The following is management's discussion and analysis of certain significant factors that have affected the consolidated financial condition and results of operations of the Company during the periods included herein. Explanations include management's best estimate of the impact of weather, customer growth, usage trends and other factors. This discussion should be read in conjunction with the Company's historical unaudited Consolidated Financial Statements and Notes to Consolidated Financial Statements in Part I, Item 1 of this Form 10-Q.The Company's actual results in the future could differ significantly from the historical results. BHE is a holding company that owns a highly diversified portfolio of locally managed businesses principally engaged in the energy industry and is a consolidated subsidiary ofBerkshire Hathaway . As ofAugust 4, 2022 ,Berkshire Hathaway and family members and related or affiliated entities of the late Mr.Walter Scott , Jr., a former member of BHE's Board of Directors, beneficially owned 92% and 8%, respectively, of BHE's common stock.Berkshire Hathaway Energy's operations are organized as eight business segments:PacifiCorp ,MidAmerican Funding (which primarily consists ofMidAmerican Energy ), NV Energy (which primarily consists ofNevada Power and Sierra Pacific),Northern Powergrid (which primarily consists ofNorthern Powergrid (Northeast) plc andNorthern Powergrid (Yorkshire) plc),BHE Pipeline Group (which primarily consists of BHE GT&S,Northern Natural Gas andKern River ), BHE Transmission (which consists of BHE Canada (which primarily consists ofAltaLink ) and BHEU.S. Transmission),BHE Renewables and HomeServices. BHE, through these locally managed and operated businesses, owns four utility companies in theU.S. serving customers in 11 states, two electricity distribution companies inGreat Britain , five interstate natural gas pipeline companies, one of which owns a liquefied natural gas ("LNG") export, import and storage facility, in theU.S. , an electric transmission business inCanada , interests in electric transmission businesses in theU.S. , a renewable energy business primarily investing in wind, solar, geothermal and hydroelectric projects, the largest residential real estate brokerage firm in theU.S. and one of the largest residential real estate brokerage franchise networks in theU.S. The reportable segment financial information includes all necessary adjustments and eliminations needed to conform to the Company's significant accounting policies. The differences between the reportable segment amounts and the consolidated amounts, described as BHE and Other, relate principally to other entities, includingMidAmerican Energy Services, LLC , corporate functions and intersegment eliminations. 28 --------------------------------------------------------------------------------
Results of Operations for the Second Quarter and First Six Months of 2022 and 2021
Overview
Operating revenue and earnings on common shares for the Company's reportable segments are summarized as follows (in millions):
Second Quarter First Six Months 2022 2021 Change 2022 2021 Change Operating revenue: PacifiCorp$ 1,314 $ 1,298 $ 16 1 %$ 2,611 $ 2,540 $ 71 3 % MidAmerican Funding 897 693 204 29 1,902 1,760 142 8 NV Energy 899 767 132 17 1,592 1,358 234 17 Northern Powergrid 345 280 65 23 660 580 80 14 BHE Pipeline Group 856 706 150 21 1,891 1,799 92 5 BHE Transmission 183 182 1 1 366 362 4 1 BHE Renewables 294 267 27 10 461 457 4 1 HomeServices 1,672 1,763 (91) (5) 2,879 2,995 (116) (4) BHE and Other 152 108 44 41 280 294 (14) (5) Total operating revenue$ 6,612 $ 6,064 $ 548 9 %$ 12,642 $ 12,145 $ 497 4 % Earnings on common shares: PacifiCorp$ 83 $ 226 $ (143) (63) %$ 213 $ 395 $ (182) (46) % MidAmerican Funding 204 211 (7) (3) 445 355 90 25 NV Energy 93 100 (7) (7) 122 134 (12) (9) Northern Powergrid 71 (25) 96 * 182 79 103 * BHE Pipeline Group 199 100 99 99 521 483 38 8 BHE Transmission 62 60 2 3 124 119 5 4 BHE Renewables(1) 249 181 68 38 353 197 156 79 HomeServices 84 135 (51) (38) 105 219 (114) (52) BHE and Other 1,839 1,256 583 46 674 229 445 *
Total earnings on common shares
29 %$ 2,739 $ 2,210 $ 529 24 %
(1)Includes the tax attributes of disregarded entities that are not required to pay income taxes and the earnings of which are taxable directly to BHE.
