United :
Environi
Agency
Office of Energy. Minerals, and
Industry
Washington DC 20460
EPA-600/7-78-155b
August 1978
Research and Development
Review of New Source
Performance Standards
for Coal-Fired
Utility Boilers

Volume II
Economic and
Financial Impacts

Interagency
Energy/Environment
R&D Program
Report

-------
                RESEARCH REPORTING SERIES

Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology.  Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:

      1.  Environmental  Health Effects Research
      2.  Environmental  Protection Technology
      3.  Ecological Research
      4.  Environmental  Monitoring
      5.  Socioeconomic Environmental Studies
      6.  Scientific and Technical Assessment Reports (STAR)
      7.  Interagency Energy-Environment Research and Development
      8.  "Special" Reports
      9.  Miscellaneous Reports

This report has been assigned to the INTERAGENCY ENERGY-ENVIRONMENT
RESEARCH AND DEVELOPMENT series. Reports in this series result from the
effort funded  under the 17-agency Federal Energy/Environment Research and
Development Program. These studies relate to EPA's mission to protect the public
health and welfare from adverse effects of pollutants associated with energy sys-
tems. The goal of the Program is to assure the rapid development of domestic
energy supplies in an environmentally-compatible manner by providing the nec-
essary environmental data and control technology. Investigations include analy-
ses of the transport of energy-related pollutants and their health and ecological
effects; assessments of,  and development of, control  technologies for energy
systems; and  integrated assessments of a wide range of energy-related environ-
mental issues.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.

-------
  REVIEW OF NEW SOURCE PERFORMANCE
      STANDARDS FOR COAL-FIRED
           UTILITY BOILERS

       VOLUME II - ECONOMIC AND
          FINANCIAL IMPACTS
March 1978

-------
                                 DISCLAIMER

     This report has been reviewed by the Office of Research 'and Development,
U.S. Environmental Protection Agency, and approved for publication.  Approval
does not signify that the contents necessarily reflect the views and policies
of the U.S. Environmental Protection Agency, nor does mention of trade names
or commercial products constitute endorsement or recommendation for use.

-------
                                ABSTRACT

This two volume report summarizes a study of the projected effects of several
different revisions to the  current New Source Performance Standard (NSPS) for
sulfur dioxide (SO-) emissions from coal-fired utility power boilers.  The revision
is assumed to apply to all  coal-fired units of 25 megawatts or greater generating
capacity beginning  operation  after  1982.   The revised standards which  are
considered are:  (I) mandatory 90 percent S02 removal with an upper limit on
emissions of 1.2 Ib S02 per million Btu; (2) mandatory 80 percent SC^ removal
with the same upper limit; (3) no mandatory percentage removal  with an  upper
limit of 0.5 Ib SCL per million Btu. In addition, effects of revising the NSPS for
particulate emissions from the current value of O.I Ib per million BtO down to
0.03 Ib  are quantified.   Projections of the structure of the electric  utility
industry both with and without the NSPS revisions are.given out to  the year 2000.
Volume I discusses air emissions,  solid wastes, water consumption, and energy
requirements.   Volume II discusses economic and financial  effects, including
projections of pollution control costs and changes in electricity prices.

-------
                                 PREFACE

This report is one of several volumes being submitted by Teknekron to the U.S.
Environmental Protection Agency under contract 68-01-3970, "Review of  New
Source Performance Standards  for  Sulfur  Dioxide  Emissions from Coal-Fired
Steam Generators."  This volume discusses the economic and financial implica-
tions of alternative New Source  Performance Standards as they will apply to the
U.S. electric utility industry.  Volume I, which is being submitted concurrently,
presents  the emissions and  non-air quality environmental implications.of these
SO2 control alternatives. A third volume discussing the air quality implications
of  the emissions control alternatives  is  anticipated, as  is a  final volume
containing a  series of "issue papers" summarizing results which bear on specific
policy issues  relating to EPS's proposal to revise the current standard.
                                     -i-

-------
                             CONTENTS
PREFACE  [[[    i

CONTENTS [[[    II

LIST OF FIGURES ................................................    v

LIST OF TABLES .................................................    vj

I.OSUMMARY AND  CONCLUSIONS  ................................   l-l
    I . I  Principal Economic Impacts ...............................   1-4
    1 .2  Principal Financial Impacts  ...............................   1-7

2.0 OVERVIEW OF THE ELECTRIC UTILITY INDUSTRY ..............   2-1
    2. 1  Industry Structure ..... . ..................................   2-1
        2.1.1    Privately Owned Utilities ........................   2-3
        2.1.2    Nonfederal Government Units  ....................   2-5
        2.1.3    REA Cooperatives ..............................   2-5
        2.1.4    Federally Owned Utilities ........................   2-6
    2.2  Operating Costs ..........................................   2-7
    2.3  Electricity  Prices ........................................  2-11
    2.4  Plant Size, Mix and Efficiency .............. . .............  2-15
    2.5  Regulatory  Setting  .......................................  2-18
        2.5.1    Regulatory Interaction with Utilities ..............  2-21
    2.6  Financial Consideration  ...................................  2-23

3.0 ECONOMIC AND FINANCIAL IMPACT ASSESSMENT OF
    ALTERNATIVE NEW SOURCE PERFORMANCE STUANDARDS ....   3-1
    3. 1  Teknekron's Electric Utility Financial Modules ..............   3-4

-------
         3.2.1    Economic Impacts on the Utility Industry .........  3-9
                  3.2.1.1   Total Revenue Requirements ........... 3-11
                  3.2.1.2   Costs  	 3-14
                  3.2.1.3   Net Profits	 3-17
                  3.2.1.4   Investments	 3-17
                  3.2.1.5   Retail Prices  	 3-19
         3.2.2    Regional Prices and  Per  Capita  Costs	3-19
         3.2.3    Regional Pollution Control Cost  and Investment.... 3-25
                  3.2.3.1   Regional Pollution Control Costs 	3-29
    3.3  Financial Impacts	3-33
         3.3.1    Return on Equity  	...	 3-35
         3.3.2    Interest Coverage 	,	3-38
         3.3.3    Quality of Earnings  	 3-40
         3.3.4    Summary of Industry  Impacts	 3-43
         3.3.5    External  Financing Impacts  	 3-45
         3.3.6    Impact on National Capital  Markets 	 3-47

4.0 COAL VERSUS NUCLEAR:   Economics and Decision-Making As
    Affected by Revised  New Source Performance Standards for
    Coal-Fired  Boilers	  4-1
    4.1  Busbar Power Costs	  4-2
    4.2  Review of  Economic Evaluations	  4-3
         4.3.1    Capacity Factors	  4.4
         4.2.2    Fuel Costs	  4-7
         4.2.3    Capital Costs	  4-8
         4.2.4    NSPS Revisions and Regional Effects 	  4-9
    4.3  Factors Difficult to Quantify  	4-10
         4.3.1    Reasons to Invest in Nuclear and Reasons to Avoid
                  Coal	4-10
         4.3.2    Reasons to Invest in Coal and Avoid Nuclear	4-12
    4.4  Summary, Emphasizing Regional Considerations	.%... 4-16
                                  -in-

-------
APPENDIX  A:   CAPITAL FORMATION PROSPECTS  	  A-1
    A.   The Role of Capitol  Markets	  A-l
         Capital Markets	  A-l
         Electric  Utility Participation in the Capital  Markets	  A-3
    B.   Factors Affecting Electric Utility  Industry Capital-Raising
         Prospects	A-13
         Macroeconomlc Factors	 A-31
         Mlcroeconomic Factors	A-32
         Regulatory Policies	A-38
         Management Policies	A-42
         Pollution Control Revenue Bonds	A-54

APPENDIX  B:   GENERATING UNIT COSTS OF SO, AND
               PART1CULATE CONTROLS	t......	  B-l
                                -iv-

-------
                            LIST OF FIGURES


                                                                     PAGE


1.1    Teknekron Utility Simulation Model	    1-3


2.1    Fuel Price and Cost for the Electric Utility  Industry,
       1940-1975	   2-12
2.2    National Average  Heat Rates for Fossil Fueled Steam
       Electric Plants, 1950-1975	   2-19


3.1    Teknekron Utility  Simulation Model	    3-2


B-l    Cost of Particulate Control Using Electrostatic
       Precipitators for New Coal-Fired Utility Boilers	    B-4


B-2    Cost of  SO2 Control for New Coal-Fired  Utility
       Boilers Using  a Limestone FGD System	    B-5

-------
                             USTOFTABLES
                                                                     PAGE
I. I     Alternative New Source Performance Standards Considered	    1-2
2.1    Total Electric  Utility Industry Sales  and Revenues,  1965-1975,    2-2
2.2    Comparative Size Characteristics, Privately  and Publicly Owned
       Electric Utilities,  1975.....	    2-4
2.3    Structures of Total Costs  of Privately Owned Electric
       Utilities, 1975	    2-8
2.4    Structure of Total Costs of Publicly Owned Utilities, 1975 ...    2-9
2.5    Price Indices for  Components of  Electric Utility Plant
       Construction,  1965-1975	  2-10
2.6    Electric Utility Industry New Construction Expenditures,
        1965-1975	.	  2-10
2.7    Electric Utility Industry Fuel Consumption and Prices,
        1965-1975	....,	  2-13
2.8    Electricity Price Index, 1965-1975	  2-13
2*9    Percent Increase in Average Electricity Bills by  Census Region
       and Customer  Class,  1965-1975 ..	  2-14
2.10   Net Generation of Electricity,  (I06  KWH) Class A and B
       Utilities, 1965-1975	,	  2-16
2.11   Privately Owned Electric Utilities Fossil Fueled Steam  Plant
       Capacity,  1965-1975	  2-17
2.12   Backlog of Electric Utility Rate  Cases	  2-22
2.13   Distribution  of Returns  on  Equity for Class A and  B Utilities,
        1970 and 1975	  2-25
2.14   External Financing of Electric Utility  Industry,  1965-1975 ....  2-26
2.15   Balance Sheet  Relationships for Privately Owned Electric
       Utilities, 1965-1975	  2-27
3.1    Input Values Passed to the Financial Module  by Other USM
       Modules	    3-5
3.2    Regions Used for Analysis of Alternative NSPS  Revisions .....    3-8
3.3    Alternative New Source Performance Standard Revisions
       Considered	  3.jo
                                  -VI-

-------
3.4    Comparison of Selected National Economic Impacts on the
       Electric Utility Industry	   3-12
3.5    Comparison of Selected National Economic Impacts on the
       Electric Utility Industry of Alternative NSPS Revisions	   3-13
3.6    Regional Price Impacts on the Electric Utility Industry of
       Alternative NSPS Revisions,  1995.........	   3-20
3.7    Per  Capita Cost of Alternative NSPS Revisions,  1995 ........   3-23
3.8    Per  Capita Cost of Alternative NSPS Revisions, 1995	   3-24
3.9    Pollution Control Costs by Region  for Alternative NSPS
       Revisions,   1995	   3-27
3.10   Pollution Control Costs by Region for Alternative NSPS
       Revisions,   1985-1995	   3-28
3.11   Direct  Pollution  Control Investment by Region for Alternative
       NSPS Revisions,  1986-1995	   3-30
3.12   Direct  Pollution  Control Investment by Region for Alternative
       NSPS Revisions,  1986-1995	   3-31
3.13   Return on  Equity......	,	   3-37
3.14   Interest Coverage	   3-39
3.15   Quality of Earnings	   3-41
3.16   Long-Term External Financing	   3-46
4.1    Comparison of Nuclear and Coal Busbar Power Costs on
       a Regional Basis	    4-5
                                    -yn-

-------
                     1.0 SUMMARY AND CONCLUSIONS

The Environmental Protection Agency asked Teknekron to assess the economic
and financial impacts of alternative  New  Source Performance Standard (NSPS)
revisions on the electric utility industry. This assessment has been accomplished
both from a regional as well as national perspective for a number of candidate
NSPS revisions, presented in Table I.I. For this analysis Teknekron has employed
its Utility Simulation  Model (USM),  which generates an integrated, internally
consistent analysis of the economic and financial impacts of alternative environ-
mental regulations on the operations of the nation's investor and publicly owned
electric  utilities.   Figure  I.I  illustrates the interaction of the economic and
financial analysis undertaken in the Financial module of the USM with the utility
planning, dispatching, and environmental analysis.

The remainder of this volume is organized in the following manner. Chapter 2
describes the structure, composition, and recent performance of the  electric
utility industry over the  last decade.  Chapter 3  contains the economic and
financial impact analysis and results of alternative NSPS revisions.   Attention
has been paid not  only to the economic and financial impacts on the industry, but
to the potential impacts on the industry's customers and the public.  Using the
Financial module of the  USM, Teknekron  has examined the regional price,
pollution  control  cost, and  investment  effects  of these  alternative  NSPS
revisions.  Financial effects on utilities1 return on investment, interest coverage
ratio, and earnings quality are analyzed in addition to the potential impact of the
NSPS  revisions  on the  nation's capital  markets.   Chapter 4  presents  an
assessment of  the coal-nuclear  trade-off in the context of changed environ-
mental regulations.  Appendix A contains a discussion of issues surrounding the
                                                                         t
capital  formation prospects of electric utilities.   Appendix B  provides some
detail as to the costs of sulfur dioxide and particulate controls.
                                  (M

-------
                                                                 Table I.I
                              Alternative New Source Performance Standard Revisions Considered
         Electricity Demand
         Growth
BASELINE                                                      BASELINE
M 1.2(0)0.1  M 1.2(90)0.1   M 1.2(80)0.03  M 1.2(90)0.03  M 0.5(0)0.03  H 1.2(0)0.1 H 1.2(90)0.1  H 1.2(80)0.03 H 1.2(90)0.03
Moderate*   Moderate*    Moderate*     Moderate*    Moderate*     High*      High*        High*        "High*
r\>
         Ceiling for SO,             •  0
          Emissions"2             '•*
                            1.2
              1.2
              0.5
            1.2
           1.2
             (.2
             1.2
         Percent Removal             _
          Requirements for SO,

         Porticulate Standard**      0.1
              90%
               O.I
80%
0.03
90%
0.03
0.03
O.I
                       90%
O.I
                        80%
0.03
                         90%
                                                                                                                                       0.03
                  5.8% per year to 1985; 3.4% thereafter.
             **   lnlb/!06Btu
                  5.8% per year to 1985; 5.5% thereafter.
             NOTE:   Standards  other  than  the baseline cases are assigned to apply  only to coal-fired generating units beginning
             	    commercial operation in I983 or later. See Volume 1 for a more detailed discusstion of the scenarios analyzed.

-------
             Figure I.
TEKNEKRON UTILITY SIMULATION MODEL
 DEMAND
 PLANNING
 DISPATCH
FINANCIAL
 RESIDUALS
 REGIONAL AIR
 QUALITY ANALYSIS

-------
I. I   PRINCIPAL ECONOMIC IMPACTS

     •    The largest increases in national economic factors facing
          the  electric utility  industry  due to  alternative  NSPS
          revisions over the 1986-1995 period (when  the majority of
          economic and financial impacts will occur) are forecast
          for pollution control costs and investment.  Nationally,
          total costs facing the utility industry under  the  NSPS
          revisions increase at most 5 percent over the  1986-1995
          forecast period. Net profits for the industry may decrease
          as  much  as 2.8 percent  under  the high growth cases.
          Pollution control investment may increase to  10  percent
          of  total industry  investment over the  1986-1995 period
          under high growth.  Comparing the forecasts of the 80 and
          90  percent SO- removal  standards over  the  1986-1995
          period indicates that there is little variation in pollution
          control expenses (costs and investment) or in retail price
          of electricity.

     •    Changes in both national retail prices and per capita costs
          (total  revenue/population)  due to  alternative NSPS revi-
          sions are  forecast not to be large over the  1986-1995
          period; the average yearly  increase  in  real  prices  is
          forecast to be approximately 0.5  percent  at most, under
          high growth, less than 0.2 percent under moderate  growth.
          National per capita costs are forecast  to increase  at most
          by 0.4 percent per year over the 10-year period.

     •    There  are  significant regional  variations in the economic
          impacts.  Retail prices of electricity,  in real  terms, are
          forecast to increase over  10 percent in the West South
          Central region, which includes the Gulf coast area where

-------
     relatively large amounts of coal-fired capacity subject to
     the  NSPS  revisions are  planned to  be  constructed  to
     replace gas-fired capacity.   Other regions where retail
     price increases  may  be  significant under high  growth
     include North Mountain, West North Central, East North
     Centr&l and South Atlantic. *
•    Regional per capita costs vary greatly over the 1986-1995
     forecast period.  As before, the West South Central region
     incurs the  largest increases, over  10  percent under the
     high growth case.   The impact of NSPS revisions on per
     capita costs for the other regions is  not so significant.
     The forecasted differences between the 80 percent and 90
     percent SO- removal cases are not large  for national per
     capita costs.  The New England, West  South Central and
     South  Mountain  regions  incur  the largest  differential
     impact between the 80 percent and 90 percent cases.

•    Both pollution control costs  and  direct pollution  control
     investment are forecast to increase significantly over the
      1986-1995  period  as a   result of  the  NSPS  revisions
     considered.  As expected, direct pollution control  invest-
     ment expenditures increase more than  costs.  The largest
     increases occur  under the high growth,  90 percent S0~
     removal cases; national  direct pollution  control  invest-
     ment expenditures increase between 174 and  195 percent
     (to  between  $48  and $52  billion  in  1975  dollars)  and
     pollution   control  (operation  and  maintenance) costs
     increase between 37 and 41  percent (to between $51 and
     $57 billion in  1975 dollars).    Direct pollution  control
See Table 3.2 for regional definitions.
                              1-5

-------
      investment increases from between  2 and 3 percent for
      the  baseline cases to at most 7  to  10 percent of total
      industry investment  under the 90 percent SOj removal
      cases.  While pollution control expenses are higher under
      the  90  percent  cases than  the 80 percent cases, on
      average for the nation over the 1986-1995 period, they are
      less than 8 percent different.

      In addition to direct pollution control  investment  expen-
      ditures that the electric  utility  industry is  forecast to
      make  under the  NSPS  revisions,  somewhat higher plant
      investment expense will be incurred  because  of the FQD
      system-related capacity penalties.*  Based on information
      supplied to Teknekron  on these  penalties, we estimate
      that  between $2 and  $5  billion may be  required  for
      additional  plant  investment over the  1986-1995 period.
      These results  represent less than one percent  of fore-
      casted total industry investment over the period.

      Again, the  West  South Central region incurs the largest
      increases in pollution control costs  and direct pollution
      control  investment,  which are  forecast to increase  a
      maximum of  85  and 300  percent respectively over  the
      1986-1995 period. Under the high growth cases, six of ten
      regions' direct investment costs  increase over  100 per-
      cent.  Because of Its relatively small dependence on coal-
      fired capacity, New England bears the lowest, increase in
      costs and investment.
These capacity penalties are assumed to be between 5 and 6 percent.
                               1-6

-------
1.2  PRINCIPAL FINANCIAL IMPACTS

Important financial parameters  that were examined include the utilities' return
on equity, their interest coverage ratios, and the quality of their earnings.  These
factors were analyzed both nationally and regionally.

     •    Alternative NSPS revisions for both the moderate and high
           growth  cases are forecast  as  having  relatively  little
           financial  impact.   Nationally,   the  utilities'  return  on
           equity decreases between 3.3 and 6.5 percent; the interest
           coverage  ratio decreases  1.3 percent under high growth,
           remains constant under moderate growth.  The quality of
           earnings,  measuring  the extent  of the  utilities' earnings
           that are composed of noncash AFDC, decreases  relatively
           little, 2.6 percent, under moderote growth and 6.8 percent
           under high growth for alternative NSPS revisions.

     •    Most affected from a  financial  perspective is  the West
           South Central region, principally because relatively large
           amounts   of  coal-fired capacity subject to  the NSPS
           revisions are forecast to be constructed to replace much
>           of the present gas-fired capacity. Other regions' financial
           impacts due to NSPS revisions are much smaller.

     •    The  utilties'  return on equity  on a  regional basis  is
           generally  stable under  NSPS revisions.  The  West South
           Central  and  North  Mountain  are  the  most  affected
           regions.

     •    Regional interest coverage ratios generally are  not signi-
           ficantly  affected by  the  NSPS revisions.    The  most
           affected   regions are  West  South Central,  East North
           Central, and South Mountain.

                                  1-7

-------
Quality of earnings for the utility industry is affected
relatively more by different electricity growth rates and
overall construction programs than by the NSPS revisions.
The most  adversely affected  regions are  East  South
Central and West South Central.
The impact on long-term external financing of the NSPS
revisions among  the  nation's investor-owned  utilities is
felt most on common stock financng. Neither long-term
debt or preferred stock issues are greatly affected;  the
greatest increase is in long-term debt under high growth,
representing 2.1  percent  increase over  the  1976-1995
period. Common stock issues increase 7 percent and 8.6
percent under the moderate and high growth  90 percent
SO- removal cases, respectively.

The impact  of  NSPS revisions  on the  nation's macro-
economic activities  and capital  markets is  relatively
small. Additional direct investment by the utility industry
due to NSPS revisions in 1990 Is forecast to be at most
$6.2 billion  in 1975 dollars, representing 0.25 percent of
real GNP  and  1.6 percent of  gross  private domestic
investment.
                         1-8

-------
           2A OVERVIEW OF THE ELECTRIC UTILITY INDUSTRY
Over the recent post the electric utility industry, already one of the largest in
the nation, has grown  in  importance within the  energy sector.   In  1950,  17
percent of the nation's  primary energy supplies was used to produce electricity.
By  1975,  this  figure had  Increased to  28  percent.   Between  1970 and 1975,
electric utility construction work in  progress increased over 80 percent in real
terms, to  over $26  billion.   Of  this  amount,  almost $2.2  billion  was  for
environmental-related construction.

Electric utilities are highly capital intensive: in 1975 the amount of investment
(gross electric utility plant) per employee was $334,480, a 37 percent increase
since 1970. In addition, $3.60 of net capital investment was  required to produce
$1  of revenue.  In  1975,  the total  electric utility  industry had  $163 billion
invested in 'plants, making it among the  largest in  the nation.  As will  be
discussed  below, this capital intensity and size both contribute to the utilities'
significant impact on the nation's capital market.

Not only is the electric utility industry large, but it is one of the fastest growing
in the nation.  As  Table 2.1 illustrates, both total  kilowatt-hour (kwh) sales and
total revenues have increased greatly over  the past decade.  Between  1965 and
1975, total  kwh sales increased by 68.6 percent, whereas the real gross national
product increased  by 27.8 percent.
2.1   INDUSTRY STRUCTURE

Although  all  electric  utilities  produce the same product, they  can  differ
significantly by type of ownership, customer  mix, cost structure and operation.
Since the first electric generating plant began commercial operation in 1892, the
                                    2-1

-------
                                  Table 2.1
         Total Electric Utility Industry Soles and Revenues. 1965-1975
Year
1965
1970
1975
Total Energy Sales
to Ultimate Customers
(!09Kwh)
953.4
1,391.4 (46.0)*
1,607.4 (13.4)
Total Revenue
from Ultimate Customers
(10*$)
15,022*
23,434 (55.9)
73,447 (68.1)
Source:  Federal  Power  Commission
*
    Figures in parentheses indicate percent increase from previous period.
    Adjusted by electricity Price Index.  In  1967 dollars.
                                    2-2

-------
Industry has undergone continuous development.  The industry now is comprised
of over 3,000 operating utilities  that  are either  privately owned, nonfederal
government, REA cooperatives, or federal projects.

      2.1.1      Privately Owned Utilities

The privately owned electric utilities dominate the entire utility industry despite
their  few numbers. While representing less than 15 percent of the nation's utility
systems, they account for  the largest share of industry sales revenues, generated
output and customers, as illustrated in Table 2.2.

The growth of the private sector, like that of the  whole industry,,has been im-
pressive; since 1965 the privately owned electric utilities' total  power generation
has increased by 68.2 percent.  Among the privately owned systems  there is great
disparity  in system size. A large number of private firms  are  small companies
serving nonurban, non-industrial markets.  Like the small publicly owned utilities,
these firms are usually distribution-only systems, purchasing their power require-
ments from the larger utilities.

Within  the  privately owned sector the large utilities account  for a dispropor-
tionate share of generated output, assets, and revenues.   These  large systems
have  grown in size both through internal expansion and through acquisitions of
other electric utilities.  In 1970 the fifty largest privately owned electric; utility
systems,  representing less than  2 percent  of the nation's operating electric
systems, generated 64 percent of the industry's net kwh output.  The 213 Class A
& B  utilities,* representing approximately one-half of the   privately owned
operating utilities, accounted for nearly  100  percent of the  privately owned
electric utilities' assets and revenues.
     The Federal  Power  Commission defines Class A utilities  as those with
     annual  electric operating revenues of  more  than $2.5 million.   Class B
     utilities are  those with annual  electric operating revenues between $1
     million and $2.5 million.  Those utilities having annual electric operating
     revenues below $1 million are defined either as  Class C or Class D, de-
     pending on their size.
                                    2-3

-------
                                 Table 2.2

           Comparative Size Characteristics, Privately and Publicly
                       Owned Electric Utilities, 1975
                                                  Private*          Public*
Total Sales (I06 Kwh) .                          1,353,089 '(84)**,  254,353

Total Net Generation (IO6 Kwh)                 1,486,676 !(86)     245,778

Total Generative Capacity (Mw)                   393,953(81)      91,696

Total Electric Operating Revenue (106$)            39,639 (90)       4,341

Total Customers (millions)                           63.5 (89)          7.9
Source;  Federal Power Commission


    Privately owned Class A & B Utilities.

    includes municipal wholesalers, municipal  retailers, federal projects,  and
    state power authorities.

**  r-
    Figures in parentheses indicate percent  of total electric  utility  industry,
    private plus public utility figures.
                                   2-4

-------
These  relatively few systems thus exert a pervasive influence on the entire
industry's economic and financial performance.  Much of the analysis  of the
utilities1 performance in the following  chapters  will focus on these privately
owned utilities.

     2.1.2      Nonfederal Government Units

The largest number of  electric utility systems, the nonfederal government sys-
tems,  include city  and  town municipal utilities, county and state systems,  and
special utility districts.  In 1975 these systems generated about 9 percent of the
industry's production and 11  percent of industry sales.  Between 1965 and  1975
nonfederal government systems increased their generation by 75.5  percent.  In
1923 there were 3,084 such systems, but by 1975 the number had declined from
this peak to approximately 2,000 with about two-thirds of them purchasing all of
their power requirements from either  privately owned or federal systems.  The
municipal systems  are  the most numerous of the nonfederal systems and vary
greatly in size.  Some serve only a few hundred customers, while others like the
Los Angeles Department of  Water and Power, the nation's largest  municipal
electric utility, serve over a million.

     2*1.3      REA Cooperatives

The Rural Electrification Administration (REA), founded in  1936, has promoted
the increased use of electric energy in  rural America through  the creation of
rural electric service cooperatives.  Federal financing of such cooperatives was
necessary due to the apparent reluctance of private industry to  provide electric
service in rural areas.   This reluctance was  likely caused in large part  by the
relatively high distribution costs per customer, making rural electrification  less
                                       i
profitable than  urban service areas.  The REA systems serve  an average load
density of about four customers per mile  of line, which  is about one-tenth the
load density in urban areas.
                                    2-5

-------
When the cooperatives were  first organized in the  1930s, they were almost
exclusively distribution systems.  As time passed and their loads grew, generation
and transmission cooperatives  were developed to supply the cooperatives' power
requirements.  The REA cooperatives now purchase about  75 percent of their
wholesale power requirements? in 1940, 92 percent was purchased. Their largest
single power source is the government sector, including  federal systems, which
supplied 45 percent of the cooperatives' requirements.

In  1975 the  cooperatives  accounted for almost 2  percent of  the nation's
generated kwh.  These utilities have grown the fastest of any systems; between
 1965 and 1975 the cooperatives  increased their  power generation by over 200
percent.

     2.1.4      Federally Owned Utilities

The federal systems account for the second largest segment of industry capacity
and generated energy.  In  1975 they accounted for  over  II  percent of the
industry's net generation.  Over the last decade, their generation  increased 46
percent.

The five largest federal systems include the Bonneville Power Administration,
the Southwestern Power Administration, the Southeastern Power Administration,
the Department of the Interior's Bureau of Reclamation,  and the nation's largest
system, the Tennessee Valley  Authority  (TVA).  Unlike  the four other federal
systems, TVA operates fossil-fuel and nuclear generating capacity in addition to
hydroelectric facilities.  These five systems sell most of  their electric power to
other publicly owned systems (municipals and  cooperatives) In their  operating
regions, to  a small number of large industrial purchasers, and to government
agencies such  as the Energy Research and Development  Administration for
nuclear diffusion and processing operations.
                                   2-6

-------
     OPERATING COSTS
The utilities' operations can include generation, transmission, and distribution of
electricity. The costs associated with these and other activities are presented In
Table 2.3 (Privately Owned Utilities) and Table 2.4 (Publicly Owned Utilities).
The  differences in  cost structures between  the privately and publicly owned
utilities  are notable, indicating  these  firms' varying operating environments.
With the exception of the municipal wholesalers, the publicly owned firm's power
production costs are relatively higher than those of the privates. In the case of
the municipal  retailers, 56  percent of  operating revenue  is accounted for by
power production costs, reflecting  the higher costs of purchased power.   In
addition, the distribution costs are relatively higher for municipal retailers than
privately owned utilities, illustrating their more distribution-oriented operations.

Also of interest is the "Other Costs" category, which includes  depreciation and
amortization  allowances and  taxes.   This cost  category for  publicly owned
utilities  represents about one-half the relative size of those for privately owned
utilities.   This is due  in large part to the relatively smaller  amount  of plant
owned by the publicly owned utilities and different tax provisions.

Labor, capital, and fuel costs are the major operating costs faced by the electric
utilities and have been increasing steadily.  Between 1970 and 1975 total salaries
and  wages for reporting Class A  & B privately owned utilities increased 50
percent to $4.06 billion; total employment grew over the same period 4.8 percent
to 403,407 in 1 975.  This increase in salaries and wages is put in perspective when
it is realized that  the privately  owned electric  utilities' generated output
increased only 25 percent between 1970  and 1975.

