VIA ELECTRONIC FILING Re: UM 1992—PacifiCorp Rebuttal … · 2019-09-10 · August 27, 2019 . VIA...

August 27, 2019 VIA ELECTRONIC FILING Public Utility Commission of Oregon 201 High Street SE, Suite 100 Salem, OR 97301-3398 Attn: Filing Center Re: UM 1992—PacifiCorp Rebuttal Testimony PacifiCorp, d/b/a Pacific Power, hereby submits for filing the Rebuttal Testimony of Nikki L. Kobliha. Please direct any informal correspondence and questions regarding this filing to Cathie Allen, Regulatory Affairs Manager, at (503) 813-5934. Sincerely, Etta Lockey Vice President, Regulation Enclosure

Docket No. UM 1992 Exhibit PAC/200 Witness: Nikki L. Kobliha

BEFORE THE PUBLIC UTILITY COMMISSION

OF OREGON

PACIFICORP

___________________________________________________________

Rebuttal Testimony of Nikki L. Kobliha

August 2019

PAC/200 Kobliha/i


TABLE OF CONTENTS I. PURPOSE AND CONCLUSIONS OF REBUTTAL TESTIMONY ................................ 1 II. FAS 87 AND COMMISSION ORDER NO. 15-226 ........................................................ 2 III. PENSION EXPENSE CURRENTLY REFLECTED IN RATES ..................................... 5 IV. 2016 CURTAILMENT GAIN ........................................................................................... 7 V. DEFERRED ACCOUNTING IS APPROPRIATE ......................................................... 11 VI. PROSPECTIVE ACCOUNTING REQUEST ................................................................ 13 VII. CONCLUSION ............................................................................................................... 13

PAC/200

Kobliha/1


Q. Are you the same Nikki L. Kobliha who previously submitted direct testimony in 1

this proceeding on behalf of PacifiCorp d/b/a Pacific Power (PacifiCorp or 2

company)? 3

A. Yes. 4

I. PURPOSE AND CONCLUSIONS OF REBUTTAL TESTIMONY 5

Q. What is the purpose of your Rebuttal Testimony? 6

A. The purpose of my Rebuttal Testimony is to respond to the Reply Testimony of Public 7

Utility Commission of Oregon (Commission) Staff witness Mr. John L. Fox (Exhibit 8

Staff/100) and Oregon Citizens’ Utility Board (CUB) witness Mr. Bob Jenks (Exhibit 9

CUB/100). Specifically, with respect to Mr. Fox’s Reply Testimony, I will address 10

the five questions set forth by Mr. Fox, which relate to Financial Accounting Standard 11

No. 87 (FAS 87), recovery of pension expense in rates, the company’s 2016 12

curtailment gain, the appropriateness of deferred accounting in this proceeding, and 13

the company’s prospective request for an accounting order for similar future events. 14

As to Mr. Jenks’ Reply Testimony, I will respond to his testimony regarding FAS 87, 15

the recovery of pension expense in rates, and the appropriateness of deferred 16

accounting in this proceeding. 17

Q. How is your Rebuttal Testimony structured? 18

A. Because Mr. Fox and Mr. Jenks raise similar arguments, my testimony is organized 19

by topic and I will address the similar arguments raised by Mr. Fox and Mr. Jenks 20

together where appropriate. 21

Q. What recommendation do you make in your Rebuttal Testimony? 22

A. I recommend that the Commission approve the company’s request with respect to the 23

PAC/200

Kobliha/2


2018 settlement loss, specifically, to (1) record the deferred amount in Account 1

