1 REPORT ON WAPA LEAC VIPSC DOCKET 289 FACTORS FOR JANUARY 1, 2013 DATE: DECEMBER 15, 2012 TO: ALL COMMISSIONERS CC: BOYD SPREHN AND TANISHA BAILEY-ROKA FROM: JAMSHED MADAN, LARRY GAWLIK AND ED MARGERISON RE: JANUARY-MARCH 2013 LEAC FILING I. EXECUTIVE SUMMARY On November 20, 2012, the Virgin Islands Water and Power Authority (“WAPA”) filed, five days later than anticipated, a request for implementation of a new Levelized Energy Adjustment Clause (LEAC) for rates to be effective January 1, 2013. In addition to being untimely filed, the filing itself did not contain the complete requirements. However, the Minimum filing Requirements (MFRs), which are to be filed concurrent with the petition as ordered by the Public Services Commission (“PSC” or “Commission”) over the past several LEAC proceedings were submitted in advance of the delayed filing. The root causes of the $0.032799 per kWh change in LEAC Rate from the October through December 2012 LEAC Rate will be discussed in detail later in this report; however, to aid the Commission in its review of WAPA’s rate petition, we have provided below in Table 1 a quick overview identifying the key cost components contributing to this change. As is shown, the key cost components can be segregated into three major cost components—fuel oil prices, forecast of production efficiency and impacts of deferred fuel recovery and other smaller cost components. Table 1 Differential Analysis Component Contribution % of Difference Fuel Oil Prices ($0.00463) -14.1% Efficiency Forecast $0.02676 81.6% Deferred Fuel/Others $0.01067 32.5% Total $0.03280 100.0%
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1
REPORT ON WAPA LEAC
VIPSC DOCKET 289
FACTORS FOR JANUARY 1, 2013
DATE: DECEMBER 15, 2012
TO: ALL COMMISSIONERS
CC: BOYD SPREHN AND TANISHA BAILEY-ROKA
FROM: JAMSHED MADAN, LARRY GAWLIK AND ED MARGERISON
RE: JANUARY-MARCH 2013 LEAC FILING
I. EXECUTIVE SUMMARY
On November 20, 2012, the Virgin Islands Water and Power Authority (“WAPA”) filed,
five days later than anticipated, a request for implementation of a new Levelized Energy
Adjustment Clause (LEAC) for rates to be effective January 1, 2013. In addition to being
untimely filed, the filing itself did not contain the complete requirements. However, the
Minimum filing Requirements (MFRs), which are to be filed concurrent with the petition
as ordered by the Public Services Commission (“PSC” or “Commission”) over the past
several LEAC proceedings were submitted in advance of the delayed filing.
The root causes of the $0.032799 per kWh change in LEAC Rate from the October
through December 2012 LEAC Rate will be discussed in detail later in this report;
however, to aid the Commission in its review of WAPA’s rate petition, we have provided
below in Table 1 a quick overview identifying the key cost components contributing to
this change. As is shown, the key cost components can be segregated into three major
cost components—fuel oil prices, forecast of production efficiency and impacts of
deferred fuel recovery and other smaller cost components.
Table 1 Differential Analysis
Component Contribution % of Difference
Fuel Oil Prices ($0.00463) -14.1%
Efficiency Forecast $0.02676 81.6%
Deferred Fuel/Others $0.01067 32.5%
Total $0.03280 100.0%
2
As will be detailed more thoroughly in the body of this report, the price of fuel oil is
forecast to decrease during the January through March 2013 period and the principal
LEAC cost components contributing to the $0.032799 per kWh rise in the Electric LEAC
rate are the projected decrease in the production efficiency of the St. Thomas power plant
and, to a lesser degree, the recovery of the deferred fuel oil balance.
The individual impacts of these changes result in an overall increase in the proposed
LEAC rate for the period January through March 2013. As shown, the fuel pricing
component represents a decrease of approximately 14% as a result of a lower forecast
market price for fuel oil. The two remaining components contribute to the increase in the
proposed electric LEAC rate. The change in WAPA’s forecast of its production
efficiency at the St. Thomas plant, which WAPA now forecasts a lower efficiency than
used in the previous LEAC period, accounts for about 82% or the overall proposed
increase in the upcoming LEAC rate.
The final major cost component impacting the $0.032799 per kWh increase in the
Electric LEAC rate over the current LEAC rate is the deferred fuel recovery for the
January through March 2013 period and other costs (i.e., regulatory costs, debt service on
GO note, regulatory asset, pilot refund, and rate financing mechanism, discussed below).
This LEAC cost component reflects a 32% increase in its contribution to the proposed
LEAC rate as compared to the current LEAC rate.
We note for the Commission that the filing was missing the LEAC reconciliation for
Fiscal 2012 (twelve months ending June 2012), which is a critical document as it is the
basis to analyze issues related to the accuracy of the large “deferred fuel balances” that
impact the LEAC rates charged to consumers. This item albeit late has been subsequently
provided. Significantly, the petition also lacked updated information regarding the Rate
Financing Mechanism (RFM) that has been approved and implemented by the
Commission and provides WAPA approximately $17 million annually to pay for the (i.)
short-term lease of a trailer-mounted emergency combustion turbine to provide reliable
power, (ii.) deferred and extraordinary maintenance, (iii.) spare parts for existing
generating units, and (iv.) the services of an Independent Advisory Contractor (IAC) to
assist WAPA in restoring its existing generation to a reliable and efficient state of
operations. In providing the funds requested for the RFM the PSC established quarterly
reporting and other requirements that are to be filed concurrent with each LEAC
application until amended by the PSC. Again, much of this information, albeit very late,
has been recently filed after post filing discussions with WAPA. Numerous
conversations, emails, and teleconferences with WAPA post its LEAC filing have been
for the most part useful, but have again compressed severely the time available for full
analysis of all of the issues that were raised by this filing.
All of the problems identified above, which have been persistent for several consecutive
LEAC filings, indicate that the filings for LEAC rate changes continue to be inadequate.
Although there were many new policy and other issues presented in the calculation of the
LEAC rates, the current LEAC petition is less than two pages long. The LEAC rate
3
protocol recovers for WAPA fuel-related and other charges from consumers of
approximately $ 292 million in FY 2013.1 These filings are the major vehicle through
which WAPA gets revenues and recovers it fuel related costs. By contrast base revenues
are approximately 25% of fuel revenues and changes requested for those revenues in
amounts that are significantly less than the cumulative changes requested for fuel related
charges are accompanied by detailed testimony supported by major witnesses. GCG has
continually recommended that the PSC require that the LEAC petitions contain more
supporting testimony and detailed information, be reviewed for filing adequacy and be
much more transparent as to the root causes for the changes in the requested LEAC rates.
Unlike the current petition, which is perfunctory and does not accurately reflect the
primary causes of the proposed increase in the LEAC rate, all changes in any underlying
circumstance should be spelled out in detail with appropriate supporting schedules and
analysis.2
Our initial comments on the major points addressed by WAPA in its petition and those
that should have been addressed are as follows:
WAPA indicates in its petition that “the increase in the LEAC rate is caused primarily by
the recent increases in oil prices resulting from the closure of the Hovensa Refinery and
the subsequent loss of the discount that we had received under previous agreements. A
further factor is the under recovered fuel costs from prior periods which also has been
growing with the increase in fuel prices.”