* Not meaningful
Earnings on common shares increased$640 million for the second quarter of 2022 compared to 2021. The second quarter of 2022 included a pre-tax unrealized gain of$2,557 million ($2,020 million after-tax) compared to a pre-tax unrealized gain in the second quarter of 2021 of$1,954 million ($1,420 million after-tax) on the Company's investment in BYD Company Limited. Excluding the impact of this item, adjusted earnings on common shares for the second quarter of 2022 was$864 million , an increase of$40 million , or 5%, compared to adjusted earnings on common shares in the second quarter of 2021 of$824 million . Earnings on common shares increased$529 million for the first six months of 2022 compared to 2021. The first six months of 2022 included a pre-tax unrealized gain of$1,310 million ($1,035 million after-tax) compared to a pre-tax unrealized gain in the first six months of 2021 of$830 million ($602 million after-tax) on the Company's investment in BYD Company Limited. Excluding the impact of this item, adjusted earnings on common shares for the first six months of 2022 was$1,704 million , an increase of$96 million , or 6%, compared to adjusted earnings on commons shares in the first six months of 2021 of$1,608 million . 29 --------------------------------------------------------------------------------
The increases in earnings on common shares for the second quarter and for the first six months of 2022 compared to 2021 were primarily due to the following:
•The Utilities' earnings decreased$157 million for the second quarter and$104 million for the first six months of 2022 compared to 2021, reflecting higher operations and maintenance expense, higher depreciation and amortization expense and unfavorable investment earnings, partially offset by higher electric utility margin and a favorable income tax benefit from higher PTCs recognized. Electric retail customer volumes increased 1.3% for the first six months of 2022 compared to 2021, primarily due to higher customer usage and an increase in the average number of customers; •Northern Powergrid's earnings increased$96 million for the second quarter and$103 million for the first six months of 2022 compared to 2021, primarily due to a deferred income tax charge of$109 million related to aJune 2021 enacted increase in theUnited Kingdom corporate income tax rate from 19% to 25% effectiveApril 1, 2023 ; •BHE Pipeline Group's earnings increased$99 million for the second quarter and$38 million for the first six months of 2022 compared to 2021, largely due to higher earnings at BHE GT&S from favorable state unitary income tax adjustments, the impacts of the EGTS general rate case and lower operations and maintenance expense. In addition, earnings for the first six months decreased from the effects of higher margins on natural gas sales and higher transportation revenue in the first quarter of 2021 atNorthern Natural Gas from theFebruary 2021 polar vortex weather event; •BHE Renewables' earnings increased$68 million for the second quarter and$156 million for the first six months of 2022 compared to 2021, primarily due to higher operating revenue from owned renewable energy projects and higher earnings from tax equity investments, with the first six months being positively impacted by the unfavorable impacts in the first quarter of 2021 from theFebruary 2021 polar vortex weather event; •HomeServices' earnings decreased$51 million for the second quarter and$114 million for the first six months of 2022 compared to 2021, reflecting lower earnings from mortgage services mainly from a decrease in funded volumes and lower earnings from brokerage and settlement services largely attributable to a decrease in closed units at existing companies; and •BHE and Other's earnings increased$583 million for the second quarter and$445 million for the first six months of 2022 compared to 2021, mainly due to$600 million and$433 million , respectively, of favorable changes in the after-tax unrealized position of the Company's investment in BYD Company Limited and lower dividends on BHE's 4.00% Perpetual Preferred Stock issued to certain subsidiaries ofBerkshire Hathaway , partially offset by lower federal income tax credits recognized on a consolidated basis.
Reportable Segment Results
Operating revenue increased$16 million for the second quarter of 2022 compared to 2021, primarily due to higher wholesale and other revenue of$30 million , partially offset by lower retail revenue of$14 million . Wholesale and other revenue increased primarily due to higher average wholesale prices and higher wheeling revenue. Retail revenue decreased primarily due to lower retail volumes of$42 million , partially offset by price impacts of$28 million from higher average retail rates primarily due to tariff changes. Retail customer volumes decreased 3.3%, primarily due to the unfavorable impact of weather and lower customer usage, partially offset by an increase in the average number of customers. Earnings decreased$143 million for the second quarter of 2022 compared to 2021, primarily due to higher operations and maintenance expense of$120 million , an unfavorable income tax benefit and unfavorable changes in the cash surrender value of corporate-owned life insurance policies, partially offset by higher utility margin of$6 million . Operations and maintenance expense increased mainly due to an increase in the loss accruals associated with theSeptember 2020 wildfires, net of estimated insurance recoveries, and higher general and plant maintenance costs. Utility margin increased primarily due to lower purchased power costs and the higher wholesale and other revenue, partially offset by higher thermal generation costs, the lower retail revenue and lower deferred net power costs in accordance with established adjustment mechanisms. The unfavorable income tax benefit was largely due to lower PTCs recognized of$22 million and the effects of ratemaking of$18 million . 