[Federal Register Volume 65, Number 150 (Thursday, August 3, 2000)]
[Rules and Regulations]
[Pages 47664-47668]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 00-19507]


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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

18 CFR Part 101

[Docket No. RM99-7-000; Order No. 618]


Depreciation Accounting

Issued July 27, 2000.
AGENCY: Federal Energy Regulatory Commission, DOE.

ACTION: Final rule.

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SUMMARY: The Federal Energy Regulatory Commission (Commission) is 
amending the General Instructions of 18 CFR part 101 to establish, for 
those public utilities and licensees that are subject to part 101, 
standards for determining depreciation for accounting purposes. The 
Commission also explains how it intends to monitor depreciation 
practices. This action is necessary in order to fulfill the 
Commission's statutory obligation to ensure that electric utilities 
charge proper amounts of depreciation to expense in each financial 
reporting period. The effect of this action will be to ensure that 
utilities allocate in a systematic and rational manner the cost of 
utility property to the periods during which the property is used in 
utility operations.

DATES: This rule will be effective October 2, 2000.

FOR FURTHER INFORMATION CONTACT:   

Wayne McDanal (Technical Information), Office of Finance, Accounting 
and Operations, Federal Energy Regulatory Commission, 888 First Street, 
N.E., Washington, D.C. 20426, (202) 219-2622
Joseph C. Lynch (Legal Information), Office of the General Counsel, 
Federal Energy Regulatory Commission, 888 First Street, N.E., 
Washington, D.C. 20426, (202) 208-2128

SUPPLEMENTARY INFORMATION:   

Before Commissioners: James J. Hoecker, Chairman; William L. Massey, 
Linda Breathitt, and Curt Hebert, Jr.

I. Introduction

    The Federal Energy Regulatory Commission (Commission) is amending 
the General Instructions of 18 CFR Part 101 to establish, for those 
public utilities and licensees that are subject to Part 101, standards 
for determining depreciation for accounting purposes. The Commission 
also explains how it intends to monitor depreciation practices.

II. Background

    On July 29, 1999, the Commission issued a Notice of Proposed 
Rulemaking (NOPR) proposing to establish the principles that public 
utilities and licensees subject to Part 101 must follow in determining 
depreciation rates for accounting purposes.\1\ In the NOPR the 
Commission noted that it has authority under Section 301 of the Federal 
Power Act (FPA) \2\ over the accounting practices of public utilities 
and licensees and that, under this Section, it has prescribed a Uniform 
System of Accounts (USofA) \3\ that these jurisdictional entities must 
follow.
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    \1\ Depreciation Accounting, 64 FR 42304 (Aug. 4, 1999); FERC 
Stats. & Regs., Proposed Regulations para. 32,544 (July 29, 1999).
    \2\ 16 U.S.C. 825.
    \3\ See 18 CFR Part 101.
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    The Commission further noted in the NOPR that it also has authority 
under Section 302 of the FPA \4\ over the depreciation accounting 
practices of public utilities and licensees and that this authority 
includes the authority to determine and fix proper and adequate 
depreciation rates for accounting purposes.
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    \4\ 16 U.S.C. 825a.
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    The Commission stated that, in order to fulfill its statutory 
obligation to ensure that electric utilities charge proper amounts of 
depreciation to expense in each financial reporting period, it had 
required public utilities and licensees to obtain Commission approval 
before changing their depreciation rates for accounting purposes.\5\ 
The Commission noted, however, that a decision of the U.S. Court of 
Appeals for the District of Columbia Circuit, Alabama Power Company, et 
al. v. FERC, 160 F.3d 7 (D.C. Cir. 1998) (Alabama Power), overturned 
the Commission's action in MidAmerican on procedural grounds.
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    \5\ See MidAmerican Energy Company, 79 FERC para. 61,169 (1997), 
reh'g denied, 81 FERC para. 61,081 (1997) (MidAmerican).
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    The Commission began this rulemaking proceeding to respond to the 
court's concern that the Commission could not exercise its authority 
with respect to depreciation accounting matters without first 
establishing standards. The Commission thus proposed to require 
utilities \6\ to use