GCG analysis shows that WAPA’s own projections for fuel prices in this proceeding of
the price per barrel for deliveries of No. 2 fuel oil for the current quarter of October
through December is $133, $141, $135 per barrel respectively and WAPA’s projection
for January through March 2013 (the upcoming LEAC period) of the price per barrel for
deliveries of No. 2 fuel oil is $135 per barrel each month. WAPA’s statement that oil
prices are the primary cause the high LEAC rates and increases in the rate is simply
incorrect. The fuel oil price forecast used by WAPA in this LEAC rate petition for the
period January through March 2013 is essentially the same to slightly less than the fuel
oil price forecast used for the October-December 2012 LEAC rate filing. The root causes
of the proposed $0.032799 per kWh change in LEAC rate from the October through
December 2012 LEAC rate will be discussed in detail later in this report; however, to aid
the Commission in its review of WAPA’s rate petition, we can identify the key cost
components contributing to the increase in the LEAC rate in this proceeding principally
as the forecast of production efficiency and impacts of deferred fuel recovery and other
smaller cost components. These will be discussed in detail in the body of the report and
are the same root causes that have been identified in prior proceedings.
WAPA’s statements on the cause of its high level of unrecovered fuel are inaccurate at
best and misleading at worst. Each quarter with the filing of a new proposed LEAC rate
1 See Electric Summary Schedule in FY 2013 Excel workbook attached to this report. 2 For example as will be discussed shortly there is a new proposal from WAPA as to how to treat Reverse Osmosis (RO) costs that relate to the production of water in this filing. There is not a mention of this change in the petition.
4
WAPA files a projection of its anticipated operational performance for that quarter—it
never meets its projected performance level and as a result consumes more fuel than it
forecast being required. This is in spite of WAPA projecting its operational performance
(i.e., heat rate for each of the plants or the kWh produced with a gallon of fuel) well
below industry standards for the plants on WAPA’s system; below the standards set by
WAPA’s consultants, Harris Group; and well below the equipment manufacturers’
standards for operation. GCG analysis that is detailed later in this report,
demonstrates that for every month in calendar year 2012 WAPA has considerably
under-performed (worse than) its own projections for operational performance. This
results in the LEAC rate under-recovering fuel expense, caused not by any PSC action,
but by poor WAPA plant operations. GCG recommends that in each LEAC application
WAPA provide an analysis in its petition showing its performance in the current and
recent LEAC periods compared to what it had projected and the resulting impact on its
deferred fuel balance—similar to the analysis we have provided later in this report. Poor
operational performance continues to plague WAPA and cause high rates for consumers
and businesses and further increases to recover the additional cost of fuel burned due to
poor plant efficiency. Our report contains an extended discussion on this issue. It is an
important issue that is not fully transparent to the public. WAPA has taken the position
that it is hampered by continually having to absorb increasing deferred fuel balances,
implying that these increases in its deferred fuel balances are created by the PSC
awarding insufficient LEAC rate relief. This is just not the case. The price of fuel oil as
included in the LEAC has been sufficient to provide for the market price of oil. This is
shown in a detailed analysis in the report below. However, in each LEAC rate filing
WAPA proposes a level of operation performance of its plants that the PSC reviews and
adopts and then WAPA never meets the operational efficiency criteria that it has
projected. This is a condition of WAPA’s own making.
In the past WAPA has posed the following question to the PSC team: if the projections
look like they cannot be met, why does the PSC team not make an appropriate
adjustment? The answer is several-fold.
First, the projections made by WAPA certainly look like they should be attained. We
would expect WAPA to meet the operating efficiencies it projects. As plant
rehabilitation work is completed we would expect a much higher standard of efficiency to
be attained. Current operations do not meet the interim efficiency standards set by
WAPA’s own consultants, the Harris Group. Failure to meet these interim operational
efficiency standards has cost VI consumers, businesses, and the economy hundreds of
millions of dollars over the years that should have been avoided. As we will show, in this
LEAC rate filing WAPA has projected operational efficiency on St. Thomas in line with
recent (inefficient) operating efficiencies and will therefore be in a position to meet these
operating standards, but on St. Croix has projected operating efficiencies much better
than recent (inefficient) operations and WAPA will have difficulty meeting those
projections. Of course, we would prefer that WAPA indeed meet all of the projections.
It should be clearly understood that a major portion of the increase in the proposed LEAC
rate (January to March 2013) is due to WAPA first making an optimistic operating
projections in the prior LEAC (October through December 2012) and then not meeting
5
those projections. No deferred fuel addition has been “imposed” on WAPA by an
unreasonable PSC order.
With regard to the RFM WAPA indicates this filing also includes the factor to cover a
Rate Financing Mechanism previously approved by the Commission to provide for an
emergency generator and repairs of existing units at $0.023 per Kwh. The temporary GE
TM 2500 has been installed at the Randolph Harley Power Plant on St. Thomas and has
been in operation since May 28th
. Of significant note is that the savings in fuel with the
new dispatches and overhaul schedules have been well in excess of the cost of the
program. These calculations have been provided in greater detail in the discoveries and
filings with the temporary and base rate.
GCG does not believe that the RFM that grants WAPA approximately $17 million
annually has been implemented as per the PSC Order, nor have the results been
significant yet. The RFM was implemented through a Stipulation reached between the
PSC staff and WAPA, which was subsequently approved by the PSC. A key feature in
that Stipulation was the requirement that WAPA bring on board an Independent Advisory
Contractor (IAC) through a Request for Proposal (RFP) process with collaboration with
the PSC staff and approval of the RFP document by the PSC. There has been little or no
collaboration with the staff and WAPA has recently presented a draft RFP document to
the PSC for direct review and approval without any involvement of the PSC staff. GCG
has reviewed this document and believes that it does not comport to the requirements of
Attachment 6 to the RFM Stipulation to which WAPA had previously agreed. In recent
discussions with WAPA executive management it was stated that WAPA did not fully
understand the requirements of the Stipulation. Having been on the other side of the
process to stipulate with WAPA it is hard to understand this position. GCG recommends
that the process move forward as per the Stipulation. WAPA has indicated that it wishes
to move forward, but to date has not been willing to discuss its draft RFP with the PSC
staff and its objections to the RFP drafted by PSC staff which meets the requirements of
the stipulation.
WAPA has indicated that it believes that the IAC would be beneficial. GCG agrees and
recommends implementation of these advisory services after a satisfactory RFP has been
approved by the PSC. The Stipulation requires collaboration to produce the RFP which
must then be approved by the PSC. GCG believes the advice of the IAC will help
improve efficiency at the plant as it has in other jurisdictions. As stated earlier, poor
plant efficiency continues to be a very major factor in the high LEAC factors that WAPA
charges consumers. GCG recommends that WAPA and GCG deliver to the PSC an
agreed to RFP scope as required by the Stipulation no later than January 31, 2013.3 In the
event that there is no agreement and no document is delivered GCG recommends that the
PSC consider what appropriate rate action it wishes to take including the possibility of
deferring the further implementation of the RFM until there is compliance with the terms
of the Stipulation and PSC order.
3 In response to discovery in the recent emergency rate filing WAPA stated that it believed that the RFP would be on the street by October 2012.
