BILL ANALYSIS                                                                                                                                                                                                    




                                                                  SB 1876
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          Date of Hearing:  June 24, 2002

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                              Roderick D. Wright, Chair
                     SB 1876 (Bowen) - As Amended:  June 19, 2002

           SENATE VOTE  :  26-7
           
          SUBJECT  :  Electrical restructuring.

           SUMMARY  :  Modifies the electric restructuring law pertaining to  
          public utility holding companies, and retention and sale of  
          public utility electricity generation assets.  Specifically,  
           this bill :

          1)Requires the California Public Utilities Commission (PUC) to  
            ensure that utility retained generation be dedicated to serve  
            the utility's bundled service customers.

          2)Defines "utility retained generation" as utility owned  
            electricity generation, qualifying facility contracts, and  
            other bilateral electricity contracts entered into by an  
            investor-owned utility (IOU).<1>

          3)Provides that the cost of major capital additions and  
            improvements to an IOU's retained generation assets shall be  
            reviewed and approved by PUC in advance of IOU being allowed  
            to invest in major capital additions or improvements.

          4)Subjects public utility holding companies to PUC jurisdiction  
            for purposes of enforcing various PUC decisions.

          5)Specifies that any gain or loss on sale associated with the  
            sale, transfer, or disposition of assets that have been  
            included in the rate base of an IOU shall be allocated  
            exclusively to the ratepayers served by IOU.

          6)Calculates gain or loss on sale as the difference between the  
            transfer or sale price and the net depreciated book value of  
          ---------------------------
          <1> This bill specifies that defining utility-retained  
          generation is not intended to predetermine the outcome of  
          pending civil or regulatory proceeding involving bilateral  
          electricity contracts entered into by the San Diego Gas and  
          Electric Company.   









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            the assets at the time of the transfer.

          7)Repeals laws requiring PUC to establish a mechanism that  
            ensures recovery by IOUs of transition costs from their  
            customers, including costs for generation related assets and  
            obligations, that were being collected in PUC-approved rates  
            on December 20, 1995, that may become uneconomic as a result  
            of a competitive generation market.<2>

          8)Repeals laws authorizing IOUs to recover utility generation  
            related plant and regulatory assets to the extent that they  
            remain un-recovered after December 31, 2001, due to IOUs'  
            ability to recover costs related to the implementation of  
            direct access, the Power Exchange (PX), and the Independent  
            System Operator (ISO).  

          9)Directs PUC to allocate uneconomic costs<3> of among various  
            classes of customers and rate schedules to ensure that costs  
            are recovered in substantially the same proportion as similar  
            costs are recovered as of June 1996 through the retail rates  
            of the relevant electric utility.

          10)Requires rates for IOU retained generation provide a  
            reasonable opportunity for both cost recovery and return based  
            on those assets' depreciated book value.

          11)Requires PUC to establish a "firewall" segregating the  
            recovery of costs of competition transition charge exemptions  
            so that the costs of the exemptions granted to residential  
            customers shall be recovered from them, and costs of  
            exemptions granted to other customer classes shall be  
            recovered from the members of that class.

          12)Directs PUC to establish a Ratepayer Refund Account for each  
            IOU.  If any refunds are recovered by an IOU in connection  
          ---------------------------
          <2> The author plans to offer an amendment in committee intended  
          to clarify that the transition costs described in Section 367(a)  
          of this bill, which are recoverable only until 12/31/01, are  
          costs of pre-12/20/95 investments, as in current law.

          <3> These "stranded costs" are frequently defined as the capital  
          costs (depreciation and return on investment) for a generating  
          plant that cannot be fully recovered in a competitive market,  
          because the revenue at the market price is less than total  
          operating cost, including the cost of capital.








                                                                  SB 1876
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            with the charging of excessive costs for wholesale power by  
            electric power generators, the refunds would be credited to  
            the account and held in trust for the benefit of ratepayers.