182.3, Other Regulatory Assets; (2) record the impact of pension event separate from 2

the existing pension regulatory asset or liability for tracking purposes; and (3) 3

amortize the regulatory asset or liability resulting from the 2018 settlement loss to 4

expense over 21 years, which is the same period that is used to amortize the 5

underlying regulatory assets or liabilities with the opportunity to recover the amount 6

in rates as part of net periodic benefit cost. The company has demonstrated that the 7

deferral request minimizes the frequency of rate changes or the fluctuation of rate 8

levels and matches appropriately the costs borne by and the benefits received by 9

customers. Further, the 2018 settlement was unforeseeable and a contributing factor 10

to the company earning below its authorized return. 11

II. FAS 87 AND COMMISSION ORDER NO. 15-226 12

Q. Mr. Fox and Mr. Jenks state that in Order No. 15-2261, the Commission 13

reaffirmed the use of FAS 87 expense as the basis of pension recovery (Staff/100, 14

7:4-8; CUB/100, 2:7-4:13). How do you respond? 15

A. I agree that Order No. 15-226 reaffirmed the use of FAS 87 as the basis for recovery 16

of the company’s pension costs. As Mr. Fox testifies, FAS 87 refers to the original 17

accounting pronouncement and ASC 715 is the codification of FAS 87, which 18

occurred in 2009 (Staff/100, 8:17-9:4). I also agree with this and Mr. Fox’s statement 19

that “…for the purposes of this docket, we are discussing total amount net periodic 20

benefit cost included in customer rates, which would be inclusive using either term” 21

(Id., 9:1-4). 22

1 In re Public Utility Commission of Oregon, Docket No. UM 1633, Order No. 15-226 (dated 8/3/2015).

PAC/200

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Q. What is the accounting standard that forms the basis for the company’s request? 1

A. While immediate recognition of a settlement loss is required under FAS 87 (codified 2

as ASC 715), the company’s request is centered on deferral accounting. Due to the 3

2018 settlement loss being unforeseen, the company’s request seeks to defer the ASC 4

715 settlement loss for recovery in future periods under ASC Topic 980, Regulated 5

Operations (ASC 980), which provides the company the ability to defer incurred 6

costs to a regulatory asset to the extent probable of recovery. ASC 980 can apply to 7

any type of revenue or expense of a regulated entity, including pension expense, 8

power costs, gains or losses on property sales, property insurance and injury and 9

damage reserves. 10

Q. Mr. Fox argues that a discussion of pension accounting is not necessary because 11

the company’s request is really about ratemaking (Staff/100, 10:1-20). Do you 12

agree? 13

A. No. It is important to understand the accounting rules, ratemaking principles, and the 14

facts and circumstances that triggered the settlement event. Mr. Fox mischaracterizes 15

the company’s filing and my Direct Testimony when he asserts “The filing implies 16

that accounting practices beyond [PacifiCorp’s] control have placed it in a 17

disadvantageous position, and therefore it would be reasonable for the Commission to 18

issue an accounting order to rectify the situation” (Staff/100, 10:2-5). ASC 715 19

triggered the settlement loss, ASC 980 allows deferral of that loss for financial 20

accounting purposes, Oregon Revised Statutes (ORS) 757.259(2) provides when the 21

Company can apply for deferral, and the Commission can exercise its discretion to 22

grant or deny that application based on the facts and circumstances of the request. 23

PAC/200

Kobliha/4


Here, an event occurred in administrating the pension plan that was unforeseeable and 1

beyond the company’s control that triggered an expense to be immediately 2

recognized under the accounting rules. As I discuss further below, the company does 3

anticipate some number of participants will elect a lump sum distribution but the 4

company cannot accurately foresee how the dollar value of those lump sums will vary 5

due to interest rates and how the resulting lump sum will compare with the settlement 6

threshold, which could result in immediate expense recognition. If the company 7

could model or accurately forecast these elements, settlement losses or curtailment 8

gains would already be reflected in rates. However, deferral of this loss is allowable 9

for financial accounting and ratemaking purposes and the company’s application 10

should be granted based on the facts and circumstances surrounding the 2018 pension 11

event. 12

Q. Mr. Fox also refers to the company’s ongoing FAS 87 expense being “entirely 13

unrelated to the provision of utility service for current customers” due to 14

employees “no longer receiving pay credits in the defined benefit plan” 15

(Staff/100, 6:7-9). How do you respond? 16

A. I disagree with Mr. Fox’s suggestion that that ongoing FAS 87 expense does not 17

support the provision of service to current customers. While it is accurate to state that 18

there is virtually no ongoing service cost due to active participants in the plan instead 19

earning enhanced benefits under the company’s 401(k) plan, the company continues 20

to incur costs associated with the pension plan under Commission-adopted FAS 87. 21