6
WAPA made no mention in the LEAC petition that it was using a new methodology to
treat RO costs allocations between the electric and water departments and that has been
included in the calculations for the proposed LEAC rates. It is important to understand
that (i) the prior allocation methodology was both disclosed and approved by the
Commission; (ii) RO production has been in effect for quite a while, over two years on
St. Croix (beginning with temporary plants) and at least since January 2012 on St
Thomas, following last winter’s loss of IDE water production; and (iii) in the 2009 rate
investigation, WAPA agreed to file a new rate case on in the installation of RO
production to develop a new cost allocation methodology.RO production has been in
effect for a while. The new contract for RO production with Seven Seas has been in
effect since January 2012 for St. Thomas and since March 2012 for St. Croix. Production
for each Island was roughly 1.5 million gallons per day (GPD). In January 2013 a new
permanent RO facility on St. Thomas is projected to be operational and a similar new
system on St. Croix is projected sometime near the end of 2013 having been delayed once
again apparently after the last indicated dated to the PSC of mid 2013. The following are
key features of the RO contracts that impact the electric and water departments:
There is no charge to Seven Seas for electricity to produce water. The electric
department supplies electricity to produce potable water which is charged to water
consumers. WAPA staff agrees that the electric cost to produce water that is
charged to water consumers should be credited to the electric department and that
it has not been included in the schedules submitted in this and LEAC filing. It
should be understood that the populations of electric and water consumers are not
the same. Virtually every household and business has electricity; however, the
water consumer population is significantly smaller. The credit that should have
been given to the electric department is approximately $5 million annually or
approximately $400,000 per month. We have made that adjustment to credit
electric consumers in our schedules with apparent WAPA agreement.
The water department makes two different kinds of water for the electric
department and credits the cost to make the water to the water department as it
should from the total cost of water for the water department. However, WAPA
did not charge the electric department for the cost of this water as it should have.
We have made the corrections to make the appropriate charges to the electric
consumers in our schedules with apparent WAPA agreement.
The net of the two adjustments to the electric department is a net benefit to
electric consumers who will avoid a double charge as a result of these errors. No
change is required for the water department.
The errors and adjustments not only apply to the next quarter, January through
March 2013, but also apply for the appropriate time period in 2012 where
corresponding adjustments should have been made. GCG recommends that this
analysis be undertaken by WAPA and presented to GCG no later than January 31,
2013. The impact of this change should be recognized in the next LEAC.
7
WAPA unilaterally determined the appropriate rate the electric department
should charge the Water department for the supply of electricity. WAPA did
not choose any of the existing customer tariffs for this rate. Rather it looked at
production costs for the fiscal year ending June 2012 and divided by gross
generation to get rate of approximately 32 cents per kWh. WAPA has not
provided a proposed tariff for PSC review and approval of what is essentially a
retail electric tariff applicable to the production of potable water. GCG does not
agree with this approach4 or the failure to account for this consumption on the
basis of a PSC approved tariff and recommends that PSC staff and WAPA
attempt to make a joint proposal to the PSC at the next LEAC proceeding and file
on this basis pending PSC approval. GCG believes that the rate cannot be “fixed”
as the fuel cost itself keeps changing and there is no consideration of the high cost
of maintenance of WAPA power plants. The use of gross generation appears to be
incorrect.5 One option would be to treat the water department like a large
commercial customer; however, this is somewhat questionable since the water
department is not the end-user of the electricity being provided—it is simply the
beneficiary of the water produced by a private party. GCG believes that full
disclosure by WAPA of what it wanted to implement together with discussions
with staff might have avoided the errors in this proceeding. This is simply a
further example of the lack of transparency that hampers the regulatory
environment.
In addition to the issues raised with the implementation of the RO contracts, GCG
recommends that spending $2.2 million per quarter on water production from the existing
IDE plants should be appropriately justified by WAPA before they should be permitted
any further inclusion the water LEAC. From January 2013, 100% of all water production
(3 million GPD) on St. Thomas should be through the RO plants. In addition to the fuel
costs there are also other operating costs for the IDE plants. There are no additional costs
for the Seven Seas contract.
The current temporary RO units (1.5 million GPD) on St. Thomas may still be available.
On St. Croix production for some time has been through temporary units (1.5 million
GPD). RO production appears to have been very reliable. On both Islands there will be
production of 4.5 million GPD of RO capacity beginning January 1, 2013. By contrast
there will remain 1.5 million GPD of water production from the IDE plants on St. Croix.
In the past WAPA has offered the justification of operating the plants as a backup for any
RO problems. As stated above the temporary units from St. Thomas are possible
available and GCG recommends that WAPA should explore whether there is a basis for
keeping them on standby or in fact deploying them on St. Croix. It is our understanding
that some of the St. Thomas units were originally on St. Croix before they were deployed
to St. Thomas because of the earlier water emergency.
4 As well as the lack of disclosure. 5 Even assuming the logic of what WAPA represented it wanted to do, the use of Net Plant Generation would be more appropriate.
8
II. ELECTRIC DEPARTMENT
WAPA filed its request for a new electric LEAC rate to be implemented effective January
1, 2013. WAPA indicates that the proposed new rate will be another increase in both the
LEAC rate and overall bills. WAPA computes that the new electric department LEAC
rate should be $0.416033 per kWh or an increase from the current factor of $0.383234
per kWh. If this factor is approved by the PSC, this would result in an increase for the
average residential consumer of about $13.12 or about 6.76 percent of the total monthly
bill. The following table presents the summary of WAPA’s filing and compares that to
GCG’s findings as described in this report:
Table 2
WAPA LEAC-Electric
($000’s)
WAPA
GCG
As Filed
As Updated
($000s)
($000s)
A Cost of Fuel $ 64,145
$ 63,074
B Regulatory Costs (Dkt 289) 55
40
C P&I on New 4-Yr GO Note 126
126
D Regulatory Asset Costs 215
215
E Pilot Refund 0
0
F Elect. Charged Water 0
(1,210)
G Ultra Pure Water Charge 0
255
H
Water Production
Charge/RO 0
358
I Plant Repair RO Contract 0
60
J Rate Financing Mechanism 4,168
4,168
Current LEAC Costs $ 68,708
$ 67,086
K Deferred Fuel Costs 6,689
6,828
TOTAL Costs $ 75,397
$ 73,913
Total mWh 181,228
181,228
Proposed LEAC Factor $ 0.416033
$ 0.407847 /kWh
Current LEAC Factor $ 0.383234
$ 0.383234 /kWh
Increase $ 0.032799
$ 0.024613 /kWh
Average Residential Usage 400
463 kWh
Monthly Increase $ 13.12
$ 11.40
Current Average Bill $ 193.97
$ 193.97
Percent Increase 6.76%
5.88%
9
GCG is uncertain as to why WAPA has reduced the average usage per residential
customer to 400 kWh per month. In the past WAPA has used 500 kWh for average usage.
Our analysis shows that the current average residential use is 463 kWh and we show bill
impacts for residential consumers based on this figure.