          13)Repeals laws authorizing an IOU that is also a gas  
            corporation, and served fewer than four million customers as  
            of December 20, 1995, to implement a rate cap mechanism that  
            reflects price changes in the fuel market.  

          14)Repeals laws listing qualifications for PX governing board  
            members, and granting the Electricity Oversight Board (EOB)  
            power to oversee PX procedures and qualifications of PX board  
            members.

          15)Repeals laws requiring EOB to ensure incorporation of ISO and  
            PX as public benefit nonprofit corporations.

          16)States the intent of the Legislature to provide for  
            development of regional electricity transmission markets in  
            the western states, through adoption of a regional compact  
            among cooperating party states, to be approved by EOB.

           EXISTING LAW:  

          1)Requires public utility generation assets to remain dedicated  
            to service for the benefit of California ratepayers.

          2)Establishes a ISO and a PX as separately incorporated public  
            benefit nonprofit corporations.

          3)Establishes EOB to oversee ISO and PX in order to ensure the  
            success of the electrical industry restructuring and to ensure  
            a reliable supply of electricity in the transition to a new  
            market structure.

          4)Grants PUC power to supervise and regulate every public  
            utility in the state and to take all actions that are  
            necessary and convenient in the exercise of that power.

          5)Requires PUC to establish an effective mechanism that ensures  
            recovery by IOUs of transition costs from their customers,  
            including costs for generation related assets and obligations,  
            that were being collected in PUC-approved rates on December  
            20, 1995, that may become uneconomic as a result of a  
            competitive generation market.









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          6)Requires each IOU to propose a cost recovery plan for the  
            recovery of the uneconomic costs.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

           Gain on Sale  

          Over several years, PUC has issued a number of decisions  
          assigning or allocating the gain on the sale of public utility  
          property to or between shareholders and ratepayers.  In general,  
          PUC has applied a risk analysis to allocation of gain on sale --  
          evaluating the relative risk to shareholders or ratepayers with  
          respect to a particular asset (or liability).  PUC rules and  
          precedent allocates gain on sale on a category by category  
          basis.

          On sales of nondepreciable property, such as land, PUC allocates  
          gain on sale, or at least a higher percentage of gain on sale,  
          to shareholders.  In the case of depreciable property, which is  
          more likely to be used for provision of services to ratepayers,  
          the gain on the sale is normally appropriately allocated to  
          ratepayers. 

          PUC typically allocates any gain to shareholders or ratepayers  
          according to the amount of time the asset was held in rate base  
          versus the amount of time it was held outside the rate base.   
          That can sometimes result in a 50/50 split of gain to be shared  
          between shareholder and ratepayer. 

          This bill allocates any gain or loss on the sale of assets  
          exclusively to ratepayers if the asset has been included in the  
          rate base of IOU.  Which goes against the rule widely followed  
          in the U.S. that those who shouldered the risk of loss are  
          entitled to the benefit from the gain.<4> 

           Holding companies  

          In a series of decisions in recent years, PUC has authorized  
          formation of holding companies.  In each decision authorizing  

          ---------------------------
          <4> Democratic Central Committee of the Dist. of Columbia v.  
          Washington Metropolitan Area Transit Comm'n (1973) 485 F. 2d 786
            








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          the holding company systems, PUC incorporated a provision  
          requiring that the utilities be given "first priority" within  
          those systems.<5> 

          The "first priority" condition has generally been interpreted to  
          require a holding company to give preference to the utility when  
          investing capital whenever the parent determines that the  
          investment requirements of the utility are necessary to meet the  
          utility's obligation to serve. 

          PUC recently issued a series of decisions<6> on the subject of  
          the first priority condition, stating that when a utility's  
          access to or possession of capital of any type is impaired, and  
          its ability to discharge its obligation to serve is consequently  
          threatened, the first priority condition requires its holding  
          company to give the utility preference over all competing  
          potential recipients of capital resources.