The utilities' construction cost is a very important factor In an industry that Is so
capital  intensive.  The costs  of  constructing electric power plants have risen
dramatically over the past  decade and are shown  in Table 2.5.  The Handy-
                                      2-7

-------
                                 Td>le 2.3
      Structure of Total Costs of Privotely Owned Electric Utilities. 1975
             Type of Cost
(I03 $)
Power Production
    Fuel
    Purchased power
    Other power production
    Maintenance
    Sub-Total
Transmission
Distribution
Customer accounting & sales
Administrative and general
    Total Operation & Maintenance
Other Costs (depreciation, amortization,
              taxes, other)
    Total Operating Costs
Utility Operating Income
    Total Utility Operating Revenue
14,545,313
3,238,934
1,314,383
1 ,403,897
20,502,527
502,186
1,753,593
2,221,102
1,100,347
26,079,755
9,995,463
36,075,218
8,522,889
44,598, 107
(33)*
( 7)
( 3)
( 3)
(46)
( 1)
( 4)
( 2)
( 2)
(58)
(22)
(81)
(19)
(100)
Source: FPC, Statistics of  Privately Owned  Electric Utilities  in the  United
                    -   - - - -
    Figures in parentheses indicate percent of Total Utility Operating Revenue.
                                   2-8

-------
                                  Table 2.4

           Structure of Total Costs of Publicly Owned Utilities, 1975

1 ,...:- -. - - - ; •
Type of Cost
Power Production
Transmission
Distribution
Customer Accounts & Sales
Administrative & General
Total Operation & Maintenance
Other Cost (depreciation, amorti-
tization, taxes, other)
Total Operating Costs
Utility Operating Income
Total Utility Operating Revenue
Source: FPC, Statistics of Publicly

Municipal
Wholesalers*
216,192
(41)**
16,004
(03)
5,279
(01)
2,875
(Of)
27,207
(05)
267,557
(51)
49,815
(10)
317,372
(61)
204,995
(39)
522,367
(100)
Owned Electric
(I03 $)
Municipal
Retailers*
2,222,341
(56)
38,390
foi)
246,219
(06)
111,113
(03)
205,307
(05)
2,822,770
(71)
498,257
(12)
3,321,027
(83)
676,163
(17)
3,997,190
(100)
Utilities in

Federal
Projects
1,041,335
(56)
92,831
<05)
1,395
(00)
4,713
(00)
57,960
(03)
1,198,234
(64)
105,037
(ID
1,403,271
(75)
472,424
(25)
1,875,695
(100)
the United
**
    States, 1975.

Municipal  wholesalers  are those publicly owned utilities  whose revenues
from  sales for  resale  are 51  percent or  more  of  total utility  operating
revenues.

Municipal retailers are those publicly owned utilities whose revenues from
sales for resale are 50 percent or less of total utility operating revenues.

Figures in parentheses indicate percent of Total Utility Operating Revenue.

                               2-9

-------
                                 Table Z5

               Price Indices for Components of Electric Utility
                       Plant Construction.  1965-1975
              Handy Whitman Public Utility Construction Index
                      1965    1970    1971   1972    1973    1974   1975

Building*
Electric Light and
87
89
121
119
133
128
144
135
158
144
190
171
211
200
   Power**
Source;  Statistical Abstract of the United States, 1976.

Note:    Based on data covering public utility construction costs for 95 items in
         6 geographic regions.  Covers  skilled  and common labor;   does not
         reflect tax payments nor employee benefit costs.  (1967= 100)
**
Includes cost of components for power plant building construction.

Includes cost of material and equipment for steam-electric plant generation
(boilers, turbine-generators, coal and ash handling equipment, condensers
and tubing, and cranes);  includes separate listing for operations employees.
                                 Table 2.6

      Electric Utility Industry New Construction Expenditures,  1965-1975
                                                    1965    1970   1975
Total National New Construction
     Expenditures (106$)

Electric Light and Power Industry
     New Construction Expenditures (10 $)
                                             73,747   94,855  132,043
                                               2,589   5,808    9,020
                                               (3.7)*  (6.1)    (6.8)
Source; Statistical Abstract of the United States, 1976

*   Figures in parentheses indicate percent of national total.

                                   2-10

-------
Whitman Public Utility Construction Cost indices, which measure the change In
costs of constructing  electric power  plant  buildings and of  steam-electric
generation equipment, have increased by  142  percent and 125 percent, respec-
tively, over the 1965-1975 period. The utilities' new construction expenditures
between 1965 and 1975 increased almost 250 percent, as shown in Table 2.6, and
account for nearly 7 percent of the nation's new construction.

Fuel cost  is the largest single operating cost faced by an  electric  utility, and
represents between  70  percent and 80 percent of total power production costs
(see Table 2.3). Table 2.7 illustrates the very large recent Increases in fuel cost
faced by the utilities.  Between  1965 and 1975 the wholesale fuel  price index
increased over 100 percent.  Figure 2.1 illustrates the relationships between fuel
prices, fuel cost per kwh generated and fuel used per kwh generated.

As shown in Figure  2.1, as the price of fuel has increased, the utilities have en-
deavored to reduce  their relative usage of fuel (indicated by fuel use per kwh)
through utilization  of  higher pressure  and  temperature steam  generating
equipment.  In order to reduce  fuel usage the  utilities have  employed more
capital-intensive generating technologies (e.g., nuclear). Together, the increased
fuel costs and rising consumption raised  fuel expenditures of privately owned
electric utilities for $3.73 billion  in  1970 to $14.55 billion In 1975, almost a 400
percent increase.

Z3  ELECTRICITY PRICES

Each of these cost increases has been manifested most directly in the increased
price of electricity.   As is shown in  Table 2.8, the electricity  price index
increased 69 percent between 1965 and  1975. This compares with the 71 percent
increase over the same period for  the consumer price index.  Table 2.9 illustrates
the  regional  breakdown for price  increase  between 1965  and  1975 in the
residential, commercial and industrial customer classes.
                                    2-11

-------
                         FIGURE 2.1

                FUEL PRICE AND COST FOR THE
                ELECTRIC UTILITY INDUSTRY,
                          1940-1975
                                          INDEX
                                            650
                            COST OF FUEL PER kWh
      1940
1945
1950
1955
I960
1965
1970    1975
   NOTE:  DATA BASED ON ALL FUEL USED IN ELECTRIC GENERATION
          AND EXPRESSED IN UNITS OF EQUIVALENT COAL.

          INDEX:  1937-1941 = 100

SOURCES:  1937-1958, FEDERAL POWER COMMISSION
          1959-1975, FEDERAL POWER COMMISSION AND  "
          EDISON ELECTRIC INSTITUTE
                           2-12

-------
                                  Table 2.7

             Electric Utility Industry Fuel Consumption and Prices,
                                  1965-1975


                      ^^^^^^^^^^II^HHHIHIHIHH^II^^H|^HHHII|HjRHBE^^^^IHHBraH|Hj^^^^^^^

                       1965    1970   1971    1972    1973    1974   1975
Millions of short
  tons of coal equi-
  valent fuel

Wholesale  Fuel
  Price Index
  (1967=100)
369    592    618     673    729     740    769
 93.5   122.6  138.5   148.7   164.5  219.4  271.5
Source; Statistical Abstract of the United States, 1976.
                                  Table 2.8

                      Electricity Price Index,  1965-1975
                       1965    1970   1971    1972   1973    1974   1975
Electricity Price Index   99.1   106.2  113.2   118.9  124.9   147.5   167.0

Consumer Price Index   94.5   116.3  121.3   125.3  133.1   147.5   J6I.2



Source;  Statistical Abstract of the United States, 1976.  (1967=100)
                                     2-13

-------
                                 Table 2.9
            Percent Increase in Average Electricity Bills By Census
            	Region and Customer Class, I&5-I975
Region
New England
Middle Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
Noncontiguous
U.S. Average
Residential
88.2%
14.5
52.9
41.9
78.7
78.0
30.1
39.0
78.3
63.2
72.3
Commercial
56.1%
38.9
36.2
33.6
58.7
40.0
21.5
41.3
65.5
51.8
63.8
^^^^^^^MPBI^^^^HHBMBMMBBI
Industrial
95.7%
55.1
57.1
47.8
06.6
89.1
42.9
58.2
90.9
70.0
89.6
Source; FPC. Typical Electrical Bills. 1975.
                                 ,  2-14

-------
Overall, the New  England region has  faced the largest increases  in  average
electricity  bills.   Both  residential and industrial  bills increased  the most
nationally between  1965  and  1975  in New  England.   The next most adversely
affected region is  the  Pacific  region,  which  had  the highest increase in
commercial  bills, and significant increases in residential and industrial bills.
These increases in labor, capital, and fuel costs have motivated the  utilities to
employ generation  techniques that realize  scale  economics by substituting
capital in place of labor  and fuel, and  raise thermal efficiencies to lower fuel
costs.

2.4   PLANT SIZE, MIX AND EFFICIENCY

Electric utilities have met the continued increase in  demand for electric power
in large part by building  larger generating units. By  1975, the largest unit size
rose to 1,300 Mw, a 30 percent increase for the largest unit in service  in 1965.
These unit size increases were accomplished in order to realize the production
economies of scale.  The utilities have maintained that using larger generating
units has allowed them to realize lower unit generating costs, thereby  holding the
price of electricity from  rising even more rapidly.

Between 1970  and 1975 the utilities almost  doubled  the number of  large (over
 1,000  Mw) plants.  Finally, by 1975 over three-quarters  of  the utilities' plants
were larger than 100 Mw.  By contrast, in I960 only one-half of the utilities'
plants were this size.  In  their move toward building larger generating units the
utilities have also been building more  nuclear and fossil-fueled base load units.
Table 2.10  illustrates the industry's   growing reliance on nuclear capacity.
Between  1970 and  1975 the nuclear  plants' generation increased almost  700
percent and supplied more than 10 percent of the nation's  electricity.   Fossil-
fueled plants, however, remain the generating foundation for the utility industry,
supplying over 80 percent of the generated kwh.

Over the past decade the utility industry has been predicting growing reliance on
nuclear  base  load  generation.  Earlier predictions  of much larger  nuclear
generating capacity, however, have not been realized, due  in part to potential

                                    2-15 !

-------
                                  Table 2.10

         Net Generation of Electricity. (I06KWH) Class A & B Utilities.
                               1965
1970
1975
Fossil-fueled
Nuclear
Hydro:
-conventional
-pumped
storage
Internal Combustion
TOTAL
735,601
(91. I)*
3,725
(0.5)
67,042
(8.3)
707
(O.I)
807,075
1,077,450
(90.7)
19,113
(1.6)
71,436
(6.0)
3,423
(0.3)
16,067
(1.4)
1,187,489
1,226,337
(82.1)
152,021
(10.2)
83,428
(5.6)
7,780
(0.5)
23,398
(1.6)
1,492,964
Source:  FPC,  Statistics of Privately Owned Electric Utilities in the  United
         States, years indicated.

4.
    Figures in parentheses represent percent of column total; exclude  station
    use.
                                   2-16

-------
                               Table 2.11

             Privately Owned Electric Utilities Fossil-Fueled
                    Steam Plant Capacity, 1965-1975
Year
1965
1970
1975
Total
No. of
Plants
653
661
631
Over
lOOMw
Capcity
398(61)*
442(67)
477(76)
Over
500 Mw
Capacity
89(14)
155(23)
222(35)
Over
1000 Mw
Capacity
17(3)
47(7)
90(14)
Total
Mw
Capacity
159,141
220,536
366,504
Source;  FPC, Statistics of Privately Owned Electric Utilities in the United
         States, years indicated.

         Figures in parentheses indicate percent of total plants.
                                 2-17

-------
pollution and  siting considerations.  The President's National  Energy Act sub-
mitted to Congress on April 29,  1977, if enacted, could significantly affect the
utilities' choice of base load capacity since the availability and price of oil and
natural  gas would be affected.  In addition, Part F  of the  President's National
Energy Act proposes amendments to the Coal Conversion Program that have the
goal of converting oil- and gas-fired steam plants.

In the generation of electric power, one facet of economic efficiency is produc-
tive efficiency. From an engineering viewpoint this productive efficiency can be
measured by  the heat rate and thermal efficiency of the plant.  The  more
efficient the plant, the lower is the heat rate measured  by units of generated
heat (Btu) per net unit of output (kwh).

Thermal efficiency measures how effectively available inputs, including labor,
plant, fuel(s), and cooling facilities, are employed to produce electric power.
The higher the thermal efficiency, the  more effectively these inputs are being
used. Changes in utilities' productive efficiency are measured by examining heat
rates for fossil-fueled steam-electric plants in the total electric power industry.
Figure  2.2 presents  the  trends  in national  average  heat rates and  thermal
efficiency over the period  1950-1975.  Average heat rates dropped almost 30
percent and thermal efficiency  increased over 30  percent, a major technical
accomplishment when facing diminishing returns.
     REGULATORY SETTING
Electric utilities have been considered "natural monopolies" and,  as  such, are
subject to public regulation.  This regulation takes place at  three jurisdictional
levels — federal, state, and local — and fails into three principal areas — issuance
of securities, rates, and accounting practices.

At the federal  level, the  Securities and Exchange Commission (SEC) regulates
the issuance of securities  by nonexempt electric utility holding company affili-
                                   2-18

-------
                                 FIGURE 2.2
             NATIONAL AVERAGE HEAT RATES
             FOR FOSSIL-FUELED STEAM ELECTRIC PLANTS
             1950-1974
     (KTBtu/NetkWh)
Heat Rate*
          1950
34%
                                                                   Thermal Efficiency
                                                                    32
             Source:  Federal Power Commission
             * Includes Internal Combustion Plants Prior to 1968.
                                     2-19

-------
ates, of which there were 70 in 1974.  The SEC has authority also with respect to
financial disclosure requirements.  The Federal  Energy Regulatory Commission
(FERC, formerly the FPC) regulates the wholesale rates of all companies oper-
ating in interstate  commerce.   The  FERC also  regulates  the issuance  of
securities  for  utilities  in states  where  no such  regulatory  authority  exists.
Finally, the FERC prescribes accounting practices, requires detailed reporting on
utility operations, and has the authority to approve development of hydroelectric
projects on navigable rivers.  A number of other federal agencies — such as the
Environmental  Protection Agency, the  Department of  Energy and the Nuclear
Regulatory Commission — have regulatory  authority which   may significantly
affect the financial  condition of the electric utility industry, but  the impact of
these authorities on the industry's finance is generally considered to be indirect.

Most electric utility regulation takes place at the state level. Comprehensive
state regulation of electric utilities  began in  1907, when the New York Public
Service Commission  was created and the Wisconsin Railroad Commission was
given regulatory authority over electric and other utilities.  By the  1920s,
electric utilities were regulated by more than two-thirds of the states. With the
implementation of statewide regulatory  authority over  electric utilities  by
Minnesota  and  South Dakota  in 1975 and Texas in 1976, 49 of the  50 states now
exercise such authority.*

The areas in which state commissions generally have regulatory authority include

     •     Determining the appropriate rate of return on the utility's
           equity investments.
     •     Determining which cost elements should be included in the
           rate base or in operating costs, and thus are  to be paid  by
           consumers, and which elements  should  be excluded, and
           thus are to be paid by the  investors.
*
     Nebraska, which  has no privately owned electric utilities,  is served  by
     public power districts and cooperatives.
                                    2-20

-------
     •     Approving a rate structure  which distributes costs with
           respect to classes of customer or types of service.
     •     Approving the issuance of securities.
     •     Prescribing accounting, auditing, and reporting standards.
    . •     Approving reorganizations, mergers, and consolidations.
     •     Certifying and licensing plant expansion
     •     Ensuring safety and service reliability.

In addition to  these powers, state commissions have a responsibility to ensure
that their  current decisions  do  not endanger the  financial viability of regulated
utilities to the extent that the utilities are unable to accommodate the needs of
customers  in the future.
                Regulatory Interaction with Utilities
Over the past five years, as the industry's capital and operating costs have risen
significantly (see Table 2.5), utilities have spent an increasingly large amount of
time before  regulatory commissions in an attempt to recover costs through rate
increases.  The result has been an increase in the time necessary for the public
utility commissions  to  decide on  the  utilities' rate increase requests.  This
increased time for regulatory case review has  been referred to as  "regulatory
lag". Table 2.12 illustrates the dollar amounts of rate increases granted annually
over the period 1970-1975 , which grew  from about $500 million in 1970 to more
than $3 billion in  1975.  However, far more significant to the financial  condition
of the industry was the fact that dollar amounts awaiting rate inclusion approval
due  to regulatory lag grew from about  $700 million at the end of 1970 to more
than $4 billion at the end of 1975.

The  major impact of the regulatory lag on the  industry's financial situation was
that by the  time the final  order was issued to allow the applicant  to increase
rates, inflation had so eaten  into the sum originally requested — this sum being
                                    2-21

-------
                                  Table 2.12
                     Backlog of Electric Utility Rate Cases
End of
Year
1970
1971
1972
1973
1974
1975
Total Dollar Value
of Increases Granted
During the Year
(Million current $)
534
825
870
1,084
2,202
3,095
Number
of Rate
Cases Pending
at End of Year
59
99
99
137
183
185
Total Dollar Value of
Requested Increases
Pending at End of Year
(Million current $)
679
1,157
1,123
\,6S6
4,015
4,073
Source;  Edison Electric Institute.
                                     2-22

-------
calculated based on costs prevailing at the time of application — that the rate
increases finally granted were insufficient to cover inflated costs.  This impact
sometimes was mitigated by a commission's granting an interim rate increase
while deliberations proceeded on the application itself.  However, for over three-
quarters of the cases decided during the period  1971-1973, no interim increases
were granted.

Another way to mitigate the financial effects of regulatory lag and inflation is to
permit so-called "forward-looking test years" to be used to calculate the amount
of  costs needed  to be  recovered  through  rate increases.   This method  of
calculation permits applicants to anticipate cost trends, but has not been widely
used in regulatory hearings.

The utilities' financial condition over the past decade is described in more detail
in  the  next section, with  particular attention  to  the utilities' future capital
requirements and their attendant costs.
                                                                         \
2L6  FINANCIAL CONSIDERATIONS

There are several important factors  that have contributed to the electric utility
industry's financial condition. This section will examine briefly these factors and
then examine  the  relationship between these factors to the industry's financial
condition.  Chapter 3  presents a more detailed discussion  of financial issues
related to changes in environmental regulations facing the industry.

Because  a sizable number of requests for rate relief  were  not acted  upon
immediately in recent years, as described above, it  has become evident that the
costs the industry incurred would have to be carried, at least for a time, by some
other means.  Since fixed charges, such  as interest payable on debt, could not  be
reduced, the major source of funds has been cash flow from operations.
                                     2-23,

-------
 Clearly, the regulatory delays that had worked to the industry's and its investors'
 advantage in the early 1960s were  working in the 1970s to their disadvantage.
 Whereas, in  the early 1960s the industry's members were generally able to earn
 more than the rate of return allowed by regulatory commissions, in the early
 1970s  they were generally earning  less.  Table 2.13 illustrates that in 1970, 53
 percent of privately owned utilities had higher than  an 11 percent  return on
 common equity,  whereas  in 1975 only 48 percent of the utilities realized that
 return.

 One direct impact of a declining rate of return in the face of a greater need for
 funds  was that the industry was forced  to become much more dependent on
 capital markets, i.e., on external financing.  When  funds from internal sources —
 earnings, depreciation and  tax deferrals — constitute  relatively  little  to the
 firm's  total investment needs, the utilities have had to acquire  external funds  in
 the capital market.  Table 2.14 shows the significant extent to which the industry
 has been required to finance itself externally.  External financing was required  in
 particular in 1974 when sufficient internal funds were not available.

 Table  2.15 shows that both long term debt and preferred stock holdings have
 increased,  as a percent of the utilities capitalization between 1965  and 1975;
 long-term debt increased  from 51.5 percent to 53.3 percent in 1975 (representing
 $70.8 billion); preferred stock increased from 9.5 percent ot 12.4 percent in 1975
(representing $16.8  billion issued.   The average debt  cost  increased  from 3.80
percent to  6.83 percent between 1965 and 1975, a very significant change-over a
period  when utilities  were financing a  larger amount of-their  capital  needs
through debt, as indicated by the increased long-term debt as a percentage of net
utility  plant.  Also  indicative of  the  utilities'  changing external  financing
patterns is that common  stock holdings decreased as  a percentage of capitali-
zation  from 27.5 percent in 1965 to 24.0 percent in  1975.

This discussion has highlighted the  economic and financial  trends that  the
electric utility industry has faced over the past ten years.  Appendix A discusses

                                     2-24

-------
                                 Table 2.13

   Distribution of Returns on Equity for Class A & B Utilities, 1970 and 1975
                (Percent of Utilities Earning Indicated Return)
   Return on Equity                    1970               1975*
Less than 5.00%
5.00 - 7.99
8.00 -10.99
11.00 -13.99
14.00 -16.99
17.00 and above
2.4%
17.9
27.1
32.3
16.4
3.9
5.7%
14.8
31.0
37.1
9.5
1.9
Source;   Federal Power Commission, Statistics of Privately Owned Electric
          Utilities in the United States

    Includes equity earnings on subsidiary companies.
                                    2-25

-------
                                 Table 2.14

           External Financing of Electric Utility Industry. 1965-1975
            Percent of Investment                    Percent of Investment
 Year        Financed Externally         Year         Financed Externally
 1965             45%                   1971                 79%

 1966             59%                   1972                68%

 1967             58%                   1973                70%

 1968             76%                   1974                92%

 1969             68%                   1975                82%

 1970             80%
Sources;  from Edison Electric institute, Statistical  Yearbook of the Electric
         Utility Industry.
                                  2-26

-------
ro
                                                        Table 2.15
                       Balance Sheet Relationships for Privately Owned Electric Utilities.  1965-1975
t
^•••••11 . •.•!!!•,• , • •.— •—•!!•• | | III .. II •^•••••^
1975 1974 1973
Percent of Capitalization:
Long-term debt
Preferred Stock
Common Stock and
other paid in capital
Retained earnings
Long-term debt as percent
net utility plant
Accumulated provision for
depreciation as percent
of total utility plant
AFDC as percent of
net income
Average debt cost

53.3% 53.
12.4 12.
24.0 23.
11.3 II.
51.5 51.
20.3 20.
26.5 28.
6.83 6.
kM^M^M.^.MBMI.»i«— I^^B_>
Source: Federal Power Commission,

0% 52.3%
2 12.1
5 23.8
3 11.8
4 50.2
2 20.4
9 24.8
32 5.80
Statistics of
^MHMMMiM^BBMII^HmMHi^HM^^I«H^^HBBaBa>*V
1972 1971 1970

53.1% 54
11.8 10
23.5 23
11.6 II
51.3 52
20.7 21
24.2 21
5.51 5
Privately

.2% 54.8%
.7 9.8
.3 23.2
.8 12.2
.2 52.5
.3 21.9
.1 17.3
.27 5.01
••••^^^•••^^H
1969

54.6%
9.4
23.4
12.6
51.9
22.4
12.6
4.52
••^•^••••(•MM
1968

53.8%
9.6
24.1
12.5
51.6
22.7
9.2
4.17
Owned Electric Utilities in
1967 1966 1965

53.0% 52.3% 51.5%
9.6 9.5 9.5
25.2 26.1 27.5
12.2 12.1 11.5
51.4 50.6 49.7
22.9 23.0 22.7
6.4 4.6 5.6
3.94 3.81 3.80
the United
               States

-------
in more detail  the capital market environment which the electric utilities will
face over the next ten to fifteen years as they find it necessary to finance their
investment requirements.  The remaining chapters will provide more detailed
analysis of the economic and financial impacts on the industry and its customers
as a result of alternative New Source Performance Standard revisions.
                                    2-28

-------
          3.0  ECONOMIC AND FINANCIAL IMPACT ASSESSMENT
       OF ALTERNATIVE NEW SOURCE PERFORMANCE STANDARDS
In this chapter the economic and financial effects of the alternative New Source
Performance Standard (NSPS) shown in Table  I.I will be assessed. The principal
analytical means of examining these impacts  is Teknekron's Financial module of
its Utility  Simulation Model (USM), which is described below.  The Financial
module  works in conjunction with the other  modules of the  USM, as shown in
Figure 3.1, so that the economic and financial impact results are fully consistent
with the technical and environmental assessments discussed in Volumes I and III
of this report.

In this chapter, "economic11 impacts focus on changes in retail prices and electric
utility expenses induced by revisions in NSPS at the  national and regional levels.
"Financial" impacts include those that may affect the relative financial position
of the electric utilities. Also examined will be the relative impact of alternative
NSPS revisions on the utility industry's external capital needs and, thus, on the
nation's capital market.  As with many types of forecasts, it is  more important to
consider the relative effects of these revisions rather than their absolute levels.
Several qualifications need to be made before commencing this examination.
First, this analysis will not attempt to identify and compare the largely non-
quantifiable private and social benefits that may be realized from revision of the
NSPS.  Such potential benefits may include improvements in human health, labor
productivity, agricultural sector output,  and visibility,  along with a general
improvement in social welfare.

Second, as is true for any forecast of future events, uncertainty surrounds our ,
projection of the relative economic and financial impacts.  We believe, however,
that the Financial module, operating in conjunction with the rest of the Utility
Simulation Model, has generated as useful, comprehensive information about the
                                   3-1

-------
                          Figure 3J
            TEKNEKRON UTILITY SIMULATION MODEL
u>
             DEMAND
             PLANNING
                                   FINANCIAL
DISPATCH
             RESIDUALS
              REGIONAL AIR
              QUALITY ANALYSIS

-------
potential  impacts of NSPS revisions as can be obtained.  The principal assump-
tions of the Financial module are discussed below in Section 3.1.1.  The USM is
discussed in the Appendix to Volume I.

Uncertainty also surrounds those estimates for a different reason. In the future
some State Implementation Plans (SIPs) may require local standards more strin-
gent  than the Federal  New Source Standards.   Under such conditions, the
economic and financial impacts  ascribed to the federal standards may more
properly be assigned to the state regulations. Although we have anticipated that
certain current SIPs are, or are expected to be, more stringent than the current
NSPS, we have assumed that the  revised NSPS will apply uniformly to all coal-
fired units operating in 1983 and thereafter.
Third, as will be discussed  in the text, there are several  regulatory agencies
besides the  state and  federal  environmental agencies that  influence  utility
operations and performance. State Public  Utility Commissions, and in the case
of publicly owned utilities, utility district or local regulators, exert predominant
authority over the utility's financial  position.  As its name implies, the rate-of-
return regulation practiced  by the State PUCs and the Federal Energy Regu-
latory Commission* over the electric  utilities establishes  an "allowed"  rate of
return for the utility.  This return and  the utility's performance then directly
influence the firm's ability  to raise capital.  Federal environmental regulations
are  but  one  of  several that the  utilities face  in their interactions with the
nation's financial markets.  As will be shown, pollution control investments made
by the utility industry as a result of state and federal environmental regulations
are  growing, but  still  represent a  small fraction of the  industry's  capital
requirements over the  next two decades.  The utilities'  ability to raise this
capital is affected above all by state PUC policies and practices.  Teknekron's
Financial module makes reasoned assumptions, similar to other such financial
models, about the responsiveness of the State PUCs  to the utilities' financial
needs. These assumptions are described below  in Section 3.1.1.
      Formerly the Federal Power Commission.
                                    3-3

-------
3.1   TEKNEKROWS ELECTRIC UTILITY FINANCIAL MODULE

The Teknekron electric utility financial module, which has been developed over
the past three years, provides economic and financial information to complement
the wealth of technical and environmental data produced by other modules of the
Utility Simulation Model.  Table 3.1 presents the inputs that are passed to the
financial  module from  other  modules.    The Financial  module  uses this
information as well as internal computations for interest, depreciation, taxes,
financing  and rate-setting to produce annual  simulated financial  statements.
These financial statements include an income statement, balance sheet, source
and use of funds statement and other financial statistics for both investor owned
and publicly owned electric utilities.

As is shown in  Figure 3.1, the Financial  module acts as an interface of the
demand and supply models by means of a computational module which calculates
prices  at  which  revenues are in balance with costs.  It constitutes  a type of
computer  simulation of regulatory control.  But, strictly speaking, a  computer
simulation of the regulatory process is impossible. Computer simulation implies
that  prices are determinable from cost information, or similar data, by definite
mathematical  formulas.   This  is often not the  case.  Rather, the regulatory
commissions (or similar public regulatory authorities) are deliberative bodies.
They consider a wide range of facts  and hear  opposing views expressed in the
form of a  formal hearing.  In making their judgments they may be called upon to
resolve problems when accepted principles are in conflict.

     3.1.1      Financial Module Assumption*

This conceptual model, like other similar regulatory models,* involves a number
of assumptions and  approximations.   It entails a uniformity of approach to
regulation which does not,  of  course, exist  among  the  many public bodies
     For example, see P. L. Joskow and M. L.  Baughman, "The Future of the
     U.S. Nuclear Energy Industry,"  Bell Journal  of Economics. Spring 1976,
     pp. 3-32.

-------
                            Table 3.1
    Input Values Passed to the Financial Module by Other USM Modules
DEMAND INFORMATION                             from DEMAND
     •  Sales to ultimate consumers
     •  Sales for resale

OPERATING DATA                                  from DISPATCH
     •  Fuel Expense
     •  Operation Expense
     •  Maintenance Expense

PLANNING DATA                                   from PLAN
     •  Cash outlays for plant construction
        for each year of simulation
     •  Details of plants coming online
        (All information broken down by asset categories)
                               3-5

-------
involved.  The  institutional complexities surrounding the regulatory process set
limits on the analysis which can be made using the regulatory model.

 The  conceptual  model  of  regulatory  control  assumes fundamentally that
 regulation acts to set prices so that revenue collected will equal actual costs of
 providing service.  These costs are to  be understood to include an appropriate
 return to investor/owners of the utilities.  Prices so  set are adjusted among
 different groups  of  customers in accordance with  criteria of fairness to both
 consumers and investors;  efficiency of resource management;  insuring adequacy
 and reliability of future supply; and similar desirable attributes of an  ideal
 pricing-regulatory  system.    The  following are  several  of  the  principal
 assumptions incorporated  into the operation of the Financial module.

 Constancy of current parameter values and accounting and tax practices.    The
 Financial module is required  to make implicit assumptions regarding the external
 financial environment of the electric utility industry over the simulation period.
 A key assumption in this regard is that conditions will either remain as they are
 today or closely follow  the historical pattern that has developed over the past 20
 years.  The model uses a predetermined  external financing mix throughout the
 simulation period; the inflation rate, specified by the EPA, remains a constant
 5.5 percent; the target return to investors on common equity is 13 percent. It is
 implicitly  assumed  that  accounting practices and income-tax  determination
 regulations will remain  the same as they are now.  The  model has been updated
 for all current changes in tax laws and accounting procedures.

 Cost of capital is constant of all financing levels.  Just   as the financing mix
 ratios are predetermined, the  cost of  capital  is set at  an  exogenuously
 determined level  for each type  of security. This cost then remains constant
 throughout the model and  all new issues of debt and equity will pay the specified
 return.  It should be noted that  in the  case of common stock, because of well-
 known forecasting difficulties, no attempt is made to predict the market price of
                                   3-6

-------
the stock or earnings per share.  Thus dividends are based on a specified per-
centage return for each dollar of common stock outstanding and are not deter-
mined on a per share basis.

Rote-setting Environment*  The  Financial module assumes a responsive rate-
setting environment.  Revenues in  any given year are a result of  an average
electricity price determined in the  previous year.  This average price is based
upon what revenue requirements would have been in effect in that year in order
for the  utility  to recover  all  its  costs and an allowed return to common
stockholders. Because  annual electricity demand growth rates are exogenously
specified, there is an implicit assumption that price sensitivity and customers'
substitution of energy  forms due to relative energy prices are not significant
factors.   Although it is possible that during the simulation a return greater or
less than  the allowed return will actually result, due to fluctuations in the real
cost of electricity and  variations in financing  levels, over the simulation period
the realized rate  of return will  not vary dramatically from the allowed return
specified.

Neutral effect of non-electric operations.  A  number of items  on an  electric
utility's balance sheet  and  income statement are outside the  scope of electric
operations but  nonetheless must be accounted for.   These items include net
income from non-electric operations, non-operating  income, non-income taxes,
other  assets and other credits.    The initial  amounts  of  these items  are
determined from FPC forms, for 1975. During each year of the  simulation they
are assumed to increase at the inflation rate.

