Central Hudson Gas & Electric Corporation Submits Sur-Reply on Tariff Filing for Electric Tariff Schedule Modification

Strategic Insights -

Central Hudson Gas & Electric Corporation has submitted a Sur-Reply to the New York State Public Service Commission on its tariff filing to modify its electric tariff schedule, P.S.C. No 15, to update pole attachment rates applicable to cable system operators. The Sur-Reply addresses several inaccuracies and inferences presented in Charter Communications, Inc.'s Reply to Central Hudson's Responsive Comments. Central Hudson emphasizes the relevance of its actual pole costs applied to the New York State Public Service Commission's pole rental formula and refutes Charter's claims of understated accumulated depreciation reserve (ADR) and improper use of pole height and cost apportionment factor.

Key Takeaways:

  • Central Hudson's proposed pole attachment rate is based on its actual pole costs applied to the New York State Public Service Commission's pole rental formula.
  • Charter's claims of understated accumulated depreciation reserve (ADR) are refuted by Central Hudson, which used its actual ADR as shown in the correct Federal Energy Regulatory Commission (FERC) Account 108.
  • Central Hudson's pole plant ADR was set at a net salvage value of -40% in its most recent rate case, as shown in Sur-Reply Attachment 1.
  • Charter's argument that Central Hudson should deviate from the New York Pole Attachment Rate formula and use a pole height other than 37.5 feet and a cost apportionment factor other than 7.41% is baseless.
  • Central Hudson's Sur-Reply emphasizes the use of an eighteen (18) foot ground clearance for its pole attachments, which is based on the utility's approximate average span of 175 feet and expected wire sags.
  • Charter's Reply fails to discuss actual weighted average pole ownership share and equivalent weighted average ownership, which are 61.92% and 68.38% respectively, as shown on Sur-Reply Attachment 2.
  • The weighted average ownership percentage and associated equivalent weighted average ownership percentage increase the pole attachment rate, contrary to Charter's speculations.

Statistics:

  • The equivalent pole count changes from 127,913 to 126,209, increasing the pole attachment rate by approximately $0.34.
  • The actual weighted average pole ownership share is 61.92%, and the equivalent weighted average ownership is 68.38%.
  • The net salvage value of Central Hudson's pole plant ADR is set at -40% in its most recent rate case.

Sources:

  • Central Hudson Gas & Electric Corporation, Sur-Reply to Charter Communications, Inc.'s Reply to Central Hudson's Responsive Comments, filed June 30, 2022.
  • Charter Communications, Inc., Reply to Central Hudson Gas & Electric Corporation's Responsive Comments, filed June 22, 2022.
  • Central Hudson Gas & Electric Corporation, Response to Charter's Objections, filed May 31, 2022.