker staffing levels and contractor resources to address the future workload, including work related to the Long-Term Infrastructure Improvement Plan.", "source_page": 58 }, { "number": 9, "text": "Monitor and control individual employee overtime levels by using overtime exception reports to actively review employees incurring excessive amounts of overtime.", "source_page": 58 } ], "themes": [], "cost_to_customers": false }, { "index": 5, "title": "Electric Operations (continued)", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 10, "text": "Include additional descriptors to outage causes and report tree-related causes as being either Vegetation Inside ROW or Vegetation Outside ROW for a more effective analysis of possible remedial actions to outage causes in future Annual and Quarterly Electric Reliability Reports to the PUC.", "source_page": 58 }, { "number": 11, "text": "Create a summary report of annual transmission and distribution line repairs to trend inspection and maintenance activities.", "source_page": 58 } ], "themes": [ "Service reliability & vegetation management" ], "cost_to_customers": false }, { "index": 6, "title": "Customer Service", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 12, "text": "Implement the extensive testing phase and training phase currently planned to prepare for the December 2019 customer care system update.", "source_page": 65 }, { "number": 13, "text": "Establish, implement, and monitor key performance indicators of third-party collection agency net recovery performance goals.", "source_page": 65 } ], "themes": [ "Workforce, training & succession planning", "Customer service & billing" ], "cost_to_customers": false }, { "index": 7, "title": "Purchasing and Materials Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 14, "text": "Implement Maximo for enhanced inventory tracking and reporting, and establish inventory turnover goals based on optimal usage patterns.", "source_page": 68 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 8, "title": "Human Resources", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 15, "text": "Revise written documents used to engage contractors to include consistent language requiring contractors to comply with all OSHA standards and to remove any language directing contractors to comply with undefined safety directives of representatives of DLC.", "source_page": 77 } ], "themes": [], "cost_to_customers": false }, { "index": 9, "title": "Fleet Management", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 16, "text": "Create an action plan to identify and resolve root causes of erroneous data to ensure fleet utilization reports are accurate.", "source_page": 81 }, { "number": 17, "text": "Establish a formal procedure for the disposal, retirement and transfer of Duquesne Light Company fleet vehicles.", "source_page": 81 } ], "themes": [ "Inventory, materials & fleet" ], "cost_to_customers": false }, { "index": 10, "title": "Information Technology", "summary": null, "is_other_matter": false, "recommendations": [ { "number": 18, "text": "Continue to improve the information technology score via enhanced information technology capabilities, internal controls and governance, and coordination with internal business partners; furthermore, periodically reevaluate the information technology maturity rating.", "source_page": 84 } ], "themes": [ "Internal audit & internal controls", "Information technology & systems" ], "cost_to_customers": false } ], "structured": true, "themes": [ "Customer service & billing", "Information technology & systems", "Internal audit & internal controls", "Inventory, materials & fleet", "Service reliability & vegetation management", "Workforce, training & succession planning" ], "cost_to_customers": false }, { "collection": "state_audit", "jurisdiction": "NJ", "source": "NJ Board of Public Utilities", "doc_type": "affiliate-transactions audit & comprehensive management audit", "id": "2014_njng_nj-ga13010008-affiliate-management-audit", "company": "New Jersey Natural Gas Company", "company_raw": "New Jersey Natural Gas Company", "docket": "GA13010008", "docket_full": null, "issued_date": null, "source_page_url": "https://www.nj.gov/bpu/about/divisions/audits/auditreports.html", "pdf_download_url": "https://www.nj.gov/bpu/pdf/auditpdfs/2014%20NJNG%20Final%20Audit%20Report.pdf", "captured_at": "2026-06-08", "source_note": "NJ BPU audit: Audit of Affiliated Transactions between NJNG and New Jersey Resources and affiliates (N.J.S.A. 48:3-49) plus a Comprehensive Management Audit of NJNG. Docket GA13010008. 