      3,1.2      Reqionolization

Throughout this assessment, when warranted, we will be  examining important
economic and financial impacts on a regional as well as national basis.   The
regions we have examined are basically those defined by the Bureau of Census,
with one exception.  In  order to gain more insight into the economic and financial
                                     3-7

-------
                                                  Table 3.2

                            Regions Used for Analysis of Alternative NSPS Revisions
co
New England
Connecticut
Rhode Island
Massachusetts
New Hampshire
Vermont
Maine
Mid-Atlantic
New York
Pennsylvania
New Jersey
South Atlantic
Delaware
Maryland/D.C.
Virginia
West Virginia
North Carolina
South Carolina
Georgia
Florida
East
North Central
Wisconsin
Michigan
Illinois
Indiana
Ohio
East
South Central
Kentucky
Tennessee
Mississippi
Alabama
            West
       North Central

       North Dakota
       South Dakota
       Nebraska
       Kansas
       Iowa
       Missouri
       Minnesota
    West
South Central

 Texas
 Oklahoma
 Arkansas
 Louisiana
North Mountain

 Idaho
 Montana
 Wyoming
South Mountain

 Nevada
 Utah
 Colorado
 Arizona
 New Mexico
  Pacific

Washington
Oregon
California

-------
effects on the utility industry  in the western United States, we have subdivided
the  Census'  Mountain  region  into two regions,  North  Mountain  and  South
Mountain.  The regions are defined in Table 3.2.

3.2  ECONOMIC IMPACTS

The economic impacts associated with changing pollution control regulations for
electric utility  coal-fired boiler  operations  can be examined from several
perspectives.  First, we will analyze the economic effects on the utility industry;
including  changes in its total revenue requirements; total  costs and important
components,  such  as  fuel, operation  and maintenance and  pollution control
equipment O&M; net profit  and capital  investment  needs, both  for plant and
pollution  control equipment.   These effects will then be  compared across the
selected NSPS revisions. See Table 3.3 for a description of  the alternative NSPS
revisions considered.

Second, we will then compare the impact on retail prices under several of the
scenarios  defining  alternative  NSPS revisions.   These prices will  be examined
both nationally and regionally, to capture important regional detail.  After this
we will analyze  the per capita  cost of the revisions.   This measure is important
when  one assumes that  cost  increases facing  industrial  and other utility
customers ultimately can be passed forward to the residential consumer.

Third, we will examine the national and regional pollution control costs and
investment expenses associated  with alternative  NSPS revisions.   As will  be
shown, it  is important to show regional data as there can be  significant variations
among regions, illustrating differences in the characteristics of their electricity
supply systems, economic factors and fuel availability and cost.

     3.2.1      Economic Impacts on the Utility Industry

Revisions  to the NSPS  may have several, inter-related effects on important
economic parameters facing the electric utility industry over the 1976-1995 time
                                     3-9

-------
                                                                Table 3.3
                              Alternative New Source Performance Standard Revisions Considered
                               BASELINE                                                      BASELINE
                               M 1.2(0)0.1 M 1.2(90)0.1   M 1.2(80)04)3   M 1.2(90)0.03  M 0-5(0)0.03  H 1.2(0)0.1 M 1.2(90)0.1  H 1.2(80)0.03 H 1.2(90)0.03
                               Moderate*  Moderate*     Moderate*     Moderate*    Moderate*     High*      High*       High*        High4
L
o
          Requirement, lor S02                             «*           »*           °           0         90%         80%         90%

        Portfcuhrte Standard**      O.I         O.I          0.03          0.03         0.03        O.I        O.I          0.03        0.03
             *    5.8% per year to 1985; 3.*% thereafter.
             *    5.8% per year to I985j 5.5% thereafter.
             NOTEj    Standards other than the baseline cases ore assigned to apply only to coal-fired generating units beginning
                —    commercial operation tn 1983 or later. See Volume I for a more detailed dlscusstion of the scenarios analyzed.

-------
period.  We have focused on the ten-year period 1986-1995 since we assume that
plants subject to the revised  NSPS will not be coming on-line until 1983.  See
Volume I for a more detailed discussion.

Tables  3.4  and 3.5 present  the forecasted national changes  in the following
economic factors for the moderate and high demand growth rates, respectively:*

           •    Total Revenue Requirements;
           •    Total Cost;
           •    Fuel Cost;
           •    Operation and Maintenance Cost;
          '•    Pollution  Control Cost;
           •    Net Profit;
           •    Total Investment Excluding Pollution Control
           •    Pollution  Control Investment; and
           •    Retail Price.

These  represent  the  principal economic  factors, facing the  electric utility
industry that may be affected by a revision of the NSPS.

      3.2.1.1    Total Revenue Requirements

As is shown in Table 3.4, total revenue requirements under moderate growth vary
little as a result of the NSPS revisions considered.  The largest increase over the
current standard (baseline, M 1.2(0)0.1) occurs with the 90 percent removal with
 !2.9ng/J (0.03 Ib/106 Btu) particulate limit.   Under this case total  revenue
requirements, which include a target return on equity (or the rate base in the
case of the publicly owned utilities), increase $24 billion over the 1986-1995 time
period,  representing about a 2 percent increase over baseline.  All of the  other
      Throughout this assessment all  forecasted dollar values are presented in
      1975 dollars.
                                     O™ I I

-------
                                        Table 3.4
            Comparison of Selected National Economic Impacts on the
              Electric Utility Industry of Alternative NSPS Revisions*
                                       1986- 1995

Total Revenue
Total Cost
Fuel
Operation &
Maintenance
Pollution Control*
, Net Profit
Baseline
M 1.2(0)0.1
$1,149.5
1,023.9
369.8
167.4
36.4
125.6
M 1.2(90)0.1
+22.1**
+26.7
-0.3
+0.5
+7.2
-4.6
M 1.2(80)0.03
+20.9**
+25.8
-0.3
+0.5
+6.9
-4.9
M 1.2(90)0.03
+24.0**
+29.0
0
+0.6
+7.9
-5.0
M 0.5(0)0.03
+20.5**
+25.5
-0.9
+0.5
+7.0
-5.0
Total Investment
Excluding Pollution
Control

Pollution Control
Investment+
    325.3
     8.0
+4.2
+ 13.0
+3.1
                               + 13.3
4.2
                            + 14.6
                                                           +3.4
                                                           + 13.3
Retail Price
(l975£/kWh)
J985.1995    1985.1995    J985  \99S      1985  1995     1985 1995

2.81  2.93    +0.04 +0.05   +0.03  +0.05    +0.04  +0.05    +0.03 +0.05
     Unless noted otherwise, figures in billions of 1975 dollars.

     Change from baseline.

     Includes expenses for SO,, NO , particulate and water pollution controls. The latter
     are not varied across scenarios?
                                          3-12

-------
                                           Table 3-5

                    Comparison of Selected National Economic Impacts on the
Electi
'


Total Revenue
Total Cost
Fuel
Operation &
Maintenance
Pollution
Control*
Net Prof it
Total Investment
Excluding Pollution
Control
Pollution Control
Investment '*


Retail Price
(!975
-------
revenue  changes   for   other   revisions,   including  moving  to  a  2l5ng/J
(0.5lb/l06Btu)  S02  c
revenue requirements.
(0.5 Ib/10 Btu)  S0~  ceiling result  in  less than  2 percent  increases in total
Under the high growth cases, total revenue requirements increase more.  Again,
the largest  increase  occurs under the 90  percent,  !2.9ng/J (0.03  Ib/IO  Btu)
case; where revenues increase over  $47  billion, representing a 3.6  percent
increase.  Each of the other revisions results in increases of about 3 percent.

Thus, the NSPS revisions considered are not forecast to increase total revenue
requirements significantly between 1986 and 1995.

      3.2.1.2    Costs

Total Costs include the following items;

                •    Fuel,
                •    Operation and Maintenance,
                •    Pollution Controls,
                •    Income Taxes,
                •    Other Taxes,
                •    Interest Expense,
                •    Depreciation and
                •    Other Utility Costs.

We have selected fuel,  operation  and  maintenance (O&M) and pollution control
costs as the most important operating costs of the  above cost categories  and
have focused our attention on them.  Under the baseline case in both moderate
and high growth, these three cost categories  are forecast to comprise over 55
percent of total costs between  1986 and 1995.  The largest is fuel cost, represen-
ting 36 percent of total costs; the smallest  of these categories  is pollution con-
trol costs, representing somewhat over  3 percent of total costs.
                                    3-14

-------
As will be shown,  some cost categories increase substantially under the NSPS
revisions.  Under moderate growth, as shown in Table 3.4, total costs increase
the most, $29 billion, under the 90 percent S02 removal case and a particulate
limit of  !2.9ng/J  (0.03 Ib/106 Btu).   This would be expected because this
represents the most stringent NSPS revision  we have considered. Putting this in
perspective,  however, this  change represents less than a 3 percent increase in
total costs. The high growth cases, presented in Table 3.5, show that the dollar
increase in total costs rise considerably, due mostly to the relatively higher costs
of building, operating  and maintaining an  electric utility system  capable  of
meeting this increased load.

The  largest increase in total costs for the high growth cases (Table 3.5) is found
for the 90 percent  12.9 ng/J (0.03 Ib/IO Btu) case; a $60.7  billion increase.  This
represents a 5.1 percent increase  in total costs.   Each of the other cases shows
between a 4 and 5 percent increase in total costs, over the ten-year period.

Under the moderate growth cases fuel costs remain essentially constant  as
illustrated in Table 3.4.  Each of the  incremental changes are well  within the
margin of uncertainty for the fuel price data used and represent less than one-
quarter  of  one percent  change.   Similarly,  the  O&M costs  do not  change
significantly across the alternative NSPS revisions*

The  fuel costs increase slightly under the high growth cases. The largest change,
$5.1 billion, shown  in Table 3.5 represents a 1.2 percent increase over the  ten-
year  period examined and should  not be considered a significant change.
Operation and Maintenance costs  also do not increase significantly; the largest
change, $1 billion, is but a 0.5 percent increase.

Pollution control costs, which  represent  not only operation and maintenance
expenses for SO, control equipment, but for NO , particulate and related control
               *•                             X
equipment,  increase significantly under  the NSPS  revisions.*   The  largest
      As mentioned  previously, pollution  control  costs include the costs  of
      meeting water pollution regulations. However, since these regulations are
      held constant, their effect is removed when we examine the  incremental
      costs  of more stringent NSPS.   Appendix  B  describes how SO- and
      particulate costs can vary for a typical generating unit based on fuel type
      and its physical characteristics.                              	
                                    3-15

-------
 increase  shown  in  Table  3.4  occurs under the  90 percent  S02»  12.9  ng/J
 (0.03 Ib/IO6 Btu) particulate  case,  $7.9  billion over the  ten-year period,  and
 represents just under a 22 percent  increase.  The other  cost  increases  range
 between 19 and 20 percent for other NSPS revisions.

 Imposition  of the 90  percent  SO2  removal  requirement, as compared  to 80
 percent does not appear to markedly increase pollution control costs.  If these
 additional costs, $1 billion ($7.9 - $6.9),  are spread evenly  over the period
 examined, they represent less than 0.5 percent annual increase in total costs.  A
 similar result is that tightening of the particulate standard does not appear to
 result in a significant cost increase,  less than 0.2 percent annual change over the
 ten-year period.*   Although pollution control costs increase significantly, as a
 percent of total costs, they increase from 3.6 percent to 4.2 percent. When put
 in the perspective of total costs the increase appears more tempered.

 Under the high growth cases, shown in Table 3.5, pollution control costs increase
 more, as expected.  The largest growth occurs under the  90 percent 12.9 ng/J
 (0.03 Ib/IO  Btu) case, when over the ten-year period these costs increase $16.3
 billion.  This represents over a 40 percent increase in these costs.  Other cost
 increases range between 27 and 37 percent.

 As was found in the moderate growth cases, the imposition of the 90 percent SO~
 removal standard, as compared to the 80 percent standard, is forecast to have a
 marginal effect on pollution control costs.  If spread evenly ovear the ten-year
 period, the stricter  standard would  increase annual total costs  by less than 0.5
 percent.  In addition, annual total costs do not  increase significantly, less than
0.4   percent,  where  the  particulate standard  is  tightened  to   12.9. ng/J
(0.03 Ib/IO6 Btu).
      This conclusion may be different if precipitators, rather than fabric filters
      had been used for Western coal; See Volume 1.

                                    3-16

-------
In Section 3.3.2.3, we will discuss the regional effects of these pollution control
cost increases.

      3*2.1.3     Net Profits

The imposition of alternative NSPS revisions is forecast uniformly to decrease
the electric utility industry's net  profits,* defined as total revenues minus total
costs.   The decreases  as a percentage of baseline  are greatest  under the
moderate  growth cases as shown in Table  3-4.   Net profits  decrease over 20
percent  under scenario M1.2(90)0.03, in part due to the one year regulatory lag
assumed in the model in covering increased  costs.    Because of relatively lower
revenue  growth under the high growth cases, net profit reductions are much less
and do not exceed  3 percent over the ten  year  period.  Generally, the  more
stringent the NSPS  revision,  the greater net profits drop, as would be expected.
More detailed analysis of the financial effects of NSPS revisions, including return
on equity and quality of earnings,  is presented in Section 3.3.

      3*2.1.4     Investment

The NSPS revisions  are  projected to influence both total  investment excluding
pollution control, representing principally plant investment, and pollution control
investment.  As presented  in Tables  3.4 and 3.5,  total investment excluding
pollution control  increases with the NSPS revisions.

In addition to the  direct  pollution control investment  expenditures that the
utility industry is forecast to make the industry also will face somewhat higher
plant investment expense due to  the capacity penalties  incurred with operation
of FGD systems.  These penalties have been estimated to be between five and six
      Net profits is used for both privately and publicy owned utilities although,
      technically, publicly owned utilities' account would be called a "surplus."

                                    3-17

-------
percent for installed generating capacity.* From this information and from the
simulation model's national  forecast  of the percent  of capacity  using  FGD
systems  in  1995, we estimate that approximately $2.7 billion (in 1975 dollars)
may be required for additional plant investment due to capacity penalties under
the  moderate  growth  case  (M1.2(90)0.03);  under  the  high   growth  case
(HI.2(90)0.03), as much as $4.8 billion may  be necessary.  These additional,
indirect  pollution control  investment  expenditures are accounted for, although.
not  explicitly,  in  the  incremental changes  in Total  Investment  Excluding
Pollution Control category  shown  in  Tables 3.4 and  3.5.   The incremental
investment, however,  is a small percentage  increase over  the  baseline.  The
largest increase  under  moderate  growth, $3 billion, represents 0.6 percent.
Under high growth the largest increase over the ten-year period is $4.2 billion,
representing 1.3 percent increase over the baseline.

Pollution control  investment increases significantly,  as  expected.   It should  be
remembered, however, that such investment represents a relatively smal I part of
the industry's forecasted capital investment needs over the 1986-1995 period.
Under the moderate  growth baseline, pollution control investment  represents 2.4
percent of total  investment. For the high growth  baseline,  it represents 3.4
percent ot total investment.

The  increases  in pollution control investment for the  moderate  growth cases
range from $13 to $14.6  billion over the 1986-1995 period, representing between
a 62 and 83 percent increase  over baseline.  The largest increase for each growth
rate is found under the Ml.2(90)0.03 scenario, as expected.  As  is described in
more detail in Volume  I,  the amount of national coal  capacity subject to FGD in
1995 increases from  16 and 13 percent to 51 and 68 percent for the moderate and
high growth cases, respectively.  Pollution control investment, as a percent of
total investment, increases to 6.9 and 10 percent under the moderate and high
         "Particulate and Sulfur Dioxide Emission Control Costs for Large Coal-
     Fired  Boilers,"  PEDCo  Environmental,   Inc.   under  EPA  Contract
     68-02-2535.
                                   3-18

-------
growth rates, respectively.   Since the regional distribution of this additional
pollution  control  investment  can  have important implications,  the regional
effects are examined in Section 3.2.3, below.

     3.2.1.5    Retail Prices

National average retail prices for each of the  NSPS  revisions considered are
found not to have  significant variation in  1985.  By 1995, only the high growth
cases shown significant variation.  The largest change occurs with the 90 percent
S02 removal !2.ng/J (0.03 Ib /I06 Btu) particulate limit, a 16 mill/kWh Increase,
representing a  5.2 percent  increase over the baseline.   These  retail  prices
represent a weighted average of retail prices for privately and publicly owned
utilities.  Section  3.2.2 contains more detailed  analysis of the regional price
effects under alternative NSPS revisions.

     3.2.2       Regional Prices and Per Capita Costs

Table  3.6  presents a detailed compilation of regional impacts on the  utility
industry's retail electricity prices in 1985 and  1995. The 90 percent S02 removal
with the tightened particulate standard scenarios were chosen for moderate and
high growth since these resulted in the largest change in national average retail
prices (see Tables 3.4 and 3.5).   In order to facilitate some comparison we  have
included the M0.5(0)0.03 scenario as well.

The regional variations can be large.  The New England region is forecast to
continue to have the highest  retail prices under both moderate and high growth
cases,  over 40 percent greater than the national average in 1995. The East South
Central region, which contains much of the Tennessee  Valley Authority service
territory, historically one of the least expensive areas for electricity, is forecast
to change, on average, less than 50 percent of the national average by 1995.

Under  both moderate and high growth scenarios, the  largest Increase in retail
prices  in  1995 occurs in the West  South Central  region.  Consumers there  bear
                                    3-19

-------
                                                   Table 3.6
to
of Alternative NSPS Revisions, 1 976- 1 996



Baseline
M 1.2(0)0.1
REGION
1985
1995


M 1.2(90)0.03
1985
1995



M 0.5(0)0.03
1985
1995


Baseline
H 1.2(0)0.1
1985
1995


H 1.2(90)00)3
1985
1995

NATION
New England
Mid-Atlantic
South Atlantic
East North Central
East South Central
West North Central
West South Central
North Mountain
South Mountain
Pacific
2.81*
3.90
3.76
2.86
2.99
1.43
2.77
2.15
2.30
2.67
2.76
2.93*
4.23
3.58
3.03
3.11
1.32
2.73
2.92
2.02
2.67
2.75
1.4**
0.3
1.3
1.7
-0.7
1.4
0
3.3
0.4
5.6
0.7
1.7**
1.7
2.0
1.7
0.3
2.3
1.8
11.0
3.5
3.7
0.7
I.I*"
0.0
1.3
1.7
-0.7
0.7
0.0
3.3
0.4
4.9
0.4
1.7**
1.
2.
1.
-0.
2.
2.
4.
1.
0.
7
0
7
3
3
2
1
5
4
0.4
2.85*
3.96
3.81
2.90
3.01
1.45
2.81
2.17
2.29
2.76
2.78
3.10*
4.31
3.83
3.27
3.32
1.42
2.95
2.91
2.30
2.91
2.90
1.8**
0.3
0
2.1
2.0
2.7
1.8
3.7
0.8
4.0
I.I
5.2**
0.2
2.1
4.6
4.8
2.8
5.4
12.0
7.4
1.7
1.0
             Average prices to retail customers expressed in £/kwh, in 1975 dollars.  Represents a weighted
             average of privately and publicly owned utilities.

             Percentage change from Baseline.

-------
the largest price increase because of the projected phase-out of oil- and gas-
fired capacity and replacement by coal capacity additons subject to the revised
standards (see Volume I, Table 2.5).  Other regions that reflect relatively higher
price  increases are the two Mountain regions, where the revisions would cause a
shift from new source compliance through the use of low sulfur coals to the use
of FGD systems.

Changes in the percentage increases between 1985 and 1995 illustrate the distri-
bution of economic effects  over time and system  expansion  schedules.  Price
changes in  1985  do not reflect major impacts of the NSPS revisions since the
revisions only  affect  capacity  on-line after  1983.  What effects are present
reflect in large part the price-related additional investment expenditure impacts
for generating equipment  construction  underway.   The  West South  Central
region's prices increase significantly more in  1995; whereas, other regions such as
Pacific, East South Central and South Atlantic reflect a more balanced increase
in prices over the period. Several regions such as South Mountain show less price
increase in 1995 than in 1985 and illustrate that by the last year of the forecast
much  of the price-related effects have been accounted for.  The 1985 price
change  for  East North Central  under moderate  growth appears  negative.
However, the change  should be interpreted  as not significantly different from
zero,  since it is within the forecast's margin of uncertainty.  Overall, the price
changes resulting from NSPS revisions do not appear to be large by 1995, with
the exception of the Gulf Coast region as previously noted.

Under  moderate growth the  2l5ng/J (0.5 Ib/IO6 Btu) SO2  ceiling  case,  the
M0.5(0)0.03 scenario,  is notable in that  there is relatively little difference in
1995 retail prices between it and the 90 percent SO2 removal scenario.  Under
this scenario, however, the West South Central and North Mountain regions' price
increases in 1995 are less than half than those under the 90 percent SO2 cases.

Another useful measure of  economic impact on the consumer is the relative
change in per capita costs, here defined as total revenue requirements divided by
population in 1995,  are presented in Tables 3.7 and 3.8 for the moderate and high

                                   3-21

-------
growth coses respectively. The growth of real per capital cost between 1976 and
 1995 is not dramatic.  In 1976, the model estimates that national real per capita
cost is $268;  by 1995 it increases  to over $500 and over $600 for the moderate
and high growth baseline cases respectively. There are several reasons for this
increase. The yearly demand growth rates we have assumed require the utility
industry to  build new capacity to  meet these projected loads with ever more
expensive generating capacity, transmission lines and distribution systems.  The
compound effect of cost escalation and demand growth rates that  exceeds the
population growth rate' increase (about one percent per year) increases the totaL
costs of operating, maintaining and financing the nation's  utility systems.   As
costs  increase, revenue requirements correspondingly  increase. Retail prices
have  been  shown not to  increase  greatly (see Table 3.6),  so  that  increased
revenue  requirements are  satisfied principally by the  constant  growth in kWh
sales.

The important information presented  in Tables 3.7 and 3.8  is the  incremental
change in per capita costs between scenarios rather than the absolute level of
these  costs.  As is shown, none of the moderate growth  cases  shows a large
increase in per capita costs. The largest national increase occurs under the most
stringent scenario, Ml.2(90)0.03; but this represents  less than a 2 percent change
in per capita costs over the baseline. Under the high growth cases the increase is
larger, $27  in  1995, representing almost a four percent increase in per capita
costs.

It is important to note the regional variations  in per capita costs.  The biggest
increases in  per capita costs occurs  in the Gulf Coast region, West South Central,
where  the largest percentage of new FGD capacity is built.  The largest increase
for this region under moderate growth, $35, represents a 6 percent change  in per
capita cost.  The next largest change occurs in the North Mountain region, where
per capita costs increase 5.1 percent.  Each of the other changes represents less
than a 3 percent increase.
                                    3-22

-------
                                  Table 3.7
           Per Capita Cost of Alternative NSPS Revisions, 1995*
Region
Nation'
New England
Mid-Atlantic
South Atlantic
East North Central
East South Central
West North Central
West South Central
North Mountain
South Mountain
Pacific
Baseline
M 1.2(0)0.1
$530
476
069
576
577
365
475
662
426
462
541
M 1.2(90)0.1
+$8+
+ 8
+~3
+ 5
+ 3
+ 7
+ 6
+31
+41
+14
+-7
M l.2<80).03
+$S+
+ 1
+ 5
+ 6
+ 5
+ 7
+ 6
+29
+38
+11
+ 8
M l.2(90).03
+$9+
+ 8
+ 7
+ 7
+ 3
+ 7
+ 6
+35
+42
+14
+ 7
M 0.5(0).03
> 7+
+ 8
+ 6
+ 7
+ 3
+10
+ 3
+25
+25
+ 1
+ 7
Defined as total revenues divided by population in 1995. All figures in 1975 dollars.
Change from Baseline.
                               3-23

-------
                           Table 3.8

      Per Capita Cost of Alternative NSPS Revisions. 1995*
REGION
Baseline
H 1.2(0)0.1
H 1.2(80)0.03
H 1.2(90)0.03

NATION
New England
Mid-Atlantic
South Atlantic
East North Central
East South Central
West North Central
West South Central
North Mountain
South Mountain
Pacific
$685
632
609
766
747
491
629
801
606
617
677
$+24+
0
+ 7
+36
+27
+ 13
+26
+80
+45
+ 1
+ 5
$+27*
0
+ 12
+40
+33
+ 14
+30
+87
+48
+ 5
+ 6
Defined as total revenues divided by population in 1995. All figures in
1975 dollars.

Change from Baseline.
                          3-24

-------
Under the high growth coses, the some regions again incur the largest increases,
both above 7 percent as shown in Table 3.8.  Also, the Mid-Atlantic, East North
Central and West North Central regions are .forecast to have relatively larger
increases in per capita costs, both between 4 and 5 percent.   Each of the other
changes is under 4 percent.

To summarize, changes in both average retail  prices and per capita costs under
the various control scenarios are not forecast  to be large at the national level.
National price  increases at most increase 5 percent in 1995.   In that year,
national per capita costs increase at most 4 percent, under the high growth case,
and at most 2 percent under the moderate growth case.

Regional  impacts display significant vqriation, with the  West  South  Central
region incurring the largest price and per capita cost increases; over 10 percent
increase for both measures under high growth.  Other  more affected  regions
include North Mountain and the West North Central regions, where coal capacity
additions using  FGD systems are significant.   Other regions analyzed are not
forecast to be severely affected in terms of price or per  capita cost as a result
of alternative NSPS revisions.
On average,  forecasted differences between the 80 percent and 90 percent
removal cases do not appear significant for either retail  prices or per capita
costs.

      3.2.3      Regional Pollution Control Cost and Investment

One of the most  important impacts on the electric  utility industry of Imple-
menting more stringent NSPS  will  be changes in  direct  pollution control
expenses,  including  both  operation  and  maintenance  costs  and  investment
expenditures.  We have previously discussed  a third  important cost, indirect
pollution  control-related expense, the cost of additional generating capacity
needed due to capacity penalties  incurred by using FGD systems  (see Section

                                    3-25

-------
3.2.1.4).  In this section we will examine the regional distribution of these direct
costs and investment over the 1986-1995 period.

      3.23.1    Regional Pollution Control Costs

We will concentrate our discussion on the regional impacts of the NSPS revisions
on pollution control costs over the period 1986-1995.   It should be remembered
that  when  used, the term pollution control costs  includes  expenses for
NO and particulate pollution control equipment operation and maintenance.*
   x
Tables 3.9 and 3.10 display the regional pollution control costs associated with
alternative scenarios under moderate and high growth cases respectively.  As is
shown in the tables, the South Atlantic, Mid-Atlantic,  East North Central and
West South  Central regions  account for the  largest percentage of pollution
control costs in the baseline cases, representing 68 percent of the national total.

As expected, the largest increases in pollution control costs occurs in the West
South Central region; for moderate growth, an 80  percent  increase, for high
growth, an 85 percent increase.  Other  large percentage increases occur  in the
Mid-Atlantic, North Mountain and Pacific regions.  Increases for New England
are less than $0.1 billion because of the nuclear and oil-fired generation in that
region (see Volume I, Table 2.5).  Finally,  note that  in all  regions pollution
control  costs under  the  80 percent SO0 removal requirement and the 215 ng/J
         /j                           £•
(0.5 Ib/IO  Btu) SOj  emission limit scenarios are nearly identical.**
*
     The costs  of  meeting chemical and thermal emission limitations promul-
     gated by EPA in 1974 are included.  However, these limits do not change
     among the scenarios.
,w w,
     Although  we  have  not  run  this  last  scenario under  the  high  growth
     assumption, we do not anticipate  that  the results  would contradict this
     conclusion.
                                   3-26

-------
                                       Td>le 3.9

                        Pollution Control Costs by Region
For Alternative NSPS Revisions*
1986- 1995
Region
Nation
New England
Mid-Atlantic
South Atlantic
East North Central
East South Central
West Norlh Central
West South Central
North Mountain
South Mountain
Pacific
Baseline
M 1.2(0)0.1
$36.4'
°-9 +
5.0
(13.7)
7.0
(19.2)
8.5
(23.3)
4.0
(11.0)
2.2
(6.0)
4.1
(11.2)
0.3
(0.8)
2.5
(6.8)
1.9
(5.2)
M 1.2(80)0.03 M 1.2(90)0.03 M 0.5(0)0.03
+$6.9** +$7.9** +$6.8**
000
+0.3 +0.5 +0.5
:+1.9 -t-2.1 +2.0
+0.3 +0.3 +0.3
+0.1 +0.2 +0.1
+0.4 +0.« +0.3
+3.0 +3.3 +2.9
+0.1 +0.1 +0.1
+0.3 +0.5 +0.2
+0.5 +0.5 +0.5
    In billions of 1975 dollars, icnludes expenses for SO,, NOx> porticuldte and related pollution
    control equipment operation and maintenance costsf

    Change from Baseline.

*   Figures  in parentheses  indicate  percent of national totalj does not add to 100 due to
    rounding.
                                         3-27

-------
                                         Table 3.10

                           Pollution Control Costs by Region
For Alternative NSP5 Revisions *

Region
Nation
New England
Mid-Atlaa
South Atlantic
East North Central
East South Central
West North Central
West South Central
North Mountain
South Mountain
Pacific
1986-
Baseline
H 1.2(0)0.1
$40.0
I.I +
4.3
(10.8)
8.0
(20.0)
10.3
(25.8)
3.8
(9.5)
2.5
(6.3)
4.6
(11.5)
0.3
(O.I)
2.7
(6.7)
2.4
(6.0)
1995
HIJX80XX03
+$13.4**
0
+2.6
+2.6
+2.2
+0.2
+0.8
+3.3
+0.2
+0.4
+ 1.2

H 1.2(90)0.03
+$16.3**
+0.1
+3.0
+3.1
+2.6
+0.5
+0.8
+3.9
+0.4
+0.5
+ 1.4
     In billions of 1975 dollars; includes expenses for SO2, NOx> participate and related pollu-
     tion control equipment operation and maintenance costs.

     Change from Baseline.

+    Figures in parentheses indicate percent of national total; does not add to 100 due to rounding.
                                       3-28

-------
     3,2,3,2    Regional Pollution Control Investment

We have discussed the national results on direct pollution control  investment in
Section 3.2.1.4  above; now we will  examine  the  regional  impacts on  direct
pollution  control  investment  incurred  under  alternative NSPS  revisions.
Tables 3.11  and  3.12 present regional  pollution  control investment expenditures
over the 1986-1995 time period.

As was  in  the  case of pollution control costs, several  regions  dominate the
industry's direct pollution control investment. The Mid-Atlantic, South Atlantic,
East North Central and West South Central in both the moderate and high growth
baseline cases account for over 65 percent of the national total throughout the
period.  In  the  moderate growth baseline case, the West South Central region
incurs the largest percentage of direct pollution control investment.  In the high
growth baseline, the East North Central region,  which contains the  northern Ohio
River  Valley area, incurs the  largest percentage of this investment expense,
illustrating  regional   variances  in  demand  growth and  generating  capacity
additions.

