LOWER VALLEY ENERGY FALL RIVER ELECTRIC COOPERATIVE BEARTOOTH ELECTRIC COOPERATIVE Evaluation of Potential Consolidation Between Lower Valley Energy, Fall River Electric Cooperative and Beartooth Electric Cooperative April 20, 2016 Prepared by: 570 Kirkland Way, Suite 100 Kirkland, Washington 98033 A registered professional engineering corporation and management consulting firm with offices in Kirkland, WA and Portland, OR Telephone: (425) 889-2700 Facsimile: (425) 889-2725 www.eesconsulting.com PRIVILEGED AND CONFIDENTIAL April 20, 2016 Mr. Jim Webb Lower Valley Energy P.O. Box 188 Afton, WY 83110 SUBJECT: Mr. Bryan Case Fall River Electric Cooperative 1150 N 3400 E Ashton, ID 83420 Evaluation of Potential Consolidation between Lower Valley Energy, Fall River Electric Cooperative and Beartooth Electric Cooperative Dear Mr. Webb: It is with pleasure that we submit our final evaluation of the potential consolidation between Lower Valley Energy, Fall River Electric Cooperative and Beartooth Electric Cooperative. We appreciate all of the help you have provided in conjunction with this study. Please feel free to contact me directly with any questions or comments. Very truly yours, Gary Saleba President 570 Kirkland Way, Suite 100 Kirkland, Washington 98033 Telephone: 425 889-2700 Facsimile: 425 889-2725 A registered professional engineering corporation with offices in Kirkland, WA and Portland, OR PRIVILEGED AND CONFIDENTIAL Contents Introduction and Background ......................................................................................................... 1 Consolidation Overview .................................................................................................................. 3 Economic Analysis ........................................................................................................................... 9 Rate Comparisons ......................................................................................................................... 21 Summary, Conclusions and Recommendations ........................................................................... 27 POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC I PRIVILEGED AND CONFIDENTIAL Introduction and Background Lower Valley Energy (LVE) and Fall River Electric Cooperative (FR) are considering a potential consolidation between the two utilities in order to provide more efficient service to members. Currently LVE is providing management services to Beartooth Electric Cooperative (BEC) under a three year contract. An option where BEC is included in a consolidation with LVE and FR is now being considered as well. EES Consulting, Inc. (EES) completed a study for LVE and FR in November 2015 to review the potential savings associated with a potential consolidation and review some of the steps necessary to proceed. The addition of BEC to the consolidation is added to the economic analysis previously completed and presented in this report. This report provides a discussion of considerations related to the potential three-way consolidation and provides an economic analysis to quantify the expected savings and benefits under a combined utility and how those savings would impact retail rates for members. The findings of the consolidation of just LVE and FR are included in this report, and the results of adding BEC to the consolidation are presented in incremental terms as well in the total impacts for all three utilities. By showing the incremental savings for BEC, this could also serve as the results for a scenario where LVE and BEC merged without the inclusion of FR. LVE serves roughly 27,000 electric customers and 4,000 gas customers in western Wyoming and eastern Idaho. It is a cooperative with a seven-person Board of Directors and 65 employees. Offices are located in Afton and Jackson, WY. FR is an electric cooperative serving southeast Idaho, western Wyoming and southwest Montana with headquarters in Ashton, ID. It serves roughly 16,000 customers. It is overseen by a nineperson Board of Directors and has 46 employees. BEC is an electric cooperative serving southern Montana and northern Wyoming with headquarters in Red Lodge, MT. It serves roughly 6,000 customers (meters). It is overseen by a seven-person Board of Trustees and has 14 employees. The cooperatives have entered into discussions regarding a potential consolidation between the three utilities. While discussions are in the early stages, a basic overview of a consolidated utility has been identified. This study is based on that broad overview and is subject to change as discussions continue. The goal of the parties is to generate cost savings on behalf of its members through the efficiencies associated with a combined utility. It is expected that the majority of these savings would come through reducing staff and expenses in areas that overlap, including management, accounting, computer systems and Board of Directors’ expenses. It is important to note that these efficiencies can be accomplished through retirements of staff and other attrition and will not result in layoffs of employees. In terms of timing, a consolidation would need to be approved by all three utilities at a Board of Directors meeting, currently expected to occur in September of 2016. FR bylaws require a 2/3rd POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 1 PRIVILEGED AND CONFIDENTIAL vote of all membership to approve the consolidation. LVE would require a simple majority of all members to approve the consolidation. BEC would need to accommodate a Montana law that would require a 2/3rd vote of those members that vote as well as a WY law requiring the majority of all members. In this case the lawyers will need to determine how these two different lawa would apply to BEC. The expected timing would allow for review and preparation prior to those Board of Directors meetings. Although a precise date for implementing the potential consolidation has not yet been identified, it is assumed to be July 1, 2017 for purposes of this study. It is the objective of this study to address some of the issues to consider with respect to the potential consolidation as well as identify the estimated financial impacts with a combined utility. The following section lays out an overview of a potential consolidation and provides a brief analysis of issues to consider. The subsequent section provides an economic analysis to determine the estimated cost savings with a combined utility compared to continued operation of separate utilities. This is followed by section on potential rate impacts associated with a consolidation. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 2 PRIVILEGED AND CONFIDENTIAL Consolidation Overview This section describes the issues that will need to be addressed in the event of a consolidation between LVE, BEC and FR. These are issues that need to be considered as part of the decision making process by the utilities. A game plan for addressing these issues under a consolidated utility will need to be developed if the utilities decide to consolidate. In some cases, such as staffing, further discussion is provided in the economic analysis section as the issue includes some potential savings under a consolidation. The following key topics are addressed in this section of the report: Governance and Board of Directors Oversight Management and Staffing Finance and Accounting Engineering and Operations Public Relations and Communication The issues included within this section, as well as the following sections, have been discussed with the General Managers at both LVE and FR. Note that this includes input for BEC as the management is now being performed by LVE. The Boards at LVE and FR have been provided with the results of the consolidation study for the two utilities and have had a chance to provide some input, while the BEC Board has provided input with respect to the management agreement but not yet for an actual consolidation. Governance and Board Oversight With a consolidation of the three utilities, there would be various legal issues associated with forming the new utility that would need to be addressed by legal counsel. EES Consulting is not providing a legal opinion of the steps that need to be taken but is addressing some of the business decisions that will need to be made. While the timing of the potential consolidation