4
Accounting for the effects of rate regulation
Description of the
Matter
As disclosed in note 7 of the consolidated financial statements, the
Company has $3.6 billion in regulatory assets and $2.3 billion in regulatory
liabilities. The Company’s rate-regulated subsidiaries are subject to
regulation by various federal, state and provincial regulatory authorities in
the geographic regions in which they operate. The regulatory rates are
designed to recover the prudently incurred costs of providing the regulated
products or services and provide a reasonable return on the equity invested
or assets, as applicable. In addition to regulatory assets and liabilities, rate
regulation impacts multiple financial statement line items, including, but not
limited to, property, plant and equipment (“PP&E”), operating revenues and
expenses, income taxes, and depreciation expense.
Auditing the impact of rate regulation on the Company’s financial
statements is complex and highly judgmental due to the significant
judgments made by the Company to support its accounting and disclosure
for regulatory matters when final regulatory decisions or orders have not yet
been obtained or when regulatory formulas are complex. There is also
subjectivity involved in assessing the potential impact of future regulatory
decisions on the financial statements. Although the Company expects to
recover costs from customers through rates, there is a risk that the regulator
will not approve full recovery of the costs incurred. The Company’s
judgments include making an assessment of the probability of recovery of
and return on costs incurred, of the potential disallowance of part of the cost
incurred, or of the probable refund to customers through future rates.
How We Addressed
the Matter in Our
Audit
We performed audit procedures that included, amongst others, assessing
the Company’s evaluation of the probability of future recovery for regulatory
assets, PP&E, and refund of regulatory liabilities by obtaining and reviewing
relevant regulatory orders, filings, testimony, hearings and correspondence,
and other publicly available information. For regulatory matters for which
regulatory decisions or orders have not yet been obtained, we inspected the
rate-regulated subsidiaries’ filings for any evidence that might contradict the
Company’s assertions, and reviewed other regulatory orders, filings and
correspondence for other entities within the same or similar jurisdictions to
assess the likelihood of recovery in future rates based on the regulator’s
treatment of similar costs under similar circumstances. We obtained and
evaluated an analysis from the Company and corroborated that analysis
with letters from legal counsel, when appropriate, regarding cost recoveries
or future changes in rates. We also assessed the methodology, accuracy
and completeness of the Company’s calculations of regulatory asset and
liability balances based on provisions and formulas outlined in rate orders
and other correspondence with the regulators. We evaluated the
Company's disclosures related to the impacts of rate regulation.
Fair value measurement of derivative financial instruments
Description of the
Matter
Held-for-trading (“HFT”) derivative assets of $429 million and liabilities of
$1,301 million, disclosed in note 15 to the consolidated financial statements,
are measured at fair value. The Company recognized $64 million in realized
and unrealized gains during the year with respect to HFT derivatives.
Auditing the Company’s valuation of HFT derivatives is complex and highly
judgmental due to the complexity of the contract terms and valuation
models, and the significant estimation required in determining the fair value
of the contracts. In determining the fair value of HFT derivatives, significant
assumptions about future economic and market assumptions with uncertain
outcomes are used, including third-party sourced forward commodity pricing