Again, the largest increases occur under the  90 percent SO- removal,  12.9 ng/J
          g                                              *•
(0.03 Ib/10  Btu) case, although national and regional  differences between the
90 percent and 80 percent S0« removal requirements, as presented in Table 3.11,
do not appear significant for the  1986-1995 period.   Regionally, the West South
Central area incurs the largest increase, representing a 400 percent increase.  As
has been stated before, this Gulf Coast region is the most severely affected due
to the utilities' movement away from gas-fired boilers to coal-fired capacity that
will be subject to the revised standards.'The South Atlantic, North Mountain and
South  Mountain regions also show substantial increases in their  direct pollution
control expenses. As before, we see that the M0.5(0)0.03 scenario shows nearly
the same direct pollution control investment  as the  80 percent S02 removal
standard.
                                   3-29

-------
                                      Table 3.11

Region
Alternative NSPS Revisions*
1986- 1995
Baseline
M 1.2(0)0.1 M l.2(80).03 M l.2(90).03

M 0.5(0).03

Nation
New England
Mid-Atlantic
South Atlantic
East North Central
East South Central
West North Central
West South Central
North Mountain
South Mountain
Pacific
$8.0- +$13.3** +$14.6**
0.5. 0 0
(6.3)
1.5 +0.8 +1.1
(18.8)
1.4 +2.2 +2.5
(17.5)
I.I +0.4 +0.4
(13.8)
0.5 +0.7 +0.8
(6.3)
0.5 +1.4 +1.5
(6.3)
1.6 +6.1 +6.5
(20.0)
O.I +0.2 +0.3
(1.3)
0.4 +0.8 +0.9
(5.0)
0.4 +0.4 +0.5
(5.0)
+$13.3**
0
+ 1.1
+2.5
+0.4
+0.8
+ 1.3
+6.0
+0.2
+0.7
+0.4
 In billions of 1975 dollars; includes expenses for SO2, NOX, TSP and related pollution control.

 Change from Baseline.

 Figures in parentheses indicate percent of national  total; does not add to 100 due  to
, rounding.
                                        3-30

-------
                                 Table 3.12

            Direct Pollution Control Investment by Region

Region
Nation
New England
Mid-Atlantic
South Atlantic
East North Central
East South Central
West North Central
West South Central
North Mountain
South Mountain
Pacific
For Alternative NSPS
1986- 1995
Baseline
H 1.2(0)0.1
$17.6
0.9 +
1.6
(9.1)
2.8
(15.9)
6.1
(34.7)
0.7
(4.0)
I.I
(6.3)
2.7
(15.3)
0.2
(I.I)
0.5
(2.8)
1.0
(5.7)
Revisions*

H l.2(80).03
+$30. 1**
+0.1
+3.5
+4.9
+5.3
+ 1.9
+3.1
+7.3
+0.4
+ 1.6
+2.0

H 1.2(901.03
+$34.4**
+0.2
+4.0
+5.5
+6.1
+2.2
+3.4
+8.3
+0.5
+ 1.8
+2.2
All  figures in billions of 1975 dollars; includes expenses for SO2, NOx, TSP and related pollution
control equipment investment.

Change from Baseline.

Figures in parentheses indicate percent of national totaU
                                     3-31

-------
Under the high growth cases presented in Table 3.12, the largest increase occurs
in the West South Central region, as occurred in the moderate growth cases.  The
increase in direct pollution  control investment for the Gulf Coast  area is 300
percent under the 90 percent SO2 removal case. Other regions where investment
expenditures at least double include South Atlantic, East South Central,  West
North Central, North Mountain, South Mountain and Pacific.  Because relatively
little of its generating capacity is  coal-fired, New England again stands out as
being relatively unaffected.

As expected, we project large  increases in the utility industry's direct pollution
control  investment,  although   it  must  be  remembered  that  this  increase
represents a relatively small portion of the industry's forecasted  total investment
needs.

To summarize, both pollution control  costs and direct pollution control invest-
ment increase significantly over the  1986-1995 period.  As would be expected,
investment expenditures increase more than costs.  The largest increases occur
under  the 90 percent SO2 removal  12.9 ng/J  (0.03 Ib/IO Btu) particulate  limit
cases, although we do not forecast large differences between the 80 and 90
percent S02 removal cases.  The West South  Central region is  the most heavily
affected, as  its  pollution  control  costs are  forecast to  increase  at  most 85
percent; this region's direct  pollution control  investment costs  may  increase as
much as 300 percent. Under the high growth cases, six of the ten regions' direct
investment costs  at least double. Becase of its minimal dependence on coal-fired
capacity, New England bears the smallest increase in these costs and investment.
                                   3-32

-------
13  FINANCIAL IMPACTS

In appraising  the relative effects of  alternative  NSPS revisions, economic
impacts, as have  been discussed, can be shown as the result of a direct cause-
and-effect relationship.  That  is, if an  NSPS revision suggests that additional
expenditures need to be  made,  then utilities will  bear the added costs and
consumers, higher prices.   Financial impacts are more difficult to relate to the
added  capital   expenditures implied  by  candidate  new source performance
standards. This is true for a variety of  possible reasons.   There is, in fact, no
direct  relationship  between utilities'  needs to incur additional  costs  and any
measure of their  financial  well-being.  A number of factors can intervene.  The
most  important  of  these factors  is  regulatory  treatment  of  the added
expenditures and the stock market's interpretation of the financial impact of the
added  cost burden.  Investors, in making these interpretations,  will take  into
account  such matters as  regulatory  recognition  of possible financial impacts,
consumer responses to  higher prices,  possible flexibility  in the overall capital
spending plans of utilities, perceptions as to  the phase of the business  cycle in
which  capital spending may take  place, the perspectives  and activities of other
market participants,  and  the  management philosophies  and overall  financial
health of the  affected  utilities.   It is impossible to take all such factors  into
account.   However, by making  certain behavioral assumptions  in  the Utility
Simulation Model, it is possible to demonstrate the relative effect of alternative
NSPS  revisions on several generally accepted measures  indicative of financial
well-being.

The financial health of  the electric utility industry may be represented by such
measures as its return on  equity, its interest  coverage ratio, and the quality of
its earnings.  The return  on equity, as used in this report, refers to a  realized
book return on equity investment.   It encompasses both  cash and  noncash
earnings. The  interest coverage ratio refers to the relationship between  earnings
and  interest payable on debt.   The  ratio  is calculated by adding  earnings to
interest  payments,  and dividing  this sum by interest  payments.  This ratio  is
significant because bond  indenture agreements  are generally written so as to
                                     3-33

-------
prohibit additional debt financing  in the event the interest coverage ratio falls
below a certain  level, usually  1.75:1  or  2:1.   The final measure,  quality  of
earnings, shows the extent  to which a current year's earnings are made up  of
noncash credits to income.  These credits are placed in an account termed the
Account for Funds used During Construction (AFDC).  Clearly, the  higher the
proportion of noncash earnings to  total earnings  (cash and noncash), the greater
will be utilities' difficulties in having both dividends to distribute and earnings  to
reinvest in the enterprise.

These measures  are  often considered  indicative of  the relative  access which
utilities may have to capital markets.  If these measures, considered jointly, are
in  a poor  state  over an extended period  of time, they may suggest that the
utilities either do not have access to traditional  sources of external funds or, if
they do, that these funds could be acquired only if the utilities were willing  to
pay a relatively high price for their use.

Before proceeding to show the extent to which the selected measures of financial
health  are  affected  under alternative NSPS revisions,  it will prove useful  to
highlight a  few aspects of the way in  which  the  Financial module  of the Utility
Simulation Model  produces financial results and, thus, the context in which these
results should  be  interpreted. (The Financial module has been described more
fully above  in Section 3.1.1.)

The essential characteristic of the Financial module is that it is, like other albeit
less elaborately developed models of its type, an  accounting structure. As such,
economic and financial  decisions are treated in  a pre-specified manner at pre-
specified times.   Accordingly, these  decisions are not constrained by  extraor-
dinary events such as unexpectedly high inflation or interest rates.  Moreover, it
should be noted that  implicit in the operation of this model is a relatively high
degree of "regulatory responsiveness."  That is, it  is assumed that at the end  of
each accounting year expected revenue requirements (for the following year) are
readjusted.  In effect, a rate hearing is held and a decision is made at the end of
each year.   This may  be considered an  optimistic assumption with respect to the

                                    3-34

-------
possible  deterioration of  utilities'  financial positions  over multi-year periods.
However, it might  be inappropriate to assume that state utility commissions
would be less responsive than this and still be able to maintain that the utilities
can operate efficiently.
                Return on Equity
For purposes of assessing the relative impacts of alternative NSPS revisions, it
was assumed that all investor-owned electric utilities would be allowed to earn a
13 percent return on  equity by their respective state commissions.   As the
figures in Table 3.1 1 under national results ("Nation", column I) for the baseline
scenarios with  moderate and high electricity  growth  rates (M 1.2(0)0.1  and
H 1.2(0)0.1, respectively) indicate, the USM projects that investor-owned electric
utilities as a whole will earn less than the allowed rate of return.  This result is
due to a combination of factors. The principal element involves the fact  that,
over an eleven year simulation period,  1985-1995, in an "average year"* the costs
incurred by the  nation's investor-owned electric utilities are greater than the
revenues they are permitted (in the year) by regulatory commissions. These
costs may be greater  than  revenues because a  net increase over the  previous
year's interest,  O&M, and fuel costs was experienced.  Since we have  assumed
that regulatory commissions will reassess revenue requirements but once a year,
if the utilities are unable to effect a net reduction in  costs in an average year,
they will be unable to  earn  more than the allowed 13 percent return on equity.
Finally,  it should be noted that it is not necessarily a severe problem for utilities
to earn less  than that which is allowed by regulators.  One  of the nation's
strongest investor-owned utilities, Pacific Gas and Electric Company, has been
unable  to  earn  its allowed rate of return in any one of the last  five years.
Despite  this failure, Pacific Gas and Electric continues to be one of the  most
                                    *
financially robust utilities in the nation.
      The USM  produces annual costs,  revenues,  returns on equity, etc. which
      vary from year to year. For purposes of interpretation, these annual values
      were averaged over an eleven year simulation period.
                                    3-35

-------
 The results of the simulation under alternative NSPS revisions show the following
 results for the nation's investor-owned electric utilities.
                                                   EFFECT
          SCENARIO                             ON RETURN
                                                 ON EQUITY
        M 1.2(80)0.03                             - 3.3%
        M 1.2(90)0.03                             - 4.2%
        H 1.2(90)0.03                             - 6.5%
 The investor-owned electric utilities in some regions are more adversely affected
 than they are in others.  For example, in New England, NSPS revisions for coal-
 fired units have an insignificant effect on the return on equity. Effects are more
 readily apparent in the Mid-Atlantic, South Atlantic, East North Central, South
 Mountain, and Pacific regions. The greatest impacts on returns on equity due to
 tightened standards are  projected  for  the East South  Central,  West  North
 Central, West South Central, and North Mountain regions.  Impacts are greater in
 these regions for both moderate and high growth rate cases.

 Two important additional  observations should be  noted regarding Table 3.13.
 First, it should be noted that there is a significant difference in the effect a 90
 percent removal requirement will have under the moderate and  high electricity
 demand growth rate assumptions  in  certain regions.   The Mid-Atlantic, East
North  Central, West  North Central, West South Central, and South Mountain
regions are more adversely affected under the high growth case than they are
under the moderate growth case.
                                   3-36

-------
CO
                                                  Table 3.13
                                             RETURN ON EQUITY
            for Investor-Owned Electric Utilities on a Regional Basis under Alternative Scenarios, 1985-1995

>yREGION
CASE^V
Baseline
M 1.2(0)0.1
M 1.2(80)0.03
M 1.2(90)0.03

Baseline
H 1.2(0)0.1
H 1.2(90)0.03

Eost Eost West West *.
triQiQrtct r\TioriTic /\TionTic f^^tf. tmt t^^ntmt tf"*An4mf f^An+rsii lYiooTiTQif* ivioiinToin

12.4% 13.9% 13.1% 10.7% 12.9% 10.9% 14.5% 10.2% 16.5% 13.2% 14.5%
12.0% 13.9 12.7 10.4 12.8 9.8 13.7 9.0 14.0 12.7 14.3
11.9% 13.9 12.6 10.3 12.8 9.7 13.7 8.9 13.9 12.7 14.3


11.5% 15.4 12.1 10.1 11.6 10.2 13.1 9.5 14.9 12.5 13.2
10.8% 15.5 11.4 9.7 10.8 9.5 11.8 7.9 13.5 11.3 12.9

-------
Second, the results of the simulation show only a marginal effect on return on
equity in going from an 80 to a 90 percent S02 removal requirement.  The small
effect that shows up in five of  the ten regions  is well within the margin of
uncertainty.*

      3.3.2      Interest Coverage

Interest Coverage ratios for  investor-owned electric utilities under the various
control scenarios are shown in Table 3.14.  As indicated in this table, baseline
conditions (current  NSPS for SO-  and  particulates under moderate and  high
electricity growth rates)  essentially foretell the extent  to  which utilities in
particular regions may have difficulty attracting needed debt financing.  In this
regard, the New England, South Atlantic, East South Central,  and West South
Central regions could have debt financing problems under the assumptions used in
the simulation model.

The interest coverage ratios in three of these regions — South Atlantic, East
South Central, and West  South Central — can be shown to be measurably affected
by alternative NSPS revisions. Adverse effects are found in some other regions,
but, with  the exception of the South Mountain region, these effects may not be
significant.  It should also be noted that  in some cases anomalies appear in these
results.  That is,  coverage ratios going  up  by one one-hundredths when these
might be expected to go down - but these results  are well within the margin of
uncertainty.

The results for the nation's investor-owned utilities are summarized as follows:
     An extensive sensitivity analysis would be required to quantify the band of
     uncertainty surrounding all the key data for this analysis.
                                   3-38

-------
                                          Table 3.14


                                     INTEREST COVERAGE
CO
CO
vo

\REGION
CASES.
Baseline
M 1.2(0)0.1
M 1.2(80)0.03
M 1.2(90)0.03

Baseline
H 1.2(0)0.1
H 1.2(90)0.03

New Mid- South East East Wesf West North South
England Atlanhc Atlonfc Cenfra| Ccntn]| Centnj| Centra| Moontam Mountom
3.14% 2.52% 3.50% 2.82% 3.44% 2.78% 3.61% 2.63% 4.38% 3.42% 3.70%
3.14% 2.52 3.47 2.81 3.43 2.73 3.62 2.62 4.36 3.38 3.68
3.14% 2.54 3.47 2.76 3.42 2.73 3.62 2.62 4.36 3.31 3.68

3.01% 3.23 3.24 2.67 3.27 2.66 3.30 2.55 3.71 3.14 3.37
2.97% 3.22 3.21 2.68 3.19 2.66 3.25 2.49 3.68 3.10 3.31

-------
                                                 EFFECT ON
          SCENARIO                        INTEREST COVERAGE
                                                   RATIO
        M  1.2(80)0.03                            No Change
        M  1.2(90)0.03                            No Change
        H  1.2(90)0.03                             - 1.3%
     33.3      Quality of Earnings

It is generally assumed that astute investors will bid down share prices if AFDC
is expected to represent a large proportion  of earnings over a long period of
time.  This would be true,  in part, because a  high proportion of (noncash AFDC)
earnings would be unavailable for immediate reinvestment in the  utility.  This
would  imply that utilities would need to go to the capital markets for additional
funds if sizeable capital or any other expenditures were required. It would imply,
moreover,  that if a significant downturn in revenues were experienced, dividends
or possible dividend increases could be endangered.

Table  3.15 shows that under the assumptions of the Utility Simulation Model,
AFDC in every region of the nation assumes  a much larger position in earnings
statements than it has traditionally. This situation can be the result of a number
of factors, most important of which are  relatively high construction financing
obligations tied  up  in the AFDC  account  and relatively low generation of cash
earnings.   That  the construction  financing account (AFDC) should be relatively
high by historical  standards can be understood by  the fact  that  additions to
generating capacity will be more costly and  capital-intensive  than  ever before.
Also, since the cost of capital assumed for the forecast period is reflective of a
current weighted average cost and not an  historical cost, the AFDC rate will be
higher  than it has ever been.
                                    3-40

-------
                                      Tdble3.l5
                               QUALITY OF EARNINGS
                    — Percentage of Earnings That is Noncash AFDC —
for Investor-Owned Electric Utilities on a Regional Basis under Alternative Scenarios, 1985-1995

\REGION
CASES.

Baseline
M 1.2(0)0.1
M 1.2(80)0.03
M 1.2(90)0.03

Baseline
H 1.2(0)0.1
H 1.2(90)0.03

NATION New Mid- South Jr"5.! £^t $**$ jj^ North South pacjfc
England Atlantic Atlantic r* * i r* * t /- * i <~ « i Mountain Mountain
Central i-entrai central central


38% 46% 32% 43% 36% 46% 31% 53% 22% 37% 28%
39% 46 31 44 38 50 30 57 23 36 28
40% 44 31 45 38 50 30 57 24 37 28


44% 60 38 51 43 52 37 55 30 42 34
47% 60 39 53 45 57 40 62 33 45 35

-------
It is certainly  debatable whether  or  not the quality of the nation's  electric
utilities'  earnings  could  erode as  much as that  represented in the  baseline
scenarios.  Part of this  erosion is due to regulatory lag, which the Financial
module includes.   However,  the  utilities' response to earnings  quality erosion
would likely be to request more rate increases (to increase cash earnings) and
higher returns on equity  (both to increase cash earnings and to attract needed
capital, which may be more difficult  to do due to investors' discounting as a
result of  earnings quality troubles).  The model does not increase the frequency
of rate relief, nor does it  increase the allowed rate of return on equity.*

With these considerations in  mind, it should be noted that the purpose of this
assessment is to show the effect, if any, on this measure of financial health,
eqrnings quality, which may be attributable to alternative NSPS revisions. For
the nation's investor-owned electric utilties, the results of the simulation model
show the following marginal impacts on earnings quality.
                                                    EFFECT
                                                           QUALITY
        M  1.2(80)0.03                              - 2.6%
        M  1.2(90)0.03                              - 5.3%
        H  1.2(90)0.03                              - 6.8%
*
     Teknekron performed an analysis of the sensitivity of earnings quality to
     increased allowable return on equity, and found that there is a greater than
     one-to-one correspondence between percentage increases  in target return
     on equity and improvements in earnings quality.
                                   3-42

-------
As for relative impacts on earnings quality over the ten regions considered in this
assessment, the regions most affected are the West South Central and East South
Central areas.  Measurable effects are also shown in the North Mountain, South
Mountain, and West North Central regions.

The  greatest impacts on earnings quality are experienced in two of the regions
with  most basic financial  difficulties as implied by results for  the  baseline
scenarios.  To reiterate, these regions are West  South  Central  and East South
Central.  The South Atlantic region, which also has a relatively high proportion
of AFDC in its baseline scenarios,  is not as significantly affected.  New England
also has an earnings quality problem in its baseline scenarios;  however, since in
this  region the  problem may  be related to nuclear capacity  expansion, the
alternative NSPS revisions  have a negligible effect.   In the results  for New
England, there is an anomaly which is within the margin for error.

It is  important  to note, at this point,  the relationship between earnings quality
and  realized return on equity.  Earnings quality is essentially a measure used to
distinguish between cash and noncash earnings. Return on equity calculaitons do
not make this distinction.  The return  on equity computation is based on a book
return (i.e., not  a cash-flow return), as is consistent with accepted accounting
practice.  Since  the cash/noncash distinction is not made for return on equity, a
particular region may have a poor  quality of earnings ratio without  its return on
equity suffering to the same extent. If the return  on equity were calculated on a
cash-flow basis, then there would be a direct relationship between it and  earnings
quality.

      3.3.4       Summary of Industry Impacts

Under the assumptions used  in the operation of the Utility Simulation Model, the
following impacts  on  the  financial well-being of the  nation's  investor-owned
electric  utility industry may be  viewed  as  attributable to  alternative NSPS
revisions:
                                    3-43

-------

M
M
H
Scenario
1.2(80)0.03
1.2(90)0.03
1.2(90)0.03
Return on
Equity
- 3.3%
- 4.2%
- 6.5%
Interest
Coverage Ratio
No Change
No Change
- 1.3%
Earnings
Quality
- 2.6%
- 5.3%
- 6.8%
The regions most significantly affected from a financial perspective are the West
South  Central  and East South Central areas.  The impacts in other regions are
less significant.   That the  impacts should be greatest in West South Central
region could reasonably be expected since a large amount of coal-fired capacity
subject to a revised standard is anticipated to be built in this area.   A sizeable
amount of new capacity — both nuclear and coal, though especially the latter —
 will  be built  in these regions prior to the units subject to  a revised standard
coming on line. This suggests that, particularly in these regions, though certainly
in other regions as well, utilities may have difficulty attracting investors on what
are now considered reasonable terms (e.g., a 13 percent allowed return on equity)
to the rather bleak prospects described under the baseline scenarios.

Accordingly,  there are  at   least  two  interpretations that  might  give  such
measures  of financial health.  First, these measures may be indicative  of the
extent to which  state  regulations in certain regions will be under  pressure to
facilitate electric utility financing (e.g., by raising the allowed return on equity,
by increasing the frequency of rate relief,  by permitting construction-work-in-
progress in rate base, or by  other means). Second, these measures may indicate
that electric utility spending plans are too ambitious.

Irrespective of the interpretation which may be attached to figures in the base-
line scenarios, the relative  effects of alternative NSPS revisions, both for the

                                    3-44

-------
moderate and high growth futures, are projected to have relatively little national
financial impact.

     3.3^5      External Financing Impact

Since a  large proportion of  the  additional costs and investment expenditures
required by  the electric utility industry due to revisions  in  pollution  control
regulations will be financed  externally,  it is useful to examine the impact on
long-term external financing of the alternative NSPS  revisions for the nation's
investor-owned electric utilities.  Results of the simulation for alternative NSPS
revisions on long-term financing are presented in Table 3.16.

For each of the cases considered, additional total external financing accounts for
approximately 60 percent of  the investor-owned utilities' NSPS revision-related
investment  requirements over  the  1976-1995 period.   The  largest percentage
occurs  under the high growth most stringent  scenario (H  1.2(90)0.03),  where
external financing represents  63 percent of total  investment.

As shown,  the  utilities' long-term  external financing  increases significantly
between the moderate and high growth baseline cases.  As would be expected,
the majority of this financing is made with long-term debt issues.  Neither long-
term debt nor preferred  stock financing is forecast to be affected greatly by the
alternative NSPS revisions under  moderate growth.  In addition, the 90 percent
SO- removal case  is not forecast to affect  significantly the utilities' external
financing requirements as compared to the 80 percent SO- removal case.  The
differences  between the two cases are less  than 0.3 percent  for each type of
financing. The NSPS revisions are forecast to influence common stock financing
more heavily than either debt or  preferred  stock, although debt remains the
major source of capital for the  utilities.  Common stock financing is forecast to
increase 7 percent  under both the 80 and 90 percent S02 removal cases.  Total
incremental  external  financing over  the twenty-year period is forecast  to be
$10.4 and $11.1  billion  (in   1975 dollars)  for the  80 percent and 90 percent
removal cases, respectively.
                                    3-45

-------
                                                     Table 3.16

                                            Long-Term External Financing
                                   Baseline External Financing
                               Long-Term    Common  Preferred
                                  Debt        Stock      Stock
                                                               Incremental Long-Term External
                                                                  Financing Attributable to
                                                                 Alternative NSPS Revisions
                                                             Long-Term
                                                               Debt
                                                    Common   Preferred
                                                     Stock       Stock
CO
J>
ON
 Baseline
M  1.2(0)0.1

M  1.2(80)0.03

M  1.2(90)0.03
$255.2*      $ 87.0
                                                          80.8
                                                                        +$3.4

                                                                          +3.8
                                                     +$6.0

                                                      +6.1
                                       +$1.0

                                        + 1.2
            Baseline
          H 1.2(0)0.1

          H 1.2(90)0.03
                        363.7
               158.3
III.3
                                                                +7.7
                                                     + 13.6
                                         +2.3
                 All dollar figures in billions of 1975 dollars.

-------
Under high growth, the 90 percent S02 removal case is forecast to require more
than 2 percent more debt and preferred stock, and more than 8 percent common
stock financing, which together represent,  on average, less than  0.2  percent
increase in total  external  financing per year over the 20-year period.   This
incremental external financing  is forecast to be $23.6 billion (in  1975 dollars)
through 1995.

     3.3.6      Impact on National Capital Markets

The Utility Simulation Model  allows for  an integrated technical, environmental,
and economic/financial  assessment  of the  alternative NSPS revisions on the
utility industry, as has been  described above.  However, the model is essentially a
micro-economic impact model and is not formally "linked" to a macro-economic
forecasting model.   Because it  is  useful  to examine the potential  macro-
economic  impacts  of alternative NSPS revisions for  electric utility industry
boilers, we have attempted to calculate  these impacts by utilizing the Data
Resources, Inc.  (DRI) long-term macro-economic forecasting model in conjunc-
tion with our results.

This effort could be undertaken because  the  data that are required to perform a
mcaro-economic analysis include forecasts for Gross National Product (GNP) and
its components.  Comparable types of forecasts are required for the operation  of
the Utility Simulation Model.  However, producing forecast consistency  is a
difficult problem because of differing assumptions about the movement of key
economic parameters such as the inflation rate, the growth in electricity demand
and financial  parameters such  as bond  rates,  returns on equity, and external
financing requirements.

Before we present the results of this co-ordinated assessment, there are several
qualifications  that must be made about the results. First, the DRI forecasts stop
in 1990, when  the financial  impacts of the NSPS revisions have not yet matured.
Thus,  the full  potential financial impact  of the revisions on  the nation's capital
markets is not discussed. Second, the problem of forecast consistency between
                                   3-47

-------
the  two models  cannot be  fully resolved.   Significant differences remain in
parameter values, data sources, and model structure.  For example, we have used
the TRENDLONG 0977 forecast, which is the  most consistent forecast with that
of the USM based on inflation rates and other parameters. However, under the
DRI forecast, an  inflation rate of 5.7 percent between 1976 and 1983 drops to 4.5
percent in the late  I980*s.   This is contrasted to the constant 5.5 percent per
year rate used in  Teknekron's forecast.

Nevertheless, we believe the results presented below are illustrative and indicate
the  general  magnitude of the macro-economic  impact of imposing the NSPS
revisions we have considered, although care must be taken in placing confidence
in the actual forecast values.

We  have  selected   the  high  growth,  90  percent  SO-   removal  scenario
(H 1.2(90)0.03) for analysis  because  it  contains  the  largest potential  macro-
economic impact since the utility industry's total investment increases the most
under this case (see Table 3.5). All other alternative NSPS revisions will likely
result in less macro-economic impact.

Comparing the high growth  baseline with the M 1.2(90)0.03  case, we forecast
that in  1990 an  additional  $6.2 billion dollars of plant and pollution  control
investment will be needed.   This figure  is converted to 1972 dollars, which the
DRI  model uses, giving $5.25 billion.  In  1990 the DRI model forecasts that GNP
will be $2,109.4 billion and gross private domestic investment,  $321.5 billion.

Thus  we estimate in  1990 that the NSPS revision-induced investment  for  the
electric utility industry will account for  0.25 percent of GNP  and 1.6 percent of
gross private domestic  investment.   From  this we conclude  that the NSPS
revisions we  considered are  likely  to have, at most,  a small  impact  on  the
nation's capital markets, e.g., on the level of interest rates in that year.
                                   3-48

-------
       4.0  COAL VERSUS NUCLEAR:  Economics end Decision-Making
          As Affected by Revised New Source Performance Standards
                           For Coal-Fired Boilers
It has been asserted by a critic of nuclear power, Charles Komanoff,* that the
golden age of nuclear economics  — said to have lasted from  1968 to  1975 —is
over. President Carter  himself has declared, in addressing a  delegation at the
International  Fuel  Cycle Evaluation Conference, that "the need for atomic power
for  peaceful  uses  has perhaps been greatly  exaggerated", suggesting that all
nations carefully assess the alternatives to nuclear power, "if for no other reason
than economics"** (emphasis added).

Alternatives  to nuclear power for new baseload electrical generation also have
economic problems.  At  present, the principal alternative to nuclear is believed
to be coal-fired.plants.   While the potential  coal resources of  the  U.S.  are
extensive, costly  restrictions  on  the extraction, combustion, and disposal of
waste products make  use of these resources an expensive proposition.  It is
sometimes alleged that, in the final analysis, electrification based on coal will be
as expensive  or more expensive than that based on nuclear power. Following this
view, revisions to current New Source Performance Standards for coal-fired
boilers might be  sufficiently  costly  to  tip  the economic scales to a  clear
advantage for the nuclear alternative.

What are the economics of  nuclear and coal power?  Is decision-making with
respect to nuclear vis-a-vis coal for new baseload electrical generating capacity
likely to be  significantly affected by added  cost burdens placed on coal-fired
plants as a result of revised  NSPS?  If so, in what regions of the nation can this
effect be anticipated to be most pronounced? If not, what factors may operate
to mitigate or otherwise make insignificant this effect?  What are the principal
quantifiable and non-quantifiable  factors likely to  be weighed in choices, on a
regional basis, between nuclear and coal?
     See Komanoff reference, Table 4.1.
     The Energy Daily, 5(204);  I, October 20, 1977.
                                    4-1

-------
The purpose of this chapter is to address these issues in such a way as to provide
a  broad assessment of  the  effect  of  a single set of possible  EPA regulatory
initiatives -  that of  revising the NSPS for coal-fired  boilers.  As such,  the
analysis does  not dwell  on any  one of  the sizeable number of sub-issues which
arise in considering  the  relative prospects for coal and nuclear  power.   Rather,
by presenting a brief review of a representative sample of economic evaluations
of these two power technologies and by  enumerating the key factors on which the
relative attractiveness of each of these technologies now rests, it is hoped this
assessment will prove useful  in the formulation of public policy.

4.1   BUSBAR POWER COSTS

The relative  economics of  alternative fuel-type/plant-types is conventionally
expressed  in  terms  of busbar power costs.  This means,  in effect, that each
fuel/plant candidate is assessed in terms of the cost which is likely to be incurred
to feed its product, electricity,  from the power plant to connecting transmission
I ines.

All anticipated capital charges, fuel, operating  and maintenance expenses are
taken into account in  this economic evaluation. Numerous detailed calculations
must be made to arrive at a  busbar power cost. Crucial decisions must  be made
as to the assumptions which  should go into the model for evaluation.  Generally,
every item input is based on someone's forecast, i.e., assumption, as to a "most
likely" value for that item.  The  end-product of such an economic evaluation is a
level ized cost - that is, a yearly cost spread over some period of time,  which is
often but not always  equal  to  the  anticipated Irfe of the plant.  This cost is
expressed in terms  of mills-per-kilowatt-hour.  In theory, the plant  which is
calculated to deliver electricity to the  transmission lines at least cost, e.g., over
the life of the plant, would be  chosen to be built.   In practice, this will not
always be so.
                                                        i
Decision-makers do  not  necessarily rely on "most likely"  estimates for values
which are critical to the evaluation. Some would rather base their decisions on
"worst-case" values for these variables.  If a particular fuel/plant type were to
                                    4-2

-------
maintain its economic  attractiveness under "worst-case" assumptions, then it
may stand a better chance of being chosen.

Another possible reason for  not choosing the alternative which is calculated to
have the lowest busbar power cost has to do with the limitations which exist as
to what can be quantified — as input  data to busbar power cost calculations or
for  other  purposes.   In theory,  probabilities can  be assigned to any  future
occurrence.  For example, one might  wish to learn  the probability of a nuclear
moratorium or shutdown aimed at then-operating plants  in a particular state.
Even if the  probability of  such an occurrence  could  be determined,  i.e.,
quantified,  this information would not be reflected in  anticipated unit  power
costs.   Moreover,  it  is unlikely that  any decision-maker  would lend much
credence to the precise odds produced  as a result of such an exercise.