Cost of Fuel:
For the forecast of fuel costs, WAPA assumed the current Hovensa contract pricing terms
and discount would remain in place until November 30, 2012. Thereafter, the new
pricing under the terms and conditions of the new fuel contract with Trafigura AG will be
in effect for Number 2 oil. The new contract was just made available during the
proceeding and a full understanding of the terms and overall impacts compared to the
Hovensa contract may take several LEAC filings to sort out. The following table shows
the actual or forecasted delivered price of both Number 6 and Number 2 oil. The vast
For the delivery of Number 6 oil, WAPA has used the pricing template it has used in the
past. Starting with a forecast of Brent Crude, WAPA adds $3 per barrel as a
transportation allowance and then multiplies that total by a historic ratio of Number 6
oil(s) price versus Brent Price. Using February 2012 as an example:
Table 3b
Cost per Barrel Forecast # 6
February 20136
STT #6 STX #6
Brent Blend Futures $ 111.71 $ 111.71
Shipping Allowance 3.00 3.00
Base Price $ 114.71 $ 114.71
Market Ratio 93% 103%
NY Harbor Price $ 106.68 $ 118.38
6 There is programming error in the WAPA workbook. The actual price used by WAPA was $116.70 for February purchases on St Croix. GCG has corrected the error in update of fuel price.
10
Currently, WAPA does not have a contract to provide Number 6 oil to the Territory.
WAPA has stated that it believes that current supply on hand will suffice for the interim,
once the current inventory has been modified to reflect differing Environmental
Protection Agency (“EPA”) requirements for St Thomas and St Croix.
The overwhelming majority of purchase for the forecasted LEAC period (January
through March 2013) is Number 2 oil. The algorithm used for forecasting the price on
Number 2 oil has changed as a result of the new fuel contract. As indicated above GCG
has only recently received a copy of the contract.
Under the provisions of the new fuel contract, WAPA will pay a price that is equal to the
average price of the price of No 2 oil as published in the Platts Oilgram Price Report7 and
the forecasted price of Heating Oil (“HO”) as published Argus US Products. These
prices are presented in dollars per gallon. Once the average is determined, the cost of
gallon is converted to cost per barrel and then an allowance of $9.97 per barrel is added
to recover delivery and other costs incurred by Trafigura as well as profit.
WAPA sought advice from its fuel consultant as to a reasonable surrogate to forecast
future deliveries under the pricing provision of its new contract. The consultant
suggested using a report available on-line from CME Group, i.e. “Energy Futures
Report.” The following algorithm shows how WAPA forecasted the price for February
2013 delivery.
Table 3c
Cost per Barrel Forecast # 2
February 2013
CME Group HO/gal. $ 2.98
Conversion gal. to
barrel 42
Shipping/markup $ 9.97
Delivered Price $ 135.20
WAPA prepared the LEAC filing in November 2012 and used the latest projection of HO
futures from this source. In the weeks between the preparation of the filing and the
preparation of this report, the price of HO has dropped creating a difference in
forecasting supply of Number 2 oil. The following table shows the difference in the
January through March projection of HO pricing
7 “US Gulf Coast Waterborne”
11
Table 3d
Heating Oil Price Futures
$/Gal
GCG has reflected the downward in price for HO to reflect the December 11 projection
by CME Group. This has been the practice accepted by the Commission in order to
reflect the most recent prices available at the time of preparation of the report.8
Efficiency of Plant Operations and Deferred Fuel
We indicated above that we would provide information on the relationship between the
efficiency of WAPA plant operations relative to the efficiencies projected by WAPA
itself and the Deferred Fuel Balances.
It is imperative that the Commission, consumers, businesses, and WAPA fully understand
the causes of the WAPA’s excessive deferred fuel balance. There appears to be a lack of
transparency on the facts related to this issue that has resulted in a misunderstanding of
the factors contributing to the deferred fuel balance. In order to examine this matter in
detail, we have prepared an analysis of calendar year 2012 to isolate the root causes of
the growing deferred fuel balance. This timeframe was chosen because it is current and
because it has been the focus of much of the discussions in the media and WAPA
pronouncements at Board Meetings and before the USVI Legislature.
The level of WAPA’s deferred fuel balance is impacted by a number of variables.—
virtually all of which are controllable by WAPA. WAPA remains totally dependent on
fuel oil in the short-term and will have little control of the world market “price level” it
pays for fuel oil. However, the deferred fuel balance is not impacted so much by the
“price level” WAPA pays for fuel oil, but more so by the “forecast” of efficiency of
expected for LEAC periods. Although WAPA has no control over the level of world oil
prices, it does have control of the forecast of oil costs used in the development of the
LEAC rate. As it relates to the deferred fuel balance the principal factors impacting the
level of the balance are the “forecasts” of (i.) oil pricing and (ii.) the efficiency of WAPA
power plants. These two factors have the greatest impact on the overall deferred fuel
balance of the LEAC rate. Both of these components of the LEAC rate and are prepared
by WAPA and provided in its quarterly LEAC petitions to the Commission.
8 In our review, we noted that the forecasted generation for the months of November and December 2012 on St Croix failed to meet demand. We have corrected this error in our calculations. This error has occurred before.
Jan-13 Feb-13 Mar-13
Forecast
As Filed $ 2.98 $ 2.98 $ 2.97
As Updated $ 2.90 $ 2.91 $ 2.91
12
In looking at the forecast of fuel oil prices used in the development of the LEAC rates in
effect for the period January through November 2012 we have prepared Figure 1 which
shows the relationship between the
fuel pricing forecasts used in the
LEAC rates and the actual fuel oil
prices incurred. The fuel oil pricing
forecasts are prepared on the basis of
an established methodology that
incorporates published oil industry
pricing benchmarks with adjustments
for shipping and other well-
established factors. WAPA files its
various LEAC petitions with the latest
available information concerning the published oil industry pricing benchmarks. The
pricing levels are sometime adjusted prior to the Commission taking action on a
particular LEAC factor if the pricing benchmarks have moved up or down by what would
be deemed to be a material amount. This occurred once in 2012 with the July through
September 2012 LEAC and resulted in a downward adjustment in the fuel pricing for that
period.
As can be seen in Figure 1 the fuel oil price forecast for the first part of 2012 was in
excess of the price that WAPA actually paid during this time period. Then in the latter
part of 2012 the price forecast used in the development of the LEAC was below the cost
of fuel incurred by WAPA during this period. As would be expected and as shown in
Figure 2 during the first part of 2012
the fuel oil price used in the LEAC
rate calculation contributed to
decreasing the deferred fuel oil
balance and resulted at its peak in an
over-recovery of the fuel pricing
component of the LEAC by slightly
over $8 million. Likewise during
the latter half of 2012 the fuel
pricing component gave back the
majority of the amount over-
recovered during the first half of 2012 and for the year-to-date ending November 2012
resulted in a cumulative over-recovery for 2012 at slightly less than $600 thousand.
Overall for 2012 the fuel oil pricing component used in the LEAC had no negative
impact on the deferred fuel balance and did an excellent job at simulating the price of fuel
oil for 2012. In fact, the fuel oil pricing forecast slightly contributed to decreasing the
The lack of fuel diversification and high level of inefficiency of WAPA’s power plant
facilities continue to expose VI consumers to risks of supply interruptions and pricing
volatility. While WAPA has made some progress in the area of fuel diversification with
its recently authorized solar projects this progress will have a limited impact on
diversification. We see the establishment of a path that could establish clear energy
efficiency standards and benchmarks consistent with industry best practices and fuel
diversification benchmarks and milestones. The WAPA board has already determined a
strategy for reducing the cost of energy in the Virgin Islands. This strategy includes both
fuel diversification and energy efficiency objectives. The Commission should consider
measures to aid in the accomplishment of these strategies. The strategies adopted by the
WAPA board could form a basis for the Commission exercising its rate setting powers to
move WAPA toward greater fuel diversification and more efficient operations of its
existing facilities. These strategies adopted by the WAPA board include:
Implementing measures to enhance production efficiency at existing power
generation facilities.