326 pp. Title page does not print a day -> issued_date null (filed 2014). Page 1 verified.", "archived_via": null, "page_count": 326, "scanned_pages": [ 2, 6, 34, 50, 62, 76, 102, 140, 204, 276, 298 ], "ocr_used": false, "audit_period": null, "industry": "gas", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Affiliate / intercompany transactions" ], "cost_to_customers": false }, { "collection": "prudence_review", "jurisdiction": "CA", "source": "California Public Utilities Commission", "doc_type": "ERRA compliance & reasonableness review decision", "id": "2010_southern-california-edison_ca-a09-04-002-d10-07-049-erra", "company": "Southern California Edison Company", "company_raw": "Southern California Edison Company", "docket": "A.09-04-002", "docket_full": null, "issued_date": null, "source_page_url": "https://docs.cpuc.ca.gov/PUBLISHED/FINAL_DECISION/121393-16.htm", "pdf_download_url": "https://docs.cpuc.ca.gov/PUBLISHED/FINAL_DECISION/121393-16.htm", "captured_at": "2026-06-08", "source_note": "CPUC Decision D.10-07-049, Application A.09-04-002 — SCE Energy Resource Recovery Account (ERRA) compliance and reasonableness review. Published HTML decision (docs.cpuc.ca.gov); fetch=false (HTML, like the other CA ERRA decisions). The HTML body does not carry an explicit issuance day -> issued_date null. Content verified: 'D1007049 SoCal Edison Co. Energy Resource Recovery Account Compliance and Reasonableness Review.'", "archived_via": null, "page_count": 0, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "CA", "source": "California Public Utilities Commission", "doc_type": "ERRA reasonableness/prudence decision", "id": "2006-01_southern-california-edison_ca-d06-01-007-erra", "company": "Southern California Edison Company", "company_raw": "Southern California Edison Company", "docket": "D.06-01-007", "docket_full": null, "issued_date": null, "source_page_url": "https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/what-is-an-energy-resource-recovery-account-proceeding", "pdf_download_url": "https://docs.cpuc.ca.gov/published/Final_decision/52767-03.htm", "captured_at": "2026-06-07", "source_note": "CPUC Decision D.06-01-007 — the Energy Resource Recovery Account (ERRA) reasonableness/prudence review for Southern California Edison Company; the Commission rejected the Division of Ratepayer Advocates' recommended $16.36M disallowance for hour-ahead-market transactions, finding SCE's least-cost-dispatch process reasonable. ERRA is California's annual fuel & purchased-power prudence determination. Adopted January 2006 (the CPUC decision number D.YY-MM-NNN encodes the adoption year+month); `issued_date` is left null because the exact adoption day is not carried in the CPUC HTML decision and is not inferred. Listed for reference (metadata-only; published as HTML on the CPUC document portal). Source: CPUC (docs.cpuc.ca.gov/published/Final_decision/52767-03.htm).", "archived_via": null, "page_count": 1, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 2, "findings": [ { "index": 1, "title": "Disallowance: $16.36 million", "summary": "act in the most cost-effective manner and that a monetary penalty was appropriate. DRA recommends a $16.36 million disallowance ($7.91 million for on-peak hour-ahead sales and $8.45 million for off-peak hour-ahead sales) for SCE selling energy in the hour-ahead market at u", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false }, { "index": 2, "title": "Approval: $7.91 million", "summary": "st-effective manner and that a monetary penalty was appropriate. DRA recommends a $16.36 million disallowance ($7.91 million for on-peak hour-ahead sales and $8.45 million for off-peak hour-ahead sales) for SCE selling energy in the hour-ahead market at unreasonable prices", "is_other_matter": false, "recommendations": [], "themes": [], "cost_to_customers": false } ], "structured": true, "themes": [], "cost_to_customers": false }, { "collection": "state_rate_case", "jurisdiction": "CA", "source": "California Public Utilities Commission", "doc_type": "ERRA reasonableness/prudence decision", "id": "2003-12_san-diego-gas-and-electric_ca-a02-12-028-d03-12-063-erra", "company": "San Diego Gas & Electric Company", "company_raw": "San Diego Gas & Electric Company", "docket": "A.02-12-028", "docket_full": null, "issued_date": null, "source_page_url": "https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/what-is-an-energy-resource-recovery-account-proceeding", "pdf_download_url": "https://docs.cpuc.ca.gov/published/Final_decision/32806-01.htm", "captured_at": "2026-06-07", "source_note": "CPUC Decision D.03-12-063, Application A.02-12-028 — the Energy Resource Recovery Account (ERRA) reasonableness review for San Diego Gas & Electric Company's fuel and purchased-power costs. ERRA is California's annual fuel & purchased-power prudence determination. Adopted December 2003 (the CPUC decision number D.YY-MM-NNN encodes the adoption year+month); `issued_date` is left null because the exact adoption day is not carried in the CPUC HTML decision and is not inferred. Listed for reference (metadata-only; published as HTML on the CPUC document portal). Source: CPUC (docs.cpuc.ca.gov/published/Final_decision/32806-01.htm).", "archived_via": null, "page_count": 1, "scanned_pages": [], "ocr_used": false, "audit_period": null, "industry": "electric", "audit_type": null, "functions": [], "forms": [], "finding_count": 0, "findings": [], "structured": false, "themes": [ "Fuel & purchased-power cost recovery" ], "cost_to_customers": false } ]