Despite these and other limitations to be discussed concerning the usefulness of
busbar  power  cost estimates  for  ultimate decision-making  purposes, these
estimates provide a point of reference.  In the following section, a review is
made of three recent estimates of the unit costs for producing electricity from
new baseloaded nuclear and coal-fired plants. In some respects, these estimates
parallel one another; in others, they diverge. Basically, in some cases analysts
would  agree as to the  future behavior of key variables affecting costs and, in
other cases, they would disagree.

4.2  REVIEW OF ECONOMIC EVALUATIONS

Over the last three years, numerous evaluations have been conducted concerning
the  relative economics of  coal  and  nuclear power.  These  studies have been
performed by  or for reactor  and boiler manufacturers,  electric  utility trade
associations, environmental organizations, and state and federal agencies.  Each
of  these  studies  was  conducted for a different  purpose.   Accordingly,  the
emphasis of each and the extent to which detailed calculations were performed
varies  enormously.  Few were published with sufficient  documentation to make
possible meaningful comparison with other studies.
                                    4-3

-------
Major assumptions as to basic investment costs, escalation rates for various cost
elements, and fixed charge rates differed among the studies. Further, costs were
levelized over different periods of time.  In sum, since these and other problems
inhibited attempts to reconcile  cost estimates, the generalizations which  are
drawn from this review should be viewed in the  light in which they are intended:
to establish a point of reference.

As might be expected, there are basically two schools  of thought on the coal
versus nuclear economics.question:  a  coal school and  a nuclear school.  This
difference in views is clearly manifest in Table 4.1.  In the Komanoff view coal is
the least-cost alternative in every region. The Electric Power Research Institute
(EPRI) presents a completely contrary  point of view.   The National  Economic
Research Associates,  Inc. (NERA) view is that  nuclear is  cheapest in most
regions.  (It should be noted that the results shown for NERA estimates represent
but one set of figures offered by  the firm in the GESMO hearings.  Other sets of
figures show the economic advantage of  nuclear  to be greater.)

     4.2.1 Capacity Factors

These estimates (and others) vary for some basic reasons. Komanoff, who  has
made some contributions to the understanding of the recent reliability of nuclear
units and of both nuclear and coal units of larger magnitude, begins with  the
premise that only larger  (over 1000 Mw) nuclear units will be available in  the
future and that these units will function at significantly lower capacity factors
thaii do smaller units built in the U.S.  in the past.  Consequently, he compares
the relative economics of three 600 Mw coal units (he alleges units of this size
are more reliable) operating at a levelized capacity factor of 70 percent to two
I ISO Mw nuclear reactors operating at a 55 percent capacity factor.

Capacity factor assumptions are  crucial inputs  to economic evaluations such as
these.  That Komanoff should assume  different capacity factors for  coal  and
nuclear plants and that EPRI and  NERA should assume equal capacity factors for
these two types of plants makes it very  difficult to compare the results of these
economic evaluations.
                                    4-4

-------
                                                       Table 4. 1
                  Comparison of Nuclear and Coal Busbar Power Costs on Regional Basis
(Mills/kWh)
New Mid- South .Eas* J^t
England Atlantic Atlantic /^ , <~ , i
v_enTroi i*cnTrai
NUCLEAR 55.7 55.7 52.0 54.0 52.0
COAL 55.4 55.4 46.5 45.5 42.0
NUCLEAR 37.7-45.5 37.7-45.5 ,34.0-41.2 36.4-44.034.0-41.2
COAL 43.4-52.8 43.4-52.8 39.9-48.6 42.3-51.439.9-48.6
NUCLEAR 50.0 50.0 45.8 48.9 45.8
MFRA - 	 	 	 - - 	
COAL 54.7 52.7 49.3 49.6 46.5
West
North
Central
54.0
42.8
35.4-42.8
38.4-46.7
48.9
46.4
W«*f North Sooth PACIFIC
Central Mountain Mountain NW Calif.
52.0 54.0 54.0 54.0 55.7
42.0 36.0 36.0 36.0 44.6
34.7-42.0 36.2-46.4 36.2-46.4 36.2-46.4
37.5-44.6 40.6-51.8 40.6-51.8 40.6-51.8
45.9 47.6 47.6 50.2 50.2
47.5 39.7 46.2 51.0 46.3
Komanoff,  Chas.,  Testimony of - on the Costs of Nuclear Power before the House  Subcommittee on Environment, Energy, and
           Natural Resources, September 21, 1977. Komanoff compared costs of generating electricity from 3 - 600 MW coal units
           to 2 -  1,150 MW nuclear units. He assumed these two configurations would achieve the same overall system reliability.
           Assumed capacity factors: 55% for nuclear;  70% for coal.

EPRI        PS-455-SR, Coal and Nuclear Generating Costs, April 1977. Assumed capacity factors: 66% for both types of plant.

NERA,      Testimony  of Dr. Lewis J. Perl, on behalf of the GESMO Utility group.   Concerning Nuclear  and Coal  Electric
           Generating Capacity Expansion, 1975-2000; March 4, 1977.  NERA produced estimates of busbar power costs for two
           scenarios under different capacity factor assumptions. The estimates shown are for the "high-cost" nuclear scenario, the
           figures for which parallel those made in the latest estimates for plants coming on  line  in 1986.   Assumed capacity
           factors: 60% for both types of plant.

-------
Komanoff bases his capacity factor assumptions, in part, on rough extrapolations
of the recent experience of nuclear units of larger capacity.  In effect, he sees
no reason to believe that nuclear  reactors of this size will operate very much
better  in the  future than they  do now.    Utilities  view this  matter quite
differently, as do reactor manufacturers.  They believe that the performance of
larger size  reactors will  improve with age.  (It  should be noted  that  reactor
manufacturers have taken issue with some of Komanoff's findings and, obviously,
with his conclusions.) They argue that a few problem plants, e.g., the Browns
Ferry units //I  and #2, bias the overall  performance of nuclear power. It is also
argued  that the  units  of some  manufacturers  perform better  than  others.
Finally, and very importantly, it is argued that regulatory  initiatives on the part
of the Nuclear Regulatory Commission (NRC), and others have had a great deal
to do with the less than anticipated nuclear capacity factors. It is suggested that
availability  factors (a measure purported to adjust for the adverse effect on
capacity factors of regulatory  initiatives to raise the probability that existing
nuclear reactors can be  operated safely) would be a more  equitable measure of
reactor performance. Also, it  is argued that as the nuclear industry matures, as
reactor designs are standardized,  and  as regulatory procedures are  routinized,
the capacity factors of nuclear power plants will rise.

It is clear that all of this takes some faith. The burden of proof rests with the
nuclear industry. It is also evident that, despite all the problems of the industry,
electricity  now  produced  from  nuclear reactors  is  competitive  with  that
produced from coal-fired facilities. This can probably be explained in  part by the
fact that when  nuclear  units are available for use there is a  large incentive to
use them as much as possible — perhaps in the process relegating coal-fired units
to a subordinate dispatch position.

On the  matter of capacity factors, another point should  be noted.  In  another
evaluation  of the  relative economics  of coal versus nuclear,  a  study  group*
     Nuclear Power;  Issues and Choices;  Report of the Nuclear Energy Policy
     Study Group, Ford/Mitre, 1977.
                                    4-6

-------
assumes that a coal-fired plant burning Northern or Central Appalachian coal and
requiring a scrubber would  have a capacity factor five to ten percent less than it
would were no scrubber required.*

     4.2.2 Fuel Costs

Another  important factor  contributing to the current economy of nuclear power
is the relatively inexpensive fuel now being used in these units.  Future fuel
prices probably  will be much higher.  How much higher cannot be determined,
because virtually no new uranium supply contracts now negotiated involve fixed-
prices (with customary cost escalation  clauses).   Instead,  all new contracts
entered are  of  the "market-price"  variety,  wherein the selling price is deter-
mined just prior to delivery, based on then-prevailing  market prices.

Since these  contractual arrangements are consummated  as  much as a  decade
before deliveries begin, this presents  a rather risky situation for a utility.  It is
especially risky  since fuel  costs, based on information from fixed-price contracts
when they were available, are expected  to represent 40 to 50 percent of total
fuel cycle costs** for plants coming on line  in  1986.  Fuel cycle costs are now
about 25 percent of total busbar power costs for nuclear units.

The combination  of  f.o.b.  mine  coal  prices and  transportation  charges  is
generally assumed to account for about  40 to  50 percent of the future busbar
power costs of  coal units. As such, the assumptions which are made as to the
future prices of coals  with  different characteristics, in different regions,  and
with different means and  costs of transport are crucial inputs to busbar power
cost calculations.
      It should be noted that possible changes in the availabilities of coal units
      due to the installation of FGD systems have not been incorporated in the
      Utility Simulation Model.                        *
  **  Fuel costs for a light-water reactor include the prices charged for mining
      and milling.  Fuel  cycle costs, assuming  no recycle,  include the prices
      chargecLfor mining, milling, conversion (U30ft to UFA enrichment (UF* to
      3% UZl"), fabrication (enriched UF, to UO3,°peNeti2e, sinter to U02, fead
      and fabricate into fuel  elements), shipping spent fuel, waste management
      (interim and long-term), and fuel inventory  charge.
                                    4-7

-------
It was not possible to determine with any degree of certainty whether the busbar
power cost differentials noted in Table 4.1 could be attributable to differences in
assumptions as to the future prices of coal and transport. The NERA study was
reasonably detailed insofar as it identified sources of coal, accordingly to Bureau
of  Mines'  regions,  and  assumed  cost  escalation  factors  were  stated
unambiguously.  A least-cost optimization model was said to have been used to
determine  coal flows.    The  EPRI and  Komanoff studies lacked equivalent
documentation.  Other studies or models of coal flows, ones with which NERA's
results might conceivably be contrasted, were not considered for this analysis.

      4.2.3 Capital Costs

The economic factor most often mentioned as the major nuclear parameter is its
capital cost.  Building a kilowatt of nuclear capacity is estimated to cost from 15
to 30 percent more than building a kilowatt of coal-fired capacity.  In the three
studies compared in Table 4.1,  it was estimated by Komanoff that a kilowatt of
nuclear capacity would  cost 26 percent more,  by NERA, 24 percent more, and
EPRI, 17 percent more.  These are national averages; there is very little regional
variation in these relationships.

In considering capital cost estimates, it is important to note not only  the  rela-
tionships between nuclear and coal investment figures but also the magnitude of
these estimates.   In this  regard, Komanoff's national  average  for nuclear,
$l,200/kw (1985 dollars, 1150 Mw), is 14 percent higher than the NERA estimate;
(same size unit); his coal investment figure, $950 (600 Mw), is  11 percent higher
than NERA's (800 Mw). EPRI figures could not be compared in this manner.

A higher absolute  level  of investment implies, other things  being  equal, that
there will  be greater amounts  of  interest charges  that  will  appear in busbar
power costs.  This  assumes, for pne thing, that the same fixed charge  rates are
used.  Komanoff and NERA did not use the same rates.
                                    4-8

-------
 To summarize, differences in  the  estimated busbar power cost advantages  to
 nuclear and coal, as displayed in Table 4.1, may be attributable to: differences
 in  assumed capacity factors; differences in assumptions as to future delivered
 coal prices; and differences in capital cost and fixed charge rate assumptions.

 Estimates for particular aspects of the nuclear fuel cycle could not be shown  to
 vary.  Nor could it be demonstrated that significant variation  exists in projected
 O & M costs for either coal or nuclear.

      4.2.4 NSPS Revisions and Regional Effects

 Based on preliminary and rough calculations of the incremental costs associated
 with NSPS revisions, it can be  stated that the  busbar power  costs of coal may
 increase  by 6.5 mills per kilowatt-hour, ± 20  percent, in 1985 dollars.  With
 reference to Table 4.1, this effect may be seen to tip the economic scales  in
 favor of  nuclear  in three of the four areas which NERA now  estimates a  slight
 advantage  for coal.  Coal would maintain its advantage, in the NERA analysis,
\
 only in the North Mountain region.  In the Komanof f analysis,  coal would lose its
 advantage in  the Northeast, Mid-Atlantic, and South Atlantic regions.

 While these may appear  significant effects in  terms of a strictly quantifiable
 measure, their true effect on decision-making concerning coal and nuclear may
 in fact be quite insignificant.  Estimates such as those discussed in Section 4.2
 may well not be  the basis for actual decision-making.  In the following section,
 other not  strictly  quantifiable factors are suggested as possible reasons for
 choosing to build a nuclear and not a coal plant, or vice-versa.

 4.3  FACTORS DIFFICULT TO QUANTIFY

 In this section, factors that are difficult to quantify are viewed from two per-
 spectives.  First of all, from the perspective of a decision-maker who  may  be
 attempting to find out  a number of good reasons to invest in nuclear. The list
                                     4-9

-------
the decision-maker draws up will include, assuming there is but one other choice,
coal, the principal reasons to avoid coal.  The other perspective is one drawn in
terms of reasons to go with coal, if for no other reason than to avoid nuclear.

     4.3.1  Reasons to Invest in Nuclear
           And Reasons to Avoid Coal

PUBLIC SUPPORT
It is not enough to simply calculate busbar power costs, do some sensitivity runs,
and then decide that nuclear power is competitive and, therefore, there can be
no argument about it.  What a decision-maker needs is backers, people who will
help to make his choice an economic one.. In  this regard, because an enormous
amount of  taxpayers' money has already gone  into the development of peaceful
uses for  atomic power, there is a  natural desire on the part of taxpayers  and
public servants to see the nuclear promise realized at some time.  Accordingly, it
may be safe to assume that the public would not permit nuclear power be made
uneconomic by, for example, lifting the tort liability protections provided  under
the Price-Anderson  Act,  by  pricing  enrichment  services or  waste  disposal
services at unsubsidized rates, or by eliminating certain special tax advantages.

EXPERIENCE
Firms such as Commonwealth Edison and an ever-increasing number of others are
learning, by experience,  about  the  economics  of nuclear power.  Significantly,
Commonwealth Edison is pushing ahead with  the siting and licensing of  more
reactors and captive uranium mine development.

DIVERSITY
Even a utility such as  Commonwealth Edison which  is heavily committed to
nuclear, recognizes the strength in a diversity of plant/fuel types. As a result, it
is also planning  to build more coal-fired units.  Utilities now principally coal-
fired may be wishing, as the effects of the coal strike are beginning to hurt sales
and profitability, that they had a reactor or two.
                                   4-10

-------
The threat of coal strikes is not the only reason to avoid too heavy a reliance on
coal.  There may be apprehension that sulfur and participate controls will  not
function properly on some coal plants, and that these plants may be required to
shut down until  such controls are effective.  The reliability and ultimately  the
economics of these plants could, as a result, be much worse than now foreseen.

Other factors  could make coal appear uneconomic.  For one thing, FGD sludge
disposal costs  may  be higher than  now  anticipated.  Severance taxes, greater
costs for  surface mine reclamation, for mine health  and safety, or for miners'
pension funds could make coal power lose its attractiveness.

SITING COAL  PLANTS
Air quality standards  make the siting of a coal-fired plant a major problem.  To
site a plant in or anywhere upwind of a Non-Attainment area could well involve
having  to invest  in . tradeoffs.    These  could prove  uneconomic given  the
alternative of  nuclear power.

In the near term, coal plants may be sited in Class II and other areas. But in so
doing, the allowable degradation increments may be used up. Again, nuclear may
be the only reasonable alternative in the long-term.

THE ENVIRONMENTAL EFFECTS OF EXPANDED COAL USE ARE UNKNOWN
One of the most compelling reasons to avoid coal is that new controls for nitric
oxides,  heavy  trace metals, and toxic and carcinogenic compounds may be  re-
quired.  The combined cost of such emissions controls is now not available.

NUCLEAR IS YOUNG, FURTHER ASSISTANCE WOULD MAKE ITS
PROSPECTS BRIGHT
Like all relatively new technologies, nuclear power has been struggling to get on
its feet.  It may need further help. In this regard, an elimination of the Con-
struction-Work-in-Progress  account (i.e., include construction expenditures in  the
rate base) would help to reduce the economic/financial bias against a capital-
intensive technology.  In addition, while plutonium recycle is contrary to current
national policy,  were this policy changed the economics of nuclear power would
be enhanced marginally.

-------
      4»3.2 Reasons to Invest In Coal ond Avoid Nuclear
INDIGENOUS RESOURCE
In  1976, greater than  80 percent of uranium procurements for future delivery
were negotiated with firms whose mines are in four western states — New Mexi-
co, Wyoming, Colorado, and Utah. About 14 percent of procurements is to come
from foreign sources.*  Nuclear electrification may end up sending a sizeable
proportion  of  electricity  rate  payers'  money   to  these  four states  and,
increasingly, to other nations.

By contrast, coal-powered electrification can keep fuel costs circulating in local
economies.   Twenty-one states  have substantial coal  reserves.  Several others
have mineable through less significant reserves.  NSPS revisions could make all
U.S. coal available for use —that is, if  these revisions imply an  effective FGD
mandate. Not all reserves can be developed economically, but the potential is
there to have many states share in the spillover benefits of electrification.

In this regard, there may be further political/economic pressure to have reliance
on indigenous coal resources become a reality.  This pressure may affect utilities
which have planned to build nuclear plants.

COMPETITIVE CHARACTERISTICS OF COAL MARKET
The  market for  coal may be seen as having more competitive characteristics
than does the market  for uranium.  'NSPS revisions may further increase the
competitiveness  of this market.  It may also be said that the market for coal-
fired boilers has more competitive characteristics than does the  market for
     Reference to study conducted by J. Patterson and G.1 Combs, DOE, Division
     of Uranium Resources and Enrichment, Supply Evaluation Branch, in The
     Energy Daily, 5(210); 4, October 31,1977.                            	
                                   4-12

-------
' nuclear reactors.   Together these factors may help to keep  the busbar power
 cost of coal-fired units very competitive - with nuclear or other types of elec-
 trical generation.

 FLEXIBILITY OF COAL-FIRED UNITS
 If for some reason  coal cannot be burned in the quantities now foreseen, units
 designed for coal can in many cases with some, albeit expensive, modification be
 converted to burn other fuels. Nuclear units have no such flexibility.

 LESS EXPOSURE TO INFLATION
 Since coal-fired units are less capital-intensive than nuclear reactors and if coal-
 fired  units continue to maintain their  several-year advantage  in  terms of
 licensing and construction, these units will be less exposed to the possibility of
 labor  and material cost overruns due to  periods of high inflation  during con-
 struction.  Moreover, for the same reason and with the same supposition in mind,
 coal-fired units will have lower  interest costs during construction.

 THE NUCLEAR FUEL CYCLE IS FRAUGHT WITH PROBLEMS
 At  present, the alternatives  for acquiring uranium to fuel a reactor  appear to
 include:  (a) making a  sizeable  investment in a captive uranium mine  — with no
 control over the rest of the fuel cycle (such  investment in a captive  coal mine
 might be more cost-effective);  or (b) entering into a  fixed-price contract with a
 supplier or middleman who has no bargaining strength — with the risk that  the
 contract  may be abrogated  (as did Westinghouse) for reasons of "commercial
 impracticability;" or, (c) entering into a "market-price" contract wherein there is
 virtually no control over the price ultimately paid for the uranium.   None of
 these options appear particularly appealing.

 Just 12  months ago,  enrichment  costs were considered relatively  stable at
 $60/Separative Work Unit (SWU).*  Now, the GAO  has called for higher, "fair
 value", prices for enrichment services.  $88/SWU is set as a new interim price.
       A separative work unit is a measure of work required to separate uranium
       isotopes in the enrichment process.
                                    4-13

-------
This increase in price will mean a yearly increase in nuclear power cost from
about $4.7 million to about $6.9 million.  Over a 30-year period, this is an added
cost of approximately $66 million.   The future is uncertain - both in terms of
enrichment prices and in terms of national enrichment capacity.

Just 12 months ago,  waste management  was being estimated in busbar power
calculations  at  $!6/kg.  Now the federal government has proposed a $IOO/kg
price for this service, and the service is simply an interim solution. The proposed
price increase would raise the yearly waste management costs to a utility from
about $400,000  to $2,500,000.   Over a 30-year period,  this means an increase
from $12  million to  $75 million.  There may be technological solutions to
ultimate waste disposal, but there may not be an institutional/political solution
for some time to come. In the meantime,  other states or the federal government
may follow the lead of California and Sweden in stopping nuclear power until an
acceptable waste disposal  solution is found.

DECOMMISSIONING
One of the frequently overlooked and potentially expensive aspects of the nu-
clear power  alternative has to do  with  what it may cost  to decommission a
reactor. The ultimate cost will depend on  numerous factors, including the size of
the reactor, the period of time over which it was used, how many kilowatt-hours
it produced over its lifetime, and the manner in which it is considered safest to
segregate the reactor vessel  and the concrete  shield from  society.   Since a
reactor may  remain hazardous for one-and-a-half million years, great care will
go into this decision.

Perhaps the easiest thing  to do with a reactor  is simply to bury, or entomb, it.
But this may not be an acceptable solution in all cases. Surveillance of some kind
may be required for  centuries.  Another possible  solution is  to  dismantle the
reactor, but radioactive dust may  be dispersed in the process.  To date, of the
eight experimental reactors  which have been decommissioned (the largest,
                                    4-14

-------
61 Mw), only  one has been dismantled.   This reactor, Elk River (22 Mw), cost
$6 million to  build (completed in 1962) and $6.9 million to dismantle (dismantled
in  1970).*

CONSEQUENCES OF ONE MAJOR ACCIDENT
The consequences of a major nuclear accident — either here or anywhere else in
the world — can be  expected to be felt dramatically throughout the industry.
Just as the property and human damages which might result from a major acci-
dent are, for all practical purposes incalculable, so, too, are the enconomic and
financial impacts on utilities that have nuclear power plants.  A major act of
sabotage could have the same effect.  The fact that the Emergency Core Cooling
System has yet  to be demonstrated  to  operate in a fullscale test adds to  this
uncertainty.

PROSPECTS  FOR HAVING SUBSIDIES ELIMINATED
There is also  an  economic risk that one day the substantial subsidies now offered
to assist nuclear power will be lost, in part or as a whole. By far the greatest
subsidy is the protection offered under the Price-Anderson Act. The provisions
of the Act, which were recently extended until 1986 (at which  time they would
need to be renewed),  limit the  tort  liability of utilities to $125 million.  The
federal government promises to cover any additional damages up to $435 million.
After that, nothing — though presumably emergency aid in the form of low-cost
loans, etc., might be provided. Beyond $560 million, the utility is subsidized by
the populace at  large — including of course,  any firm which would choose to
locate in the  neighborhood of a nuclear power plant.

There are additional taxpayer subsidies offered to nuclear power:  a heavy em-
phasis  on nuclear in federal  R&D budgets; accelerated  depreciation both  for
plant (16 years,  versus 22.5 for coal) and fuel core (4 years); and fuel cycle
subsidies.
     "The Cost of Turning It Off," M. Resnikoff et al., Environment, 18(10); 26,
     December 1976.
                                   4-15

-------
Without special treatment for nuclear power it is doubtful that, in the near-term,
it could remain competitive with coal.  It cannot be assumed that this special
treatment will last.  Coal producing  states may one day clamor for making
nuclear meet the market test.

*A  SUMMARY, EMPHASIZING REGIONAL CONSIDERATIONS

This discussion of the relative economic  advantage, on a regional basis, of coal
and nuclear power,  as effected by NSPS revisions for coal-fired boilers, had two
parts.  First, we discussed the key factors affecting differences in busbar power
cost estimates for  coal and nuclear, on a regional basis, as performed in the
three existing evaluations of this  type. Second, a description was made of some
of the crucial difficult-to-quantify factors which may well convince decision-
makers to choose one technology over another irrespective of values produced as
a result of busbar power cost calculations.

It  was determined  from the  review of three studies of regional busbar power
costs for coal and  nuclear that differences  in results were due principally to
variation in assumed capacity factors, though also to variation in assumed coal
prices  and assumed  relative and absolute differences in capital costs for nuclear
and coal.  Based  on a rough calculation of the  incremental  costs due to NSPS
revisions, it was determined that in a few regions — notably the Mid-Atlantic and
South Atlantic regions —  the economic scales might tip slightly in favor of the
nuclear alternative should the coal  alternative  be  subject to a more stringent
new source standard.

However,  care should be taken not to  read an inordinate  amount  into these
results. This is necessary both because the incremental costs were calculated as
approximations and particularly because the  studies to which these costs  were
applied were not  well documented.   In sum, the purpose  of  the first part of the
analysis was primarily to provide  a quantitative frame of reference. In so doing,
                                   4-16

-------
it  became clear that nuclear  and coal power are quite competitive  in most

regions.  Finally, it should be noted that site-specific data were not analyzed. In

reality, of course, true economic evaluations are made solely on the basis of such
data.


In the second part of the analysis, factors which are not readily amenable to

quantification  were  described  as very  important to the  coal  versus  nuclear

decision-making process.  Many decisions to build one type of unit over another

may be strongly influenced by such things as public support for or disfavor with

subsidies  to  the nuclear industry,  by  a need  to diversify a  firm's generating

capacity, by siting restrictions, by political/economic pressure to utilize indig-

enous  coal resources, by  a  major nuclear accident, by the perceived competi-

tiveness of  coal  and uranium markets, by perceptions as  to  ultimate costs of
waste  disposal, enrichment, and decommissioning and by several other factors.


As for the combined effect  of  all these factors,  it is our judgment  that the ten

regions will — in general — be affected by NSPS revisions for coal-fired boilers in

the ways and for the reasons described below.
      New England
      Mid-Atlantic
      South-
      Atlantic

      East North
      Central
      East South
      Central
Relatively insensitive to revised NSPS; nuclear
is perceived  to  have  advantage; experience
with  nuclear;  diversification  possible,  but
other fuels competitive.

Relatively insensitive to revised NSPS in New
York and New Jersey; more so in Pennsylvania;
some  diversification  possible;  residual  fuel
available due to refinery capacity.

Relatively insensitive  to revised  NSPS; mixed
coal and nuclear.

Relatively insensitive to revised NSPS; some
utilities strongly nuclear may diversify; polit-
ical  pressure  to  use  indigenous  resources;
siting restrictions  may in  some  cases neces-
sitate nuclear.

Relatively insensitive  to revised  NSPS; mixed
nuclear and coal; some possible siting restric-
tions.

              4-17

-------
West North      Relatively insensitive to revised NSPS; politi-
Central         cal pressure to use indigenous resources; some
                diversification to nuclear.

West South      Relatively insensitive to revised NSPS; siting
Central         restrictions  possible;  some  diversification;
                residual  fuels available due to refinery capa-
                city.

North           Relatively insensitive to revised N..  S; heavy
Mountain       commitment to coal.

South           Relatively insensitive to revised NSPS; heavy
Mountain       commitment to coal;  possible siting  restric-
                tions.

Pacific         In Northwest, relatively  insensitive to revised
                NSPS; some nuclear, much hydro.

                In California, both coal  and nuclear  stymied;.
                "coal-by-wire" from mountain states; hydro
                and residual fuel oil.
                               4-18

-------
        APPENDIX A
CAPITAL FORMATION PROSPECTS

-------
             APPENDIX A: CAPITAL FORMATION PROSPECTS

A. THE ROLE OF CAPITAL MARKETS

INTRODUCTION

No industry  is  more capital-intensive than the electric utility industry.  To
illustrate, the ratios of net investment to annual revenues in the steel, chemical,
and automobile manufacturing industries are such that it takes about twelve, ten,
and  seven months, respectively,  to generate  sales  revenues  equal  to net
(depreciated)  assets.   By  comparison,  it takes  about  four years' worth of
electricity sales revenues to match the industry's net tangible investment.  The
electric  utility  industry's current level  of capital-intensiveness  suggests that,
under the best of circumstances, in order to fund new projects, it will require a
good  deal  more  capital funds than  it it likely  to  raise from  internal  sources
(depreciation allowances, retained earnings, and tax deferrals).  This causes the
industry  to seek funds in the capital markets.

The  industry's requirement  for external  funds  from 1978 to 1995 could  be  very
large — on the order of $200-300 billion (1977 dollars), depending on the amount
of total  capital need, earnings, dividend policies,  and many other factors.  It
cannot be assumed that the industry will be able to acquire funds sufficient to do
all it would like or may be asked to do.  Numerous factors, many of which are
discussed in this section, will affect the outcome.

The  purpose  of this Section is  to describe the capital  market environment  in
which the electric utility industry will find it necessary to fund a portion of one
of its major spending  programs — that of NSPS-related investment—through
1990.  To describe this environment first a brief sketch is presented of the
capital markets in which funds for ail purposes are acquired.  The important
aspects affecting  electric utilities' participation in raising external capital  over
the last 10 to 15 years are described next.
                                    A-1

-------
In the second Section, the discussion becomes prospective in nature. Factors are
discussed which will affect the industry's need and ability to raise capital.  Since
macroeconomic factors will affect the availability and cost of external capital,
some of these key economic variables are described first. The notion of "capital
shortage" will be discussed briefly.

The investment and financing policies of firms seeking external capital will be
important  determinants of relative access to the capital  markets; hence,  an
overview will be presented of some of the important firm-level policy decisions.
First, consideration will be given to the uncertainty which pervades the industry's
capital budgeting environment.

The policies of both state regulatory  authorities and  utility management may
have a strong  influence on the  industry's capital-raising prospects; hence, some
of  the key policy options available to regulators and management will be dis-
cussed briefly.

Further, since utility investment for air pollution abatement purposes will  be
made in  the context of the industry's possible investment requirements  for other
purposes, as well as the requirements of all other public and private entities and
parties,  a   discussion  will be  presented of the  types of projects which may
compete for investment funds.

Finally,  since  the electric utility  industry would appear to hope  that  a  major
proportion  of  pollution abatement  spending could be funded through issuance of
tax-exempt debt, particular attention is given to  the feasibility of this  approach
to investment  funding and to the impact that widespread use by investor-owned
utilities  of pollution control revenue bonds could have on the market  for tax-
exempt securities.
                                    A-2

-------
CAPITAL MARKETS  <

Capital markets are the network of institutions and mechanisms through which
intermediate-term funds (loans of up to ten years maturity) and long-term funds
(longer-term loans and corporate stocks) are  pooled  and made available to
businesses, governments and individuals.  Capital markets include both primary
markets, in which an issuer's securities are first sold to the public, and secondary
markets in  which outstanding securities  are transferred.  Examples  of capital
markets include the markets for government,  corporate, and municipal bonds,
corporate stocks, and mortgages.

A distinction is made  between capital markets and money markets.  The latter
are regarded as including financial assets that are short-term (obligations of a
year  or less to maturity) and possess low risk  and  a high degree of liquidity.
Examples of money markets include the markets for  short-term government
securities, bankers' acceptances, and commercial paper.

Although  focus of this  section is on the capital markets, the capital and money
markets should be considered interdependent.  Suppliers and users of funds may
use both  markets depending on investment policies  and on  the relative rates
available  in the different markets. Funds flow back and  forth between markets
as, for example, when  a bank  lends the  proceeds of a maturing mortgage to a
business firm for a short period of time.