Convert base-load power production from fuel oil to liquefied natural gas and/or
propane
Develop grid interconnection between the Virgin Islands and Puerto Rico;
Maximize development of solar and wind resources; and
Pursue biomass energy and ocean thermal energy as potential diversification of
base load energy.
WAPA is to be commended for adopting the fuel diversification and energy efficiency
strategies described above. It is critical that objective measures, benchmarks and
milestones be developed so that the process for implementation of these strategies is fully
transparent to consumers, businesses, and the Commission. To provide for accountability
and transparency to the public and to insure that WAPA does not slip into a mode of
simply relying on its ability to pass through whatever its fuel cost are without regard to
the underlying efficiency (the current situation) some form of incentive should be
considered to get these type of programs implemented. As a first step, we recommend
that WAPA be required to provide the Commission with the existing tactical and
implementation plans, activities and milestones it will undertake to implement the five
strategic fuel diversification and energy efficiency objectives identified by the WAPA
board.
Docket 289 Costs
WAPA has forecasted the cost of the regulation for the LEAC to be $55 thousand over a
three-month period with no allocation to the water department. WAPA also projects a
similar amount for the three months ending December 2012. WAPA has failed to
allocate a portion of these costs to the water department, which should be done. It is
18
important to understand that WAPA has been currently recovering from both electric and
water consumers the actual and projected cost of regulation as it applies to this item and
is currently in arrears in paying these costs. We have allocated an appropriate portion of
these regulatory costs to the water department as we have done in the past that has been
adopted by the PSC. The net effect of this adjustment is to include $40 thousand of
projected regulatory costs in the electric LEAC rate and to include the remaining $15
thousand in the water LEAC rate.
General Obligation Note
In the derivation of the electric LEAC rate, WAPA shows constant monthly payments of
principal and interest $42 thousand per month and in every month after the refinanced
note in August 2012. WAPA is assuming a 48 month collection period for the electric
department and a shorter period for the water customers (16 months @ $198 thousand per
month). This increases the short-term burden of the water consumers, but decreases the
costs for the first sixteen months for electric consumers. After seventeenth months, the
monthly payment goes back to $240k for the electric department and the water
department would have no further burden.
WAPA has made this proposal in order to accelerate payments and reduce the amounts
owed to the electric department by the water department. As of October 2012, the water
department owed the electric department $9.8 million, including the water department’s
responsibility on the GO note. We have accepted WAPA’s proposal.
Regulatory Asset and PILOT
Both of these items are fixed monthly amounts and have been approved by the PSC for
inclusion in the LEAC computation. It appears that the PILOT refund will be fully
amortized by December 2012 and no further credit is being given starting in January. As
currently projected, the regulatory asset amortization will not cease in June of 2013.
Therefore an allowance of the amortized costs related to the regulatory asset is
appropriate for the next LEAC. GCG has accepted the projection of these costs in its
update of the LEAC request contained in this report.
Ultra-Pure Water Cost
WAPA has proposed a credit (reduction) to the water department of the costs of
production of water by the Reverse Osmosis (“RO”) unit on St Thomas. The RO unit
produces ultra pure water that is used exclusively for the generation of electricity and is
not distributed by the water department for consumption by water consumers. While
WAPA has filed the water department LEAC rate request using this as a reduction in fuel
costs for water consumers, based on our discussions with WAPA we find that it failed to
include these as costs to the electric consumers. GCG agrees that this cost is a
responsibility of the electric department. As a result, GCG has included the cost in our
calculation of the electric department LEAC rate and made an adjustment to the
forecasted electric LEAC costs as well as an allowance for costs incurred since July 1,
2012. A more complete explanation may be found in the water department LEAC rate
19
discussion. GCG recommends that the credits and debits for the period July 1, 2012
through December 31, 2012 that were not used as current charges in the LEAC
determinations should be reviewed in the next LEAC proceeding for the period April 1,
2013 through June 30, 2013.
Water Production Costs
As with the Ultra-Pure water costs, WAPA has included a second credit to the water
department LEAC. This is a charge for production of water from the RO units on both
Islands for the benefit of the generating plants to the benefit of electric consumers. While
WAPA has provided a credit to the water department for the production of this water, it
again failed to charge electric consumers in its LEAC request for the electric department.
GCG believes that this expense is appropriately charged to the electric department and
has included additional costs in its update of the WAPA LEAC electric department. A
more detailed explanation may be found in the discussion of this matter contained in the
narrative described the water department contained below. Consistent with the above we
recommend that the debits and credits for the periods should be reviewed in the next
LEAC.
Plant Repair RO Contract
WAPA has also requested a third credit to the water department related to the installation
of the RO equipment on St Thomas. In the contract with Seven Seas, it was requested
that the water intake valves of the generating units be repaired or replaced. This charge
should be the responsibility of electric consumers. GCG has included these costs as
estimated by WAPA. WAPA has not provided work papers showing how this was
calculated and we recommend that the PSC should require work papers before its next
LEAC petition is filed. Consistent with the above we recommend that the debits and
credits for the periods should be reviewed in the next LEAC.
Rate Financing Mechanism
Rate Financing Mechanism (RFM) costs of $4.3 million is included in the cost of fuel for
this quarter. Annually this is a $17 million recovery. These costs reflect the: (i.) short-
term lease and operating costs exclusive of fuel of a trailer-mounted emergency
combustion turbine to provide reliable power, (ii.) deferred and extraordinary
maintenance, (iii.) spare parts for existing generating units, and (iv.) the services of an
Independent Advisory Contractor (IAC) to assist WAPA in restoring its existing
generation to a reliable and efficient state of operations. The costs has been computed as
the product of 2.3 cents and kWh sales. WAPA has been recovering these costs
beginning in April 2012, according to the LEAC workbooks for Fiscal 2012 and Fiscal
2013.
The RFM, a temporary power plant maintenance funding allowance, was agreed upon by
prior Stipulation between WAPA and the PSC Staff on September 27, 2011 and
20
subsequently approved by the PSC Order.9 It was estimated that at the time of PSC
approval of the RFM mechanism that consumers would obtain an economic benefit of no
less than $50 million annually through more efficient operation of WAPA generating
units. Pursuant to PSC Order the RFM funds collected from consumers by WAPA can
only be used to pay the leasing, operating and maintenance costs of the GE trailer
mounted (TM 2500) emergency generating unit, the systematic completion of the
rehabilitation and chronic deferred maintenance of certain WAPA generating units, the
acquisition of spare parts, and the services of an Independent Advisory Contractor (IAC),
an expert in the maintenance and efficient operation of generating units. The total RFM
revenue component approved in the PSC order accepting the Stipulation was based on the
product of 2.3 cents per kWh times the then current kWh sales forecast. An RFM
component of the LEAC has been included in all LEAC rates since April 1, 2012. Under
the terms of the Stipulation, the PSC is to approve the inclusion of the RFM component
in each quarterly LEAC based upon its review and approval of specific information
provided by WAPA pursuant to the Stipulation concerning, among other things, the
proposed uses of the funds and benefits to be derived by consumers.