30 -------------------------------------------------------------------------------- Operating revenue increased$71 million for the first six months of 2022 compared to 2021, primarily due to higher wholesale and other revenue of$45 million and higher retail revenue of$26 million . Wholesale and other revenue increased primarily due to higher average wholesale prices and higher wheeling revenue. Retail revenue increased primarily due to price impacts of$43 million from higher average retail rates largely due to tariff changes, partially offset by lower retail volumes of$17 million . Retail customer volumes decreased 0.7%, primarily due to the unfavorable impact of weather and lower customer usage, partially offset by an increase in the average number of customers. Earnings decreased$182 million for the first six months of 2022 compared to 2021, primarily due to higher operations and maintenance expense of$138 million , an unfavorable income tax benefit, higher depreciation and amortization expense of$20 million , mainly from additional assets placed in-service, and unfavorable changes in the cash surrender value of corporate-owned life insurance policies, partially offset by higher utility margin of$20 million . Operations and maintenance expense increased mainly due to an increase in loss accruals related to theSeptember 2020 wildfires, net of estimated insurance recoveries, and higher general and plant maintenance costs. Utility margin increased primarily due to the higher retail, wholesale and other revenues, partially offset by higher thermal generation costs. The unfavorable income tax benefit was largely due to lower PTCs recognized of$27 million and the effects of ratemaking of$27 million .MidAmerican Funding Operating revenue increased$204 million for the second quarter of 2022 compared to 2021, primarily due to higher electric operating revenue of$139 million and higher natural gas operating revenue of$65 million . Electric operating revenue increased due to higher retail revenue of$77 million and higher wholesale and other revenue of$62 million . Electric retail revenue increased primarily due to higher recoveries through adjustment clauses of$59 million (fully offset in expense, primarily cost of sales) and higher customer volumes of$11 million . Electric wholesale and other revenue increased mainly due to higher average wholesale per-unit prices of$59 million . Electric retail customer volumes increased 3.3% due to higher customer usage and the favorable impact of weather. Natural gas operating revenue increased due to higher purchased gas adjustment recoveries of$63 million (fully offset in cost of sales), primarily from a higher average per-unit cost of natural gas sold. Earnings decreased$7 million for the second quarter of 2022 compared to 2021, primarily due to higher depreciation and amortization expense of$68 million , unfavorable changes in the cash surrender value of corporate-owned life insurance policies, higher operations and maintenance expense of$16 million and higher interest expense of$5 million , partially offset by higher electric utility margin of$68 million , a favorable income tax benefit and higher allowances for equity and borrowed funds used during construction of$9 million . Depreciation and amortization expense increased primarily from the impacts of certain regulatory mechanisms and additional assets placed in-service. Electric utility margin increased primarily due to the higher retail and wholesale revenues, partially offset by higher purchased power costs. The favorable income tax benefit was largely due to higher PTCs recognized of$39 million from higher wind-powered generation, partially offset by the effects of ratemaking. Operating revenue increased$142 million for the first six months of 2022 compared to 2021, primarily due to higher electric operating revenue of$202 million , partially offset by lower natural gas operating revenue of$51 million . Electric operating revenue increased due to higher wholesale and other revenue of$105 million and higher retail revenue of$97 million . Electric wholesale and other revenue increased mainly due to higher average wholesale per-unit prices of$78 million and higher wholesale volumes of$28 million . Electric retail revenue increased primarily due to higher recoveries through adjustment clauses of$63 million (fully offset in expense, primarily cost of sales) and higher customer volumes of$28 million . Electric retail customer volumes increased 4.4% due to higher customer usage and the favorable impact of weather. Natural gas operating revenue decreased due to lower purchased gas adjustment recoveries of$71 million (fully offset in cost of sales), primarily from a lower average per-unit cost of natural gas sold driven largely by theFebruary 2021 polar vortex weather event, partially offset by the impacts of certain regulatory recovery mechanisms of$5 million , the impacts of tax reform of$5 million and the favorable impact of weather of$5 million . Earnings increased$90 million for the first six months of 2022 compared to 2021, primarily due to higher electric utility margin of$157 million , a favorable income tax benefit, higher natural gas utility margin of$20 million and higher allowances for equity and borrowed funds used during construction of$20 million , partially offset by higher depreciation and amortization expense of$111 million , unfavorable changes in the cash surrender value of corporate-owned life insurance policies, higher operations and maintenance expense of$15 million , higher interest expense of$9 million and lower nonregulated utility margin of$8 million . Electric utility margin increased primarily due to the higher wholesale and retail revenues, partially offset by higher purchased power costs. The favorable income tax benefit was mainly due to higher PTCs recognized of$91 million from higher wind-powered generation, partially offset by the effects of ratemaking. Depreciation and amortization expense increased primarily from the impacts of certain regulatory mechanisms and additional assets placed in-service. 31 --------------------------------------------------------------------------------
NV Energy
Operating revenue increased$132 million for the second quarter of 2022 compared to 2021, primarily due to higher electric operating revenue of$123 million and higher natural gas operating revenue of$8 million . Electric operating revenue increased primarily due to higher fully-bundled energy rates (fully offset in cost of sales) of$121 million and higher regulatory-related revenue deferrals of$11 million , partially offset by unfavorable price impacts from changes in sales mix of$12 million . Electric retail customer volumes increased 0.4%, primarily due to an increase in the average number of customers, partially offset by the unfavorable impact of weather. Natural gas operating revenue increased primarily due to a higher average per-unit cost of natural gas sold (fully offset in cost of sales). Earnings decreased$7 million for the second quarter of 2022 compared to 2021, mainly due to unfavorable changes in the cash surrender value of corporate-owned life insurance policies, higher depreciation and amortization expense of$3 million , primarily from additional plant placed in-service, and higher operations and maintenance expense of$2 million , primarily from an unfavorable change in earnings sharing at theNevada Utilities , partially offset by higher interest and dividend income of$9 million , primarily from carrying charges on regulatory balances. Operating revenue increased$234 million for the first six months of 2022 compared to 2021, primarily due to higher electric operating revenue of$213 million