The company is obligated to fund benefits to retirees and will continue to incur costs 22

under FAS 87/ASC 715 as long as that obligation remains. These costs include 23

PAC/200

Kobliha/5


interest cost on the company’s obligation, amortization of actuarial gains and losses 1

and the benefit of expected return on plan assets. Importantly, Mr. Fox’s testimony 2

suggests that actual and ongoing obligations to employees provide no benefit to 3

customers. This is simply not the case. A critical component of PacifiCorp’s 4

business is the ability to attract and retain employees, which includes offering 5

competitive retirement benefits. PacifiCorp’s credibility with current and future 6

employees would be damaged if this Commission adopts the view that future 7

retirement liabilities provide no benefit to customers. 8

III. PENSION EXPENSE CURRENTLY REFLECTED IN RATES 9

Q. Both Mr. Fox and Mr. Jenks claim that PacifiCorp has over-recovered pension 10

expense in rates and as a result, the settlement loss can be absorbed by the over-11

recovery (Staff/100, 12:3-16:3; CUB/100 4:14-6:17). How do you respond? 12

A. As an initial matter, I disagree with both their assertions that the loss can be absorbed 13

by over-recovery. With respect to the parties’ calculations, I agree with Mr. Fox’s 14

calculations and disagree with Mr. Jenks. I will first address the calculations set forth 15

by CUB. 16

Q. Mr. Jenks calculates that between 2014 and 2018 the company over-recovered 17

pension expense by $160.9 million (approximately $40 million Oregon allocated) 18

(CUB/100, 5:7-6:6). Are these calculations correct? 19

A. No. Mr. Jenks’ calculations are incorrect in that he has included the amount reflected 20

in rates for Local 57 pension costs. The company’s request and any information 21

provided in this docket have excluded the Local 57 plan. This is because the Local 22

57 plan is a multiemployer plan for which the company’s expense is equal to its 23

PAC/200

Kobliha/6


required contributions to the plan. The provisions of settlement and curtailment 1

accounting apply to accounting for single employer defined benefit plans and thus do 2

not apply to the Local 57 plan. Thus, Mr. Jenks has overstated the difference between 3

what is in rates and the company’s ASC 715 expense associated with the company’s 4

pension plan. Parties negotiated a black box settlement in the company’s last general 5

rate case which the commission approved, but for purposes of correcting Mr. Jenks’ 6

calculations, the amounts presented in Exhibit PAC/201 reflect the as-filed pension 7

expense. As one can see in this exhibit, Mr. Jenks’ reference to a “$51.9 million over-8

payment of FAS 87 pension expenses in 2018” should actually be $38.9 million, 9

assuming deferral treatment of the 2018 settlement. 10

Q. Based on their individual calculations, both Mr. Fox and Mr. Jenks conclude the 11

company has collected enough to absorb the 2018 settlement loss (Staff/100, 12

15:16-16:3; CUB/100, 6:13-17). Do you agree with the witnesses’ analyses and 13

ultimate conclusions? 14

A. No. In a general rate case proceeding, the Commission sets rates to approximate the 15

costs and investments that will likely be incurred for the period when the rates will be 16

in effect. During the time the rates are in effect, costs will vary from the amounts 17

estimated in the rate case. While the company’s actual ASC 715 expense has 18

fluctuated since its last general rate case filing, it is not appropriate to isolate this 19

single cost to compare actual expense to what was presented for recovery in the latest 20

general rate case. The company takes a more holistic view when managing costs. To 21

the extent the company is earning its authorized return, the benefit of any lower costs 22

offset higher costs. This cost management has enabled the company to stay out of 23