The leased unit (also referred as “Unit 25”) is one of the authorized uses of funding
through the RFM. Unit 25 has been in operation since late May 2012 and has been
operating at an efficiency level of approximately 11,700 BTU/kWh and a 63% utilization
factor since that time. Unit 25 operates more efficiently than any of WAPA’s other
combustion turbines and is contributing to improving performance of St. Thomas power
production. The availability of this unit is a significant factor in the abrupt and modest
improvement in the St. Thomas plant’s fuel efficiency in the June timeframe, shown in
Figure 6 above. Also, the emergency leased unit allows WAPA to have available the
capacity to perform vital and crucial maintenance on its other St. Thomas facilities for the
purpose of improving unit availability and performance—the primary purpose of WAPA
acquiring the emergency unit.
The September 27, 2011 Stipulation and subsequent Commission Order approved the
RFM as a temporary “supplemental” financing source. The RFM was approved to
provide WAPA a source of funding so that consumers could be assured of near- and
long-term benefits. These consumer benefits are to be measured by the PSC using
specific benefit-cost assessment metrics that target improvements to WAPA production
efficiencies and improvements to allow its facilities to provide a continuous and
uninterrupted supply of electricity. The Order requires that WAPA timely provide
certain information concurrent with its quarterly LEAC Rate filings to the PSC. The
RFM component included as part of any LEAC rate is to be specifically ordered quarterly
by the PSC. The amount of the RFM authorized by the PSC for inclusion in the LEAC
rate shall only be used for specifically “authorized” emergency power, generation
maintenance management activities, performance improvements, and spare parts. The
9 PSC Order 02/2012, dated October 25, 2011.
21
authorized uses of these RFM funds may be amended by the PSC at any time—ideally
concurrent with the setting of a new LEAC Rate.
As an accountability measure for the PSC, concurrent with every future quarterly LEAC
rate filing, the prudence and applicability to the FMP funding mechanism, should be
quantitatively supported, since the rate setting responsibility of the Commission requires
review of the status of RFM activities. For the PSC to meet its obligation authorizing the
amount of the RFM in each LEAC Rate cycle, WAPA is required to provide the PSC
certain quarterly RFM information which the PSC will consider in its LEAC rate
deliberations. Pursuant to Commission order approving the Stipulation, WAPA is
required concurrent with each LEAC filing to support the PSC’s inclusion of a RFM
amount in the LEAC Rate. The following is a list of these requirements to which WAPA
has agreed and the PSC approved:
1. An 18-month forward look at WAPA demand and resource balance which will
identify WAPA’s projected available generating capacity and surpluses or
(deficits) for St. Thomas/John district. Albeit late information provided. Without
any explanation the information shows that WAPA is apparently planning on
keeping the emergency unit well past the 18-month lease period.
2. An 18-month forward look at the estimated expenditures that WAPA request be
approved by the PSC for funding with the RFM supplemental financing
component included in the LEAC Rate. The 18-month forward looking list of
expenditures is to include the proposed activities that WAPA proposes the PSC
approve funding in the current LEAC rate as related to emergency generation,
performance and capital improvement projects, deferred preventative
maintenance, purchasing spare parts, and the IAC. Albeit the information was
provided late, we would note the information is sparse and does not reflect what
we would consider a reasonable level of rehabilitation and maintenance activity.
3. A detailed financial report providing the PSC monthly derived RFM revenues, a
summary of all authorized Commission expenditures incurred, and the monthly
ending balances in the RFM fund. All financial activities are to be held in a
separate account. No financial report was provided to the PSC.
4. A detailed analysis of the economic and other benefits to be derived by
residential, business, and government consumers as a result of the proposed
emergency generation, performance of critical deferred maintenance, and the
inclusion of the RFM in LEAC Rates. The analysis is to show for each facility its
estimated operating hours, available capacity, power production, unit efficiency,
fuel use and fuel costs. This analysis was originally to be provided to the PSC in
November 2011—it was not—and is to be updated with each quarterly LEAC
Rate filing. This element is critical since the RFM concept is based upon WAPA
providing benefits in excess of the RFM costs. To date, actual St. Thomas
performance data for 2012 does not support a reasonable level of benefits
22
necessary to justify the level of RFM funding being provided. Hopefully, this
situation will improve.
5. Status of the implementation of a comprehensive and sustainable maintenance
management protocol (MMP) which is to be completed no later than December
31, 2012. No updated information was provided.
Following the Commission September 24, 2012 Order, WAPA did make progress in
providing the quarterly information and reports required by the Stipulation and for the
PSC to continue the funding of the RFM component of the LEAC Rate. For instance, it
made a filing on October 24, 2012 which addressed the reporting activities required by
the Stipulation. However, this is now the fifth LEAC Rate proceeding since the
Stipulation was approved by the PSC and the third LEAC Rate proceeding since the PSC
authorized WAPA to begin collecting RFM revenues as part of the LEAC rate and once
again WAPA has not addressed, concurrent with its current LEAC rate filing, each of the
activities required quarterly by the Stipulation, nor has it made any meaningful progress
in complying with the IAC requirements outline in Attachment 6 to the Stipulation.
Lastly, the RFM temporary funding mechanism established by the PSC requires
accountability, public transparency, and rate setting assessment. To those ends, WAPA
should retain an IAC specializing in power generation who shall provide technical
expertise in the oversight, review and reporting on critically deferred maintenance,
performance and capital improvement projects, and the overall efficiency and reliability
of power plant facilities. At WAPA’s request, on July 17, 2012 the PSC staff provided
WAPA with a detailed IAC work scope for use in the IAC procurement process.
Subsequently, an extended conference call was held to walk through the draft work scope
at which time WAPA indicated it would respond with its comments in writing within a
brief period of time. WAPA continues to indicate that the IAC can have no operating
authority; however, it is understood by the PSC staff that the IAC shall have no
operating responsibilities. This understanding was written into the first draft work
scope provided by the PSC staff. The obligations, duties, and reporting responsibilities of
the IAC are outlined in Attachment 6 of the Stipulation approved by PSC Order. No
progress has been made in securing an IAC.
The parties have held no discussions since the update provided in our previous LEAC
report; however, the parties have agreed to meet on December 17, 2012 for the purpose
of discussing this matter. This matter needs to be resolved at the earliest date since
currently the PSC has no independent means by which it can assure consumers the
accountability, public transparency and assessment that the funds collected are be used
for the purposes granted.
The PSC should consider the failure of WAPA to comply with conditions of its previous
Order concerning the deficiencies in WAPA’s compliance with the quarterly filing
requirements and retention of an IAC when deliberating on its LEAC Rate request for the
23
January through March 2013 period and GCG recommends that the PSC indicate that if
it does not receive an RFP with the appropriate scope as defined in Attachment 6 to the
Stipulation that continuation of the RFM could be deferred until the document is received
and all other requirements of the RFM are current.
