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Minutes of the Annual Meeting of the Power - New York Power ...

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F. Issue: Request for CoS Credit for Authority’s Investment Income.<br />

Public Comments:<br />

The Neighboring States argue that <strong>the</strong> Authority’s investment income should be<br />

treated as derived from “customer-contributed” capital and <strong>the</strong>refore credited<br />

against <strong>the</strong> CoS. (NS Comments, § 3). NYAPP concurs with this position.<br />

(Russell at 41).<br />

Staff Analysis:<br />

This novel argument again runs counter to <strong>the</strong> ratemaking principles established<br />

in <strong>the</strong> contracts. The preference rates are cost-based rates where no working<br />

capital charge is included and no real rate <strong>of</strong> return is earned. A portion <strong>of</strong> <strong>the</strong><br />

Authority’s investment income is derived from <strong>the</strong> Hydro Projects, but <strong>the</strong><br />

Authority’s investments are not preference customer-contributed capital for which<br />

<strong>the</strong> interest must be credited to <strong>the</strong> preference customers. A claim for a share <strong>of</strong><br />

<strong>the</strong> Authority’s investment income would produce preference rates that are below<br />

cost in violation <strong>of</strong> Auer Settlement principles. Yet, that is exactly <strong>the</strong> result if<br />

investment income derived from such excess revenues is used as a credit to <strong>the</strong><br />

CoS.<br />

Recommendation:<br />

Staff recommends that a credit not be provided for investment income.<br />

24

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