Some  institutions serve both markets.  Commercial banks, for  example, make
both intermediate and short-term loans.   Moreover, yields, in the long- and short-
term  markets are interrelated.  A rise in short-term interest rates reflecting a
condition of credit stringency is likely to  be accompanied or followed by a rise in
long-term rates.

To complete this introductory overview of capital markets, it is useful to  dis-
tinguish the markets according to the instruments involved; that is, the instru-
ments that represent funds supplied to and obtained from  the capital markets are
                                     A-3

-------
either debt instruments, such as corporate bonds, or equity instruments, such as
corporate stocks.  This distinction will  prove convenient when we consider the
electric utilities' participation in the capital markets.

Long-term Corporate Debt Financing

Historically, corporate bonds have been issued for a variety of reasons. The most
important of these is to reduce the cost of financing and to increase the rate of
return on equity capital by applying the principle of leverage. The after-tax cost
of  long-term  debt can  be lower than  that of equity  capital because of its
preferred risk position and  the tax deductibility of interest payments.  Bond
financing also avoids possible dilution of  control.

On the other  hand, debt  financing has definite disadvantages.  The contractual
payments and restrictions on working capital and retained earnings contained in
the indenture  agreements inhibit corporate flexibility and diminish the appeal of
debt financing.  Also, because fixed  changes are involved, the debt financing can
have an adverse impact on earnings during an economic  downturn.

Corporate debt, either secured or unsecured,  can be offered  either publicly or
privately. Public issues are distributed through investment banking houses, which
form  syndicates of investment banks and underwrite the bond issues for resale to
institutions and individual investors.  The investment banker provides the issuers
with  advice  on  the terms,  timing, and prices of bond financing  and  with
continuing counsel after the issue is floated.  Correspondingly, the members of
the underwriting syndicate serve as broker-dealers  and provide  investors  with
information on the financial  condition of the issuers, the form and terms of the
financing, and general investment advice.

Investment banking   syndicates  acquire  new  corporate  bond  issues  by either
negotiated or  competitive bidding. Direct negotiation between issuer and under-
writer (acting alone  or as a manager of  a syndicate)  ends in a  purchase contract
whereby the  banker  acquires the issue  at a net price and yield determined by
                                     A-4

-------
bargaining.  Such underwriting is largely confined to offerings of industrial firms
and financial institutions.  Competitive bidding, in which the issuer invites sealed
bids, is ordinarily required by federal or state statute in the case of public utility
and railroad issues.  The cost of flotation of fully underwritten public  issues
consists of the bannker's gross spread or commission and the expenses involved in
preparation and negotiation, as required by the Securities  Act  of  1933.  The
banker's commission varies with size and quality of  the issues and the methods of
distribution, and ranges from 0.5 to 0.8 percent.

The price that a borrower pays for the use of borrowed funds is the interest rate.
When  the  borrower issues a particular debt  instrument,  he agrees to meet a
schedule of interest payments over the life of the instrument at a stated rate of
interest (sometimes called the "coupon" rate).  Normally, the stated rate is based
upon current market interest rates for similar debt issues and is  chosen so that
the market value of the issue will be very close,  if not identical, to the face
value  of the instrument.  For  example, if a firm  is planning to  sell some new
thirty  year bonds and  similar  ones are currently  selling to yield 8fe, then we
would  expect  that a stated interest rate of 8fe would result in the market paying
approximately $1000 for each $1000 face value bond.

Over  time, market  interest  rates fluctuate substantially.  Since  the stated
interest rates on outstanding debt instruments do not change, fluctuations in the
market rates  cause the prices at which the instruments trade  in the secondary
markets to adjust accordingly.  If the market rate for a given bond is higher than
the stated rate, the bond will sell at a discount; if  it is lower, the bond will sell
at a premium. The rate of return that an investor will earn if  he purchases the
bond at the market price and holds it to maturity is  called the yield.

There  is no single  market  interest rate.   Instead,  there is a range of  rates,
observable  at  any  time,  that encompasses such factors as the supply of funds
available, the expected rate of inflation and the risk of default  by the borrower.
Issues  of the  U.S. government are normally considered  free of default risk and
thus their  yields are used as a proxy for the market's riskless  rate of interest.
                                     A-5

-------
This rate captures the market's time value of money, i.e., the rate at which the
market is willing to forego consumption today for future consumption, and the
anticipated  rate of inflation, which adjusts for the loss of purchasing power of
the dollars received in the future over the dollars invested now.

For  issuers  other  than the U.S.  government there is the possibility of default.
Hence, the market interest rate for these issuers is equal to the riskless rate for
an  instrument  of  the  same maturity  (since the effect of inflation varies with
maturity) plus a risk  premium,  which  increases  as the possibility of default
increases.   The way that the market determines  the possibility of default and
hence  the size of a  risk  premium  is  not  fully  understood.   However,  one
important ingredient of the market's decision process is the ratings assigned the
bond by the two  ratings agencies, Standard  and Poor's and Moody's  Investor
Service. These agencies  evaluate the quality of bonds and state their opinion in
letter  grade form. A brief discussion of the factors considered impoortant by
these bond raters is presentedlater in this section.

While  the  magnitudes  of the interest rate differentials between  the various
rating categories fluctuate over time, they are typically small relative to the
fluctuations of the entire interest rate structure.  And it is this  latter pattern of
movements  which is  considered  to  be one of  the most  significant  aspects of
interest  rates — their  role as an index of the availability of funds.  In  theory, a
firm, no matter how risky, should always be able to borrows funds at some price.
But in  practice there are many legal and institutional constraints and conventions
that place limits on how high interest rates may go. As a result, a period of high
interest  rates usually  reflects tight money, even  though the high rates may be
primarily attributable to high levels of anticipated  inflation. For small firms and
for high  risk large firms,  periods of rising interest rates may indicate increasing
difficulty in obtaining new debt financing.
                                     A-6

-------
Corporate Stock Financing

Corporate stocks  in the form of transferrable certificates represent the equity
interest in the company. There are two types of corporate stocks, preferred and
common.   Stocks  having a  preferred status rank ahead of common stock as the
claim on  assets and in the  receipt of dividends.  The common  stock represents
the residual equity in  the corporation and participates in net assets in liquidation
and  in dividends after all claims of creditors and of any preferred stockholders
have been met.

New corporate  stocks are  sold  to investors both directly by the issuer  and in-
directly through investment bankers and dealers.  The chief means of direct sale
of common  stocks is through the issuance of rights to existing stockholders
entitling  them to buy new  shares (including covertible bonds and  preferreds)  in
proportion to existing holdings.  Sale of  securities to employees  in connection
with savings, stock purchase,  and stock options incentives is  also  considered
direct. Some stock issues are directly placed with institutional buyers; these are
chiefly higher grade preferred stocks of public utility companies.

The majority of new  common stock issues  of public utilities is underwritten by
syndicates of investment banks, who negotiate the transaction directly with the
issuer and purchase the entire offering  at a price  net  of  discounts  and com-
missions. They then sell the new shares to the public at the offering price which
usually is very  close  to the most recent  price at which the issuers shares were
traded in its secondary market (such as the New York Stock Exchange).  Thus,
the  value which an issuer receives when selling new shares of stock is dictated by
the  current market price of its outstanding shares.  The balance sheet or book
value  of  the firm's shares  plays no role  in determining the price at which new
shares are to be offered (unless it is the first public offering of the firm).
                                     A-7

-------
Composition of Sources off Funds

It is instructive to note that as business spending has been rising over the period
1960-1974,  two significant  changes in the composition of funds  sources  has
occurred. First, internal sources of funds have declined relative  to total need for
funds.  Second, the use of common and preferred stocks  has declined relative to
the use of debt instruments.  These trends can be observed in Table I.

These trends signify  that U.S. firms  chose to grow  in the Sixties and early
Seventies by applying debt leverage.  Of course, while the use of debt leverage
has its benefits, it too has its costs.  It tends to destabilize earnings since firms
with fixed debt funding become more sensitive to cyclical swings in the economy.
As equity investors perceive this change, they tend to require higher prospective
returns to  compensate  them  for  added risk-taking.  As firms become more
leveraged,  incremental debt  generally carries higher interest rates.  As the cost
of financing grows, so grow the costs of production. With some lag, selling prices
rise,  too.  Inflation may result, and this would  further boost returns sought by
investors.

Apparently, what  has happened of  late is that  firms  have continued to invest
without earning their costs of capital. Investors again bid up the required return;
consequently, share prices fell.  Since some individual  investors left the market
entirely, seeking greater opportunities  in real  estate and other investments, the
                                                              P
new  equities market narrowed.  Consequently, the significance of institutional
trading increased.

Institutional Sources of Long-term Capital

It has been estimated that individuals hold about 70 percent of outstanding equity
securities,  20 percent of corporate bonds outstanding, 30 percent of municipal
debt,  and about 25 percent  of  outstanding  federal debt (these figures include
holdings of individuals as beneficiaries of trusts managed  by trust departments of
banks).   Despite their large holding of equities (mostly common stocks) indi-
                                    A-8

-------
                                                   Table I

                                               Sources of Funds

                               Domestic Non-Financial Business Corporations
                                                  1960-1975

                                              (billions of dollars)

Total Financing Need
Funds Internally Generated
(as percentage of Total)
Adjusted Retained Profits
(as percentage of Internal)
Capital Consumption
Allowances (Depreciation)
(as percentage of Internal)
External Funds Raised
(as percentage of Total)
Bank Loans and Other
Short-Term Debt
(as percentage of External)
Long-Term Funds
(as percentage of External)
Equity
(as percentage of Long Term)
Long-Term Debt
(as percentage of Long Term)
Mortgage Bonds
(As percentage of Long Term Debt)
Debentures
(as percentage of Long Term Debt)
I960
$44.1
34.4
78
10.1
29
24.2
71
9.7
22
2.1
22
7.5
78
1.5
20
6.0
80
2.5
42
3.5
58
1961
$49.2
35.6
72
10.1
28
25.4
72
13.7
28
2.8
20
10.8
80
2.2
20
8.6
80
4.0
47
4.6
53
Source: Flow of Funds Statistics, Board of Governors of
1962 1963
$55.2 $57.6
41.8 43.9
76 76
12.7 13.1
30 30
29.2 30.8
70 70
13.4 13.7
24 24
3.9 5.5
29 40
9.5 8.2
71 60
0.4 (0.6)
4 (7)
9.1 8.8
96 107
4.5 4.9
49 56
4.6 3.9
51 44
1964 1965
$67.2 $79.2
50.5 56.6
75 71
17.7 21.2
35 37
32.8 35.2
65 63
15.0 22.6
25 29
6.1 13.4
41 59
8.9 9.2
59 41
1.3 (O.I)
15 (1)
7.6 9.3
85 101
3.6 3.9
47 42
4.0 5.4
53 58
1966
$86.7
61.2
71
23.0
38
38.2
62
25.6
29
10. 1
39
15.5
61
I.I
7
14.4
93
4.2
29
10.2
71
1967
$86.5
61.5
71
20.0
33
41.5
67
24.9
29
3.5
14
21.4
86
2.2
10
19.2
90
4.5
23
14.7
77
1968
$96.1
61.7
64
16.6
27
45.1
73
34.4
36
16.1
47
18.4
53
(0.2)
(1)
18.6
101
5.7
31
12.9
69
1969
$96.3
60.7
63
10.9
18
49.8
82
35.6
37
15.5
44
20.0
56
3.4
17
16.6
83
4.6
28
12.0
72
1970
$95.3
59.4
62
5.8
10
53.6
90
35.8
38
5.2
15
30.4
85
5.7
19
24.7
81
5.2
21
19.5
79
1971
$ 1 16.8
68.0
58
10.3
15
57.7
85
48.8
42
7.0
14
41.5
86
11.4
27
30.1
73
11.3
38
18.8
62
1972
$ 133.9
78.7
59
15.7
20
63.0
80
55.2
41
15.9
29
39.2
71
10.9
28
28.3
72
15.6
55
12.2
45
1973
$ 154.1
84.6
55
17.1
20
67.5
80
69.5
45
34.9
50
34.5
50
7.4
21
27.1
79
16.1
59
9.2
41
1974
$ 163.1
81.5
53
9.0
II
72.5
89
81.5
47
45.3
56
36.3
44
4.1
II
32.2
89
10.9
34
2|,3
66
1975
$ 137.3
90.3
66
11.3
13
79.0
87
47.0
34
(12.8)
(27)
59.8
127
10.0
17
49.8
83
23.6
47
26.2
53
the Federal Reserve System
Note: Parentheses indicate net negative flows.

-------
viduals directly engage in trading only about 30 percent of equities, commercial
banks trade about 40 percent (including trading for noninsured pension fund and
for trust  fund  accounts), and other institutional investors — principally mutual
funds, life insurance, and property and casualty insurance companies - trade the
remainder.

Since institutional investors engage in about 70 percent of equity trading -versus
about 30 percent in  I960 — the character of their trading habits has become of
concern.  It has been alleged that the institutions show active interest in  no more
than about 200 to 300 stocks and that they,  in fact,  limit trading mostly to the
so-called  Favorite Fifty.  Not many electric utilities are among these  stocks  .
(Institutional  investors,  as  evidenced by their current holdings,  show great
interest  in  Texas Utilities,  three Florida utilities, and  PSC of  Indiana; some
interest  in some firms  located in  Illinois,  California, Ohio, Wisconsin,  and
Montana;  virtually no interest in forms located  in New York, Pennsylvania, and
Massachusetts; and particularly low regard for the common equity of firms such
as Con Ed, Boston Ed, Detroit Ed, Iowa PS, and Portland G&E).

The lack of institutional  interest in most electric utilities — and indeed  in about
90 percent of all stocks publicly traded — tends to make these stocks illiquid, and
{(liquidity tends to negatively affect  share  prices.   Further, since the  value of
shares traded in the secondary market has  great influence on the price of new
issues, a lack of institutional activity in  a  particular stock can add a cost and
serve as a constraint to the issuance of new utility equity.

Stocks that institutions do actively trade  may also be made more risky  by their
trading (hence, the required return is bid up;  if by no other means, by bidding the
share price down). This may well be true due to the so-called "air-pocket effect"
—  if one firm  sells  a large block of shares, other  institutions may follow suit.
This tends to create significant  swings in  stock  prices.  Individual investors who
are not privy to the  same information that  institutional investors are and those
individuals who do not watch closely their  investments may be adversely  affected
by institutional transactions.
                                    A-IO

-------
In summary, there may be significant  benefits to institutional activity in the
stock market,  but without restrictions on institutional trading,  new  electric
utility stock issues may not enjoy a marketplace characterized by breadth, depth,
and  resiliency.   Ultimately,  this  affects  the financial  options  available to
investor-owned electric utilities.

The  market for debt securities is largely institutional in nature. Therefore, the
policies of and restrictions placed  upon financial institutions  are  important in
determining where funds go and at what interest rates.  There are essentially
four markets for debt securities:  the mortgage market, the federal market, the
municipal market, and the corporate bond market.  The interest here centers on
the  municipal  and corporate  bond  markets,  but  it  should  be noted  that the
mortgage and  federal government  securities  market  can, at  times, offer very
serious  competition for funds.  Under normal circumstances, most institutional
investors hold some proportion of their portfolios in debt securities of all types.

The  Municipal Market

The  major  participants in  the municipal market are  as  follows:   commercial
banks,  with about  45 percent of  outstanding securities; individual  investors,
including those entrusting  their accounts to banks, with about 30 percent; and
property  and  casualty  insurance   companies, with  about 20 percent.    The
remaining  5 percent  is shared  by  life insurance companies, state  and  local
retirement  funds, mutual savings banks, and business corporations.  Lately the
largest  growth in municipal participation has  been evidenced  by the household
(individual)  sector.

The  municipal  bond's distinguishing  feature is its tax-exempt status. The market
for municipals is thus principally composed of those seeking this status for  their
own  tax purposes; that is, investors with high marginal tax rates.  The market's
major attraction  is also  a  cause for concern  for those seeking funds,  because
when the earnings of its three large participants dip,  they  lose interest in the
market. In  fact, though they  hold  about 95 percent  of outstanding municipals,
                                    A-ll

-------
municipals represent only about 6 percent of the total combined financial assets
of commercial banks, property and casualty insurance companies and individuals.
Hence, a one percent shift in their combined assets away from  municipals could
have major repercussions in  the  municipal  market.  Later in this  section, the
municipal market will be reconsidered in light of the expanding use of pollution
control  revenue bonds,  which now account for  about  10 percent of all  newly
issued tax-exempts.

The Corporate Bond Market

The  major participants in the  corporate bond market  are life  insurance com-
panies  and private and government pension funds.  Other participants include
mutual savings banks, property and casualty insurance companies, mutual funds,
commercial banks, and foreign investors.

Since most 'corporate  bonds are  purchased  by institutional  investors, their
secondary  market is rather  thin.  The institutions that  buy these bonds  are
generally satisfied to hold them to maturity. However, in the event of a liquidity
problem  faced by a  particular  holder  of corporate  bonds,  these bonds  can
generally be sold rather quickly -  as evidenced  by  the narrow bid-and-ask
spreads  these bonds now enjoy.  (Bid-and-ask spreads are stated as a percentage
of a bond's face  value,  and  refer to the difference between what  a potential
buyer is willing to pay and what a potential seller is willing  to sell a bond for.)
                                   A-12

-------
ELECTRIC UTILITY PARTICIPATION IN THE CAPITAL MARKETS

Trends and events occuring over the last decade have significantly affected the
setting in which the industry operates, the industry's financial condition, and the
manner and extent  to which the industry participates in the capital markets. Of
course,  the extraordinary events of  1974-1975 had a particularly adverse effect
on the industry. But trends beginning earlier, that is, in the late Sixties, had the
effect of making the industry very vulnerable to the Oil Embargo, high inflation,
pronounced  regulatory lag, and other occurrences which shook the industry and
its investors in 1974-75.

Key Factors Affecting Financial Position

Demand

Over the past ten  years, the industry's annual growth  rate in peak demand has
exceeded the annual growth rate in average system demand on six occasions,
sometimes by as much as 2 or 3 percentage points. Over the last decade, in only
one  year,  1967, did the growth in peak  demand fall significantly below  the
average demand growth rate.   The variability  in the peak growth rate was
substantial over the 1966-1975 period.  The  peak growth rate, more than any
other factor at present, signals the likely need for expansion of plant capacity.
With such great year-to-year variability in the peak, the accuracy of predicting
future capacity needs tends  to be low.  Still, the rate  of peak growth, whether
considered over the 1966-1973 period (8 percent) or over  the'1966-1975 period
(6.7  percent), seemed to indicate  the need  for  large capital  expenditures to
accommodate anticipated future demand.

The  financial implications of the foregoing discussion are:  (I) great uncertainty
had  crept into the  industry's capital budgeting process; (2) peak demand growth
(at  least for  the  years 1966-1973) suggested that a substantially  increased
amount  of   capital would  be required   to  construct additional  capacity —
irrespective of  added-expenditures implied by environmental guidelines; and (3)
                                    A-13

-------
since peak demand was rising a good deal faster than yearly average demand,
operating efficiency would suffer.

Load Factor

Capacity utilization, as measured by  load factor, did suffer.   Over the last
fifteen years, load factor has fallen from about 65 percent to its current level of
61 percent.

When peak demand  rises faster than average system  demand,  the load  factor
deteriorates, and a greater portion of the industry's plant is idle or underutilized.
Since three-quarters or more of the industry's costs are either actual fixed costs
or essentially fixed, declining load factor signifies — other things being equal —
an increase in cost per unit sales.

Increasing  Costs of Production

Fixed overhead did not remain stable during this period. Indeed, it rose drama-
tically.  Historically, the electric  utility industry had  been faced with the fact
that the incremental cost of electrical  production —  that is, the cost of pro-
ducing an  additional kilowatt-hour — was less  than the average cost of each
kilowatt-hour then being produced. This  meant that the more the industry built,
the  cheaper  would  be the rates everyone paid.  In the late 1960s, however, the
factors that made the industry increasingly cost efficient ended.

One reason for the demise of the  economies associated with the building of
larger conventional plants was that the industry was unable to continue lowering
its heat rate, the number of BTUs from fuel required to generate each kilowatt-
hour of electricity.  At the same time,  the major components of construction
costs — equipment, materials, labor,  and money — were increasing rapidly. The
increase  in the cost of  constructing new facilities is a  major factor contributing
to the change in the industry's financial setting.
                                    A-14

-------
Cost of Copital Funds

Over  the last decade, the cost of capital funds has risen steeply. This rise may
be attributed chiefly to a greater use of debt  financing and to the  high rate of
inflation and to inflationary expectations over  the decade.  As shown in Table 2,
the yields on high-quality utility debt and equities essentially doubled over the
period 1966-1976.

Costs of Environmental Controls

During the past decade, environmental  protection  has become an  important
aspect of electric utility planning and operations.  Three major federal environ-
mental laws were enacted, and had  significant  impact on the industry. First, the
National Environmental Policy Act, enacted in  1969,  affected utility plant siting
and land uses. Second, the Federal  Water PoHution Control Act, and subsequent
amendments, affected the industry's  practices with respect to the  discharge of
effluents and waste water  in both existing  and planned facilities.  Third, the
Clean Air  Act of  1970, and the subsequent  amendments  to  it, affected the
industry's practices with respect to the discharge of air  pollutants,  in particular
sulfur dioxide, nitrogen oxide,  and  total suspended particulates.  In addition to
federal regulations, state and local agencies proposed environmental regulations.
The net effect of  all these new  laws  and  relationships was to increase both
capital and operating costs.

Fuel Costs

Fuel costs began to be a problem to the industry in the late 1960s. The closing of
the Suez Canal  in 1967 affected oil tanker rates.  Coal  prices began to rise, due
in part to coal  industry  investments  in  health and safety improvements and in
part to  the fact that  the electric industry, in general, was neither vertically
integrated back to the mine nor made extensive use  of  the long-term  contract.
Natural gas prices, too, began to rise as  the Federal Power Commission began to
lift the ceiling on these prices.
                                     A-15

-------
                                  Table 2

                Average Yields on Top-Grade Utility Bonds and
                   High Quality Utility Stocks, 1966-1976
                  BONDS     PREFERRED STOCK  Divi-    COMMON STO^CK
End of Month   Overall Avg.      High Quality        dend     High Quality
   of March        Yield            Yield           Yield    Earnings/Price Ratio
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
1966
9.36%
9.74
8.53
7.67
7.81
8.03
8.37
7.37
6.39
5.37
5.23
8.96%
9.31
8.06
7.39
6.99
6.91
7.26
6.39
6.04
5.15
4.69
9.00%
10.34
8.35
6.42
5.96
5.55
5.62
4.75
4.85
3.89
3.79
13.51%
15.63
11.63
9.34
8.55
7.51
7.71
6.54
7.01
5.83
5.44
Source: Moody's Investors Service

    The overall average refers to the average of 40 utility bonds, 10 in each of
Moody's four top-grade ratings, Aaa, Aa, A, Baa.


    This is the highest quality preferred rated by Moody's.

{+
    This is the highest quality common rated by Moody's.

Note;  In  the  past few years, the ratings given the issues of electric  utilities
       generally been lower than those  given other utilities, so the percentages
       above may understate that cost of money to the electric utilities.

                                      A-16

-------
Of course, the largest fuel price increases occurred during the oil embargo, a
time at which the industry was more heavily dependent on  petroleum than ever
before.  This dependence resulted from the fact  that many utilities had just
completed the conversion to oil-burning of coal-fired plants in an effort to meet
sulfur  dioxide  emission standards.   In 1974, when the price of oil  increased
137 percent  and the price of  coal increased  58 percent,  the industry was
dependent on petroleum for 16.9 percent of its fuel for electrical generation and
on coal for 45.5 percent.

Regulatory Setting

As the industry's costs rose, it found it necessary to spend an increasingly large
amount of time preparing materials for and testifying before regulatory com-
missions in an attempt to recover costs through rate increases. As the first wave
of rate-increase  applications appeared, regulatory commissions, had  difficulty
processing the large  number  of applications.   More  applications were  forth-
coming,  however, and as the effects of the first round of  rate  increases were
beginning to be felt —  and, in many cases, resisted by consumers — the com-
missions were compelled to take ever greater pains to scrutinize the arguments
for rate increases.  This scrutiny required a great deal of time.

The major impact of regulatory  lag on the industry's financial situation involved
the fact that by the time the final  order was issued to allow the applicant to
boost  his rates, inflation had so eaten  into the  sum originally requested  — this
this sum being calculated based on costs prevailing at the time of application —
that the rate increases finally granted were insufficient to cover inflated costs.
This impact  was sometimes mitigated by a commission's granting of an interim
rate increase while  deliberations proceeded on the  application itself.  However,
for over  three-quarters of the cases decided during the period 1971-1973, no
interim increases were granted.

Another  way to soften  the financial blow  delivered by a combination of regu-
latory lag and inflation  is to permit  so-called "forward looking test years" to be
used  to  calculate the amount of costs needed  to  be recovered through rate

                                    A-17

-------
increases.  This method of calculation permits applicants to predict cost trends.
Perhaps fearing that applicants might erroneously  inflate costs, throughout the
late 1960s and early  1970s, the regulatory authorities typically did not permit
such a practice.

In the early 1970s, one of the few concessions the industry was generally able to
win  from regulatory  commissions was the  authority  to pass  certain  "uncon-
trollable costs on to the  consumer without having to go through formal rate
proceedings.  By mid-1974, 43 states and the District of Columbia permitted fuel
cost adjustment/pass-through clauses.  On the nationwide basis, 75 percent of
investor-owned utilities were permitted some form of fuel adjustment  clause,
though in some cases, the adjustments were restricted  to  industrial and com-
mercial customers.  A few regulatory commissions permitted  utilities to pass
through taxes and the cost of power purchased from  other utilities, but as a
general rule, such adjustments were not permitted.

Pass-through clauses undoubtedly  helped utilities to recover costs more quickly.
Still, when fuel costs were soaring, for example, during the winter of 1973-1974,
even the  normal lag between billing and collection added to the strain  on a
utility's working capital.

While the pass-through clauses  gave the industry's financial condition a moderate
boost, the need for rate increases to recover costs generally unrelated  to fuel
outlays  was  growing  rapidly.   The dollar amounts of rate increases  granted
annually over the period  1970-1975 grew from about $500 million in 1970 to more
than $3 billion in 1975.  However, far more significant  to the financial condition
of the industry was the fact that dollar  amounts requested for rate increase
approval grew from about $700 million at the end of 1970 to more than $4 billion
at the end of 1975.

Since a sizable number of requests for rate relief were  not acted upon imme-
diately, it became evident  that the costs the industry had incurred would have to
be carried, at least for a  time, by some other means. Fixed  charges, such as
                                   A-18

-------
interest payable on debt, could not be reduced, lest foreclosure proceedings be
commenced.  The major source  of funds would have  to be cash  flow from
operations.

Clearly what had happened was that the regulatory delays that had worked to the
industry's and its  investors' advantage in the ealy 1960s were now working to
their great  disadvantage.   Whereas, in the early  1960s  the industry's members
were generally able to earn more than the rate of return allowed by regulatory
commissions, in the early 1970s, they were generally earning less.

It is misleading to attribute all of the decline in the earnings rate of the electric
utility industry to regulatory lag.   Regulatory lag does  not explain why  the
amounts requested and  the amounts  still pending at the end of the year were
progressively so much higher  year to  year.  Allusion has been made to some of
the factors that contributed to this situation — load-factor deterioration, higher
construction  costs,  environmental  costs,  and  higher   fuel  costs.    Other
contributing factors,  including a  higher level of construction activity,  greater
external financing, a higher  level  of debt financing, and the use  of  certain
accounting practices will be discussed in ensuing paragraphs. The combination of
these factors has had extremely adverse impacts on earnings.

External Financing

As the industry found it could not prevent a lower rate of return (on shares  and
rate base ), a number of factors came into play. The first impact of a declining
rate of return in the face of  a greater need for funds was that the industry was
forced to become more dependent on capital markets, i.e., on external financing.
A review of  Table  I shows  this quite clearly - as earnings  contributed as
decreasing  share  to capital  expenditures,  external   financing  assumed  an
increasing share.  As external financing of the electric utility industry increased,
it came to  represent an ever-growing proportion of all long term capital funds
available for U.S. industry.  Table 3 shows that electric utility industry financing
of late has taken an extremely prominent position in the new issues market.
                                    A-19

-------
                                 Table 3

 Electric Utility Industry Incremental Long-Term Financing as Percent of Total
                     For all U.S. Industries,  1965-1976                ~~~~
Year              Long-Term Debt    Preferred Stock     Common Stock

1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
10%
15%
12%
18%
20%
20%
17%
15%
23%
27%
18%
16%
29%
44%
51%
72%
56%
83%
50%
75%
55%
77%
46%
57%
7%
8%
9%
8%
10%
19%
22%
24%
33%
51%
51%
46%
                                  A-20

-------
The declining rate of return also meant utility stocks were less attractive. While
a portion of  that which is returned to stockholders, the dividends,  remained
attractive, and in many cases become more attractive as dividend payouts were
moderately increased, the other portion of the return, the capital appreciation,
was falling rapidly.   In the face of the overall decline in return to stockholders,
investors were requiring a higher rate of return.  The reasons for this fact were
that general  inflation made higher nominal (i.e., not inflation-adjusted) returns a
necessity,  and higher bond yields were pushing  the required  yield on common
equity, the riskier the instrument, still higher. Since the industry was unable to
fulfill  the expectations of  common  shareholders,  the price/earnings ratio,  a
measure used in the valuation of common stocks, had to fall.  Table 4 shows the
decline in the price/earnings ratio, the multiplier the market applies to current
earnings in order to arrive at a market value, over the period  1965-1976.

The  third impact of the reduced rate of return was  that the  industry's ability to
carry heavy interest burdens was being reduced.  Over the period  1965-1974, the
industry's annual amounts of debt  issued increased more than sixfold.  Over the
same  period, bond yields doubled.   The combination  of  these  factors  caused
interest charges to grow from less than $1  billion in 1965 to $4.6 billion in  1974.
Over the same period, the amount of income available to service this debt grew
by only  83 percent.  As a  result of  these trends, the  annual  interest  coverage
ratio,  the ratio of net income (before payment of taxes and interest) to interest
fell precipitously.

Interest coverage ratios are heavily  relied upon  by financial rating  agencies in
evaluating the  quality  of a  utility's bonds.   As these coverage ratios  have
declined in the last  five years in particular,  the ratings of  the bonds of many
utilities have been downgraded by the rating agencies. When a utility's bonds are
downgraded, these bonds trade at a  discount, i.e. the cost of new debt to the
utility  rises.   Another, and  perhaps more important, effect of declining and
relatively low coverage ratios emerges from the fact that the indentures of
existing issues of utility bonds have provisions which will not permit a  utility to
issue  additional  bonds when  the  coverage ratio falls below a  certain level,
generally 1.75 to 2.0 times.
                                     A-21

-------
                                  Table 4

            Price/Earnings Ratios of the Electric Utility Industry.
                                 1965-1976
Year    P/E Ratio       Year    P/E Ratio      Year    P/E Ratio

1965
1966
1967
1968
19.8
16.3
15.3
14.8
1969
1970
1971
1972
13.7
11.5
11.8
10.4
1973
1974
1975
1976
9.4
6.3
6.4
7.4
                                  A-22

-------
With both the common stock and debt securities routes to financing fraught with
problems, the industry came to rely on preferred stock far more than it had when
the  industry's finances were on  better ground.   Preferred stock was  once
regarded as the most expensive form of financing —  in terms of cash payout —
because  dividends  are not tax deductible to the issuing firm.  However, new
issues  of preferred stock offer tax advantages to  investing corporations (85
percent deductibility for dividends received) and this  fact allows the issues to be
sold at yields within a percentage point of those of common stocks.