PAC/200

Kobliha/7


general rate cases beyond the commitment made in the last general rate case.2 In 1

2018, the unforeseen pension settlement event was beyond the company’s ability to 2

manage through other cost reductions. 3

Q. Did either Staff or CUB calculate whether the company has been under or over 4

earning its authorized return in 2018? 5

A. No, they did not. The company’s normalized return on equity in 2018 for Oregon 6

was 9.493 percent when including Oregon’s share of the 2018 pension settlement, 7

which is below the authorized return of 9.8 percent granted in the company’s last rate 8

case.3 Without the pension settlement normalized return on equity for Oregon would 9

have been 9.751 percent. The company did in fact under earn its authorized return in 10

2018 which I would attribute largely to this unforeseen pension settlement. 11

IV. 2016 CURTAILMENT GAIN 12

Q. Mr. Fox asserts that the Commission deny the company’s request because of its 13

treatment of the 2016 curtailment gain (Staff/100, 17:3-18:18). Do you agree? 14

A. No. While I agree with Mr. Fox’s testimony where he notes that when a curtailment 15

gain occurred in 2016, the company did not file an application for an accounting 16

order, I disagree with his assertion that the Commission deny the company’s request 17

on this basis. 18

Q. Can you explain the circumstances surrounding the 2016 curtailment gain? 19

A. As part of the company’s ongoing risk mitigation and cost management efforts the 20

company decided to fully freeze the pension plan and shift all future pay credits to the 21

2 Docket No. UE 263, In the Matter of PacifiCorp d/b/a Pacific Power, Request for A General Rate Revision (2013 Rate Case), Order No. 13-474 (dated Dec. 18, 2013), p. 6. 3 2013 Rate Case, Order No. 13-474, Appendix A, p. 4.

PAC/200

Kobliha/8


401(k) plan. The plan freeze in 2008 was only a partial freeze as employees hired 1

prior to January 1, 2008 could elect to continue their pay credits in the pension plan. 2

Continuation of pay credits in the pension plan for those who elected that option 3

increases the plan liability and adds to the company’s risk as the future obligation 4

grows. Shifting the pay credits to the 401(k) puts the burden of having enough funds 5

for retirement to the employee. In making this decision, the company realized a $5 6

million curtailment gain. 7

Q. How did the company treat the $5 million curtailment gain? 8

A. Without consideration for regulatory accounting, the company could have recognized 9

the entire $5 million 2016 curtailment gain to income immediately. The company 10

instead opted to follow the provisions of ASC 980 and deferred the gain to a 11

regulatory liability consistent with treatment of the 2008 curtailment gain. The 12

company also began amortization of this gain over three years effective January 1, 13

2017, which was based on the amortization period used in a majority of the 14

company’s jurisdictions for the 2008 curtailment gain. Using the three years 15

provided the opportunity for the amortization to be part of base period pension costs 16

had the company filed for a rate case in any of the three years following the gain. 17

Q. Mr. Fox also notes that the company amortized the gain over three years (unlike 18

the 21 years the company proposes to amortize the settlement loss) (Staff/100, 19

18:7-18). Can you explain the basis of the three years used with respect to the 20

2016 curtailment gain and the 21 year amortization period proposed in this 21

proceeding? 22

A. As noted above, the company amortized the 2016 curtailment gain over three years 23

PAC/200

Kobliha/9


based on it being the amortization period used in the majority of the company’s 1

jurisdictions for the 2008 curtailment gain. The 21 year amortization of the 2018 2

settlement loss was selected to approximate the time period over which the 3

unrecognized loss balance would have otherwise amortized to expense had a 4

settlement event not occurred. The company would be open to a shorter amortization 5

period if so desired by the Commission. 6

Q. Did freezing the plan have other impacts besides the curtailment gain? 7

A. Yes. In addition to the curtailment gain, freezing the plan resulted in a reduction to 8

pension service cost. Since participants no longer earn a pay credit in the pension 9