and higher natural gas operating revenue of$21 million . Electric operating revenue increased primarily due to higher fully-bundled energy rates (fully offset in cost of sales) of$209 million , higher regulatory-related revenue deferrals of$8 million and higher transmission and wholesale revenue of$5 million , partially offset by unfavorable price impacts from changes in sales mix of$7 million . Electric retail customer volumes increased 2.0%, primarily due to an increase in the average number of customers and higher customer usage, partially offset by the unfavorable impact of weather. Natural gas operating revenue increased primarily due to a higher average per-unit cost of natural gas sold (fully offset in cost of sales). Earnings decreased$12 million for the first six months of 2022 compared to 2021, mainly due to unfavorable changes in the cash surrender value of corporate-owned life insurance policies, higher operations and maintenance expense of$8 million , primarily from an unfavorable change in earnings sharing at theNevada Utilities and increased plant operations and maintenance expenses, and higher depreciation and amortization expense of$6 million , primarily from additional plant placed in-service, partially offset by higher interest and dividend income of$14 million , primarily from carrying charges on regulatory balances.Northern Powergrid Operating revenue increased$65 million for the second quarter of 2022 compared to 2021, primarily due to higher distribution revenue of$60 million and revenue from a gas project that commenced commercial operation inMarch 2022 totaling$40 million , partially offset by$40 million from the strongerU.S. dollar. Distribution revenue increased due to the recovery of Supplier ofLast Resort payments totaling$45 million (fully offset in cost of sales) and higher tariff rates of$25 million , partially offset by a 4.0% decline in units distributed of$9 million . Earnings increased$96 million for the second quarter of 2022 compared to 2021, primarily due to a deferred income tax charge of$109 million related to aJune 2021 enacted increase in theUnited Kingdom corporate income tax rate from 19% to 25% effectiveApril 1, 2023 and the higher distribution tariff rates, partially offset by higher distribution-related operating and depreciation expenses of$27 million , including higher storm-related costs,$9 million from the strongerU.S. dollar and the decline in units distributed. Operating revenue increased$80 million for the first six months of 2022 compared to 2021, primarily due to higher distribution revenue of$70 million and revenue from a gas project that commenced commercial operation inMarch 2022 totaling$50 million , partially offset by$45 million from the strongerU.S. dollar. Distribution revenue increased due to the recovery of Supplier ofLast Resort payments totaling$45 million (fully offset in cost of sales) and higher tariff rates of$39 million , partially offset by a 3.3% decline in units distributed of$12 million . Earnings increased$103 million for the first six months of 2022 compared to 2021, primarily due to a deferred income tax charge of$109 million related to aJune 2021 enacted increase in theUnited Kingdom corporate income tax rate from 19% to 25% effectiveApril 1, 2023 and the higher distribution tariff rates, partially offset by higher distribution-related operating and depreciation expenses of$27 million , including higher storm-related costs, the decline in units distributed and$8 million from the strongerU.S. dollar. 32 --------------------------------------------------------------------------------
Operating revenue increased$150 million for the second quarter of 2022 compared to 2021, primarily due to higher non-regulated revenue of$58 million (largely offset in cost of sales) at BHE GT&S from favorable pricing, an increase in regulated gas transportation and storage services rates due to an agreement in principle for EGTS' general rate case of$25 million , higher LNG variable revenue of$25 million atCove Point , higher transportation revenue of$17 million atNorthern Natural Gas due to higher volumes and rates and higher gas sales of$9 million (largely offset in cost of sales) related to system balancing activities atNorthern Natural Gas . Earnings increased$99 million for the second quarter of 2022 compared to 2021, primarily due to higher earnings of$90 million at BHE GT&S largely due to favorable state unitary income tax adjustments, the impacts of the EGTS general rate case, lower operations and maintenance expense, favorable valuations of system gas and higher margin from non-regulated activities. Operating revenue increased$92 million for the first six months of 2022 compared to 2021, primarily due to higher non-regulated revenue of$69 million (largely offset in cost of sales) at BHE GT&S from favorable pricing, higher LNG variable revenue of$38 million atCove Point and an increase in regulated gas transportation and storage services rates due to an agreement in principle for EGTS' general rate case of$25 million , partially offset by lower gas sales of$32 million related to system balancing activities atNorthern Natural Gas , lower gas sales of$17 million at EGTS used for operational and system balancing purposes and lower transportation revenue of$3 million atNorthern Natural Gas . The variances in gas sales and transportation revenue atNorthern Natural Gas included favorable impacts recognized in the first quarter of 2021 of$77 million and$49 million , respectively, from theFebruary 2021 polar vortex weather event. Excluding this item, gas sales increased$45 million (largely offset in cost of sales) and transportation revenue increased$46 million due to higher volumes and rates. Earnings increased$38 million for the first six months of 2022 compared to 2021, primarily due to higher earnings of$99 million at BHE GT&S, partially offset by lower earnings of$60 million atNorthern Natural Gas . Earnings at BHE GT&S increased mainly due to favorable state unitary income tax adjustments, the impacts of the EGTS general rate case, lower operations and maintenance expense, favorable property tax assessments, increased earnings atCove Point and higher margin from non-regulated activities. Earnings atNorthern Natural Gas decreased as the higher gross margin on gas sales and higher transportation revenue in the first quarter of 2021 from theFebruary 2021 polar vortex weather event were partially offset by the favorable transportation revenue due to higher volumes and rates. BHE Transmission Operating revenue increased$1 million for the second quarter and$4 million for the first six months of 2022 compared to 2021, primarily due to higher non-regulated revenue and higher revenue atAltaLink from recovery of higher costs, partially offset by$7 million from the weakerU.S. dollar.