Since preferred yields are relatively  high and the amount of  preferred stock
issued between 1965 and 1974 rose by a  factor of 10, and further, the income
available for preferred dividends increased a mere 26 percent over these years,
the industry's preferred dividend coverage ratio fell rapidly.

Preferred  stocks  are also rated  by  the rating agencies.   Declining and  low
coverage ratios for  these  stocks  lead to lower  ratings,  and low  ratings mean
higher yields will  be required in the future.  Moreover, as preferred stocks may
also have indenture agreements which prohibit new issues when coverage ratios
fall below a  certain level (generally a level somewhat higher than that applicable
to debt) the  ability of utilities to issue more preferred stock without first raising
the rate of earnings has been limited. ,

Internal Sources of Funds

Given the  increased expense and difficulty involved in raising funds externally, it
remains  to be reviewed why the industry was generating a declining proportion of
its investment funds internally.

The  key factor in  this decline involves the fact that the amount of funds a given
utility can generate is relatively fixed in proportion  to, its existing plant.  Both
the rate of return allowed and the depreciation funds  allowed are generally fixed
in proportion to the investments in plant that the utility has made. It has been
estimated that the amount of funds the ordinary utility can generate internally is
approximately 4 to 5 percent of its net plant. By contrast, the industry's capital

                                    A-23

-------
expenditures relative to initial assets rose from 7.5 percent to 13.5 percent over
the period  1965-1973.   Thus, even if the industry had earned all  that it was
allowed to earn  under  regulatory  limitations, the  proportion of its investment
funds generated internally would still have declined substantially.

Another reason  for  the  decline  in importance of internally generated  funds
involved the  use of the flow-through accounting  by regulatory commissions
having jurisdiction over  40  percent of the industry's assets.  This method  of
accounting caused firms to report higher earnings, due to the use of accelerated
depreciation for  determining their tax payments, than they would have reported
had they been allowed  to use an alternative accounting method, normalization,
wherein tax differences are  normalized by showing a deferred tax credit.  When
earnings appear  high, it  is,  of course, more difficult for utilities  to  convince
regulators  that higher  rates  of return are necessary.  The effect of the  flow-
through accounting practice  was to  maintain,  if  not increase, the  utilities'
dependence on external financing.

Though earnings  for the industry grew at an average  annual  rate  of  about  11
percent over  the last decade, the quality of these  earnings deteriorated  badly
over the period.  One measure of the quality of earnings is obtained by relating
reported net  income to cash income.   That which does not contribute to cash
income is created by accounting entries and, thus, is in a very real sense "paper
profit", i.e., a reporting  of future cash income in the current year. In 1965,; 9
percent of  the industry's earnings were noncash credits.  By 1974, noncash credits
to income  were fully one-half of  net  income.  When so  little of that which the
industry reports as earnings is actual cash which can be distributed (for  example,
as dividends), rating agencies and  investors tend to view  the industry as a higher
risk enterprise.

The  major factor contributing to the deterioration   in the quality of the
industry's  earnings  is an  accounting  practice  used  by the great  majority  of
commissions which regulate  the  industry.   The  practice entails  prohibiting
utilities from including the  carrying  charges of  construction  work  in progress
                                    A-24

-------
(CWIP)  in the  base amount- upon  which  rates  are calculated.   Instead  of
permitting utilities to pass on the carrying cost of CWIP to current rate-payers,
regulators required utilities  to  credit an allowance for the use of funds during
construction (AFDC) to  income for each year in which the facility is still being
built.  The offsetting debit entry is to CWIP. The AFDC account includes bo'.h
interest paid on construction debt and an allowance for the return on the equity
portion of funds invested in the plant under construction.  Only when the facility
comes on-line, i.e., starts producing electricity, are rates permitted to be raised
to cover the amortization of accumulated  interest and equity return, as well as
the actual plant costs.

It has been estimated that AFDC charges amount to 20 to 25 percent of the costs
of plant.   Since plant costs have risen a  great deal  in the last  decade, these
charges, which are in effect a reporting of future earnings in the current year,
have become a major item in that which is reported as income.  Over the period
 1966-1974, the AFDC proportion of earnings rose from 5 percent to 31  percent.
By 1974,  AFDC had risen to such an extent that aggregate reported earnings less
AFDC and dividends was negative.

Since cash earnings had become negative, the only positive sources of internal
funds  in  1974 were  deferred income taxes, 19 percent, and amortization and
depreciation,  81 percent.  The former source of funds has grown far more signi-
ficant of  late. It may be considered, either as a noninterest bearing federal loan,
one  that, in effect, never has to be  paid back so long as utilities' investment in
depreciable assets does not decline, or as a contribution to  capital  by the federal
taxpayers.

Another problem related to earnings reported over the last decade stems from
the  percentage of  plant which is allowed  to be depreciated annually for rate-
making purposes.   For tax purposes, the industry's assets are given relatively
short depreciable lives -  for example,  four years for the nuclear fuel core,  16
years for nuclear plants, 22.5 years for nonnuclear plants —  which allows  for
accelerated depreciation.  However,  for rate-making purposes, the asset lives of
the industry's plant are more in line with their useful lives, 30 to 40 years.

                                    A-25

-------
The  problem  with  these relatively  long depreciable  lives for  rate-making
purposes is that no more than about three percent of  plant can  be expensed
annually to meet the cost of plant replacement.  When the cost of new plant is
far greater than it was  for existing plant, such a low percentage added to the
accumulated depreciation account each year proves inadequate to cover the cost
of new  plant.   Again, if internal funds are insufficient, dependence on external
funds is increased.

Market Participation by Public and Cooperative Utilities

Thus  far,  the consideration  of financial condition and problems faced  by the
electric  utility industry  in recent years has focused, for the most part, on the
investor-owned  sector of the industry.   All  but 21   percent  of the installed
capacity and 28 percent of  total customers  served fall  in  the investor-owned
sector, and these shares  have remained relatively unchanged for the last decade.
The fact that these shares have not changed appreciably suggests that publicly-
and cooperatively-owned segments of the industry have faced many, if not most,
of the problems experienced of late by the investor-owned segment.

Indeed,  the publicly and  cooperatively-owned utilities, too, were affected by the
vagaries of demand, the  deterioration  of load factor, the  lack of improvement in
heat rate,  the increasing costs of construction and environmental protection, and
the increasing  cost of fuel and money.  The only problems they escaped were
ones having to do with state regulatory commissions and distressed stock holders.

The publicly-owned  and  cooperatively-owned electric utilities can be subdivided
into municipals, federal  projects, and cooperatives according to the responsible
governmental unit or agency. A discussion follows for  each  type  of utility as to
its participation in the capital market to meet its capital requirements.

Municipal Electric Utilities

The municipal utilities' percentage of electrical  energy generation has remained
relatively constant since 1962. In 1976 the municipals  produced about 9 percent

                                    A-26

-------
of the net electrical output, evenly divided between utilities owned by munici-
palities and utilities owned by state projects and power districts.

Municipal utilities participate in the capital markets by issuing bonds which enjoy
interest  exemption from federal  income taxation.   These bonds may be either
revenue  bonds,  which  are  secured  by  the revenues of  the  issuing utility,  or
general obligation bonds, which are  guaranteed by the general taxing power of
the  issuing governmental  unit.  Generally,  municipal utilities  find  it  more
expedient to issue revenue bonds.  The reasons for issuing revenue bonds  include:

      •    Additional  general obligation debt  cannot be issued be-
           cause of statutory limitations.
      •    Legal  restrictions  exist  on  the  employment  of tax
           revenues.
      •    When general credit of  a municipality  is not highly re-
           garded, revenue  bonds may  command a more favorable
           market than general credit bonds and can be sold at lower
           interest rates.
      «    A governing body of a municipality may be able to issue
           revenue bonds by securing a simple voting majority and
           not,  as in the case with general obligation bonds,  a two-
           thirds majority.

In the issuance of long-term debt, the municipal utility must first obtain authori-
zation by the  governmental  unit.  The bonds may then be advertised, specifying
the terms of the  issue as to denominations, coupon rates, and maturities.  The
sale of the bonds takes place either on competitive bidding or a negotiated basis.
Competitive bidding does deprive the issuer of the initial advice and services of
an investment banker.  Revenue bonds are frequently sold on a negotiated basis.
The  more specialized nature of the  bonds make the aid of an investment banker
important.

Bidding for these bonds is on a yield  basis. The underwriters or syndicates bidding
for an issue determine  the yields  for the various maturities within the issue and
add  a spread  to  cover risk and distribution expense to arrive  at a cost  of
                                    A-27

-------
purchase. The successful bidder may then resell all or part of the issue with the
difference between cost and resale price ranging from I to 1.5 percent.  This
gross spread depends on the type, size, quality, marketability,  and maturity of
the issue.  The purchasers of such issues are institutions or individuals who have
the most to gain by holding tax exempt bonds.

The yields on municpal bonds are determined by factors which include:
      •    The  general  level  of  interest rates determined by  the
           supply of, and demand for, funds in the capital market.
      •    The value to investors of the tax-exempt privilege.
      •    The  particular factors affecting supply and demand for
           municipal bonds.
In addition, the yields on individual issues are a function of quality, size, and
marketability.  Quality tends to correlate with size,  with the larger issues ob-
taining the more favorable yields.

Municipal bond yields have doubled since 1965.   Yields on long-term municipal
bonds have remained about 70 percent of the yield of corporate bonds  with the
same maturity. It can further be stated that the spread between Aaa rated bonds
and Baa rated has more than doubled.  The spread was 40  basis points in 1965; in
1975 the spread has increased to 131 basis points.  Unlike investor-owned utilities
with Baa  ratings,  municipal  utilities Baa-rated bonds were-able to obtain long-
term  debt financing  in  1975.  A possible explanation   for  this is  that the
municipals obtain  a significant proportion of their capital in a local segmented
market where knowledge of the municipal  may be  more important than a bond
rating by a national rating service.

Capital expenditures by municipal utilities  have  averaged about 10 percent  of
investor-owned utilities' spending  over the last  decade.   Internally generated
funds have contributed somewhat more to capital  expenditures  for these utilities
than they have for investof-owned utilities.  Partial explanations for this fact are
                                    A-28

-------
that these utilities do not distribute dividends, and taxes as a percent of revenues
are less than they are for  investor-owned utilities (on average about 4 percent
versus 15 percent).  It  has also been  suggested these utilities do  better with
respect to internal  funds generation since their rate requests do not have to be
approved by state  public  service commissions.  Because they have generated
more funds internally, municipals have had to raise less long-term debt.

Federal Agencies

Federal agencies — for example, the Tennessee  Valley Authority, which produces
half the  federal output  and Columbia River Power  System,  which generated an
additional 30 percent of the total — generated  12 percent of the U.S. electrical
output in 1975.  All of  this output is marketed  through federal agencies —  such
          /
as the Bonneville Power Authority and the TVA itself  —  to nonfederal utilities
who, in turn, sell it to ultimate consumers. Statutory preference  in the sale of
this electricity is  given  to  public  bodies and  cooperatively-owned systems.
Though investor-owned  utilities may contract for federal power, such contracts
may be cancelled on five  years' notice if  the  power is needed by a preferred
customer.

Federal power tends to  cost a great deal  less  than that which is generated by
investor-owned utilities. This fact reflects the lower interest costs  required on
federal debt, the fact that no taxes need  be paid by  federal agencies, and the
fact that federal power is,  as it turns out, generated at  a higher load factor.

TVA, one of  the more  visible members of the electric utility  industry, is a
permanent,  independent corporate agency of  the  Federal  Government.  The
responsibility of this agency is to supply electric power as  a wholesaler to the
Tennessee Valley area.  The capital investment required for the building of dams,
steam plants and  transmission facilities has been  raised by  Congressional
appropriation, retained  earnings, and the issuance of long-term debt.  In I960,
TVA began issuing long-term debt; such financing has become the primary means
for financing its capital expenditures.
                                    A-29

-------
Cooperatives

Cooperatively-owned utilities produced about  2 percent of the total electrical
output in 1975, but they accounted for 8 percent of the  total kilowatt-hour
sales.

Co-ops are a creation of the Rural Electrification Program initiated in 1935 and
the legislation of 1936 which established the Rural  Electrification Administration
(REA) to lend money to the co-ops.  The original purpose for the co-op program
was to see that rural areas would have electrical service that was dependable and
not overly expensive. Originally, loans to co-ops were made so that distribution
systems  could be established.  These systems  would  purchase wholesale power
from  both government-owned and investor-owned generating facilities.  As some
of these  distribution co-ops grew in size, they  realized economies in generating
and transmitting electricity on their own.  In 1975, co-ops had installed capacity
of about  7,600 MW.

Since  their  creation, co-ops  have been permitted  to borrow funds from  the
federal government at  attractive interest rates —   2 percent in most cases,
though 5 percent in some.  In 1971,  the REA adopted a policy requiring certain
REA electric borrowers to obtain part of their loan funds from non-government
sources.   This policy has caused coops  to issue long-term  tax-exempt debt.
Cooperatives now issue several million dollars in tax-exempt debt each year.
                                   A-30

-------
B.   FACTORS AFFECTING ELECTRIC UTILITY
     INDUSTRY CAPITAL-RAISING PROSPECTS
Having  reviewed the nature  of  the capital  markets and the electric  utility
industry's recent participation in those markets,  the discussion turns to the
factors  which are likely to affect the ability of the industry to attract capital
sufficient for purposes of complying with  NSPS as well  as for other possible
purposes.

This  section  begins  with a brief discussion of some  of  the  important
macroeconomic factors contained in a compilation of economic forecasts through
the year 1985. This discusion is not intended to be an analytical critique of the
projections or of the key.assumptions which drive the projections.  Instead, the
purpose is simple to  indicate the importance of macroeconomic variables as they
may affect electric utility capital spending.

In the second portion of this section, the nature of the discussion changes some-
what. With reference to the compilation of forecasts, the discussion explores the
nature of the "capital shortage" that a number of  economic forecasters allege
will exist in the future.

In the third portion  of this section,  the discussion turns to some of the macro-
economic factors which will affect  electric  utility capital spending.  The un-
certainty-filled environment in which the industry must make investment deci-
sions  is  described in  brief.  Next, the important constraints to large-scale capital
investment by the industry are discussed, and some policy options available to
state  regulatory commissions and  utility  management to  overcome these
constraints are discussed.  Finally, some remarks are made  concerning the in-
vestor-owned electric utilities' use of pollution control revenue bonds.
                                   A-31

-------
MACROECONOMIC FACTORS

The condition of the national  economy  is often considered  a crucial factor in
determining the need for electric  utility capital spending and the ability of the
industry to meet its financial requirements.  In Table 5, a compilation of U.S.
financial  parameters  prepared by  FEA  is  reproduced.    Perhaps the most
important figures  to consider are  the estimates of real annual GNP growth  for
the years 1975 to  1985. These estimates range from 3.6 to 5.0 percent.  The real
GNP rate is important since electric utility capital requirements are to a large
extent related to electricity demand (especially to peak demand, and to a lesser
extent  to average  demand), and electricity  demand is, in turn, believed to be
related to real  GNP  growth.  If  real GNP growth turns out to be lower than
forecast, estimates of utilities' capital requirements and external financing needs
are likely to be overstated.

The corporate bond rate is another important financial parameter. Table 5 shows
estimates of the Aaa bond rate. It should be noted that there are practically no
utilities currently  in  a financial  position  strong enough  to earn Moody's Aaa
rating for their  bonds.  Most utilities in  reasonably good financial condition are
selling Aa bonds, while those utilities in fair condition are selling bonds rated A.
Utilities whose bonds were rated Baa in 1974-75 were unable to secure new debt
funds.  Should utilities be  unable to improve their  financial  condition in the
future,  they may well pay significantly more  than the corporate Aaa bond rate
for  their  external funds  (provided  they are  not  prevented by indenture
agreements or usury laws from seeking the funds).

The  amounts  of gross  private  domestic investment and  total savings in the
national economy are also important influences on the financial  markets. Table
5 shows investment and  savings  broken down  into  separate  components  and
calculated  as  percentages  of GNP.  As  gross investment (including foreign  in-
vestment) must  always  equal gross savings (including depreciation), the invest-
ment and savings totals in  Table 5 should be identical.  Four of the five studies
estimated total investment and total savings as about 15 percent of GNP —which
is consistent with  percentages achieved  in the 1950s and in pre-recession 1973.
For dramatic purposes, the NYSE totals do not match.
                                   A-32

-------
               TobleS
National Finance Parameters. 1975-1985


Real GNP Growth
Rate^
High grade (Aaa)
corporate bond rate
As % of GNP
Gross private domes-
tic investment
Non-residential
Inventory
Residential
Total Savings
Business
Personal
Government
Federal
State &
Local
Other
DRI
4.5%
8.6

15.3%
10.6
0.7
4.0
15.3
11.0
5.4
-0.8
-1.0
0.3
-0.2
NYSEa
3.6%
-

16.4%
9.4
3.1
4.0
15.0
10.6
4.0
0.3
-0.2
0.5
0
BDCb
4.3%
7.5

15.6%
10.9
0.7
4.0
15.6
10.6
4.6
0.2
0.3
-0.3
O.I
Labor
5.0%
-

15.4%
11.2
0.9
3.3
15.4
11.2
4.7
-0.4
-0.7
0.4
-O.I
Chase0
3.6%
9.9

14.5%
10.6
0.7
3.1
14.5
10.2
6.2
-2.0
-2.1
O.I
O.I
a!974- 1985. b!973- 1980. CI975- 1984.
dOther forecasts of GNP growth include Electrical World, 3.5%
               A-33

-------
The  relative proportion  of  GNP constituted  by total  savings is an important
indication of the amount of money potentially available in the capital markets.
One  of the major influences on the amount of  savings in the economy is the rate
of inflation.  When the rate of inflation is as high  or  higher than the rate of
interest, money saved actually loses value; thus, there  is a greater incentive to
spend than to save.  Accordingly, the Chase study, which forecasted  the lowest
amount of total savings,  14.5 percent of GNP,  also forecasted the highest rate of
inflation, 6.2 percent.  BDC, which estimated total savings  at  15.6  percent pf
GNP, estimated the rate of inflation to be only 4.7 percent.

The  lower  the  total  real savings in  the economy, the less money will be made
available for business investment; hence, the higher the yield which must be paid
to obtain that which is available. Ultimately,  businesses may find interest rates
are so high thaf a reasonable rate of return on investment cannot be  generated.
Therefore, one  would expect that the demand for capital  would be reduced;
reduced demand for capital tends to result  in reduced interest rates.  A reduced
level of inflation tends to provide incentive to save,  increasing savings available
for business investment or to other borrowers such as government.

Government saving is a particularly important component of total savings in that
government savings are often negative; that is, it spends more than it  collects in
taxes. When there is a government deficit, the government  must obtain money
from external sources. Deficit spending may tend to drive up interest rates. A
government deficit could tend, therefore, to make external financing for the
utilities  more  costly.  Chase forecasted  the largest  government   deficit,  2
percent of  GNP. DRI and the Department of  Labor  forecasted smaller  deficits,
0.8  and  0.4 percent of  GNP, respectively.   BDC  and NYSE estimated  a
government surplus of 0.2 to 0.3 percent of  GNP over the next five to ten years.

Capital Shortage?

Given certain macroeconomic parameters, is there reason to expect that the U.S.
will  experience a "capital shortage," one that  could affect the spending plans of
                                   A-34

-------
the electric  utility industry?  In answering this question, it proves convenient
first to segregate the relevant issues into what are, in fact, two integral parts —
a macroeconomic view of capital availability  and a microeconomic view of the
utility industry and its member firms that are  anticipated to require the capital.
The  macroeconomic  view  takes  into  account such factors as the  aggregate
amounts of prospective saving and investment,  the essential manner  in which
prices (including interest rates) are determined, the financial conditions of the
firms requiring capital, the prospective rates of economic growth and inflation,
the  extent to  which  productive  capacity is now  utilized, and the role of
government policies (fiscal, monetary, and tax), programs, and  laws, e.g., with
respect to environmental protection.   The macroeconomic  view focuses on the
ability of specific firms to generate investment funds internally and to  compete
for external financing.

In the last three years, a number of studies have been undertaken to assess the
likely characteristics of the U.S. financial markets over the next  decade. Among
the  studies are those summarized in  Table 5.   Essentially what most of the
studies did was  to  add up a likely supply of aggregate  national savings and
compare  that  total to  the capital investment  plans  of  the nation's  business
corporations.  Some studies found the aggregate investment figure to exceed the
likely  aggregate amount of  savings (generally assumed to be  about 4 trillion
dollars over the next  ten years) and thereupon declared that a "capital shortage"
would exist in the U.S.

The  arguments advanced to justify a  concern for a "shortage" include the fol-
lowing:

Inflation  has and will likely  continue to keep internal generation of funds low
relative  to the need for investment funds.  First, internal  funds are generated
chiefly through depreciation  allowances and through retained earnings.  In the
absence  of technological change  and  the presence  of a  relatively high rate of
inflation, depreciation allowances may be considered inadequate to maintain a
firm's  stock of capital.  During inflationary times, earnings are taxed at rates
which do not reflect the reduced buying power of such earnings.  When  corpora-

                                    A-35

-------
tions  are unable to generate  funds internally,  they must seek  their financing
needs in the capital markets.  But if all corporations seek external financing at
the same time, the argument  is made, there may not be enough  capita] to go
around.

Second, the argument is made that  internally generated funds constitute prac-
tically all of gross corporate savings, and gross corporate saving (including depre-
ciation) generally accounts for about three-quarters of gross saving in the U.S.
each  year.  So, it is argued, the pool of savings  may be insufficient to meet the
demands placed upon it.

Another argument made to support the notion of "capital shortage" is as follows:
Federal fiscal policy may foster enormous budget deficits. Deficit spending may,
it is  argued, cause interest rates to rise (in fact, this alleged linkage is by no
means proven), and this may cuase the inflation rate to rise, and  this, in turn,
may  inhibit  internal funds generation and  force  corporations into the capital
markets.   It is also argued that mandated air and water pollution control may
require capital spending of tens of billions of dollars over  the  next  decade.
Occupational  health  and safety  legislation  will  also require  what  industry
spokesmen have called "non-productive" capital  spending.  Further, it is  argued
that the nonprice rationing of credit to certain essential industries, e.g., electric
utilities, would appear unlikely given the relationship between government and
the banking industry in the U.S.

On the other hand, it  can be stated  that as a practical matter, ex post, savings
always equals  investment.  Firms which cannot  compete for capital are  always
"crowded out."  Further, it can be said that  the  studies which purported to show
the existence of a capital shortage took the investment plans of corporations
without associating these  plans to prices, interest rates, and/or  the abilities of
the firms to earn their costs of capital. Spending plans tend to  be grandiose in
the absence of  financial constraints.

While a shortage of capital may not take place in the economy as  a whole, it may
surely take  place  at the  level of  the individual  firm.   Thousands  of firms

                                    A-36

-------
experience capital  shortages from time to time - they cannot compete, either
because  they cannot lure investors or because legal  restrictions prevent their
would-be participation in capital markets.   Are a particular state's electric
utilities  likely to be spurned by investors or otherwise prevented  from raising
capital for NSPS compliance or other purposes? It would be helpful in answering
this question to be able to foretell federal and state  tax policy, incentives for
individuals to save  rather than consume, the realistic spending  plans  of other
firms, the expansion in the productive facilities of equipment and plant suppliers,
and many  other facts.   These  factors are  very difficult to predict  with any
accuracy.   Hence,  this discussion of capital  raising  prospects  is confined to
general and  suppositional areas. The discussion  here turns to microeconomics
                                                                        F
and involves such factors and issues as the significance for capital formation of
accounting  practices  peculiar  to public  utilities, certain utility  management
initiatives  which might  be taken to  improve the  industry's financial condition,
and other possible policies and constraints.
                                    A-37

-------
MICROECONOMIC FACTORS

It  was shown in the first section that  the financial condition  of  the electric
utility industry is significantly affected by a combination of factors, including
low capacity utilization, a high rate of  inflation, high interest costs, and regu-
latory lag.   These  and other factors affect  the industry's ability to attract
capital.  If the industry is to be in a position to fund necessary expansion of
plant, mandated  NSPS, and other projects,  it must, above all, generate an ade-
quate level of  earnings, improve  the state  of its balance sheet, and reevaluate
some of its conventional  management  policies.   It will need  to  do so  in  an
environment characterized  by great uncertainty,  with the prospects good for
more uncertainty in  the future rather than less.  To describe the environment in
which the industry must operate,  it is useful to begin with one of its most basic
types of decisions: capital budgeting.

Capital Budgeting in the Electric Utility Industry

In an industry of  inherently great capital intensiveness, the most crucial manage-
ment decisions have to do with capital  budgeting.  In attempting to determine
the amount and type of facilities to build to meet the demands of customers and
comply with state and federal environmental protection standards, a great many
factors need to be taken into consideration.  For example, it is necessary to have
a reasonable amount of knowledge about the amount, type, cost lead time, and
profitability of capital  expenditures.  At present,  much uncertainty clouds the
investment environment. The uncertainty is manifest in areas which  include:

Demand

The uncertainty of electricity demand is a major problem affecting the industry's
mix, timing, cost, lead time, and profitability of capital expenditures.

This uncertainty  is  affected by uncertainties as to the degrees of voluntary,
mandatory, and price-induced conservation likely among consuming sectors. It is
                                   A-38

-------
affected, as well, by the interaction of a dozen or so demographic and economic
variables whose future course is by no means clear. It is affected, also, both by
the substitution of electricity for the direct use of certain fuels whose costs may
be high or availabilities scarce and by the substitution of alternative means of
power generation —  for example, solar — for the electrical output.

Regulatory Response

Many believe the remedies or  solutions to any financial  problems the industry
may  have should come  first  and foremost from the industry's regulators  —
through  timely and effective rate relief, allowance for higher rates of return on
investment, change in  accounting practices, and perhaps changes  in  the  way
electricity is priced.  The regulators —  federal, state, and local, evidence no
common pattern of response to the industry's financial condition.

Construction and Equipment Costs

Economic choices need to be  made periodically as to the  amount, type, and
timing of new plants —  if for no other reason than to retire old, economically or
technologically, inefficient plants.  These choices must now be made in a setting
characterized, among other  things, by more lengthy  plant gestation periods —
which could well get longer —   and potentially rapid shifts in the economic and
financial  advantage  of one type of plant  construction  and equipment over
another.  For example,  it is by no means clear, even on pure cost grounds,  to say
nothing of the imponderables introduced by legal  interventions, whether nuclear
or NSPS-complying coal-fired units will be preferred for baseload capacity.

Fuel Supply and Cost

To determine the type of capacity to build  to meet an estimated demand for
electricity, it is crucially important to have some notion as to the likelihood of
the availabilities and costs of  fuels to burn over the life of the appropriate
generating plants. Since these plants may take 5 to 10 years to site, license, and
build, the fuel supply and cost calculation takes as a starting  point 5 to 10 years

                                   A-39

-------
from  now  and continues for perhaps  another thirty to  forty years  from the
starting point.

Even  in  the least  volatile  of times such  long-range forecasts are hazardous.
Today, even 3 to 4 year fuel supply and cost forecasts may miss the target by a
wide margin.

To begin to forecast coal supply and cost one needs, for example, some idea as to
how much is in the ground and whether it can be mined at a reasonable cost.
Further, it  is necessary  to know which coals can be mined and where.  To begin
to forecast the cost of nuclear  fuels, one needs, for example, some notion as to
the future costs of enrichment  and the future availability of disposal facilities.
Though fuel cost forecasts  must be made for planning purposes, they should be
treated with extreme caution.

One means  to the control of fuel supply and cost involves the industry's purchase
or lease of coal and/or uranium  mines.  Yet, there  is a great deal of uncertainty
as to whether  the  industry could  afford such investments in supply and as to
whether its regulators would permit such investments in all instances.

Environmental Constraints

The future course of environmental legislation and standards present large uncer-
tainties to the electric utility industry.  Controlling the discharge of effluents to
the air  and water may cost a good deal more than now anticipated.  Standards
may preclude the use of certain fuels and processes  now in use.

Controls on the use of land for  mining, generating, transmitting, or distributing
energy may be more stringent than now foreseen. Environmental concern for the
safety of nuclear operations could prevent large scale, if any, use of this source
of electrical generation.
                                   A-40

-------
Federal Policies

There  are numerous  things that the  federal government  can do,  wittingly or
unwittingly, to help or hinder the electric utility industry. To the extent that the
federal government through expenditure, tax, and monetary policy can control
inflation, it  helps the electric industry.   To the extent  that  federal  deficit
spending is maintained or is increased, it may hinder the industry, in at least the
price the industry must pay for new debt issues or for the refunding of old  issues.

In the  short term, the federal government could probably also help the industry —
though perhaps not its rate-payers or taxpayers —  by guaranteeing industry debt
issues. Whether such a measure is a long-term help is more problematic.

There  are other federal policies or actions which might be pursued in an attempt
to aid  the industry. They might include incentives to engage in  load management
programs, policies  with respect to  the accounting practices which  the Federal
Power Commission may  permit to be  used  (e.g., with  respect to CWIP  and
AFDC), and an increase in the investment tax  credit rate.
                                    A-41

-------
REGULATORY POLICIES

State public utility commissions  have considerable influence over the capital-
raising  prospects  of the nation's investor-owned  electric utilities.   Potential
investors view the fact that electric utilities are regulated monopolies as both an
asset and a liability.  It is an asset because utilities have a  legal right  to  the
opportunity of earning a fair return on their investments and because a monopoly
may be  less subject to the operating risks faced by competitive firms.  On  the
other hand,  the regulated nature of the industry is perceived  as  a liability
because, in some instances, regulators have had a role to play in the instability
which utilities' earnings have exhibited of late.

In May,  1976, a brokerage and research firm rated  the "regulatory environment"
in 46  states  and the  District of Columbia.  (It  noted Utah's Public Service
Commission the most "favorable"; West Virginia's, the least.)  It based its ratings
on factors which include: allowed return on equity;  rate request processing time,
in months;  test year for rate calculation, historical, forward-looking, or both;
rates go into effect under  bond; limit on time permitted until  rate decision
rendered; fuel adjustment clause; normalization of  accelerated depreciation and
investment tax  credits; and CWIP in rate base.  In effect, regulatory climate
refers to alleged adverse treatment of investors either through insufficient rate
of return, insufficient rate relief,  or delay in granting that relief.