[[Page 47665]]

depreciation rates for accounting purposes that were based on the 
straight-line method of depreciation and the assets' estimated useful 
lives, the predominant method traditionally used by utilities. The 
Commission proposed, also, to monitor utility depreciation rates for 
accounting purposes on a case-by-case basis, e.g., as a result of or in 
conjunction with complaints or audits. The Commission's proposal to 
monitor depreciation practices and rates was in lieu of a requirement 
that utilities make individual filings and obtain prior Commission 
approval to change their depreciation rates for accounting purposes.
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    \6\ As in the NOPR, henceforth when we use the word 
``utilities'' in this final rule, we intend to encompass both public 
utilities and licensees; we will refer to ``utilities'' for ease of 
reading. See 18 CFR Part 101, Definition No. 39.
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III. Comments Received

    The Commission received 20 comments in response to the NOPR.\7\ The 
overwhelming majority of those comments agreed with the Commission's 
proposal not to require individual utilities to file their accounting 
depreciation rates with us for our approval.\8\ However, they strongly 
opposed the Commission's proposal to adopt the straight-line method of 
depreciation to the exclusion of other methods of depreciation that 
also result in systematically and rationally allocating the cost of 
utility property to the periods during which the utility uses the 
property in operations.
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    \7\ A list of Commenters appears in the Appendix; we will refer 
to each Commenter by the short form listed there next to each name. 
The Mississippi Public Service Commission filed a notice of 
intervention, but did not comment.
    \8\ FERC Stats. & Regs. para. 32,544 at 33,808. See, e.g., EEI 
at 2.
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    Only two Commenters, the Florida Public Service Commission and 
NARUC, supported the exclusive use of the straight-line method of 
depreciation,\9\ and NARUC asked for clarification of the inconsistency 
between this proposal and the accelerated cost recovery provisions that 
we have agreed to consider with respect to new transmission 
investment.\10\ All of the other Commenters opposed exclusive reliance 
upon the straight-line method of depreciation as the only permissible 
method of accounting for depreciation in the utility industry.
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    \9\ Florida Public Service Commission at 3; NARUC at 5.
    \10\ NARUC at 4.
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    For example, the Edison Electric Institute (EEI) argued that the 
proposal is ``inconsistent with the Commission's adopted policies 
promoting greater competition in electric markets * * * [which require] 
a flexible approach to depreciation accounting * * * '' \11\ EEI notes 
that in an era of rapid technological change an asset's productivity 
may vary greatly over its service life. EEI suggests that, under such 
circumstances, accelerated depreciation will provide a better match of 
expenses to revenues than would straight-line depreciation. EEI notes 
that unregulated companies have the advantage of using accelerated 
depreciation to meet the changing needs of a free market economy; it 
asks that the Commission make the same advantages available to 
utilities as they enter the competitive era. \12\
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    \11\ EEI at 2.
    \12\ EEI at 16.
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    EEI urges the Commission to allow utilities the flexibility to meet 
the constantly changing conditions of the marketplace by permitting 
utilities to change the estimated service lives of their capital 
equipment and to adopt methods of depreciation other than straight-
line, if, in their judgment, circumstances warrant. EEI points out that 
generally accepted accounting principles (GAAP) \13\ allows for methods 
of depreciation other than straight-line that are also systematic and 
rational ways of accounting for the depreciable life of assets.\14\ 
According to EEI, this flexibility would permit companies to use 
depreciation schedules that incorporate service lives of varying 
lengths as well as varying rates of obsolescence. This would allow 
management to more carefully track costs and cost causation.
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    \13\ GAAP encompasses the conventions, rules and procedures 
necessary to define accepted accounting practices. GAAP incorporates 
the accounting profession's consensus at a particular time as to 
which economic resources and obligations companies should record as 
assets and liabilities, which changes in assets and liabilities they 
should record, how they should measure assets and liabilities and 
changes in them, what information they should disclose, how they 
should disclose it, and what financial statements they should 
prepare.
    \14\ EEI at 18-19.
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    EEI submits that the proposed adoption of a straight-line 
depreciation method of accounting does not meet the reporting needs of 
a changing industry and runs counter to the Commission's efforts to 
promote efficient competition by reducing the regulatory and accounting 
burden on utilities.\15\ EEI also observes that the NOPR's proposal for 
universal straight-line depreciation is inconsistent with the 
Commission's recent Order No. 2000, in which the Commission indicated 
that it would consider the application of accelerated depreciation for 
new transmission investment.\16\
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    \15\ EEI at 4-6.
    \16\ EEI at 21. In Order No. 2000, the Commission included as 
one of the innovative rate treatments offered to Regional 
Transmission Organization (RTO) participants non-traditional 
depreciation for ratemaking purposes for new transmission 
investments. RTOs would have to support their proposals with: (a) a 
detailed explanation of how the proposed rate treatment would help 
achieve the goals of Regional Transmission Organizations; (b) a 
cost-benefit analysis, including rate impacts; and (c) a detailed 
explanation of why the proposed rate treatment is appropriate for 
the RTO requesting it. See 18 CFR 35.34(e)(1), .34 (2)(iii); 
Regional Transmission Organizations, Order No. 2000, FERC Stats. & 
Regs. para.31,089 at 31,194-95, order on reh'g, Order 2000-A, FERC 
Stats. & )Regs. para.31,092 at 31,387-88.
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    Detroit Edison submits that the Commission ``is being far too 
prescriptive for an industry in transition and subject to competitive 
pressures.'' \17\ According to Detroit Edison, GAAP mandates only that 
companies determine depreciation in a systematic and rational manner 
and recognizes several different methods of accounting for depreciation 
that would accomplish this.\18\ Detroit Edison also argues that 
straight-line depreciation necessarily defers the recognition of 
certain costs to future years, when, in a competitive environment, a 
company charging the higher prices necessary to recover these deferred 
costs could drive away customers. Detroit Edison submits that other 
methods of depreciation, such as double or 150-percent declining 
balance or sum-of-the-years digits depreciation, better match cost 
accrual with revenues and allow companies the flexibility to survive in 
a competitive world.\19\
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    \17\ Detroit Edison at 2.
    \18\ Id. at 2, 8.
    \19\ Id.
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    Detroit Edison observes that the straight-line method of accounting 
for depreciation worked well when there was an obligation to serve and 
a guarantee of future income because technology changed little and 
customers had few options. Today, technology is changing rapidly, costs 
are becoming more differentiated, and choice is becoming the norm. As a 
result, the assumption that assets will produce a steady stream of 
revenue throughout their physical lives is no longer valid.
    Rather, Detroit Edison submits, the assumption in today's world 
should be that each asset will produce a different, individual income 
stream, which will depend on its economic usefulness. Detroit Edison 
argues that ``accounting should reflect that reality[]'' \20\ and help 
the industry prepare for competition rather than re-enforce existing