Earnings increased
Operating revenue increased$27 million for the second quarter of 2022 compared to 2021, primarily due to higher wind, geothermal and solar revenues of$51 million from higher generation and pricing, partially offset by unfavorable changes in the valuation of certain derivative contracts totaling$14 million and lower natural gas revenues of$13 million from lower generation. Earnings increased$68 million for the second quarter of 2022 compared to 2021, primarily due to higher wind earnings of$58 million and higher geothermal earnings of$11 million , largely due to the higher operating revenue and lower maintenance costs. Wind earnings increased primarily due to higher earnings from owned projects of$31 million , largely from the higher operating revenue and favorable production tax credits offset by the unfavorable derivative contract valuations, and higher earnings from tax equity investments of$27 million , mainly from higher production tax credits offset by unfavorable performance. 33 -------------------------------------------------------------------------------- Operating revenue increased$4 million for the first six months of 2022 compared to 2021, primarily due to higher wind, geothermal and solar revenues of$77 million from higher generation and pricing, partially offset by unfavorable changes in the valuation of certain derivative contracts totaling$57 million , lower natural gas revenues of$10 million from lower generation and lower hydro revenues of$6 million due to the transfer of the Casecnan generating facility to thePhilippine National Irrigation Administration inDecember 2021 . Earnings increased$156 million for the first six months of 2022 compared to 2021, primarily due to higher wind earnings of$150 million , higher solar earnings of$10 million , mainly due to the higher operating revenue, and higher geothermal earnings of$9 million , largely due to the higher operating revenue and lower maintenance costs, partially offset by lower hydro earnings of$10 million due to the Casecnan generating facility transfer. Wind earnings increased primarily due to higher earnings from tax equity investments of$123 million , mainly as a result of the unfavorable impacts in the first quarter of 2021 from theFebruary 2021 polar vortex weather event and higher production tax credits offset by unfavorable performance, and higher earnings from owned projects of$27 million , largely from the higher operating revenue and favorable production tax credits offset by the unfavorable derivative contract valuations.
HomeServices
Operating revenue decreased
Earnings decreased$51 million for the second quarter of 2022 compared to 2021, primarily due to lower earnings from brokerage and settlement services of$33 million , largely attributable to the decrease in closed units at existing companies, and lower earnings from mortgage services of$22 million from the decrease in funded volume. Operating revenue decreased$116 million for the first six months of 2022 compared to 2021, primarily due to lower mortgage revenue of$160 million from a 34% decrease in funded volume due to a decline in refinance activity, partially offset by higher brokerage revenue of$67 million from a 3% increase in closed transaction volume. The increase in brokerage volume was due to acquisitions and a 10% increase in average sales price at existing companies offset by 15% fewer closed units at existing companies. Earnings decreased$114 million for the first six months of 2022 compared to 2021, primarily due to lower earnings from mortgage services of$71 million and lower earnings from brokerage and settlement services of$49 million due to the decrease in closed units at existing companies. Earnings from mortgage services were lower primarily due to the decrease in funded volumes, partially offset by favorable operating expense variances.
BHE and Other
Operating revenue increased$44 million for the second quarter of 2022 compared to 2021, primarily due to higher electricity and natural gas sales revenue atMidAmerican Energy Services, LLC , from favorable pricing and higher electricity volumes offset by lower natural gas volumes. Earnings increased$583 million for the second quarter of 2022 compared to 2021, primarily due to the$600 million favorable comparative change in the after-tax unrealized position of the Company's investment in BYD Company Limited, lower corporate costs and$25 million of lower dividends on BHE's 4.00% Perpetual Preferred Stock issued to certain subsidiaries ofBerkshire Hathaway , partially offset by$41 million of lower federal income tax credits recognized on a consolidated basis, unfavorable changes in the cash surrender value of corporate-owned life insurance policies and higher BHE corporate interest expense from anApril 2022 debt issuance. 34 --------------------------------------------------------------------------------
Operating revenue decreased
Earnings increased$445 million for the first six months of 2022 compared to 2021, primarily due to the$433 million favorable comparative change in the after-tax unrealized position of the Company's investment in BYD Company Limited, lower corporate costs,$46 million of lower dividends on BHE's 4.00% Perpetual Preferred Stock issued to certain subsidiaries ofBerkshire Hathaway and higher earnings of$45 million atMidAmerican Energy Services, LLC , mainly due to favorable changes in unrealized positions on derivative contracts, partially offset by$95 million of lower federal income tax credits recognized on a consolidated basis, unfavorable changes in the cash surrender value of corporate-owned life insurance policies and higher BHE corporate interest expense from anApril 2022 debt issuance.
