FERC Transmission Ratemaking

FERC Transmission Ratemaking

April 24-25, 2023 | Online :: Central Time

“Very good information and timely discussion of current issues.” Director, Electric Transmission Engineering, Montana-Dakota Utilities Co.

“Overall, this was a very informative FERC formula rate training class.” Lead Rates & Regulatory Analyst, Duke Energy

“Every time I have attended an EUCI training event, I was thoroughly pleased.” Paralegal II, Ameren

“I appreciate the flexibility of EUCI and their ability to offer engaging and informative courses. I learned a lot and will continue to look for available online courses.” Dominion Energy

The Federal Energy Regulatory Commission (FERC) has always maintained a significant presence in the electric industry in regulating the rates, terms, and conditions by which utilities provide wholesale transmission service. The electric industry’s transformation has expanded FERC’s traditional role as rate regulator. Against this backdrop, FERC is addressing the expansion of Regional Transmission Operators (RTOs) and changes to RTOs’ goals and strategies regarding transmission investment, the continued proliferation of new renewable energy sources connecting to the U.S. transmission grid, and rules governing wholesale market participation and interconnection of demand response, energy storage, and energy efficiency resources. FERC is also re-evaluating its policies towards return on equity levels and incentives for FERC jurisdictional transmission rates. Today, more than ever, having a thorough understanding of transmission rate setting is critical to the success of all interested stakeholders.

Attendees of this program will learn the fundamentals of federal transmission rate regulation and cost of service-based rate setting as applied today. They will explore how important FERC initiatives may impact transmission rates and service in the future. Attendees will also learn practical rate setting skills such as how to determine a transmission revenue requirement and how to establish transmission rates using commonly available data sources. Real world examples and dynamic interactive discussion of seminar topics will provide attendees with a keen appreciation for the nuances of transmission rate regulation.

Learning Outcomes  

  • Review the key statutes, regulations, and FERC orders that form the foundation governing transmission rates
  • Identify how to prepare, defend, or oppose a transmission rate filing
  • Explore the financial and operating data used to prepare a transmission cost of service and rate study
  • Assess and evaluate the differences between stated and formula rates
  • Review recent transmission rate setting FERC policy developments that can affect future transmission rate setting
  • Discuss regional and market differences in process and application of transmission rate setting activities

    Agenda

    Monday, April 24, 2023 : Central Time

    8:45 – 9:00 a.m.
    Log In and Welcome

    12:30 – 1:15 p.m.
    Lunch Break

    9:00 a.m. – 4:30 p.m.
    Course Timing

     

    Legal and Policy Introduction and Background

    • Legislative and Regulatory Framework for Electric Transmission Rate Setting
      • Overview and Purpose – Transmission as Natural Monopoly Regulation; The Regulatory Compact
      • Hope and Bluefield Decisions – Prudent Investments; Just and Reasonable Rates
    • Legislative Structure
      • Jurisdictional Divide Between Retail (States) and Wholesale (Federal)
      • FPA Section 205 ‐ Structure and Relevance to Rate Setting
      • FPA Section 206 ‐ Structure and Relevance to Rate Setting
      • Energy Policy Act 2005 ‐ FPA Section 219, Repeal of PUHCA 1935 With Expanded FERC Jurisdiction
    • FERC Regulatory History
      • Order 888/889/890 – Opened Transmission Markets
      • Order 2000 – Establishing ISO/RTO Framework
      • Order 679 – Transmission Incentives
      • Order 1000 (2011) – Competitive Transmission Planning
      • Orders 719 and 745 – Demand Response Wholesale Market Participation
      • Order 841 (2018) – Energy Storage Wholesale Market Participation

    Rate Regulation Under the Federal Power Act (FPA)

    • FPA Structure and Filing Timelines/Considerations
      • FPA Section 205 Filings
      • FPA Section 206 Filings
      • Key Procedural and Legal Aspects to Each Type of Filing Including Burden of Proof
      • Filing Timelines and Process
      • Regulatory Strategy Considerations
    • Fundamental Components of a 205/206 Filing and Evidentiary Showing
      • Cost of Service and Revenue Requirements Study
      • Depreciation Study
      • Cost of Capital Study
      • Other Special Studies Such as Power Flow Analysis
      • Accompanying Expert Testimony
      • Review of Other Evidentiary Showing Requirements