Under-Recovery Amortization
In the original filing, WAPA estimated that there will exist an under-recovery balance as
of December 31, 2012 of $26.8 million (over and above the GO note amortization) for a
total of $33.9 million. WAPA proposes to amortize (collect) the under-recovery balance
not financed with the GO note over a period of twelve months ending December 2013 at
a rate of $2.2 million per month. We have accepted the proposed amortization period for
recovery of this deferred fuel expense.
As the Commission is well aware, there has never been a full reconciliation between the
deferred fuel expense on the books of WAPA and the deferred fuel expense in the LEAC,
although an audited adjustment was made for Fiscal 2010 and Fiscal 2011. The electric
department unaudited financial statements for September 2012 show a deferred fuel
balance (current and non-current) of nearly $50 million. The LEAC balance (including
the GO financing) shows a deferred fuel balance of $31.5 million.
Through the discovery process and conferences, WAPA has acknowledged that another
accounting entry needs to be made and has provided a sample journal of proposed
accounting entries to correct this problem. Although management states that once these
entries are made for Fiscal 2012 audit and similar adjustment are made for the months
subsequent to June 2012, the accounting balance and LEAC deferred fuel balances will
be identical, no data has been provided. As of this report, GCG does not know whether
these adjustments impact the earnings of WAPA as did occur in the aforementioned
adjustments for Fiscal 2010 and Fiscal 2011. Once the entry has been made and the
balance of deferred fuel expense are in “sync,” GCG recommends that WAPA should
provide the PSC the impact(s) of these adjustments will a full explanation of any impacts
related to those entries for Fiscal 2012 and Fiscal 2013.
Sales, Losses and Uses
The projection of sales, losses and uses are provided in the LEAC Schedule 4.1
workbook. For the Electric Department WAPA projects a line loss percent of 8.3% on St
Thomas and 7.6% on St Croix. These amounts are greater than the 6.6% line loss
standard the Commission set in 2005 for WAPA to achieve by 2009. In addition, the
Commission approved in Docket No. 575 a line loss surcharge for the purpose of
reducing line losses to the standard established by the Commission. In Docket 575, the
Commission awarded WAPA a specific surcharge for a program to reduce line losses of
$0.00291 per kWh. This surcharge went into effect on July 1, 2009 and has continued in
place since that time. The cash from this surcharge is to be solely used for projects
designed to reduce the level of line loss which would in turn reduce the level of oil
24
required to produce enough generation to meet demand. To date, losses have not been
reduced to the standard set by the Commission. Meanwhile, the Commission has allowed
WAPA to collect millions of dollars in a line loss surcharge for the purpose of reducing
line loss to this level. In spite of these factors, we have accepted the loss percentages
used by WAPA in its LEAC filing. However, we recommend that WAPA be required to
provide the Commission:
1. A complete reconciliation of the revenues and reserves from the Line Loss
Reduction Surcharge and the intended use of those funds no later than February
15, 2013.
2. A plan demonstrating the activities, milestones, and interim performance levels
showing its approach to achieving a loss level of 6.6% no later than February 15,
2013
3. If such information is not provided on the date recommended, we recommend that
the line loss surcharge be suspended.
25
III. WATER DEPARTMENT
WAPA also filed for a change in its WLEAC for water consumers. WAPA assumptions
deriving the WLEAC concludes that water LEAC rates should be increased from $11.14
per kGal to $13.72 per kGal for an overall bill increase $6.18 for a residential consumer
using 2400 kGal per month or about 7.9% of average monthly bill. The following table
shows the computation of the proposed WLEAC rate and compares that to GCG update
of the filing:
Table 4
WAPA LEAC-Water
($000’s)
WAPA
GCG
As Filed
As Updated
($000s)
($000s)
A Cost of Fuel $ 2,224
$ 2,190
B P&I on New 4-Yr GO Note 594
594
C RO Lease Costs 1,374
1,374
D Elect. Charge Water 1,210
1,210
E Ultra Pure Water Charge (255)
(255)
F Water Production Charge/RO (358)
(358)
G Plant Repair RO Contract (60)
(60)
H Docket 289 Costs 0
20
Sub-Total $ 4,729
$ 4,715
I Base Rate Recovery (913)
(913)
Current LEAC Costs $ 3,816
$ 3,801
J Deferred Fuel Costs 535
800
TOTAL Costs $ 4,350
$ 4,601
Total kGal (000) 317,153
317,153
Proposed WLEAC Factor $ 13.72
$ 14.51 /kGal
Current WLEAC Factor $ 11.14
$ 11.14 /kGal
Monthly Increase $ 2.58
$ 3.37 /kGal
2,400
2,400 Gal
Monthly Increase $ 6.18
$ 8.08
Current Average Bill $ 78.60
$ 78.60
Percent Increase 7.9%
10.3%
Cost of Fuel
WAPA projects that the cost of fuel for the three month period ending March 2013 is
$2.2 million. The cost of fuel is allocated using an algorithm established decades earlier.
Within the spreadsheets of the LEAC fuel allocation is basically a “black box.” Our
26
understanding is that WAPA generally applies experienced fuel allocation from historic
periods for forecasting purposes. There is no specific methodology within the LEAC
spreadsheets that could be easily adjusted for differing forecast techniques. As discussed
in the electric department testimony, this cost of fuel is for the operation of the IDE
plants that for the LEAC period will produce approximately 1.5 million GPD at a cost
that is approximately three times higher than the actual RO cost. It is recommended that
a transfer of the temporary RO equipment on St. Thomas to St. Croix be evaluated. The
transfer of equipment from St. Croix to St. Thomas when there was a water emergency
was accomplished in a very short period of time. It is recommended that the PSC require
such an analysis from WAPA by January 31, 2013.
RO Costs
WAPA now has three RO units in operation under two separate contracts on both St
Thomas and St Croix. WAPA has included the payments to Seven Seas (the owner and
operator of the units) as a cost to be recovered from water consumers in the LEAC. The
total costs included in the three month forecast is $1,374,000. To make this forecast,
WAPA assumes that the St Thomas and St Croix units will be fully operational producing
water for consumers at a rate of approximately 1.2 million gallons per day (MGD) on St
Croix and 2.1 MGD on St Thomas. At a purchase rate from Seven Seas of $3.43 per
kGal on St Croix and $4.77 per kGal on St Thomas, this results in a total monthly charge
of $261 thousand and $337 thousand per month for St Croix and St Thomas, respectively.
These amounts are consistent with the historic production and costs of both units and we
have accepted these projections.10
The PSC has approved inclusion of these costs in the
WLEAC in the past. At the time of the initial operations, these incremental costs were
not a component of base rates.11
Electricity Charged Water
WAPA has introduced a new item for which it seeks recovery from the water consumer.
WAPA has included $1.2 million of costs to be recovered from the consumer for the
electricity used in the production of water through RO that is not paid for by Seven Seas.
To estimate this amount, WAPA assumes a rate of $0.32 per kWh on both an actual (July
2012 through December 2012) and forecasted basis (January 2013 through March 2013).
In the filing, WAPA assumed that this new cost would be effective January 1, 2012.
Later discussions with WAPA indicated that it wished to institute this new collection
effective July 1, 2012. Once this change in assumptions is adjusted the net effect was to
increase the deferred fuel balance for the water department as of June 30, 2012.