plan no service costs exist. This cost shifted to the 401(k) plan where pay credits are 10

now applied. 11

Another impact to freezing the plan was the change in the amortization of 12

unrecognized gains and losses. For an active plan, unrecognized gains and losses are 13

amortized back to pension expense over the average remaining service life of the plan 14

participants, or 8.4 years in 2016. A frozen plan amortizes unrecognized gains and 15

losses over the average remaining life of the plan participants, or 21 years. Freezing 16

the plan had the effect of spreading the unrecognized gains and losses over a much 17

longer period of time and reducing near term pension expense. This is purely a 18

timing issue as unrecognized gains and losses must be recognized through income 19

eventually. Had the company not frozen the plan, pension costs would have been 20

higher by approximately $27 million in 2017. This could have led to the company 21

filing a general rate case in late 2016 or early 2017. This type of cost management 22

demonstrates the holistic view I referred to above where the company considers all 23

PAC/200

Kobliha/10


offsetting costs and benefits when making decisions. 1

Q. Has the company filed an application for deferred accounting for curtailment 2

gains? 3

A. Yes. Based on Staff and CUB Reply Testimony, the implication is that the company 4

is only requesting deferred accounting when it benefits the company’s shareholders.4 5

This is not accurate. The company did file an application for deferred accounting 6

with respect to a curtailment gain in 2008 related to employee participation in 7

PacifiCorp’s defined benefit pension plans, which declined substantially, when union 8

employees and approximately 41 percent of non-union employees migrated to 401(k) 9

retirement plans. The commission approved the company’s requested authorization 10

to defer $41 million pension curtailment gain and a $14 million measurement date 11

change transitional adjustment related to both the pension and other postretirement 12

welfare plan. In recommending approval of the company’s request, Staff’s analysis 13

included information gained in the conference call with the company, and reviewing 14

the company’s responses to its data requests.5 15

Even though Staff states that Decision 08-0598 should not be given any 16

weight,6 I agree with Mr. Jenks that application of deferred accounting should not be 17

one-sided. The company actions have demonstrated that it has requested an 18

application for deferred accounting when it has benefitted its customers. 19

4 Staff/100, 18:5-18; CUB/100, 8:1-92. 5 Docket No. UM 1400, In the Matter of PacifiCorp d/b/a Pacific Power Application for an Accounting Order Regarding Pension Curtailment, Order No. 08-598, Appendix A, p. 2. 6 Staff/100, 6:13-15.

PAC/200

Kobliha/11


Q. Have there been other circumstances where the company has filed an application 1

for deferred accounting when it has benefitted its customers? 2

A. Yes. In response to the 2017 H.R. 1 Tax Cuts and Jobs Act the company filed an 3

application for deferral shortly after the law was enacted to defer the benefits of tax 4

reform for customers.7 5

V. DEFERRED ACCOUNTING IS APPROPRIATE 6

Q. Mr. Jenks states that the company’s proposal does not minimize the frequency of 7

rate changes or match costs to benefits (CUB/100, 7:7-19; 9:3-13). 8 How do you 8

respond? 9

A. I disagree with Mr. Jenks. While I am not an attorney, I understand that under ORS 10

757.259(2)(e), under which the company is requesting a deferred accounting order, 11

that the company has to demonstrate that such a deferral will minimize the frequency 12

of rate changes or the fluctuation of rate levels or match appropriately the costs borne 13

by and the benefits received by customers. Just as the company’s accounting order 14

requested in 2008, the accounting order requested in this proceeding allows the 15

company to smooth costs and credits associated with its remaining defined benefit 16

contribution plans over the actuarial lives of the employees who are vested in the 17

plan. Thus the deferral will allow the company to continue the prior amortizations 18

that would have continued if it were not for the accelerated recognition due to the 19

7 The Tax Cuts and Jobs Act was signed into law on December 22, 2017 and PacifiCorp filed an application in UM 1917 to defer the impacts related to the Tax Act on December 28, 2019. 8 Mr. Jenks adds that a similar request made by the PacifiCorp in Utah was denied. If the Commission wishes to consider the decision of other state Commissions, I note the Washington Utilities and Transportation Commission approved the company’s application without modification. See Docket UE-181042, In re Pacific Power & Light Company, Petition for an Accounting Order Approving Deferred Accounting Related to Non-Contributory Defined Pension Plans, Order 01, dated April 11, 2019.