is assumed to be July 1, 2017 for purposes of this study, an exact date would be dependent upon the legal process, approvals required, and management and Board agreements that would need to be reached. A business agreement between the utilities would be the first step in the process and would need input from both management and the Boards of LVE, BEC and FR. From there a legal agreement could be drafted that would encompass the business agreement and any other necessary legal steps required. While a general business agreement that includes the basic framework of the consolidation would be necessary, some of the major decisions could be made by the Board of the new utility once the consolidation took place. Many of the detailed decisions would also be most effectively made by the combined management under the new utility. Currently LVE and BEC both have seven board members and FR has nine board members. For LVE and FR alone, the previous study discussed an initial consolidation reflecting the combining POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 3 PRIVILEGED AND CONFIDENTIAL of two equal partners, and it was expected that each utility would have an equal number of members on the new Board. With the addition of BEC, there would need to be a different split in voting that would reflect the inclusion of three different parties. For practical reasons, all three utilities would need to reach a general consensus on major issues to make the consolidation work for all parties. The initial make-up of the Board would need to be included as part of the business agreement. While this initial Board make-up would be required during the start-up and transition phase to ensure that the existing utilities are fairly represented to make the major decisions for the consolidated utility, this Board make-up would need to be simplified and reduced over time to provide a manageable Board. It is expected that this initial Board make-up would only apply for the first three years. Typically a cooperative Board would have an uneven number of members with staggered election terms. As with the current utilities, using separate districts to reflect the members within the various geographical regions of a consolidated utility may provide the best assurance that all members are represented in the future. A move towards the final Board composition could be made all at once at the end of a transition period or it could be done over a phase-in period that would reflect the natural election cycles of the current Board members. It is recommended that the agreement contains a specified transition period for the initial Board and that after that time period the Board would be formed based on districts with equal membership per District throughout the combined service area. While this report is designed to reflect a consolidation of all three utilities, it does not preclude the consolidation of just LVE and FR or just LVE and BEC. There is also a possibility that the utilities could consolidate at two different times, however, it may be more efficient for a single consolidation all at one time. Bylaws for the new utility would need to be developed. It is expected that the current bylaws of each utility have many common provisions. Any items that have conflicting provisions would need to be resolved. Also, changing the bylaws would need to meet the legal requirements in all three states and legal review is required for this issue. Finally, a new name that would reflect the combined geographical areas and history of the current utilities would need to be selected. This decision would need to be made as part of the business agreement so there would be ample time to develop a communication plan for the members prior to the actual consolidation date. As with other issues, this could include an immediate change at the time of the consolidation or a more phased-in approach with an initial combined name in place initially and a move towards a shorter name after a few years. Management and Staffing As there are two general managers at the present time there would need to be some consolidation in management. As BEC is currently managed by LVE, the duplication in management does not exist for BEC. It is expected that there will be additional work during the transition period to develop all of the structures and protocols for the new utility, as well as provide information to the Board so that they can make the necessary decisions for the POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 4 PRIVILEGED AND CONFIDENTIAL consolidated utility. Communication with staff and utility members will also be vital during the transition period. And the day-to-day running of the utilities will still be necessary. The structure of top management could include co-general managers, a general manager and an assistant general manager, a chief executive officer and chief operations officer, or a transition manager and operations manager. Tasks would need to be split between the two managers and a clear reporting structure would need to be established. After the transition period the Board would select one permanent General Manager to run the consolidated utility. The existing General Managers would need to evaluate the next tier of management and develop a new reporting structure for those staff. There will be some overlap in management, however, it is expected that retirements will take care of the overlap over a few years. Early retirement offers for both management and other staff may be necessary to speed up the process. There may need to be some temporary assignments made to deal with transition issues before the final management structure would be in place. There will also need to be management in place at all locations over the short term until decisions are made about permanent office locations. For remaining staff, any reductions are expected to occur through retirements and normal attrition. There may need to be some re-assignments in positions and in a few cases there may need to be some re-locations. For the most part, staff will be needed at all locations to meet operational and customer service needs. Current technology also allows for coordination of staff located in different locations. Staffing levels and potential cost savings are addressed further in the next section. Note that for BEC, savings in staff would not be based on further reductions from existing levels but rather in comparison to a standalone case where BEC would have to hire back top management at the end of the LVE agreement. During the transitional period of the new utility, it is expected that the LVE and FR headquarters will be maintained with administrative and operational staff at each site. BEC’s location has remained in use for local operational staff under the management agreement. After the consolidation it is expected that the new Board will need to consider the optimal location for the administrative headquarters. This may be at one of the current locations, or at a new site that is centrally located to the combined service area. Operational staff will still need to be located throughout the service area to reach the various facilities in a timely manner. Added travel will be required by both management and staff during the transition period to effectively manage staff, to coordinate joint projects, for cross-training of staff and for transitioning functions such as billing, accounting, IT, etc. to one system. Finance and Accounting The various financial aspects of the utilities would need to be combined under a consolidated utility. This would include existing and new debt, accounting systems and procedures, customer billing systems and procedures as well as all of the IT and communications systems. In most cases the utilities have their own systems in place and a decision will need to be made whether one of the current systems, or a new system, would be implemented after the consolidation. Under the management agreement some migration in systems for BEC has already been made, but more POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 5 PRIVILEGED AND CONFIDENTIAL would need to be done under a consolidation. There may need to be some redundancy in systems during the transition period to provide a smooth transition, allow time for migration of data and avoid any interruption in required service. Rather