[[Page 47666]]

regulatory practices. \21\ Most of the other Commenters expressed 
similar views. \22\
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    \20\ Id. at 10.
    \21\ Id. at 11.
    \22\ See, e.g., American Institute of Certified Public 
Accountants at 1, 4; Commonwealth Edison at 1, 3-4, 7 (competition 
mandates various types of accounting for depreciation, including 
accelerated depreciation); Consumers Energy at 4-5 (Commission 
should allow all methods of accounting for depreciation, including 
accelerated depreciation, that result in a rational and systematic 
allocation of the cost of a utility's plant); PSE&G at 1 (under 
certain conditions methods of accounting for depreciation, other 
than straight-line, provide for a better matching of expenses with 
revenues); NRECA at 2 (changes in technology often require 
accelerated depreciation because of rapid obsolescence of assets); 
Cinergy at 1 (endorses comments of EEI); Allegheny Energy at 1 (the 
changing needs of the market place are affecting the useful lives of 
capital equipment and the rate at which equipment is becoming 
obsolete); Virginia Power at 6 (same); Old Dominion at 2 (GAAP 
recognizes other methods of accounting for depreciation that result 
in systematically and rationally recording depreciation expense over 
an asset's useful life.); AEP at 4 (proposed rule would impose more 
regulation and record keeping on the utility industry at the very 
time that it needs far less regulation in order to meet the demands 
of competition.); Arthur Anderson at 3 (depreciation accounting 
should be flexible to recognize the economic effects of regulation 
during the transition to a competitive business environment); Price 
Waterhouse at 1 (if the expected productivity or revenue-earning 
power or maintenance requirements vary greatly over the life of an 
asset, a depreciation method of accounting other than straight-line 
may more appropriately allocate costs to revenues); First Energy at 
2 (the Commission should accept all methods of depreciation, 
including accelerated depreciation, that are consistent with GAAP); 
Deloitte & Touche at 2 (same); Southern at 13 (proposal runs counter 
to Commission's willingness to consider accelerated depreciation for 
new investment in transmission facilities).
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IV. Discussion