PAC/200

Kobliha/12


settlement. In other words, the current matching of the costs borne by and the 1

benefits received by customers will continue and ensures the matching of this loss to 2

the offsetting gains that the company will experience over time through lower annual 3

pension expense. 4

Further, it will be difficult for the company to commit not to file a rate case 5

for a period of time as it did in its last rate case if it cannot request deferral accounting 6

in instances such as experiencing unforeseen settlement losses, like in the current 7

proceeding. The granting of deferred accounting can allow a utility to avoid 8

immediately filing a rate case when an unforeseen event occurs (such as the 9

settlement loss) and thus, minimize the frequency of rate changes. I also note that 10

rates do not change as a result of the Commission granting the company’s application 11

for deferral but it does provide the opportunity for the company to request recovery of 12

this loss in its next filed rate case. 13

Q. Mr. Fox concludes that the Commission reject the company’s application 14

because the settlement loss that PacifiCorp experienced in 2018 was a “stochastic 15

risk” or foreseeable and does not rise to the level for a deferred accounting 16

request (Staff/100:21:5-22:2). Do you agree? 17

A. No. The company does not consider settlements to be foreseeable. While 18

participants electing to take lump sum distributions is foreseeable, there are multiple 19

variables associated with triggering settlement accounting under ASC 715 that are not 20

predictable or within the company’s control as described in my Direct Testimony, 21

including changes in discount and interest rates. The fact that the number of 22

participants electing lump sums has stayed relatively constant since 2007 and yet the 23

PAC/200

Kobliha/13


company has not realized a settlement speaks to the unforseeability of pension 1

settlements as it is influenced by more than this one relatively predictable factor. 2

Further, as I noted early in my testimony, the company is earning under its 3

authorized return by approximately 31 basis points and the settlement loss was a 4

major contributing factor. Based on the facts and circumstances surrounding the 2018 5

pension event, the company should be allowed to defer the loss with the opportunity 6

to recover in its next rate case. 7

VI. PROSPECTIVE ACCOUNTING REQUEST 8

Q. Mr. Fox recommends that the Commission reject the company’s proposal for an 9

accounting order for future similar settlement losses (Staff/100, 23:4-24:3). How 10

do you respond? 11

A. In order to narrow the issues in this proceeding, the company withdraws this element 12

of its request. 13

VII. CONCLUSION 14

Q. Please summarize the conclusions of your Rebuttal Testimony. 15

A. A settlement event occurred during the company’s administration of its pension plan 16

that was unforeseeable and beyond the company’s control. The company cannot 17

accurately foresee how the dollar value of lump sum payments to plan participants 18

will vary due to interest rates and how the resulting lump sum will compare with the 19

settlement threshold. Deferral of this loss is allowable for financial accounting and 20

ratemaking purposes and the company’s application should be granted based on the 21

facts and circumstances surrounding the 2018 pension event. 22

PAC/200

Kobliha/14


Q. Does this conclude your Rebuttal Testimony? 1

A. Yes. 2

Docket No. UM 1992 Exhibit PAC/201 Witness: Nikki L. Kobliha

BEFORE THE PUBLIC UTILITY COMMISSION

OF OREGON

PACIFICORP

___________________________________________________________

Exhibit Accompanying Rebuttal Testimony of Nikki L. Kobliha

Actual Pension Expense

August 2019

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VIA ELECTRONIC FILING Re: UM 1992—PacifiCorp Rebuttal … · 2019-09-10 · August 27, 2019 . VIA...

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