    Focus on Revenue Requirements and Cost of Service Development

    • Major Sources and Tools
      • Uniform System of Accounts – Purpose and Use
        • Review of Major Transmission Related Account Series
      • FERC Form 1 – Review and Introduction as Study Source
    • Revenue Requirements Formula
    • Cost of Service Study Components
      • Three Step Process: Functionalization, Classification and Allocation
        • Rate Base – 13‐Month Average Approach
          • Rate Base Special Topics
        • O&M and A&G
        • Depreciation
        • Taxes
      • Cost Allocation and Assignment Topics
        • FERC 7 Factor Test
        • General Plant, A&G, Working Capital, Other
        • Regional and Inter‐Regional Cost Allocation

    Rate Design

    • Formula Rates
      • Transmission Formula Rate Template: Basis and Function
      • Inputs into Formula Rate – Uniform System of Accounts, FERC Form 1
      • Transmission Rate Protocols
        • 2014 Guidance Paper
        • Recent Precedent
    • Stated Rates
      • Approach and Theory
        • Test Year
        • Cost Allocation
    • Trade‐offs Between Using Stated vs. Formula Rate Approach
    • Billing Parameters
      • 1 CP, 4 CP, 12 CP
      • Network Integration T Service (NITS), Point to Point Service (PTP)
      • Load Ratio Share Basis Use

    Tuesday, April 25, 2023 : Central Time

    8:45 – 9:00 a.m.
    Log In

    9:00 a.m. – 12:00 p.m.
    Course Timing

    Current Issues

    • Recent ROE Decisions Pre‐Coakley, Post-Coakley
    • FERC Investigation into Transmission Incentives: Order 679, 2012 Policy Statement, 2019 Notice of Inquiry
    • Changes to Income Tax Allowance Policy
    • Update on Order 841 and How Energy Storage May Affect Transmission Market

    Instructors

    Matthew Bly, Partner, Duncan & Allen

    Mr. Bly’s practice focuses on representing public power entities, municipalities and rural electric cooperatives, states and state agencies, large energy consumers and trade organizations, renewable energy project developers and interest groups, Native American Tribes, telecommunications firms, and grid edge technology companies in administrative litigation and settlement proceedings, appeals of agency decisions, and in various other state and federal matters concerning energy and environmental regulation, enforcement actions, and commercial interests. He regularly represents clients before federal and state courts and regulatory bodies on a broad range of matters affecting the domestic energy and utilities industries, including issues such as: utility rate design and regulatory ratemaking; contract drafting, negotiation, and interpretation; utility depreciation, accounting, and financial reporting requirements; mergers and acquisitions; transmission planning and systems integration; open-access requirements; federal vs. state jurisdiction; the governance, restructuring, expansion, and operation of organized wholesale energy markets; greenhouse gas regulation and renewable resource investment incentives; energy efficiency and sustainability; and Bulk Power System reliability standards, compliance, audits, and enforcement. Mr. Bly is also frequently called upon to advise clients on various implementation and compliance obligations imposed and enforced by entities such as FERC, NERC, DOE, EPA, and state regulatory bodies throughout the country.

    As an active member of the Energy Bar Association, Mr. Bly served as Chair of the State Commission Practice Committee from 2019-2020, served as Vice Chair of the State Commission Practice Committee from 2018-2019, and co-authored both the 2018 and the 2019 State Commission Practice Reports published by the Energy Law Journal.


     Miles Kiger, Associate, Troutman Pepper  

    Miles represents utility transmission owners, energy producers, and other electric power market participants in proceedings before the Federal Energy Regulatory Commission and federal courts. He also counsels wind, solar, and battery storage developers on RTO market policy and entry, and advises them on mergers and acquisitions, market-based rate, and PURPA qualifying facility matters. Miles regularly develops filings under Section 205 of the FPA, and litigates tariff, contract, and market design disputes under FPA Section 206, including in challenges before the U.S. Courts of Appeals. Clients rely on Miles’ ability to communicate in plain English on highly technical issues and to devise workable strategies that maximize the opportunities presented by the energy transition. 