    The Commission's Uniform System of Accounts for electric utilities 
defines depreciation as the loss of an asset's service value not 
restored by current maintenance.\23\ Some of the causes for the loss in 
service value include wear and tear, decay, action of the elements, 
inadequacy, obsolescence, changes in the art, changes in demand, and 
requirements of public authorities. The primary objective of recording 
depreciation expense is to allocate an asset's service value over its 
remaining useful life. To accomplish this objective the Commission has 
traditionally used a straight-line depreciation method to allocate an 
asset's service value over its remaining life.
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    \23\ 18 CFR Part 101, Definition No. 12.
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    We thus initially proposed to adopt for accounting purposes the 
straight-line method of depreciation as our standard. As we noted in 
the NOPR, straight-line depreciation was the method typically used by 
utilities.\24\ While, in general, we expect that that is likely to 
continue to be the case for most utility property, commenters have 
persuaded us that requiring its universal use would be overly 
prescriptive. The primary objective of depreciation accounting is to 
allocate in a systematic and rational manner the cost of property to 
the periods during which the property is used in utility operations, 
i.e., over its estimated useful service life. As Commenters correctly 
observe, there are methods of depreciation other than the straight-line 
method that also meet this objective.
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    \24\ See 64 FR 42304 (1999); FERC Stats. & Regs. para.32,544 at 
33,806. See also, e.g., J. Suelflow, Public Utility Accounting: 
Theory and Application 96 (1973) (``Straight line is the predominant 
method used by utilities and sanctioned by most regulatory 
bodies.''); Deloitte Haskins & Sells, Public Utilities Manual 23 
(1980) (``[T]he straight-line concept is applied almost universally 
for both accounting and rulemaking. * * *''); C. Phillips, The 
Regulation of Public Utilities: Theory and Practice 272 (3d ed. 
1993) (The straight line method * * * is the simplest and most 
commonly used.''); L. Hyman, America's Electric Utilities: Past, 
Present and Future 292 (5th ed. 1994) (``The book depreciation rate 
is a straight line rate for most utility companies.''); accord 
Depreciation Subcommittee of the NARUC Committee on Engineering, 
Depreciation, and Valuation of the National Association of 
Regulatory Utility Commissioners, Public Utility Depreciation 
Practices 12 (1968) (``In the two decades, since the Report of the 
Committee on Depreciation of the NARUC was published in 1943, the 
use of the straight-line method for accounting and rate-making 
purposes has became almost universal for public utilities.'').
    In addition, the FERC Annual Report Form No. 1's appeared to 
indicate the same.
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    Therefore, we will modify our proposed rule and simply require 
utilities to use for accounting purposes methods of depreciation that 
allocate the cost of utility property over its useful service life in a 
systematic and rational manner. Such methods include not only a 
straight-line method of depreciation, but other methods of 
depreciation. The broader systematic and rational standard will ensure 
that depreciation for accounting purposes is done properly while at the 
same time allowing flexibility in a changing business environment.
    We are not unmindful that this additional flexibility could create 
a potential for abuse. However, we believe that our monitoring of 
utility depreciation practices will mitigate that potential. 
Consequently, as noted in the NOPR, we will not require utilities to 
make a separate filing to obtain Commission approval before 
implementing changes in depreciation rates for accounting purposes.\25\ 
Instead, we will monitor utility depreciation practices on a case-by-
case basis.\26\
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    \25\ Our action today authorizes utilities to change their 
method of depreciation for accounting purposes only; it does not 
authorize any utility to change prices charged for power sales or 
transmission services (whether determined by stated rates or formula 
rates) to reflect a change in depreciation.
    To change prices charged for power sales or transmission 
services (whether determined by stated rates or formula rates) to 
reflect a change in depreciation, a utility would first have to make 
a filing with us, pursuant to sections 205 or 206, 16 U.S.C. 824d, 
824e, as appropriate, to that effect.
    \26\ As we noted in Midwest Power Systems Inc., 67 FERC para. 
61,076 at 61,209 (1994), utilities ``most common[ly]'' change their 
depreciation rates in the context of a rate case. Accord, id. at 
61,208, n.7.
    We expect that utilities will continue to change their 
depreciation accounting predominantly in the context of rate cases, 
and that, in fact, changes in depreciation accounting will rarely 
occur outside of a rate case.
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V. Environmental Statement