Liquidity and Capital Resources
Each of BHE's direct and indirect subsidiaries is organized as a legal entity separate and apart from BHE and its other subsidiaries. It should not be assumed that the assets of any subsidiary will be available to satisfy BHE's obligations or the obligations of its other subsidiaries. However, unrestricted cash or other assets that are available for distribution may, subject to applicable law, regulatory commitments and the terms of financing and ring-fencing arrangements for such parties, be advanced, loaned, paid as dividends or otherwise distributed or contributed to BHE or affiliates thereof. The Company's long-term debt may include provisions that allow BHE or its subsidiaries to redeem such debt in whole or in part at any time. These provisions generally include make-whole premiums. Refer to Note 18 of Notes to Consolidated Financial Statements in Item 8 of the Company's Annual Report on Form 10-K for the year endedDecember 31, 2021 for further discussion regarding the limitation of distributions from BHE's subsidiaries. As ofJune 30, 2022 , the Company's total net liquidity was as follows (in millions): BHE Pipeline MidAmerican NV Northern BHE Group and BHEPacifiCorp Funding Energy PowergridCanada HomeServices Other Total Cash and cash equivalents$ 61 $ 390 $ 497 $ 83 $ 327 $ 60 $ 294 $ 369$ 2,081 Credit facilities(1) 3,500 1,200 1,509 650 259 835 3,400 - 11,353 Less: Short-term debt (385) - - - (15) (378) (1,170) - (1,948) Tax-exempt bond support and letters of credit - (218) (370) - - (1) - - (589) Net credit facilities 3,115 982 1,139 650 244 456 2,230 - 8,816 Total net liquidity$ 3,176 $ 1,372 $ 1,636 $ 733 $ 571 $ 516 $ 2,524 $ 369$ 10,897 Credit facilities: Maturity dates 2025 2025 2023, 2025 2025 2024, 2026 2023, 2026 2022, 2023, 2026
(1)Includes
Operating Activities
Net cash flows from operating activities for the six-month periods endedJune 30, 2022 and 2021 were$5.1 billion and$4.2 billion , respectively. The increase was primarily due to changes in working capital and favorable income tax cash flows.
The timing of the Company's income tax cash flows from period to period can be significantly affected by the estimated federal income tax payment methods selected and assumptions made for each payment date.
35 --------------------------------------------------------------------------------
Investing Activities
Net cash flows from investing activities for the six-month periods endedJune 30, 2022 and 2021 were$(3.5) billion and$(3.0) billion , respectively. The change was primarily due to higher capital expenditures of$534 million . Refer to "Future Uses of Cash" for a discussion of capital expenditures.
Financing Activities
Net cash flows from financing activities for the six-month period endedJune 30, 2022 was$(605) million . Sources of cash totaled$2,188 million and consisted of proceeds from subsidiary debt issuances totaling$1.2 billion and proceeds from BHE senior debt issuances totaling$987 million . Uses of cash totaled$2,793 million and consisted mainly of purchases of common stock totaling$870 million , preferred stock redemptions of$800 million , repayments of subsidiary debt totaling$542 million , distributions to noncontrolling interests of$246 million and net repayments of short-term debt totaling$54 million . For discussions of recent financing and BHE shareholders' equity transactions, refer to Notes 4 and 10 of Notes to Consolidated Financial Statements in Part I, Item 1 of this Form 10-Q. Net cash flows from financing activities for the six-month period endedJune 30, 2021 was$(1.2) billion . Sources of cash totaled$784 million and consisted of proceeds from subsidiary debt issuances totaling$539 million and net proceeds from short-term debt of$245 million . Uses of cash totaled$2.0 billion and consisted mainly of repayments of subsidiary debt totaling$1.2 billion , repayments of BHE senior debt totaling$450 million and distributions to noncontrolling interests of$234 million .
Future Uses of Cash
The Company has available a variety of sources of liquidity and capital resources, both internal and external, including net cash flows from operating activities, public and private debt offerings, the issuance of commercial paper, the use of unsecured revolving credit facilities, the issuance of equity and other sources. These sources are expected to provide funds required for current operations, capital expenditures, acquisitions, investments, debt retirements and other capital requirements. The availability and terms under which BHE and each subsidiary has access to external financing depends on a variety of factors, including regulatory approvals, its credit ratings, investors' judgment of risk and conditions in the overall capital markets, including the condition of the utility industry and project finance markets, among other items.