than making these types of decisions as part of the business agreement, it would be recommended that key staff from all utilities work together to develop the best solution considering both cost-effectiveness and workability. Their recommendations would be reviewed by the management and Board as needed prior to implementation. In terms of existing debt, it is expected that all existing debt would be retained as is with a simple change in the utility name as required under the provisions of the debt. New debt would be issued as needed by the new utility. The exception would be for RUS debt at BEC. BEC currently has over $7 million in debt with RUS. Because LVE and FR do not carry RUS debt, it would be easier to pay off that debt and refinance with CFC or amortize the up-front cost over time. There would be a $1.5 million pre-payment penalty associated with this debt. It was assumed for this study that the pre-payment (debt plus penalty) would be refinanced for the remaining 27 years term of the debt. The refinance would add the $1.5 million penalty to the principal but would be at a slightly reduced interest rate, resulting in added costs of $42,734 per year. While there may be some one-time transition costs required in order to implement the consolidation, it is expected that each utility would need to contribute to the cost in an equitable manner for any costs incurred prior to the consolidation. After the consolidation, funds would be combined and would be used as needed to fund any required consolidation costs. Funding issues prior to the consolidation implementation would need to be part of the business agreement. Rates for the three utilities are considerably different at the present time with LVE rates significantly lower than FR rates, and FR rates considerably lower than BEC rates. Options for rates under a consolidated utility are discussed in more detail in a later section of this report. Because of the rate differences, it is expected that different rates will need to be maintained over the short term, if not indefinitely. While that will be a decision for the new Board at a later time, it will be important to set up a billing system that can accommodate regional rates. In addition, tracking some of the costs separately for the various regions will need to continue in order to provide the cost basis for future rate differentials by region. Costs that are common to all regions will need to be allocated between the regions. Over time this may become more difficult as the separation between the utilities becomes blurred and more costs are incurred for joint projects. The utilities are looking at potential rate impacts associated with allocating the common costs of a consolidated utility on a regional basis outside of this study. Engineering and Operations A consolidated utility will require a total system approach for engineering and operations of the utility. While some aspects will be simple to view as a whole and managed on a more global basis, operations at the more local level may continue to be managed on a more regional basis. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 6 PRIVILEGED AND CONFIDENTIAL Power supply and transmission purchases for LVE and FR from BPA will not be combined under the consolidation due to FR’s existing membership in PNGC. For that reason, no savings are expected in power supply costs. Both LVE and FR have some of their own small resources and operation of those resources will need to be coordinated to ensure the greatest benefit to the combined utility. Planning for future power supply in light of BPA’s tiered rates will also need to be completed on a global basis, taking into account any FR commitments with PNGC. As BEC is served from a different power supply source and interconnection point, power purchases will continue to be separate and no specific savings will result from diversity with the other utilities. Currently FR is a member of PNGC Power and receives services from the organization related to planning, reporting and operations of power supply and transmission. LVE is a member of Northwest Requirements Utilities (NRU) which provides information and advocacy services related to power supply and transmission. There is overlap between the services provided by these two organizations, and LVE provides some of its own reporting using internal staff compared to FR’s use of reporting services from PNGC. Note that BEC recently exited from Southern and the costs associated with that exit have already been included in retail rates. For utility owned transmission, planning will need to be done on an integrated basis for the consolidated utility. Whether or not there are benefits associated with a direct interconnection between the utilities is something that should be examined by engineering staff after the consolidation. One benefit of the consolidation would be a reduction in time and reporting associated with WECC. Due to some inadvertent flows from LVE to FR, WECC reporting for LVE is more complex than for a typical distributing utility. This will no longer be an issue after the consolidation. Distribution planning and operations will continue to be examined on a local level, however, standards and operating criteria will need to be standardized for the consolidated utility. As with other functions, this is best completed by studying the alternatives cooperatively among existing staff. While it is expected that crews will be maintained at the current locations spread throughout the combined service area, those crews will need to adhere to any new standards and protocols established for the new utility. It is expected that cross-training of staff between the existing utilities will provide benefits and that new safety and other employee training will be done in a coordinated manner. Public Relations and Communications With a consolidation, communication with members will be a critical factor. This includes information made publically available during the decision-making process, information required prior to the FR membership vote, and information that is important for the membership in preparation for a consolidation once an agreement is reached. While the majority of this will be aimed at members, it will be important to inform employees of the status of the potential consolidation and what it will mean to them personally as well as how the new utility will operate. BEC and LVE recently managed a successful communication plan associated with the management agreement. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 7 PRIVILEGED AND CONFIDENTIAL During the decision-making process it will be important to provide a limited amount of information ahead of the process so that rumors and misinformation are not spread among staff and members. For the membership vote required by the utilities, and specifically in the case of FR where a 2/3rd of full membership vote is required, background information will need to be distributed to explain the rationale for the consolidation, the potential savings and how the Board of Directors will work under the new utility. Generally this type of information is distributed through direct mailings and advertising as well as open meetings to allow for a presentation along with the ability for members to ask questions. At the same time, meetings with staff would need to be held to ensure their concerns and questions are answered. It is typical to provide a list of frequently asked questions and answers to cover details associated with the consolidation. The utilities are working on a coordinated effort to determine what would be required for the membership vote in each case and the cost for that process has been excluded from this study as it would occur prior to a final consolidation agreement. If a consolidation is approved, a detailed public relations plan will need to be developed to prepare for the consolidation. This would need to address branding, advertising and direct mail and bill stuffer communications. Members will need to be made aware of how the changes will affect them in terms of rates, reliability, contacting the utility, where to pay bills, etc. The plan will also need to address the roll out of the new name, signage, contact numbers and addresses for the utility. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 8 PRIVILEGED AND CONFIDENTIAL Economic Analysis To quantify the potential efficiencies associated with the potential consolidation between FR, BEC and LVE, the expected savings in expenditures for a combined utility were determined for various system accounts. Savings were expected to occur in staff salaries and benefits, reduced consultant and contractor costs, reductions in publications, public relations and advertising, warehouse savings, and competitive bid savings. More details on quantifying savings in those categories are provided below. In all cases the individual utility budget by line item was used as the starting point for the analysis of savings. The 10-year financial forecast for the utilities was also incorporated into the analysis, and extended to run through 10 years after the potential consolidation. For the case of BEC, the 2016 budget was used as the starting point for both 2016 and 2017, as those years both reflect having the management agreement with LVE in place. After 2017, it was assumed that in the base case BEC would revert back to self-management. This required adding staff back into the costs, reverting certain expense items back to the 2014 level, and eliminating the cost of the management agreement. A 2% rate of inflation was applied to all costs for the years 2016 through 2026. For those line items where savings were expected, the percent of the budget that would be saved was estimated to determine the total dollar savings expected in each year. The analysis then provides a long-term estimate of costs for a combined utility in comparison to the sum of the two individual utilities without a consolidation, assuming an implementation date of July 1, 2017. Any accounts not specifically addressed in this section were assumed to be the same with or without the potential consolidation. To determine the overall impacts on members, the estimated savings were subtracted from the forecast costs for the individual utilities combined, resulting in a net percent savings amount related to the consolidation. In the future, rates may or may not be equalized between the service areas. A more detailed discussion of rates is included in the next section. To corroborate the potential savings, a look at benchmarking of staff and costs for other utilities of the same size was completed. The Washington PUD Association provides a periodic benchmarking report showing the staffing levels and various cost categories for the PUD’s in the state. For the utilities of comparable size to LVE and FR the staff levels and expenses other than power supply costs were well above LVE and FR current levels. For the larger utilities that would be comparable to the size of the consolidated utility there were four comparable PUD’s that were also BPA purchasers without their own generation to manage. Again, the staff levels for these utilities were in the range of 150 staff compared to the total combined staff of LVE and FR of 106 for the electric business. Because of LVE’s and FR’s current levels of efficiency, we determined that the benchmarking approach would not provide any relevant information regarding savings associated with a consolidation. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 9 PRIVILEGED AND CONFIDENTIAL Staffing Reductions Through Retirements LVE has a total electric staff of 60 and FR has a staff of 46 at the present time. BEC has a current staff of 14 with the management agreement in place. It was assumed that three staff would need to be added back in 2018 if the utility were to operate independently. For the gas/propane business LVE has 5 staff and FR has 6 staff in addition to those working for the electric utility. The utilities are facing some retirements over the next 5 years and by not replacing some those positions total costs can be reduced. For purposes of this study positions have been categorized into four categories, as follows: Administrative Member Services Engineering Operations With a consolidated utility there will be some overlap in positions which will allow for reduced staffing overall. There are two issues to consider when looking at reduced staffing. First, there may be additional work during the first year or two of the consolidation and positions may not be able to be eliminated immediately. Secondly, while not replacing retired staff will be the approach used to reach reduced staffing levels, the retirements may not exactly line up with the positions that are overlapping. For this reason it is expected that some staff may have to shift to alternate positions or responsibilities may change for various positions. This report has not assessed individual positions or responsibilities but rather looks at the overall needs in each of the four categories relative to the expected retirements in each category to determine the overall reduction that can be achieved. Table 1 provides a summary of the number of staff by category for the utilities, as well as the expected retirements as provided by the utilities. Note that this table includes both electric and gas/propane employees. Table 1 Staffing Levels and Retirements Current Staffing Levels Administrative Member Services Engineering Operations Total 1 LVE FR BEC 10 8 13 34 65 4 11 12 25 52 4 2 0 11 17 1 Expected Retirements (through 2021) Total LVE FR BEC Total 18 21 25 70 134 5 2 5 13 25 0 1 4 3 8 0 1 0 3 4 5 4 9 19 37 Note that the staffing includes 3 administrative staff added to current levels in the year 2018. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 10 PRIVILEGED AND CONFIDENTIAL In examining both the overlapping positions and the expected retirements, the number of staff that would be reduced each year by not replacing retired staff was estimated by category. Note that specific staff or positions were not identified and the number from each utility was also not identified. However, the eligible retirement status and positons of various staff at each utility were considered when developing the expected reductions per year. The reductions for the engineering and operations categories are less than the potential retirements. It is expected that many of the positions will need to be filled in those two departments as retirements occur. Table 2 provides the number of positions that would be reduced through retirement for each year and in each category. It was expected that no reductions were applied to the first year as there would be additional work required due to the transition to the consolidated utility. These are estimated numbers per year and the actual timing may differ slightly based upon both needs and staff preferred retirement dates. Also, reductions are assumed to be for the entire year, although in actuality retirements may occur throughout the year. Based on the numbers, the total reduction is roughly 5% per year for 2018 and 2019 and 5% in total for 2020 and 2021. This results in 1 total reduction of 15% across the combined utility. Table 2 Staffing Reductions Through Retirement Administrative Member Services Engineering Operations Total 2017 2018 2019 2020 2021 Total 0 0 0 0 0 3 1 1 1 6 2 1 2 1 6 0 1 1 2 4 0 0 1 1 2 5 3 5 5 18 Note that in the case of BEC, it is assumed that three additional management/administrative staff would be added to the utility in 2018 if a consolidation does not proceed. Because these are not existing positions, they are not included in the staff reductions shown in Table 2. The costs for these three employees are included for BEC without the consolidation starting in 2018, and are not included in the cost of the consolidated utility. Therefore there will be savings shown for BEC as a result of a consolidation, they just do not reflect a cut in existing staff. To determine the dollar savings associated with these reductions, an average annual cost per employee was estimated. While salaries differ among employees, for purposes of this study the average level was used for each staff reduction as the specific staff members have not been identified. There was little difference in the average amounts for the utilities. Based on total labor and benefit expenses identified in the 2015 budgets for the two utilities, and the number of staff, the average loaded cost per employee is roughly $93,000. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 11 PRIVILEGED AND CONFIDENTIAL After applying the average loaded cost to the number of reductions each year, the dollar savings were estimated. Note that these cost savings have also been adjusted to account for inflation each year. The results are provided in Table 3. Note that savings for 2018 are shown based on annual salaries. Actual savings for that year would only apply for the latter 6 months of the year. Table 3 Savings in Staff Expenses per Year 2017 Administrative Member Services Engineering Operations Incremental $ per Year Cumulative $ per Year $0 $0 $0 $0 $0 $0 Administrative Member Services Engineering Operations Incremental $ per Year Cumulative $ per Year $0 $0 $0 $0 $0 $0 Administrative Member Services Engineering Operations Incremental $ per Year Cumulative $ per Year $0 $0 $0 $0 $0 $0 20182 2019 2020 Consolidation of LVE and FR Only $296,077 $201,332 $0 $98,692 $100,666 $102,680 $98,692 $100,666 $205,359 $98,692 $201,332 $102,680 $592,154 $603,997 $410,718 $592,154 $1,207,994 $1,642,872 Added Savings with BEC $441,0003 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $441,000 $0 $0 $441,000 $449,820 $458,816 Consolidation of LVE, FR and BEC $737,077 $201,332 $0 $98,692 $100,666 $102,680 $98,692 $100,666 $205,359 $98,692 $201,332 $102,680 $1,033,154 $603,997 $410,718 $1,033,154 $1,657,814 $2,101,689 2021 Total $0 $0 $104,733 $104,733 $209,466 $1,885,196 $523,666 $314,199 $523,666 $523,666 $1,885,196 $1,885,196 $0 $0 $0 $0 $0 $467,993 $467,993 $0 $0 $0 $467,993 $467,993 $0 $0 $104,733 $104,733 $209,466 $2,353,189 $991,658 $314,199 $523,666 $523,666 $2,353,189 $2,353,189 The total savings associated with staff reductions ranges from over $1.0 million in 2018 (reflects 12 months of savings) to $2.35 million by the year 2021. This reflects a 15% reduction in staff costs and a 2.4% savings to the electric utility overall by year 5 of the consolidation. Contracts, Material & Supplies The next largest category of savings is for contracts with outside parties and materials and supplies that can be reduced. These estimates come from specific accounts in the budget and 2 Reflects annual savings is labor costs for the year. For BEC the savings would occur mid-2018 when the management agreement expires. When BEC labor savings are calculated in total for subsequent tables, only 6 months of these savings would apply. 3 Based on expected cost for senior staff required rather than the average per employee used for other categories. Note that only $352,893 of this would be expensed and the rest would be capitalized. However the full amount is included as savings for the year. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 12 PRIVILEGED AND CONFIDENTIAL are for expense items not associated with labor costs. Expense savings were developed by looking at those functions that contained overlap between the utilities and would therefore first be combined and then reduced under the consolidation scenario. For example, each utility subscribes to professional publications to inform its staff members. As individual utilities, each might subscribe to the same publication and therefore together they pay for and receive 2 or 3 copies of the same thing. After the consolidation this overlap could be eliminated and only one copy ordered. But it is not expected that all of these costs would be split in half. In the example, there may be some national or regional subscriptions that overlap and others that are local and therefore do not overlap. To estimate the savings for each line item where overlap was identified, the total costs for each line item were summed for LVE, BEC and FR as the starting point. From there, a percent savings would be expected in each year was determined. For example, if the utilities have the same expenses associated with publications, then a 40% reduction in the combined cost was applied. In some cases, cost savings were capped at 40% because although there may be duplication of items, the cost may be greater as the utility would be larger with more staff and more employees. Once the reductions in expenses were calculated for the identified line items, they were summed into general categories to match with the overall financial forecast structure. The following table provides the cost per line item and the expected % savings achieved each year. The majority of the savings is within the A&G category for expenses such as computer-related costs, membership dues and Board-related costs. Costs savings in the O&M category do not include any savings or reduction in service levels associated with maintenance of facilities. Costs savings for this category are limited to more efficient training for a combined staff and outside contracting. Whereas the staffing level savings were projected to occur over a 5-year period, the expense savings are projected to occur within a 3-year period. In this case, there are some areas where savings would occur in the first year of the consolidation, although it would reflect only the second half of the year. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 13 PRIVILEGED AND CONFIDENTIAL Table 4 Line Item Expenses and Potential Savings Percent 2015 Combined Budget (LVE + FR) 2015 Combined Budget (LVE+FR+BEC) 2017 % Savings 2018 % Savings 2019 % Savings Computer Software/Equipment/Fees $589,749 $650,749 0% 20% 40% Holiday Party, Longevity $51,880 $51,880 10% 25% 40% Outside Consultants $58,260 $95,751 10% 25% 40% Legal Costs $120,343 $170,343 0% 25% 50% Auditor Fees $27,800 $43,309 0% 20% 40% Publications $6,779 $6,779 0% 5% 10% Dues (Excluding Power Supply) $219,198 $261,198 15% 25% 30% Public Relations/Advertising $47,684 $89,684 20% 30% 40% Meeting Expenses $172,229 $207,229 5% 20% 40% Board Expenses/Annual Meeting $398,457 $629,305 5% 30% 50% $1,692,379 $2,206,227 Communications/Newsletters $85,055 $97,308 10% 20% 40% Bank Fees $60,576 $60,576 20% 30% 40% Credit Card Merchant Fees $272,755 $272,755 0% 5% 10% Subtotal $418,385 $430,638 Employee Training $151,879 $188,787 25% 50% 50% Safety Training $98,131 $98,131 25% 50% 50% Contract Labor & Materials $1,696,501 $1,796,501 5% 15% 25% Subtotal $1,946,511 $2,083,419 TOTAL $4,057,275 $4,720,284 Administrative & General Subtotal Customer Service Operations & Maintenance Based on the 2015 expenses and the percent savings, Table 5 provides the savings expected in each year when all three utilities are consolidated. As the percent savings reflect the cumulative savings in each year, the total savings as shown in Table 5 are also cumulative amounts. In addition, inflation has been used to adjust the savings for each year. After year 3 the savings are expected to continue for the entire 20-year period. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 14 PRIVILEGED AND CONFIDENTIAL Table 5 Line Item Expenses and Potential Savings 2017 Savings 2018 Savings 2019 Savings $0 $5,398 $9,962 $0 $0 $0 $40,762 $18,662 $10,780 $32,736 $118,300 $138,116 $13,764 $25,403 $45,192 $9,192 $360 $69,296 $28,552 $43,983 $200,347 $574,205 $281,757 $22,463 $41,458 $92,192 $18,752 $734 $84,819 $38,831 $89,724 $340,590 $1,011,319 $10,124 $12,605 $0 $22,728 $20,653 $19,285 $14,472 $54,410 $42,132 $26,228 $29,524 $97,883 Subtotal $49,104 $25,524 $93,454 $168,081 $100,171 $52,069 $285,969 $438,209 $102,175 $53,110 $486,148 $641,432 TOTAL $309,110 $1,066,824 $1,750,634 Administrative & General Computer Software/Equipment/Fees Holiday Party, Longevity Outside Consultants Legal Costs Auditor Fees Publications Dues (Excluding Power Supply) Public Relations/Advertising Meeting Expenses Board Expenses/Annual Meeting Subtotal Customer Service Communications/Newsletters Bank Fees Credit Card Merchant Fees Subtotal Operations & Maintenance Employee Training Safety Training Contract Labor & Materials With LVE and FR only, the total savings associated with these overlapping expenses is $1.45 million, or nearly 10% of total combined O&M and A&G costs. This also reflects a savings of 1.7% of the total combined revenue requirement after three years. Adding BEC to the consolidation provides an incremental savings of $300,000. A large portion of this savings results from separate training for BEC staff and contract labor which would be required if BEC was a standalone utility. The final savings with all three utilities, as shown in Table 5, are $1.75 million, reflecting 11% savings to combined O&M and A&G costs and 1.9% of the total combined revenue requirements after three years. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 15 PRIVILEGED AND CONFIDENTIAL Capital Cost Savings With a consolidation, it is expected that some savings will occur for capital related costs. One of these savings would come from maintaining a smaller inventory as the inventory for larger items could be shared. A second type of savings would occur from being a larger utility and benefitting from more competitive bidding on equipment and contracts. A third type of savings would be from the consolidation of offices in the future. For LVE and FR alone, warehouse savings are estimated at $10,000 per year and competitive bidding savings are estimated at $10,000 per year. For BEC, another $10,000 for warehouse and $10,000 for competitive bidding savings would be expected, however, savings would begin earlier as they are already taking place under the management agreement and would continue automatically with a consolidation. Office consolidation savings are estimated at $50,000 per year starting in year 5. This savings reflects the utility, maintenance and other operating costs for the facility as well as avoidance of rent, rental income for leasing unused space or amortization of the sale of a building. Table 6 Capital Related Savings 2017 2018 2019 2020 2021 Consolidation of LVE and FR Only Warehouse Savings $0 $10,000 $10,200 $10,404 $10,612 Competitive Bidding $0 $10,000 $10,200 $10,404 $10,612 Office Consolidation $0 $0 $0 $0 $50,000 Total per Year $0 $20,000 $20,400 $20,808 $71,224 Added Savings with BEC Warehouse Savings $5,000 $10,000 $10,200 $10,404 $10,612 Competitive Bidding $5,000 $10,000 $10,200 $10,404 $10,612 Office Consolidation $0 $0 $0 $0 $0 $10,000 $20,000 $20,400 $20,808 $21,224 Total per Year Consolidation of LVE, FR and BEC Warehouse Savings $5,000 $20,000 $20,400 $20,808 $21,224 Competitive Bidding $5,000 $20,000 $20,400 $20,808 $21,224 Office Consolidation $0 $0 $0 $0 $50,000 $10,000 $40,000 $40,800 $41,616 $92,448 Total per Year In total, for LVE and FR alone these items are expected to provide savings of roughly $71,000 per year, or 0.1% of total costs for the combined utility. Greater savings occur through BEC because the smaller size of the utility provides less efficiency in warehousing and competitive bidding. With all three utilities consolidated, the cost savings would be $92,000 by the year 2021. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 16 PRIVILEGED AND CONFIDENTIAL Transition Costs While a consolidation is expected to save money for the utility over time, there will be some upfront costs associated with the consolidation of operations. Costs for these items would occur prior to or in the first year of the consolidated operation. For LVE and FR alone, these added costs are estimated to include $50,000 each for legal and outside services, advertising and communications, and computer/billing system integration. An additional $30,000 is estimated for employee transition costs. In total, the costs for the transition would be $180,000 in total. Adding BEC to the consolidation would not double the transition costs because some tasks would be combined and other expenses already occurred as a result of the management agreement. An incremental transition cost of $50,000 was assumed for BEC. This results in total transition costs of $230,000. One potential transition cost that has not been identified is the cost associated with any early retirement benefits that may be offered. While retirements and attrition are expected to account for the staff reductions, it may be necessary to offer some benefits packages to entice staff to take retirement a little early. The economics of this type of program would be examined at a later time as necessary to determine if the savings would offset the costs of the program. These costs do not include costs incurred by the utilities individually prior to the consolidation or the overlap of staff during the transition period to help with the transition. Total Electric Utility Savings Table 7 summarizes the cost savings by category for the year 2021. Savings are broken down into O&M, Customer and A&G categories. There are no expected savings in power supply costs. One additional issue for BEC is outstanding debt with RUS. BEC has $7.4 million in debt with RUS. Under a consolidation, holding onto that debt would lead to LVE and FR losing a current discount on their outstanding debt with CFC, as well as an additional administrative and reporting burden. For that reason it was assumed that the RUS debt would be prepaid. The prepayment would incur a $1.5 million penalty, so a total of $8.9 would need to be refinanced. The interest rate is expected to be slightly lower, with an expected incremental cost of $42,734 that would be an offset to the savings estimated for BEC. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 17 PRIVILEGED AND CONFIDENTIAL Table 7 Estimated Savings by 2021 by Category Consolidated LVE & FR Savings Incremental BEC Savings Consolidated LVE, FR and BEC Savings $0 $0 $0 $1,047,331 $0 $1,047,331 O&M Expenses $618,410 $48,936 $667,346 Warehouse $10,612 $10,612 $21,224 Bidding $10,612 $10,612 $21,224 Subtotal O&M $1,686,965 $70,160 $1,757,126 Customer Labor $314,199 $0 $314,199 Customer Expenses $92,580 $0 $92,580 Subtotal Customer $406,779 $0 $406,779 A&G Labor $523,666 $449,820 $973,486 A&G Expenses $762,985 $289,191 $1,052,176 Office Consolidation $50,000 $0 $50,000 $1,336,650 $739,011 $2,075,661 $0 -$49,734 -$49,734 $3,430,395 $766,438 $4,196,832 Power Supply O&M Labor Subtotal A&G Prepayment of RUS Debt Net Savings When the various types of savings are summed together, the total savings estimated for the potential consolidation of LVE and FR alone reach a total of roughly $3.4 million per year by year 5. This reflects percent savings of 19% for the costs that the utility can control, namely O&M and A&G costs. When compared to total costs, the percent savings is 3.9%. When the savings are estimated for the entire 10-year period, the total is $21.1 million in net present value. Adding BEC to the consolidation adds a considerable amount of additional savings relative to the size of BEC. Because of BEC’s smaller size, there are naturally less efficiencies than for LVE and FR. Adding the customers from BEC to the consolidated utility does not add significant costs to the A&G for a consolidated utility. The total savings for a three-way consolidation are $4.2 million per year by year 5. This reflects savings of 20% for O&M and A&G costs, and 4.3% relative to the total costs for the consolidated utility. The 10-year net present value of combined savings is $26.7 million. The annual costs of the consolidated utility, the savings and the % savings per year are shown in Table 8. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 18 PRIVILEGED AND CONFIDENTIAL Table 8 Annual Savings Associated with Consolidation Consolidated Utility Costs Annual Savings % Savings O&M/A&G Costs % Savings Total Costs Consolidation of LVE and FR Only 4 $82,667,070 $36,369 0.2% 0.0% 2018 $83,802,822 $1,495,990 8.8% 1.8% 2019 $83,423,559 $2,678,351 15.4% 3.1% 2020 $86,829,243 $3,125,527 17.6% 3.5% 2021 $85,440,045 $3,430,395 19.0% 3.9% 2022 $88,098,391 $3,481,893 18.9% 3.8% 2023 $89,700,443 $3,534,422 18.8% 3.8% 2024 $92,195,105 $3,588,001 18.7% 3.7% 2025 $94,224,071 $3,642,651 18.6% 3.7% 2026 $97,270,541 $3,698,395 18.5% 3.7% 2017 Added Savings with BEC 2017 $8,745,972 $202,036 7.7% 2.3% 2018 $8,206,496 $769,153 27.1% 9.4% 2019 $8,281,713 $714,038 25.1% 8.6% 2020 $8,440,054 $735,612 25.3% 8.7% 2021 $8,592,741 $766,438 25.8% 8.9% 2022 $8,749,482 $796,881 26.3% 9.1% 2023 $8,909,357 $827,933 26.7% 9.3% 2024 $9,072,430 $859,606 27.1% 9.5% 2025 $9,238,764 $891,912 27.6% 9.7% 2026 $9,408,425 $924,865 28.0% 9.8% Consolidation of LVE, FR and BEC 4 2017 $91,413,042 $238,405 1.3% 0.3% 2018 $92,009,317 $2,265,144 11.5% 2.5% 2019 $91,705,272 $3,392,389 16.8% 3.7% 2020 $95,269,297 $3,861,139 18.8% 4.1% 2021 $94,032,786 $4,196,832 20.0% 4.5% 2022 $96,847,873 $4,278,774 20.0% 4.4% 2023 $98,609,800 $4,362,354 19.9% 4.4% 2024 $101,267,535 $4,447,607 19.9% 4.4% 2025 $103,462,835 $4,534,564 19.9% 4.4% 2026 $106,678,966 $4,623,260 19.9% 4.3% Note that 2017 savings reflects 6 months rather than a full year of savings. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 19 PRIVILEGED AND CONFIDENTIAL Gas/Propane Savings While the gas and propane utilities serve fewer customers and have smaller budgets than the electric utility, it is expected that there will be additional savings on the gas side of the business. Some of these savings may have been captured with the reductions in administrative staff over time as those staff contribute to both the electric and gas/propane utilities. We have not identified specific line item savings associated with the gas/propane utility for this study. However, percent savings are likely to be of a similar magnitude as for the electric utility, in the range of 4% per year. Given combined costs for the gas /propane businesses of roughly $12 million per year, the expected savings would be in the range of $600,000 per year for LVE and FR alone. This places the combined savings for electric and gas/propane at roughly $4 million per year for LVE and FR alone. Currently, BEC does not provide propane service to its members. The ownership structure of the gas/propane business will need to be reviewed on a legal basis as the requirements differ by state. After the consolidation, additional benefits could be achieved by expanding the propane business. Direct benefits to members of improved access to propane have not been quantified. The utility would benefit because of the sharing of overhead costs between the electric and propane business. It is estimated that $50,000 to $100,000 of overhead costs per year could be shared by the propane business over time and included in the cost of propane. This would provide an equivalent reduction in cost assigned to the electric business. Direct staff costs and other expenses associated with the propane business would also be included in the cost of propane sold to customers and would therefore not impact electric customers. Given these additional benefits, the net combined savings for electric and gas/propane when all three utilities are included in the consolidation would be roughly $4.8 million per year. While this represents significant savings associated with the gas/propane business, this study has not quantified the additional benefits that may be possible. With a consolidated service area, there are ample opportunities to expand the gas and propane business in the consolidated service area, without incurring added overhead costs. This could lead to rate reductions for all gas and propane customers. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 20 PRIVILEGED AND CONFIDENTIAL Rate Comparisons With a consolidation, the combined utility will need to decide on how to treat rates for the different utilities. Both the level of the rates as well as the rate structure differs between the two utilities at the present time. Whether rates continue to remain different for the service areas or consolidated into one rate is a decision to be made. It is often the case with a consolidation that rates remain separate for some fixed amount of time to help lessen the impacts. This section discusses the issues to consider regarding rates but does not propose any specific plan for rates. That is a decision for the Board of the potentially consolidated utility to evaluate in the future. Rate Consolidation Currently FR rates are significantly higher than LVE rates, in large part due to the fact that the FR service area is less dense than the LVE service area and the average electric use per customer is lower. BEC rates are even higher than FR, due to even lower density and average use per customer. Historically, higher rates for BEC were also due to power supply costs, but those costs have been significantly reduced with corresponding rate reductions. The other factor would be the economies of scale for that differ among the utilities, with larger utilities able to spread administrative costs over a large amount of sales. Because of the difference in current rate levels, careful consideration will need to be given as to whether the rate differential should continue or whether rates should be consolidated at some point. There are instances where rates remain separate indefinitely after a consolidation or acquisition, some cases where the rates of one utility are applied to the entire combined utility right away, and some cases where combined rates are phased-in over time. In the case of acquisitions for investor-owned utilities there is often a requirement that rates are frozen for some set amount of time before any changes can be made. This reflects the argument made by the utility that costs will not increase as a result of the acquisition. Under a scenario where the utility plans to keep rates differentiated by service area there are several ways to accomplish this. To keep cost-based rates for all three service areas, costs would need to be tracked separately over time. This would include maintaining separate assets lists and employees for items that would not be shared, such as the cost of meters and meter reading. For shared costs, such as accounting and the annual meeting costs, the costs would need to be allocated between the two service areas on the basis of customers and/or sales. An alternative would be to establish a fixed split between assets and costs based on current costs for the utilities, and apply that split to all costs in the future. Another approach would be to establish the percent increase required for the utility as a whole and apply the same percent increase to the current rates for each utility. While any of these approaches would work well for the short term, the only method to ensure long-term equity between customers would be to maintain the tracking of costs by service area. This approach would require a greater level of effort, and potentially a higher cost overall. Given the differences in the rate designs between LVE, BEC and FR, it is recommended that some POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 21 PRIVILEGED AND CONFIDENTIAL of the rate design features be standardized over time even if rates are never consolidated. This will allow for better understanding from customers, easier administration by the utility and allow for the potential to consolidate rates in the future. This would not necessarily need to be done overnight but may be incorporated over one or two rate increases. In terms of a potential consolidation of rates, there are several options that could be used to phase-in new rates. The first option would include different rate increases for the utilities to move towards rate equity over time. A second option would be to freeze rates for BEC and FR and apply all rate increases to LVE (and FR later on) until rates are equalized. A third option would be having a common rate but apply a rider to FR and BEC rates to reflect the current difference between them. In this case the riders could be reduced over time if desired. Comparison of Current Rates LVE, BEC and FR are different in size, mix of customers and average rates. Table 9 below provides a summary of the sales and revenues for the various utilities, as well as average use and average revenue by class. Note that for LVE and FR the information is based on 2014 actuals while BEC data is based on the 2016 budget. Because BEC implemented a 10% rate decrease after the budget was developed, the revenues were reduced by 10% to provide an up to date comparison. BEC is also considering an additional 5% rate decrease later this year that is not included in the table. In general, LVE is bigger than FR with roughly 70% more customers and about 150% more sales. In turn, FR is larger than BEC, with more than double the number of customers and over four times the amount of sales. Both LV and FR have roughly 55% of their sales coming from the residential class, while BEC has 80% of its sales from residential customers. FR has a much larger irrigation class with 16% of sales compared to 5% for BEC and only 1% at LVE. LVE has more commercial sales with 43% of its sales from commercial customers compared to 29% for FR and 15% for BEC. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 22 PRIVILEGED AND CONFIDENTIAL Table 9 Sales and Revenue Comparison Fall River Lower Valley Beartooth5 Combined Number Customers Residential 12,831 20,162 5,518 38,511 Commercial 2,181 4,814 374 7,369 Irrigation 629 186 112 927 Lights N/A 1,552 N/A N/A Total 15,641 26,714 6,004 Annual MWh Sales 48,359 Residential 156,254 407,140 51,314 614,708 Commercial 83,227 309,106 9,750 402,083 Irrigation 45,923 4,075 2,894 52,891 Lights N/A 635 N/A N/A Total 285,404 720,956 63,958 1,070,318 Revenue ($000) Residential $17,701 $24,786 $7,512 $49,999 Commercial $6,928 $17,227 $1,186 $25,341 Irrigation $3,125 $240 $399 $3,764 Lights $56 $125 $47 $228 Total $27,810 $42,377 $9,145 $79,332 Average Use per Customer Residential 12,178 20,193 9,299 15,962 Commercial 38,160 64,210 26,088 54,566 Irrigation 73,010 21,907 25,835 57,057 Lights N/A 409 N/A N/A Total 18,247 26,988 10,653 22,133 Average $/ kWh 5 Residential $0.113 $0.061 $0.146 $0.081 Commercial $0.083 $0.056 $0.122 $0.063 Irrigation $0.068 $0.059 $0.138 $0.071 Lights N/A $0.196 N/A N/A Total $0.097 $0.059 $0.143 $0.074 Reflects 2016 forecast values after 10% rate decrease. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 23 PRIVILEGED AND CONFIDENTIAL In addition to the differences in overall size and mix of customers, LVE has the largest average use per customer for both the residential and commercial class. Again, BEC average use is lower than that for FR. For the irrigation class, however, FR has not only more customers but much larger customers. Overall, average rates per kWh for BEC are the highest at 14.3 cents per kWh compared to 9.7 cents per kWh for FR and 5.9 cents per kWh for LVE. This is a difference of 47% between BEC and FR and a difference of 66% between FR and LVE. These differences are a result of different densities between the utilities, different average use levels and different power supply sources. These results for LVE and FR are based on 2014 actual sales and revenues. When sales and revenues are projected for the future, some differences are seen. This may be in part due to the wholesale power rate increases recently put in place by BPA and partly to conservative projections in some cases. Based on the long-term cost and sales projections associated with each utility, the rate differential between LVE and FR is expected to be reduced to 43% by the year 2017 and to 45% for the difference between FR and BEC. Note that BEC is considering another 5% rate decrease later this year, which would further reduce the difference in rates between BEC and FR. Because that rate decrease has not yet been approved or implemented, it is not included in the rate comparisons. Residential Rates In looking at the potential for combined rates in the future, the issue of the average revenue as well as the rate design is an important consideration. For the residential class, the average rate per kWh is 6.1 cents for LVE, 11.3 cents for FR and 14.6 cents for BEC. This reflects an 86% differential between LVE and FR and a 29% differential between FR and BEC. This differential is larger than for the other classes but is likely due to the large difference in use per residential customer and the fact that fixed expenses associated with the T&D system must be spread over fewer kWh sales. Table 10 shows the rate structures for the different utilities. Table 10 Residential Rates Line/Service Charge Block 1 (first 2000 kWh) Block 2 (over 2000 kWh) Fall River Lower Valley Beartooth $36.00 $16.00 $33.50 $0.05193 $0.10316 per kWh $0.05193 $0.10316 per kWh $0.07427 $0.08765 per customer per month The residential rate for FR has a higher service charge and has inverted block rates. Beartooth has a slightly lower service charge than FR and a flat energy rate. LVE also has a lower service charge and a flat rate energy charge. To prepare for consolidation, if desired, rates would need to move towards a consistent service charge and have either an inverted rate or flat rate for all service areas. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 24 PRIVILEGED AND CONFIDENTIAL Commercial Rates All utilities have two different classes for commercial customers, although the revenues and sales are shown for the two rates combined. In addition, BEC has a separate industrial rate. The average commercial rate per kWh is 12.2 cents for BEC, 8.3 cents for FR and 5.6 cents for LVE. This reflects a 46% difference between BEC and FR and a 49% difference between LVE and FR. Table 11 shows the rate structures for small and large commercial/industrial customers for the utilities. Table 11 Commercial Rates Fall River Lower Valley Beartooth $36.00 $16.00 $33.50 $0.05551 $0.05193 $0.101408 Small GS/Commercial Line/Service Charge Energy Rate Demand Charge $8.17 per customer per month per kWh per kW per month GS/Large Power Line/Service Charge Energy Rate Demand Charge $121.80/218.25 $58.00 $0.05284 $0.03489 $0.062778/$0.065797 $8.17 $6.91 $12.40 per customer per month per kWh per kW per month The FR rates contain the same demand charge for both small and large customers but has a higher system charge and lower energy charge for large customers. LVE has a service charge for small customers only and a demand charge for large customer only. The energy rate is significantly lower for large customers due to the addition of the demand charge. BEC has a service charge for small commercial, large commercial and industrial rates. They do not have a demand charge for small commercial customers but have a high demand charge for both large commercial and industrial customers. To prepare for consolidation, if desired, the utility needs to decide whether a system charge, demand charge, or both should be applied to the different classes. The qualifying loads for each class should also be equalized. Irrigation Rates LVE and FR have different rates for small and large irrigators while BEC has one rate for all sizes. FR has one irrigation rate with different terms by size while LVE has a separate small and large rate. For small irrigators, FR has an annual HP charge, a demand charge and an energy charge. LVE has a service charge plus an energy charge but no demand charge. It also has an optional charge that eliminates the service charge but has a higher energy charge. BEC has a service charge, demand charge and energy charge. For large irrigators FR has the same rate as for small irrigators, however, the HP charge is higher. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 25 PRIVILEGED AND CONFIDENTIAL There is also a difference in billing, with BEC charging the service charge for 6 months while LVE charges for all 12 months and FR charges an annual amount but on a per HP basis. The average irrigation rate per kWh is 6.8 cents for FR and 5.9 cents for LVE, reflecting a 16% difference. The BEC average rate is twice that of FR. Table 12 shows the rate structures for small and large irrigation customers for the utilities. Table 12 Irrigation Rates Fall River Lower Valley Beartooth $16.00 $121.80 $0.05456 $0.057036 Small Irrigation Line/Service Charge Annual HP Charge Energy Rate Demand Charge $21.00 $0.03037 per customer per month per HP per year $12.40 $1.44 per kWh per kW per month Large Irrigation $121.80 Line/Service Charge Annual HP Charge Energy Rate Demand Charge $30.87 $0.03037 $1.44 per HP per year $0.03489 $0.057036 $6.91 $12.40 per kWh per kW per month The FR and BEC rates are more complicated than those for LVE, and all FR irrigators are billed on demand requiring a demand meter for each. As FR has a much larger irrigation load, it is important that those customers are not unduly harmed in terms of changing rates under a consolidation. To prepare for consolidation, if desired, the utility will need to decide whether it should apply a demand charge to all irrigators, whether the HP charge should continue and if a service charge should be used. Rate Impacts of Consolidation As stated earlier, while the 2014 differential in rates between LVE and FR was 66%, this differential is expected to be 43% by the year 2017 and beyond. The differential between FR and BEC are expected to be 45% in the future, and possibly lower if BEC implements another 5% decrease later in 2016. No agreement has been reached as to whether rates would continue to be differentiated by region or how savings would be shared between the utilities. In total, the savings associated with the consolidation would be passed on to customers, whether it be equally across all three areas or not. Given that the percent savings reaches 4.3% by year 5 of the consolidation, it is expected that rates can be reduced by an equivalent amount. POTENTIAL CONSOLIDATION BETWEEN LVE, FR AND BEC 26
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