    The Commission excludes certain actions not having a significant 
effect on the human environment from the requirement to prepare an 
environmental assessment or an environmental impact statement.\27\ The 
promulgation of a rule that is procedural or that does not 
substantially change the effect of legislation or regulations being 
amended raises no environmental considerations.\28\ This final rule 
amends Part 101 of the Commission's regulations and does not 
substantially change the effect of the underlying legislation or the 
regulations being revised.
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    \27\ 18 CFR 380.4.
    \28\ 18 CFR 380.4(a)(2)(ii).
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    Further, approval of actions under Section 301 of the FPA, relating 
to accounting orders, also raises no environmental considerations.\29\ 
The instant rule fundamentally involves accounting matters, 
establishing standardized depreciation accounting practices. 
Accordingly, no environmental consideration is necessary.
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    \29\ 18 CFR 380.4(a)(16).
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VI. Regulatory Flexibility Act

    The Regulatory Flexibility Act (RFA), 5 U.S.C. 601-612, requires 
rulemakings to contain either a description and analysis of the effect 
that the final rule will have on small entities or a certification that 
the rule will not have a significant economic impact on a substantial 
number of small entities.
    In Mid-Tex Elec. Coop. v. FERC, 773 F.2d 327 (D.C. Cir. 1985), the 
court found that Congress, in passing the RFA, intended agencies to 
limit their consideration ``to small entities that would be directly 
regulated'' by proposed rules. Id. at 342. The court further concluded 
that ``the relevant `economic impact' was the impact of compliance with 
the proposed rule on regulated small entities.'' Id. at 342.
    Most public utilities to which this final rule would apply do not 
fall within

[[Page 47667]]

the definition of small entity.\30\ Consequently, the Commission 
certifies that this final rule will not have a significant economic 
impact on a substantial number of small entities.
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    \30\ See 5 U.S.C. 601(3), citing to section 3 of the Small 
Business Act, 15 U.S.C. 632, which defines ``small business 
concern'' as a business that is independently owned and operated and 
that is not dominant in its field of operation.
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VII. Public Reporting Burden and Information Collection Statement

    The Commission is amending 18 CFR part 101 to establish the 
principles for determining depreciation rates for accounting purposes. 
While we are adding an instruction to an information requirement, the 
instruction is not adding to the information reporting burden because 
the Commission is not requiring public utilities to do anything more or 
less than they are already doing to account for depreciation. 
Accordingly, this final rule does not impose any additional public 
reporting burden. We are forwarding a copy of this to the Office of 
Management and Budget for their information.
    Interested persons may obtain information on the reporting 
requirements by contacting the following: Federal Energy Regulatory 
Commission, 888 First Street, NE., Washington, DC 20426 [Attention: 
Michael Miller, Capital Planning and Policy Group, Phone: (202) 208-
1415, Fax: (202) 208-2425, E-mail: [email protected]].
    To submit comments concerning collections of information and 
associated burden estimate(s), please send your comments to the contact 
listed above and to the Office of Management and Budget, Office of 
Information and Regulatory Affairs, Washington, DC 20503, [Attention: 
Desk Officer for the Federal Energy Regulatory Commission, Phone: (202) 
395-3087, Fax: (202) 395-7285].

VIII. Document Availability

    In addition to publishing the full text of this document in the 
Federal Register, the Commission provides all interested persons an 
opportunity to view and/or print the contents of this document via the 
Internet through FERC's Home Page (http://www.ferc.fed.us) and in the 
Commission's Public Reference Room during regular business hours (8:30 
a.m. to 5 p.m. Eastern time) at 888 First Street, NE., Room 2A, 
Washington, DC 20426.
    From FERC's Home Page on the Internet, this information is 
available in both the Commission Issuance Posting System (CIPS) and the 
Records and Information Management System (RIMS).

--CIPS provides access to the texts of formal documents issued by the 
Commission since November 14, 1994.
--CIPS can be accessed using the CIPS link or the Energy Information 
Online icon. The full text of this document is available on CIPS in 
ASCII and WordPerfect 8.0 format for viewing, printing, and/or 
downloading.
--RIMS contains images of documents submitted to and issued by the 
Commission after November 16, 1981. Documents from November 1995 to the 
present can be viewed and printed from FERC's Home Page using the RIMS 
link or the Energy Information Online icon. Descriptions of documents 
back to November 16, 1981, are also available from RIMS-on-the-Web; 
requests for copies of these and other older documents should be 
submitted to the Public Reference Room.