    Miles draws on his experience at FERC, where he advised the Commission on a wide array of energy market and electric rate proceedings. Miles also has significant cost-of-service ratemaking and administrative litigation experience, having prepared and testified in support of retail rate cases for American Water Co. and EPCOR Water prior to law school. 

    Miles holds an advanced degree in economics, writing a thesis that tested a question from the environmental federalism literature, i.e., whether a uniform national drinking water standard was economically efficient from one state’s perspective, in addition to analyzing the law’s distributional impacts. 

    Online Delivery

    We will be using Microsoft Teams to facilitate your participation in the upcoming event. You do not need to have an existing Teams account in order to participate in the broadcast – the course will play in your browser and you will have the option of using a microphone to speak with the room and ask questions, or type any questions in via the chat window and our on-site representative will relay your question to the instructor.

    • IMPORTANT NOTE: After November 30 you will not be able to join a Teams meeting using Internet Explorer 11. Microsoft recommends downloading and installing the Teams app if possible. You may also use the Edge browser or Chrome.
    • You will receive a meeting invitation will include a link to join the meeting.
    • Separate meeting invitations will be sent for the morning and afternoon sessions of the course.
      • You will need to join the appropriate meeting at the appropriate time.
    • If you are using a microphone, please ensure that it is muted until such time as you need to ask a question.
    • The remote meeting connection will be open approximately 30 minutes before the start of the course. We encourage you to connect as early as possible in case you experience any unforeseen problems.

    Register

    Please Note: This event is being conducted entirely online. All attendees will connect and attend from their computer, one connection per purchase. For details please see our FAQ

    If you are unable to attend at the scheduled date and time, we make recordings available to all registrants for three business days after the event

    REGISTER NOW FOR THIS EVENT:

    FERC Transmission Ratemaking

    April 24-25, 2023 | Online
    Individual attendee(s) - $ 1195.00 each

    Volume pricing also available

    Individual attendee tickets can be mixed with ticket packs for complete flexibility

    Pack of 5 attendees - $ 4,780.00 (20% discount)
    Pack of 10 attendees - $ 8,365.00 (30% discount)
    Pack of 20 attendees - $ 14,340.00 (40% discount)

    Your registration may be transferred to a member of your organization up to 24 hours in advance of the event. Cancellations must be received on or before March 24, 2023 in order to be refunded and will be subject to a US $195.00 processing fee per registrant. No refunds will be made after this date. Cancellations received after this date will create a credit of the tuition (less processing fee) good toward any other EUCI event. This credit will be good for six months from the cancellation date. In the event of non-attendance, all registration fees will be forfeited. In case of conference cancellation, EUCIs liability is limited to refund of the event registration fee only. For more information regarding administrative policies, such as complaints and refunds, please contact our offices at 303-770-8800

    CEUs

    Credits

    AP_Logo

    EUCI is accredited by the International Accreditors for Continuing Education and Training (IACET) and offers IACET CEUs for its learning events that comply with the ANSI/IACET Continuing Education and Training Standard. IACET is recognized internationally as a standard development organization and accrediting body that promotes quality of continuing education and training.

    EUCI is authorized by IACET to offer 1.0 CEUs for this event.

    Requirements for Successful Completion of Program

    Participants must log in each day and be in attendance for the entirety of the course to be eligible for continuing education credit.

    Instructional Methods

    PowerPoint presentations, interactive group exercise, and group discussion will be used during this course.


    Upon successful completion of this event, program participants interested in receiving CPE credits will receive a certificate of completion.

    Course CPE Credits: 11.5
    There is no prerequisite for this Course.
    Program field of study: Specialized Knowledge
    Program Level: Basic
    Delivery Methood: Group Internet Based
    Advanced Preperation: None

    CpeEUCI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org

     

     

    Who Should Attend 

    • Utility analysts, attorneys, supervisors, and directors without previous electric transmission ratemaking experience
    • Managers and supervisors of municipal and cooperative utilities
    • Transmission customers with significant transmission rate exposure
    • Investors and financial analysts seeking a better understanding of transmission cost recovery
    • Regulatory and legislative personnel dealing with transmission ratemaking as overseen by FERC
    • Newcomers to the industry or to cost-of-service ratemaking working in areas such as legal, financial, regulatory, customer care, or community relations

     

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