WAPA management decided to implement this effective July 1, 2012. WAPA no longer
received compensation directly from Seven Seas related to the electricity required to
10 While we have accepted the forecast given the limited time to evaluate, we need further discussion of the actual way to present costs in future LEACs. 11 When reviewing the calculations on Schedule 7 to determine these costs, WAPA noticed that it had some
programming errors on Schedule 7. We have made the corrections.
27
produce water from the RO system. Under the new contract, WAPA is responsible for
the provision of electricity for the production of water. WAPA measures the usage
required by these units and prices that usage at a rate of $0.32 per kWh. WAPA has
stated that this rate was internally derived by taking the total production costs
(predominantly fuel without any allowance for plant O&M expenses) and dividing by the
total gross generation at the plant using Fiscal 2012 to determine that amount. The PSC
should require that WAPA provide the calculations of this rate. WAPA is proposing to
recover the costs of the additional electricity from the water department. WAPA
proposes that this recovery begin July 1, 2012. To estimate these costs for the LEAC
period ending March 2013, WAPA estimates the total electricity provided to produce
both potable and ultra-pure water and multiplies that total by the $0.32 per kWh. We
agree in concept to the general principles of this adjustment and have accepted the
adjustment from July 1, 2012, but believe that some adjustment may be required for the
year ending June 2012 depending upon when the cessation of payment by Seven Seas
occurred for each Island.
Amount Billed for Ultra-Pure Water
In the RO contract on St Thomas is a provision for the production of “ultra-pure” water
which is used as feed water in the production of electricity from the steam units on St
Thomas. WAPA is proposing to credit water consumers for this cost since this is
included in the total cost of water produced and should properly be a charge to electric
consumers only. For the LEAC period, WAPA proposes to credit the WLEAC $255
thousand based upon the forecasted production of ultra-pure water. To calculate and
estimate the cost of this item, WAPA uses contractual terms that require that Seven Seas
produce a minimum of 12.5 million gallons on the first pass and 2.5 million gallons on
the second pass. This is “priced out” at a rate of $032 per kWh. The amount is just
coincidental to the electric charge of $0.32 per kWh, but is per kGal. The total amount is
then credited to the water department, and we have included these costs in the electric
department LEAC on both an actual and forecasted basis.
Electric Plant Internal Use of Water
WAPA is proposing to credit the water customer a total of $358 thousand for water
produced on St Thomas that is used in the operations of the plant and according to
WAPA would be appropriately charged to the electric department. This is a water
production cost for the amount of production as opposed to the electricity required, which
was described as Ultra-Pure Water.
Plant Repair Intake Valve
WAPA is proposing to further credit water consumers another $60 thousand for Amount
Billed Electric Station #2. This is neither an electricity usage charge nor water
production direct charge. WAPA has informed us that during the installation process
Seven Seas was required to repair and replace the water intake valves on the St Thomas
power plant. WAPA estimates the value of this additional service and has amortized
over a period of time. This is truly an electric production costs and as such we have
28
accepted this credit and have include the costs in the adjusted electric LEAC factor, but
WAPA should provide appropriate work papers and explanation.
Under-Recovery
As with the electric department, the deferred fuel expense shown on the LEAC summary
should mirror the book balance in every month (or at least be able to be reconciled). This
again is not the case. WAPA originally projected an under-recovery of about $1 million
(net of the GO financing) for the period ending December 31, 2012 which it is proposing
to amortize over the next six-months. While we have accepted the amortization period,
the opening balance of deferred fuel beginning July 2012 has been adjusted to reflect the
credit for electricity that was originally in the Fiscal 2012 water LEAC, which reduced
the opening balance of deferred fuel expense as of July 1, 2012. To reflect
management’s decision to begin this credit effective July 1, 2012, we have reversed those
credits in Fiscal 2012 as did WAPA in its revised Fiscal 2012 reconciliation, but reserve
the right to review these credits as indicated earlier.
29
IV. RECOMMENDATION AND PROPOSED ORDER
As a result of our investigation into this filing and for reasons presented herein, our
recommendations are that:
1. A LEAC rate of $ 0.407847 per kWh should be set for the Electric Department.
2. A WLEAC rate of $14.51 per KGal should be set for the Water Department.
3. WAPA should provide all MFR requirements for future quarterly LEAC filings
including the expanded requirement to provide information regarding billing and
collection activity and outstanding balances for the previous two quarters for all
accounts government and non-government by customer class (MFR5);
4. WAPA should provide a detailed and fully transparent narrative to accompany each
LEAC filing describing the request in detail and highlighting the reasons for
underperformance or better than expected performance of the generating units and the
resultant fuel costs. The complete filing including all MFRs should be filed no later
than the 15th day of the second previous month from the initiation of the proposed
LEAC. It is further recommended that a delay or incomplete filing should result in
the day-for-day delay of the implementation of the requested new LEAC factor as
determined by the PSC.
5. The PSC should require that a proposed RFP for the IAC consistent with the
requirements of Attachment 6 to the RFM Stipulation, and produced in collaboration
with the PSC staff, should be filed no later than January 31, 2103. In the absence of
such a filing the PSC should consider suspending implementation of the RFM until a
satisfactory document is filed.
6. WAPA be required to provide a complete reconciliation of the revenues and reserves
from the Line Loss Reduction Surcharge and the intended use of those funds no later
than February 15, 2013. WAPA should include a plan no later than February 15,
2013 demonstrating the activities and interim performance levels showing its
approach and milestones to achieving a loss level of 6.6%. If such information is not
provided we recommend that the line loss surcharge be suspended.
7. WAPA should provide an analysis to support the continuation of the IDE units into
calendar year 2013 and why the temporary units on St. Thomas should not be
deployed to St. Croix.
8. WAPA should provide a full reconciliation of all the appropriate credits and debits
related to the production of RO water from the inception of the new contracts on each
Island by January 31, 2013.
9. WAPA should file a full report showing the full reconciliation of the deferred fuel
accounts on its books and the deferred fuel accounts used in the LEAC calculations
by January 31, 2013. All adjustments related to reconciliation should be provided.
10. WAPA shall provide the Commission no later than January 31, 2013 the tactical and
logistical implementation plans and measures it will take to achieve the five fuel
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diversification and energy efficiency strategies recently adopted by its Board, as well
as the milestones for implementation.
11. The PSC staff shall be required to include on its website the following:
WAPA power production efficiency figures showing projected and actual
monthly power plant efficiency and availability for no less than 12-months.
Summary of RFM improvements currently underway and projected as well as a
forecast of performance benefits of such improvements.
Appropriate links, if any, to WAPA’s website on matters dealing with power and
water costs, service improvements and operating performance.
The staff shall be responsible for updating this information monthly.
12. The effective date for the approved electric and water system LEAC rates shall be the
later of January 1, 2013 or the date upon which WAPA becomes current (to within 30
days of invoices received for administrative assessments and 60 days for docket
specific assessments) on all Commission administrative and docket specific
assessments.
The Virgin Islands Water and Power Authority
LEAC Projection for Fiscal 2013EXHIBIT A 1 January LEAC
1 Increase Deferred Fuel Balance (Water) for Removal of Credits For Electricity in FY12
2 Correct Programming Errors on Schedule 7 and Schedule 3
3 Debit and Credit Electric Department for Items Adjusting Water Department