    User assistance is available for RIMS, CIPS, and the Website during 
normal business hours from our Help line at (202) 208-2222, or by E-
Mail (to [email protected]) or the Public Reference Room at (202) 
208-1371 (E-Mail to [email protected]).
    During normal business hours, documents can also be viewed and/or 
printed in FERC's Public Reference Room, where RIMS, CIPS, and the FERC 
Website are available. User assistance is also available.

IX. Effective Date

    This final rule will take effect October 2, 2000. The Commission 
has determined, with the concurrence of the Administrator of the Office 
of Information and Regulatory Affairs of the Office of Management and 
Budget, that this rule is not a ``major rule'' within the meaning of 
Section 251 of the Small Business Regulatory Fairness Act of 1996.\31\ 
The Commission will submit the Final Rule to both houses of Congress 
and to the General Accounting Office.\32\
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    \31\ 5 U.S.C. 804(2).
    \32\ 5 U.S.C. 801(a)(1)(A).
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List of Subjects in 18 CFR Part 101

    Electric power, Electric utilities, Reporting and recordkeeping 
requirements, Uniform System of Accounts.

    By the Commission.
David P. Boergers,
Secretary.

    In consideration of the foregoing, the Commission amends Part 101, 
Title 18 of the Code of Federal Regulations, as follows.

PART 101--UNIFORM SYSTEM OF ACCOUNTS PRESCRIBED FOR PUBLIC 
UTILITIES AND LICENSEES SUBJECT TO THE PROVISIONS OF THE FEDERAL 
POWER ACT

    1. The authority citation for Part 101 continues to read as 
follows:

    Authority: 16 U.S.C. 791a-825r, 2601-2645; 31 U.S.C. 9701; 42 
U.S.C. 7102-7352, 7651-7651o.


    2. In Part 101, General Instructions, paragraph 22 is added to read 
as follows:

General Instructions

* * * * *
    22. Depreciation Accounting.
    A. Method. Utilities must use a method of depreciation that 
allocates in a systematic and rational manner the service value of 
depreciable property over the service life of the property.
    B. Service lives. Estimated useful service lives of depreciable 
property must be supported by engineering, economic, or other 
depreciation studies.
    C. Rate. Utilities must use percentage rates of depreciation 
that are based on a method of depreciation that allocates in a 
systematic and rational manner the service value of depreciable 
property to the service life of the property. Where composite 
depreciation rates are used, they should be based on the weighted 
average estimated useful service lives of the depreciable property 
comprising the composite group.

    Note: This appendix will not be published in the Code of Federal 
Regulations.

Appendix--Commenters

------------------------------------------------------------------------
               Name                          As styled in order
------------------------------------------------------------------------
Allegheny Energy, Inc............  Allegheny Energy.
American Electric Power Service    AEP.
 Corporation (filing on behalf of
 itself and on behalf of its
 operating public utility
 affiliates: Appalachian Power
 Company, Columbus Southern Power
 Company, Indiana Michigan Power
 Company, Kentucky Power Company,
 Kingsport Power Company, Ohio
 Power Company and Wheeling Power
 Company).

[[Page 47668]]

 
American Institute of Certified    American Institute of Certified
 Public Accountants.                Public Accountants.
Arthur Andersen, LLP.............  Arthur Andersen.
Cinergy Services, Inc............  Cinergy.
Cleco Corporation................  Cleco.
Commonwealth Edison Company......  Commonwealth Edison.
Consumers Energy Company.........  Consumers Energy.
Deloitte & Touche LLP............  Deloitte & Touche.
Detroit Edison Company...........  Detroit Edison.
Edison Electric Institute........  EEI.
FirstEnergy Corp.................  FirstEnergy.
Florida Public Service Commission  Florida Commission.
Mississippi Public Service         Mississippi Commission.
 Commission.
National Association of            NARUC.
 Regulatory Utility Commissioners.
National Rural Electric            NRECA.
 Cooperative Association.
Old Dominion Electric Cooperative  Old Dominion.
PricewaterhouseCoopers, LLP......  Price Waterhouse.
Public Service Electric & Gas      PSE&G.
 Company of New Jersey.
Southern Company Services, Inc.    Southern.
 (acting as agent for Alabama
 Power Company, Georgia Power
 Company, Gulf Power Company
 Mississippi Power Company and
 Savannah Electric and Power
 Company (collectively, Southern
 Company).
Virginia Electric and Power        Virginia Power.
 Company.
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[FR Doc. 00-19507 Filed 8-2-00; 8:45 am]
BILLING CODE 6560-50-P