          Thus, at least under certain circumstances, PUC has decided that  
          the first priority condition includes a requirement that a  
          holding company infuse all types of capital into its respective  
          utility subsidiaries when necessary to fulfill the utility's  
          obligation to serve.

          But none of PUC decisions broadly interpreting the first  
          priority condition has brought a holding company within PUC  
          jurisdiction, as is done in this bill.  This is a significant  
          change, despite the fact that the jurisdiction here is for the  
          limited purpose of monitoring and enforcing PUC holding company  
          decisions.

           Cost recovery
           
          AB 1890 (Brulte), Chapter 854, Statutes of 1996, restructured  
          California's electric industry in order to establish a  
          competitive generation market.  Under that law, IOU generation  
          assets are subject to rate regulation by PUC, and were to  
          ---------------------------
          <5> For example, PUC decision in PG&E's case stated: "The  
          capital requirements of PG&E, as determined to be necessary and  
          prudent to meet the obligation to serve or to operate the  
          utility in a prudent and efficient manner, shall be given first  
          priority by PG&E Corporation's Board of Directors."  
          (D.96-11-017).

          <6> See, e.g., D. 02-02-039, issued January 11, 2002.








                                                                  SB 1876
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          continue to be subject to PUC regulation until those assets have  
          undergone market valuation. 

          AB X1 6 (Dutra), Chapter 2, Statutes of 2001, First  
          Extraordinary Session, repealed the reference to market  
          valuation, and provided that the remaining generation facilities  
          will continue to be regulated by PUC until the owner of those  
          facilities has applied to PUC to dispose of those facilities,  
          and has been authorized to sell the assets by PUC.  This bill  
          further prohibits the sale of any public utility-owned power  
          plant until January 1, 2006, and requires PUC to ensure that  
          generation assets remain dedicated to service for the benefit of  
          California ratepayers.

          In light of the "re-regulation" of utility generation assets,  
          PUC began to apply cost-based ratemaking to IOU retained  
          generation assets.  Thus, the costs of those utility generation  
          assets that would have been recovered (or not) in the market  
          were to be recovered in cost of service rates. 

          The author of this bill states, however, that given that rates  
          were increased twice last year, and that IOUs have recovered  
          billions of dollars of stranded costs, repealing the cost  
          recovery sections of AB 1890 are necessary and simply recognize  
          the reality that existing AB 1890 stranded cost recovery  
          provisions are no longer necessary or functional.

           Pending litigation  

          Repealing the cost recovery provisions of AB 1890 could have an  
          effect on Southern California Edison v. Lynch, et al.  In that  
          action, on which a decision by the Ninth U.S. Circuit Court of  
          Appeals is imminent, TURN alleges as an Intervenor that Edison -  
          PUC settlement agreement entered into last October violates the  
          relevant restructuring laws in two respects.  First, TURN argues  
          that the settlement expressly maintains the rate-freeze beyond  
          March 31, 2002, and does so for the purpose of allowing Edison  
          to recover its past procurement costs - the costs the statute  
          says and PUC has, until this agreement, insisted could trigger  
          the risk of less-than-full recovery of uneconomic costs.  And  
          second, TURN alleges the settlement the rate-freeze guarantee  
          that protects consumers from price increases during the  












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          transition to a competitive market.<7>

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Coalition of California Utility Employees
          TURN
          Public Utilities Commission
           
            Opposition 
           
          Berkeley Chamber of Commerce
          Kearny & Associates
          Labor Management Services
          Oakland Metropolitan Chamber of Commerce
          Pacific Gas & Electric Company
          Sempra Energy


           Analysis Prepared by  :    Paul Donahue / U. & C. / (916) 319-2083  






















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          <7> A similar set of allegations was recently made in a petition  
          for a Writ of Mandamus now before the California Supreme Court  
          in Foundation For Taxpayer and Consumer Rights v. CPUC.