It is unknown the degree to which investors attach importance to these subjec-
tive ratings  or  to  the  factors upon  which the ratings are based.  If investors
believe the factors very significant, they may either bid  up the returns required
in particular states or from particular utilities.  One thing that can be observed,
however, is  that there  are electric utilities in  states which have so-called
unfavorable environments which  are doing quite well, and  there are utilities
operating in so-called  favorable  regulatory settings  which are not doing very
well.  Perhaps  the only real  evidence that "regulatory environment" is being
taken into account explicitly can  be found in the area of  bond ratings. This fact
and its implications is discussed in the next portion of this section.
                                     A-42

-------
There  are three particularly interesting regulatory policies which,  if altered,
have a major effect on utility finances and thus capital-raising prospects.  They
are: CW1P/AFDC treatment, the automatic fuel adjustment clause, and the cost
of capital  adjustment clause.  Until recently, there were  four such  policies to
consider,  but last  year, Congress would  appear to have removed one  from
immediate need for consideration. This one involved the question as to whether
utilities should  be  permitted to normalize tax  credits and accelerated depre-
ciaiton or whether Public Service Commissions could force  them to flow-through
the benefits of  these  tax subsidies to current rate-payers. In effect, normali-
zation was decreed.  (California's PUC  has vowed to take the issue to the
Supreme  Court.)   A  discussion  follows of  the three remaining  policies for
consideration.

Construction Work in Progress (CWIP)

CWIP is a temporary utility plant account which collects all funds, including the
cost of construction funds, which are tied up in the construction of new facilities
that have not yet come  on line.   When the facilities are completed, their  costs
are transferred to a permanent plant account —  a rate base  account.

Currently, 35 states, the District  of Columbia,  and the FPC exclude the CWIP
account from the rate base.  The major arguments in support of this policy are:
(I) the costs of future generating plants should be borne by future rather than
current ratepayers, or, to state it differently, utilities should be able to charge
consumers only for  assets that are "used and useful"; and (2) utility management
should have an incentive to see  that projects are completed and  completed
expeditiously. The  major arguments for CWIP inclusion in rate base are: (I) cash
flow would be increased at  a time whenJt is most needed;  and (2) both the
quantity and cost of  capital would be reduced; hence, the  ultimate cost of the
electricity would be reduced.

Inclusion of the CWIP account in the rate base, given that the allowed rate of
return were kept constant, would,  of course, immediately increase electricity
rates and  revenues.  Ceteris paribus, taxes would also increase,  since net income
would be higher.  Construction projects would be much less  risky, however, since
                                    A-43

-------
including CWIP in the rate base reduces the risk of building a plant which, if not
deemed necessary by a regulatory commission, might not be included in the rate
base upon  completion.  With the risk reduced, external financing  could be
cheaper. Inthe long term, this could result in lower electricity rates.

The "Construction Work in  Progress" account  includes the interest and equity
costs  of construction  funds.   These  costs  are capitalized  in the  account
"Allowance  for Funds Used During Construction" (AFDC) which is  credited to
income over the construction period. AFDC is noncash, non-taxable  income and,
like  CWIP,  is currently not  allowed  by many regulatory commissions to be
collected in rates until the plant is transferred to the rate base.  Were  CWIP to
be included  in the rate base, there would no longer be a need for AFDC since the
utility would be realizing revenues that cover the interest costs on CWIP.

The following example shows  the relationship  between capital expenditures, the
AFDC account (an income statement account), and the CWIP account (a balance
sheet account).  In the example, the following  assumptions are made: (a) capital
expenditures are made the first day of the year; (b) the AFDC rate is 8 percent;
(c) the plant takes three years to build; and (d) after three years of construction
expenditures,  including those  for use of construction  funds, the plant comes on
line.
Year

Capital
Expenditure
AFDC

CWIP at end
of year


1
2
3
$100
200
100
$8
24
32
$108
332
464
                                    A-44

-------
The  important points to  note from  the example are (I)  the CWIP account
accumulates all capital expenditures and AFDC associated with the construction
of the plant.  When the plant comes on line, the amount of CWIP associated with
the plant  is added to the rate base and begins to be amortized for rate-making
purposes.   (2) For tax purposes, only that portion of the CWIP account which
represents capital expenditures, $400 (i.e., excluding AFDC) may be depreciated;
(3) for tax purposes, only the debt component of AFDG is an allowable expense
and this deduction must be taken in the period in which the interest was paid.  (4)
AFDC is not compounded.

Fuel Adjustment Clauses (FACs)

During the Embargo and shortly thereafter, electric utilities argued strenuously
for the right to use automatic fuel adjustment clauses to pass on to customers
the rising cost of fuel without having to go through formal rate proceedings to do
so.  The  argument  was  that fuel costs  were not  in any way controllable by
utilities and  it made no sense to require utilities to  formally justify expenses
over which they had no control.  Further, fuel costs were seriously depleting cash
positions.  All but five states agreed with utilities and allowed FACs to be used.
It may have  appeared that the FAC issue was resolved, and that  in the future,
utilities could count on  charging  customers on a timely basis increases infuel
costs.

But the issue is  far from resolved, as evidenced by  a  recent speech given by
President  Carter in which  he stated that: "It  is hard to  believe that every time
energy costs go up, that utility companies automatically raise your rates, and the
regulatory agencies don't have a thing in the world to say about it.  That ought to
be changed."

The President no doubt had in mind a July 1977  report by the Senate Govern-
mental  Affairs Committee, which  criticized Public  Service  Commissions for
permitting utilities  to  pass through  in  FACs both  direct  fuel and  non-fuel
expenses.   Non-fuel expenses  in FACs  include  those involving  line  losses,
efficiency factors, taxes and fees, fuel handling  costs, fuel-related salaries and

                                    A-45

-------
labor,  allowance for uncollectable expenses, lag correction factors,  wheeling
charges, hydro and geothermal power.  The authors of the report suggest that
FACs have been abused and that FACs should be abolished.

The issue is not clear cut either way. There may be good arguments for relieving
utilities  and  Public Service  Commissions from the  drudgery  of  having  to
scrutinize, in lengthy  proceedings, many  costs which  utilities cannot control.
This assumes these costs are indeed uncontrollable.  If  they are uncontrollable,
regulators  might  more  profitably focus  on controllable  costs  and devise  a
performance/incentive structure for dealing with these costs agreed to be under
management  control.    That  is,  allowed  rate  of  return might  be tied  to
management performance —  as it  is supposed to be in the rest of the corporate
sector.

As for the immediate financial consequences of a possible abolition of FACs, if
the electric utility industry is an increasing cost industry, the normal regulatory
lag associated with the review of expenses which were previously passed on in
FACs will adversely affect the industry and its capital-raising prospects.

Capital Adjustment Clause (CAC)

In April 1975, the New  Mexico Public Service Commission  instituted a novel
rate-making mechanism which, if adopted by other PSCs, could have very  impor-
tant implications for the ability of the electric utility industry to attract funds
from the capital markets.  For the Public Service Company of New Mexico, the
PSC established an automatic capital adjustment clause which permits the utility
to adjust rates on a quarterly basis such that it realizes the rate of return on
equity allowed by the Commission. The Commission set a range of 13.5 percent
to 14.5 percent for the return on equity.

In effect, the CAC guarantees that at the end of each 3-month period - i.e., not
prospectively - the equity return  will be no less than 13.5 percent. By the same
token, every quarter the equity return is adjusted down  to a ceiling level of 14.5
percent, if  during the preceeding three  months,  it has exceeded  that  level.

                                   A-46

-------
Clearly,  this is a different sort of equity.  This raises some interesting public
policy questions.  Some of these questions will  be explored  momentarily.  But
first, it is useful to consider the PSC's motivation for establishing the CAC and
what CAC's effect has been to date.

New Mexico PSC's basic motivation  for instituting the CAC was that it saw a
need for the utility to attract capital at the least possible cost in order to build
new generating capacity.  Specifically,  it saw a need to build coal and nuclear
plants.  It recognized that construction  costs had  mushroomed in recent  years,
and it believed that while fuel adjustment clauses recover some costs on a timely
basis,  the  normal  regulatory  lag  involved  in  scrutinizing other costs  had a
sufficiently  adverse  effect on  earnings'  stability that funds to be used for
construction were becoming more difficult and expensive to attract.

It has been  determined that the CAC  has had a positive influence on Public
Service Company's cost of capital. Limited evidence suggests  a decrease in its
cost of debt, and more robust evidence suggests an increase in its P/E  ratio
roughly equivalent to a one to two percent decrease in its cost of equity.

From a public policy  viewpoint, the  principal problem with  the CAC is that it
may tend to reduce a  good  deal of the  risk  which equity investors can be
expected to be willing to assume for a 13.5 to 14.5 percent return. If this be the
case, then the risk is shifted to consumers.

Another question is whether  issuing  this form of  equity is less expensive than
issuing debt in the same amount.  This is a difficult question since there may be
serious  constraints on the firm's ability  to  do  so —  even with the  earnings
stabilizing influence of a CAC.  Further, it can  be argued  that at some point a
firm needs an infusion of equity capital to maintain its target debt/equity ratio.
Undoubtably these questions and others involving  the New Mexico PSOs CAC
will be debated at many other PSC's  in the  near  future.   Streamlining the
regulatory process by essentially eliminating the need for adversary proceedings
may be  a  course of  action implying  greater  efficiency, but the  risk/reward
                                    A-47

-------
element tends to be altered by such initiative.  Probably the ultimate question
with the  CAC  is  the  same  as  it is  with the  normalization/flow-through,
CWIP/AFDC, and FAC issues; that is: Is  there a high probability that consumers
will receive a net benefit from a change in policy?
                                 A-48

-------
MANAGEMENT POLICIES

The policies noted thus far would require regulatory initiative for change. There
are other  policies  which may  affect  capital-raising  prospects  which  utility
management would need  to take it upon themselves to establish. These policies
and their possible effects on financial position are described below.

Debt Ratio

Financial  decisions concerning capital structure and dividend policy may  have a
significant impact  on an  electric utility.  It  has been suggested that utilities
increase their debt ratio; that is, their degree of financial leverage. A change of
this nature in the  capital structure could have a  noticeable financial impact,
particularly/because most U.S. electric utilities are already highly levered (the
average debt-equity ratio is  approximately 1:1).  A higher debt  ratio could lead
to a lower revenue requirement, since the after-tax cost of debt is less than it is
for equity.  However, equity holders would require a higher rate  of return  to
compensate them for their additional risk, and there may be no  net reduction in
the weighted average cost of capital.  But,  if the proportion of debt  in the
capital structure were to increase, since interest charges are tax deductible,
taxes would decrease if rates did not change.  If rates were to rise, however, net
income might benefit greatly, due to the increased  degree of financial leverage.
This same leverage would hurt the utility considerably in the case of a decline in
revenues.  External financing might become increasingly  difficult with a  higher
debt ratio, and this might curtail some capital spending.

Dividend Payout

Another change which  financial  management could implement would  be  to
decrease  dividend  payout.   This, in turn, would  increase the proportion  of
earnings which the utility could retain and reinvest in its projects.  One  theory
holds that investors are  indifferent to  the amount of  dividends  they receive,
assuming the  retained earnings are reinvested profitably.  Therefore, decreasing
dividend payout should result in less need for  external financing and perhaps in

                                    A-49

-------
greater incentive for the utility to undertake capital expenditures.  Rates would
be unchanged, as would taxes, since dividends are not a tax-deductible expense.
However, another theory holds that investors do value more highly stocks which
pay higher dividends -  current income.  Adherents to this  latter theory would
argue that if the dividend  payout were reduced, the utility would lose equity
holders, thereby having to raise rates somewhat to increase the return on equity
to attract new equity holders.

New Types of Capital Expenditures
As has been  noted, a great deal of uncertainty now pervades the environment in
which the industry must plan its capital expenditures.  For example, it does not
know precisely what types of new generating facilities to build —  base load,
intermediate, or peaking — what would be most economical and most reliable for
baseload — coal or nuclear — and whether or not an attempt should be made to
acquire leases or producing companies to secure fuel supplies of  a  certain type
for new generating plants.

The  industry  must  also consider  the possibility that, for example, State Imple-
mentation Plans for emissions to air may be tightened to require either that fuels
with different characteristics be used, that coal cleaning plants be financed and
constructed to reduce the polluting characteristics of the fuel, or that stack gas
desulfurization investments be made.

There is an  enormous  number of  possible  investments for which  the electric
utility  industry may feel a  need or may be  required to make between now and
1995. The following is a partial list of possible capital investments which might
be made prior to 1995.

     •     New generating plants of an appropriate mix.
     •     Physical  or  chemical  coal-cleaning facilities associated
           with the use of existing plants.
     •     Scrubbers for all new plants and for some proportion of
           existing plants.  Investment in sludge disposal facilities.
                                   A-50

-------
           Facilities constructed  for compliance with  the  water
           pollution control act.

           Purchase or lease of coal and uranium mines. Acquisition
           of operating companies.  Investment in mining equipment,
           additional railroad spurs, conveyor belts, slurry pipelines,
           etc.

           Investment in railroad rolling stock.

           Investment in gasification and liquefaction projects.

           Investment  in  solar energy  —   either  for electricity-
           making purposes or for installation in consumer homes.

           Investment in making consumer loans for insulation retro-
           fit.

           Investment  in  transmission  and distribution  facilities,
           including those that are more energy-efficient or environ-
           mentally-benign  but  which  carry  higher  first-costs
           (presumably lower  life-cycle  costs,  or some  form  of
           subsidy would be requested).

           Undergrounding'of existing distribution facilities.

           Investment in load management hardware —  at the utility
           end and very likely at the consumer end as well.

           For  combination  utilities,   investment  in  gas  supply
           projects, as well as insulation retrofit  and  conventional
           transmission and distribution investment.
It  is not clear what all these possible investments would  cost.  It is clear that

some investments should make others unncecessary.  However, it is also evident

that not all these investments can be made prior to  1995.  Still, there are advo-

cates for  each  type of  investment,  and  there  will  be  competition among

advocates to effect the course of electric utility capital spending.


The  existence  of this competition for the spending capacity  of the  industry

suggests three things.  First, it suggests capital expenditures for purposes related

to NSPS revisions could squeeze out possible expenditures for other purposes.

Second, it suggests that state regulatory commissioners will be under pressure to
                                    A-51

-------
expand the industry's spending capacity by permitting higher allowed returns and
other favorable treatment.  Third, it suggests  that, if  state regulators permit
increased spending capacity and if the rates of  GNP and savings do not increase
as fast as the rate at which industry spending  capacity does, the industry may
command a greater share of available capital than it would otherwise.

Constraints to Greater Investment
It has been suggested that  the level of earnings  the  industry can generate proves
to be  the greatest determinant of the success which will be had in attracting
investment capital.  Earnings affects share prices which, in  turn, affect the
ability to raise equity funds.   Earnings also affects  interest coverage ratios
which, in turn,  affect bond ratings.   Bond ratings have proven in recent years
crucial constraints on the ability to issue debt securities. In 1974-1975, no utility
with bonds rateJ Qiu or below was able to issue debt.

Bond ratings  are purported to measure the probability that a firm will meet its
debt obligations in a timely fashion.   A lower rating implies a  lower probability
of prompt payment; hence, a higher degree of risk.  Riskier bonds must carry
greater risk premiums to compensate  investors for bearing the risk of default.

In the  last decade, bond ratings have become extremely significant in affecting
the capital-raising prospects of firms whose financial positions  are not as robust
as those of the nation's strongest and most stable firms.  Electric utilities, which
a decade ago were considered both strong and stable, are now frequently counted
among the firms whose ability to  gain relatively good ratings for their bonds is
somewhat problematic.  Indeed,  in recent years, numerous  utility bonds have
been downgraded.  The industry appears to consider 1976 a fairly good year in
this  respect, since only eight bonds were downgraded that year, whereas  15
received such treatment in 1975.

What privileges accrue to the firm  with  relatively high  ratings for its bonds?
First,  it  can attempt to market  the bonds  in the  widest possible market  for
securities.  Institutional investors -   including commercial  banks,  insurance
                                    A-52

-------
companies,  and pension funds —  are generally prohibited from purchasing any
bonds below Baa.  Second, the firm is more likely to get the proceeds it  needs
with lower transaction costs.  These costs include investment bankers' fees and
commissions, and such costs tend to rise the more difficult it is to place the bond
with an eligible and willing buyer.  Third, the firm is  likely to acquire the debt
funds at a lower effective interest rate.

The magnitude of the effective interest rate presents special problems to firms
operating in about a  dozen states.  The  problem is a statutory one,  the states'
usury laws.  These laws  prohibit  lenders of certain types  —  read: investors —
from requiring more  than a certain percentage effective annual interest on any
loan.  The statutory  percentage rates vary from state  to state, but the majority
are in the range of 9  to 12 percent per annum.

An exhaustive legal  analysis of the extent to which usury  laws  would present a
serious constraint to utility capital formation has not been performed to date.
However, it is clear  that in certain states investors are not exempt from  these
usury provisions.  As matters now stand, under the current usury laws of some
states, a  utility with a relatively low bond  rating must either sell bonds of a
shorter term and  lower interest rate  or  sell  bonds (the maturity of which may
match the life of the asset) with an interest rate which exceeds the usury level
and trust  that there  will be  lenders willing to risk the possibility of legal  com-
plications.

One of the interesting aspects of bond rating  practices is that the raters now
look beyond such matters as a firm's asset protection, financial and .management
resources,   and  earnings stability,   to  subjective  measures   of  the  regula-
tory/political climate of the state in which the utility operates.  Firms operating
in "favorable"  regulatory climates —   that determination  being made based on
allowed returns, present accounting practices, and other factors noted earlier —
may be given the benefit of the doubt where there is  some  question  as to
appropriate rating. Clearly, the firm that has limited financial1 and management
resources, exhibits wide swings in profitability  (due perhaps, in part,  to a highly
leveraged position), and which operates in an unfavorable regulatory environment
may have serious problems attracting outside capital.
                                     A-53

-------
POLLUTION CONTROL REVENUE BONDS

It is estimated that the United States business sector invested about $7.5 billion
in 1977 for pollution control purposes.  The investor-owned electric utility indus-
try accounted for about $2.3 billion, or 30 percent, of the estimated total.  Sixty-
five percent  of  the  investor-owned  utilities  share went to  air  pollution
abatement,  thirty percent to water pollution control, and five percent to waste
disposal.  Eleven percent of all new utility capital expenditures was devoted to
pollution control.

About  half of all new capital raised by the business sector for pollution control
spending is  being acquired by use of tax-exempt pollution control revenue bonds
(PCRB's). 'These tax-exempt issues now represent about ten percent of all new
debt issued  by state and local governments.  It is thouught that over the next ten
to fifteen years PCRB's issued by public  authorities for the benefit of  private
firms could assume a much larger share of the tax-exempt market.  In so doing,
the expanded use of PCRB's  may present  a number of problems the ulimate
effect of which could be either a loss of advantage for their use by private firms
or an abolition of that use.

The use of  public credit to finance private projects began forty years ago with
the industrial  revenue bond (IRB's) program; however, IRB's were not widely used
until the economic boom in the Sixties at which time states and municipalities
bid against one another to attract industry.  In 1968, an enormous amount of IRB
debt was issued, so  much that municipal bond rates rose by twenty-five basis
points.  Urged by municipal organizations and the Treasury Department, which
argued  that a massive  amount of income tax revenue would be lost, Congress
redefined eligibility requirements for use of IRB's, and their use fell to about $40
mi 11 ion in 1969.

Congress, believing private investment in pollution control facilitates a use of
IRB's that was genuinely in the public interest, continued to legitimize the use of
pollution control  revenue  bonds.    Subsequent  passage of the  water and air

-------
pollution control acts essentially mandating certain private expenditures implied
an expanded use of PCB's.  In effect, it was determined that the cost of cleaning
up the environment should be a responsibility shared between industry and tax-
payers.

It is a concern for the nature and possible magnitude of the shared-burden which
prompts  a growing  interest in tax-exempt pollution  control financing.   One
concern is that federal and, in many cases, state and municipal tax revenues may
be adversely affected by the expanded use of PCRB's.   One estimate is  that
PCRB's will cost the federal government  more than $1 billion a year in foregone
tax revenue by 1980.  Another $450 million will  be  incurred by state and local
governments — the  loss representing higher interest costs caused by overloading
the tax-exempt bond market with private industry debt and representing  lost tax
revenue  as  well.   It  is argued  that the major proportion  of the tax loss to
government is due to the tax sheltering PCRB's would provide those investors in
the  highest  tax  brackets,  those for whom  the tax-exempt feature has  the
greatest attraction.

Precisely how  much more  state and local governments would have  to pay in
interest costs due to the alleged flooding of the tax-exempt market by PCRB's is
very difficult to estimate. This would depend among other things upon the phase
of the economic cycle, the cash positions of  the  principal market participants,
the relative size of the  municipal issue,  and the magnitude of tax-exempt  debt
used by the business sector and particularly by the electric utility industry.

Energy policies, environmental protection standards  (form and stringency),  and
Internal Revenue Service rulings will have a great deal to do  with the magnitude
of PCRB's which the electric utility industry may wish to use.  An energy policy
which encourages utilities and other industries to  use dirtier, though  perhaps
more plentiful, fuels implies greater use of PCRB's.  Further, an energy policy
which encourages  load flattening implies greater need for and use of coal  and
nuclear baseload units. Both types of plants may be considered "dirty".
                                    A-55

-------
The  immediate problems  with  coal are fairly evident, thoijgh further research
may find all  sorts of new environmental problems related to its use.  Further
tightening of standards for known pollutants may be required, and standards for
other emissions the effects of which are not now  well  understood,  may be
necessary.

The  use of nuclear power plants  involves  serious pollution problems as well  -
due  to radiation.  The very design of nuclear power  plants may be seen as an
attempt to minimize hazards from radiation.  It has been estimated that from
twenty-two to thirty percent of the investment in nuclear power plants could be
considered for purposes of pollution control  (radiation and other pollution).  If the
IRS  confirms this estimate, a very large proportion of the investment could be
financed with tax-exempt securities.  Since it is estimated that investment could
be made in as many as 187 nuclear plants by the year 1990, this could mean as
much as $6.5 billion worth of nuclear power PCRB's  coming to the tax-exempt
market each year from  now until 1990.  This would represent about twenty
percent of the entire new  issues market, for nuclear power alone!

Clearly, the  above scenario bodes ill for  state and  local  governments seeking
funds.  It should be noted that seventeen  states have interest rate ceilings on
their tax-exempt general  obligation bonds, and these  limits are nearly met al-
ready.  It should also be  noted that it has  been suggested that states and local
governments  issue taxable bonds to widen their access to the capital markets.  It
would seem  ironic if states and local governments in the future gained a large
proportion of their external funds in the  taxable market while private firms
dominated the tax-exempt market.

Political reality suggests this cannot happen. Indeed it suggests that if state and
local governments make sufficient noise about the potential effects of expanded
use  of  PCRB's, the  PCRB as a financial  tool  for  private industry  may be
endangered.
                                    A-56

-------
On balance, it could well be that private industry will share the disenchantment
that some state and local governments have expressed for the thin, volatile tax-
exempt market.  Yield spreads between good-quality corporate bonds and PCRB's
have narrowed considerably in recent years.  In future years, PCRB yields could
conceivably rise above some corporate rates.  All this suggests that the once
clear financing advantage of PCRB's may only  continue to exist under certain
circumstances.  Congress may perceive "the  problem", for  last year  it enacted
another method of sharing the pollution  control  investment burden  with tax-
payers —  by permitting such investments to qualify for both accelerated depre-
ciation and tax credits.
                                    A-57

-------
                    APPENDIX B
GENERATING UNIT COSTS OF SO2 AND PARTICULATE CONTROLS

-------
                                APPENDIX B
     GENERATING UNIT COSTS OF SO2 AND PARTICULATE CONTROLS

The  generating unit cost  of SO2 control  to meet the revised new source
performance standards as a function of the coal sulfur content for a typical new
500 MW plant is illustrated in Table B-l.  Cost for the current and the revised
SO2 standards is illustrated in Figure B-l.  These costs are for a limestone wet
slurry flue gas desulfurization system having a 90 percent removal efficiency.  If
less  than 90 percent removal of S02 is required to meet  the standard, it  is
assumed that only part of the flue gas will be scrubbed".

The costs are based on a plant capacity factor of 0.65 and a capital recovery
factor of 0.15.  The energy required to operate the FGD system is included as the
cost of the replacement  capacity (and its associated pollution control devices)
needed  to provide the energy.  Interest during  construction is not included for
this simplified  cost  comparison,  although it  is in  the Utility Simulation Model.
Also, differences in fuel and boiler costs  for  the various  fuel types are not
considered here.  This  comparison illustrates that based on SO^ control costs
alone the revised new source  perfomance standards provide low sulfur coal with
less of a cost advantage than the current new source performance standard.

Table B-2  illustrates the cost of particulate control as  a function of the  coal
sulfur  content  for a typical  new 500  MW  plant  meeting an emission limit of
22 ng/J.  The costs of  meeting  the current particulate  limit of 43 ng/J and a
22 ng/J  limit are illustrated  in Figure B-2.   The proposed  13 ng/J limit is not
illustrated here.  Hot-side ESP costs are shown for a fuel  that is a subbituminous
coal or lignite  with  a sulfur content less than one percent.  For all other fuels,
cold-side ESP costs  are illustrated.  In the Teknekron Utility Simulation Model,
the  levelized  least-cost particulate control device  (ESP or fabric filter)  is
selected.  In the model, in all cases, fabric  filters were selected for use on the
low sulfur Western coals.
                                   B-l

-------
NJ
                                                   Table B-1
                     Typical Limestone Slurry FGD Costs (1975) for a New 500 Mw Plant Burning
Various Coals

Coal
Type

(Heating
Value
(J/g)

Sulfur
Content
(ng/J)
to Meet a

Capital
Cost
($I06)
90% Removal SO, Standard

Fixed
Operating
Cost
($I06)

Variable Operating
Cost
@CF= 1.0
($I06)

Capacity
Penalty
@ CF = 1.0
(MW)

Bituminous
Bituminous
Subbituminous
Lignite
30,700
25,600
19,800
16,300
455
1,410
350
490
43.25
55.71
42.94
46.08
0.41
0.41
0.41
0.41
7.11
12.89
6.44
7.13
26.9
27.0
28.6
30.7

-------
                                         Table B-2



Typical Electrostatic Precipitation Costs (1975) for a New 500 Mw Plant Burning Various Coals to
Meet a Particulate Standard of 22 ng/J


Coal
Type

CD ....
CO
Bituminous
Bituminous
Subbituminous
Lignite


Heating
Value
(J/g)


30,700
25,600
19,800
16,300


Sulfur
Content
(ng/J)


460
1,410
350
490


Ash
Content
(ng/J)


1,680
4,030
4,650
4,180


Capital
Cost
($I06)


16.49
1 1 .67
30.74
31.91


Fixed
Operating
Cost
($I06)


1.23
0.89
2.42
2.51

Variable
Operating
Cost
@ CF = 1.0
($I06)


0.05
0.117
0.136
0.122


Capacity
Penalty
@CF= 1.0
(MW)


3.2
2.4
6.0
6.3

-------
   3
to
O
U
O
U
LLJ
_
y
i—
cc
<
0.
    2-
     200
 i
400
                  500 MW, 1975 Costs
                  Midwest Location
                  0.65 Capacity Factor
                  Current NSPS Limit =  43 ng/J
                  Revised NSPS Limit =  22 ng/J
1
NSPS
O
0
A
KEY |
REVISED NSPS
O Bituminous-
Unc leaned
O Subbituminous
A Lignite

600
800
1000    1200    1400   1600
                    COAL SULFUR CONTENT (ng/J)

         Figure B-1  COST OF PARTICULATE CONTROL
              USING ELECTROSTATIC PRECIPITATORS FOR
                  NEW COAL-FIRED UTILITY BOILERS
                             B-4

-------
      1 -
          500 MW, 1975 COSTS, MIDWEST LOCATION
          0.65 CAPACITY FACTOR
          CURRENT NSPS LIMIT = Sttng/J
          REVISED NSPS LIMIT = 90% REMOVAL
                                 O Bituminous Cooi

                                 a Subbituminous Coal

                                 A Lignite
                    600   800    1000   1200

                     COAL SULFUR CONTENT (ng/J)

Figure B-2 COST OF SO, CONTROL FOR NEW COAL-FIRED
                   2  UTILITY BOILERS
              USING A LIMESTONE FGD SYSTEM
1400    1600
                              B-5

-------
The basis for the  particulate control costs are the same as for the FGD costs,
and operating energy  costs  are calculated as  discussed previously.   The cost
comparison illustrates  that the type of coal used is as important as the emission
limit in determining particulate control cost.
                                  B-6

-------
4. TITLE AND SUBTITLE
                                   TLCIIWICAL REKWT DATA
                           (!'k'o:;c read limlniftions on the jcrmr before coinptrtiiir)
 . REPORT NO.
 Review of New Source Performance Standards  for Coal-
 Fired Utility Boilers,  Volume II: Economic  and
 Financial  Impacts
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 Energy and Environmental Engineering Division
 Teknekron, Inc.
 2118 Milvia Street
 Berkely, California  94704
 12. SPONSORING AGENCY NAME AND ADDRESS
     U.S.  Environmental Protection Agency
     Office of Energy,  Minerals, and Industry
     Office'of Research and Development
     Washinaton, 1J.C.  20460
                                                           3. Kt-CIPIkNTS ACCb'SSIur+NO.
                           5. REPORT DATE
                           _March	1518	.
                           6. PERFORMING ORGANIZATION COOE
                                                           8. PERFORMING ORGANIZATION REPORT NO.
                                                           10. PROGRAM ELEMENT NO.
                                  INK 624
                           11. CONTRACT/GRANT NO.
                            68-01-1921
                           13. TYPE OF REPORT AND PERIOD COVERED
                           14. SPONSORING AGENCY COOE
                                 EPA-ORD
 15. SUPPLEMENTARY NOTES
     This project is part of the EPA-pianned and coordinated Federal Interagency
     Energy/Environment R&D Program.
 16. ABSTRACT
 This two volume  report summarizes a  study,, of the projected effects of several
 different revisions to the current New  Source Performance Standard (NSPS)  for  sulfur
 dioxide  (SC^)  emissions from coal-fired utility power boilers.  The revision is  as-
 sumed to apply to all coal-fired units  of  25 megawatts or greater generating capacity
 beginning, operation after 1982.  The revised standards which are considered  are:  (1)
 mandatory 90 percent S02 removal with an upper limit on emissions of 1.2  Ib  SO-  per
 million Btu;  (2)  mandatory 80 percent S02  removal with the same upper limit; (3)  no
 mandatory percentage removal with an upper limit of 0.5 Ib S02 per million Btu.   In
 addition, effects of revising the NSPS  for partic'ulate emissions from the  current
 value of 0.1 Ib  per million Btu down to 0.03 Ib are quantified.  Projections of  the
 structure of the electric utility industry both with and without the NSPS  revisions
 are given out  to the year 2000.  Volume 1  discusses air emissions, solid wastes,
 water consumption,  and energy requirements.   Volume 11 discusses economic  and
 financial effects,  including projections of pollution control costs and changes  in
 electricity prices.
17.
            (Circle One or More)
KCY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              li.lDCNTIF-IERS/OPCN ENDED TLRMS
                                        c.  COSATI I'icld/Groiip
     Earth Atmosphere
     Combustion
     Energy Conversion
               Energy Cycle: Energy
                 Conversion
               Fuel:  Coal
                                                                              97G
13. OISTHIBUI ION STATEMENT

  Release  to  public
              19. SECURITY CLASS (Tliis Report)
                unclassified
21. NO. Or PAGLS
	170	
22. P'FUCC      ~
                                                unclassified
EPA Form 2220-1 (9-73)
                   *U.S. GOYB
                           «TW6 OFFICE: 1978—260-880/98

-------