Capital Expenditures
The Company has significant future capital requirements. Capital expenditure needs are reviewed regularly by management and may change significantly as a result of these reviews, which may consider, among other factors, impacts to customers' rates; changes in environmental and other rules and regulations; outcomes of regulatory proceedings; changes in income tax laws; general business conditions; load projections; system reliability standards; the cost and efficiency of construction labor, equipment and materials; commodity prices; and the cost and availability of capital. 36 -------------------------------------------------------------------------------- The Company's historical and forecast capital expenditures, each of which exclude amounts for non-cash equity AFUDC and other non-cash items, are as follows (in millions): Six-Month Periods Annual Ended June 30, Forecast 2021 2022 2022 Capital expenditures by business: PacifiCorp$ 819 $ 894
MidAmerican Funding 720 862
1,913
NV Energy 365 541
1,228
Northern Powergrid 369 450
776
BHE Pipeline Group 308 457 1,252 BHE Transmission 156 95 210 BHE Renewables 80 60 185 HomeServices 18 20 55 BHE and Other(1) 13 3 16 Total$ 2,848 $ 3,382 $ 7,914 Capital expenditures by type: Wind generation$ 483 $ 300
Electric distribution 817 815
1,763
Electric transmission 339 620
1,773
Natural gas transmission and storage 308 336 976 Solar generation 67 100 230 Other 834 1,211 2,286 Total$ 2,848 $ 3,382 $ 7,914
(1)BHE and Other represents amounts related principally to other entities,
including
The Company's historical and forecast capital expenditures consisted mainly of the following:
•Wind generation includes both growth and operating expenditures. Growth expenditures include spending for the following:
•Construction of wind-powered generating facilities atMidAmerican Energy totaling$5 million and$172 million for the six-month periods endedJune 30, 2022 and 2021, respectively. Planned spending for the construction of additional wind-powered generating facilities totals$106 million for the remainder of 2022. •Repowering of wind-powered generating facilities atMidAmerican Energy totaling$214 million and$82 million for the six-month periods endedJune 30, 2022 and 2021, respectively. Planned spending for the repowering of wind-powered generating facilities totals$314 million for the remainder of 2022.MidAmerican Energy expects its repowered facilities to meet Internal Revenue Service guidelines for the re-establishment of PTCs for 10 years from the date the facilities are placed in-service. The rate at which PTCs are re-established for a facility depends upon the date construction begins. Of the 593 MWs of current repowering projects not in-service as ofJune 30, 2022 , 292 MWs are currently expected to qualify for 80% of the PTCs available for 10 years following each facility's return to service and 301 MWs are expected to qualify for 60% of such credits. •Construction of wind-powered generating facilities atPacifiCorp totaling$4 million and$79 million for the six-month periods endedJune 30, 2022 and 2021, respectively. Construction includes 516 MWs of new wind-powered generating facilities that were placed in-service in 2021. Planned spending for the construction of additional wind-powered generating facilities totals$24 million for the remainder of 2022. The energy production from the new wind-powered generating facilities placed in-service by the end of 2024 is expected to qualify for 60% of the federal PTCs available for 10 years once the equipment is placed in-service. 37 -------------------------------------------------------------------------------- •Planned acquisition and repowering of two wind-powered generating facilities byPacifiCorp totaling$7 million and$2 million (excluding the 2021 sale of wind turbines) for the six-month periods endedJune 30, 2022 and 2021, respectively. In 2021,PacifiCorp sold wind turbines previously acquired from a third party toBHE Wind, LLC , an indirect wholly owned subsidiary of BHE, for$6 million . The repowered facilities are expected to be placed in-service in 2023 and 2024. Planned spending for acquiring and repowering generating facilities totals$14 million for the remainder of 2022.
•Repowering of wind-powered generating facilities at
•Electric distribution includes both growth and operating expenditures. Growth expenditures include spending for new customer connections and enhancements to existing customer connections. Operating expenditures include spending for ongoing distribution systems infrastructure needed at the Utilities andNorthern Powergrid , wildfire mitigation, storm damage restoration and repairs and investments in routine expenditures for distribution needed to serve existing and expected demand.
•Electric transmission includes both growth and operating expenditures. Growth expenditures include spending for the following:
•PacifiCorp's transmission investment primarily reflects planned costs for the 416-mile, 500-kV high-voltage transmission line between the Aeolus substation nearMedicine Bow, Wyoming and the Clover substation nearMona, Utah ; the 59-mile, 230-kV high-voltage transmission line between theWindstar substation nearGlenrock, Wyoming and the Aeolus substation; and the 290-mile, 500-kV high-voltage transmission line from the Longhorn substation nearBoardman, Oregon to the Hemingway substation nearBoise, Idaho . Expenditures for these segments totaled$296 million and$35 million for the six-month periods endedJune 30, 2022 and 2021, respectively. Planned spending for these Energy Gateway Transmission segments to be placed in-service in 2024-2026 totals$614 million for the remainder of 2022. •Nevada Utilities' Greenlink Nevada transmission expansion program. In this project, the company has received approval from the PUCN to build a 350-mile, 525-kV transmission line, known as Greenlink West, connecting the Ft.Churchill substation to the Northwest substation to the Harry Allen substation; a 235-mile, 525-kV transmission line, known as Greenlink North, connecting the new Ft.Churchill substation to the Robinson Summit substation; a 46-mile, 345-kV transmission line from the new Ft.Churchill substation to the Mira Loma substations; and a 38-mile, 345-kV transmission line from the new Ft.Churchill substation to the Robinson Summit substations. Expenditures for the expansion program and other growth projects totaled$60 million and$41 million for the six-month periods endedJune 30, 2022 and 2021, respectively. Planned spending for the expansion program estimated to be placed in-service in 2026-2028 and other growth projects totals$109 million for the remainder of 2022. •Operating expenditures include spending for system reinforcement, upgrades and replacements of facilities to maintain system reliability and investments in routine expenditures for transmission needed to serve existing and expected demand. •Natural gas transmission and storage includes both growth and operating expenditures. Growth expenditures include, among other items, spending for the Northern Natural Gas Twin Cities Area Expansion and Spraberry Compression projects. Operating expenditures include, among other items, spending for asset modernization, pipeline integrity projects and natural gas transmission, storage and liquefied natural gas terminalling infrastructure needs to serve existing and expected demand.
•Solar generation includes growth expenditures, including spending for the following:
•Construction of solar-powered generating facilities atMidAmerican Energy totaling 141 MWs of small- and utility-scale solar generation, with total spend of$77 million and$63 million for the six-month periods endedJune 30, 2022 and 2021, respectively and planned spending of$63 million for the remainder of 2022. •Construction of a solar-powered generating facility atNevada Power totaling$23 million and$5 million for the six-month periods endedJune 30, 2022 and 2021, respectively and planned spending of$67 million for the remainder of 2022. Construction includes expenditures for a 150-MW solar photovoltaic facility with an additional 100 MWs of co-located battery storage that will be developed inClark County, Nevada . Commercial operation is expected by the end of 2023. 38 --------------------------------------------------------------------------------
•Other capital expenditures includes both growth and operating expenditures, including spending for routine expenditures for generation and other infrastructure needed to serve existing and expected demand, natural gas distribution, technology, and environmental spending relating to emissions control equipment and the management of coal combustion residuals.
Material Cash Requirements
As ofJune 30, 2022 , there have been no material changes in cash requirements from the information provided in Item 7 of the Company's Annual Report on Form 10-K for the year endedDecember 31, 2021 , other than those disclosed in Notes 4 and 8 of the Notes to Consolidated Financial Statements in Part I, Item 1 of this Form 10-Q.
Quad Cities Generating Station Operating Status
Constellation Energy Corp. ("Constellation Energy," previouslyExelon Generation Company, LLC , which was a subsidiary of Exelon Corporation prior toFebruary 1, 2022 ), the operator of Quad Cities Generating Station Units 1 and 2 ("Quad Cities Station ") of whichMidAmerican Energy has a 25% ownership interest, announced onJune 2, 2016 , its intention to shut downQuad Cities Station onJune 1, 2018 . InDecember 2016 ,Illinois passed legislation creating a zero emission standard, which went into effectJune 1, 2017 . The zero emission standard requires theIllinois Power Agency to purchase ZECs and recover the costs from certain ratepayers inIllinois , subject to certain limitations. The proceeds from the ZECs will provide Constellation Energy additional revenue through 2027 as an incentive for continued operation ofQuad Cities Station .MidAmerican Energy will not receive additional revenue from the subsidy. ThePJM Interconnection, L.L.C. ("PJM") capacity market includes a MinimumOffer Price Rule ("MOPR"). If a generation resource is subjected to a MOPR, its offer price in the market is adjusted to effectively remove the revenues it receives through a state government-provided financial support program, resulting in a higher offer that may not clear the capacity market. Prior toDecember 19, 2019 , the PJM MOPR applied only to certain new gas-fired resources. An expanded PJM MOPR to include existing resources would require exclusion of ZEC compensation when bidding into future capacity auctions, resulting in an increased risk ofQuad Cities Station not receiving capacity revenues in future auctions. OnDecember 19, 2019 , theFERC issued an order requiring the PJM to broadly apply the MOPR to all new and existing resources, including nuclear. This greatly expanded the breadth and scope of the PJM's MOPR, which became effective as of the PJM's capacity auction for the 2022-2023 planning year inMay 2021 . While theFERC included some limited exemptions, no exemptions were available to state-supported nuclear resources, such asQuad Cities Station . TheFERC provided no new mechanism for accommodating state-supported resources other than the existing Fixed Resource Requirement ("FRR") mechanism under which an entire utility zone would be removed from PJM's capacity auction along with sufficient resources to support the load in such zone. In response to theFERC's order, the PJM submitted a compliance filing onMarch 18, 2020 , wherein the PJM proposed tariff language reflecting theFERC's directives and a schedule for resuming capacity auctions. OnApril 16, 2020 , theFERC issued an order largely denying requests for rehearing of theFERC's December 2019 order but granting a few clarifications that required an additional PJM compliance filing, which the PJM submitted onJune 1, 2020 . A number of parties, including Constellation Energy, have filed petitions for review of theFERC's orders in this proceeding, which remain pending before the D.C. Circuit. As a result, the MOPR applied toQuad Cities Station in the capacity auction for the 2022-2023 planning year, which preventedQuad Cities Station from clearing in that capacity auction. At the direction of the PJM Board of Managers, the PJM and its stakeholders developed further MOPR reforms to ensure that the capacity market rules respect and accommodate state resource preferences such as the ZEC programs. The PJM filed related tariff revisions at theFERC onJuly 30, 2021 , and, onSeptember 29, 2021 , the PJM's proposed MOPR reforms became effective by operation of law. Under the new tariff provisions, the MOPR will no longer apply toQuad Cities Station . Requests for rehearing of theFERC's notice establishing the effective date for the PJM's proposed market reforms were filed inOctober 2021 and denied by operation of law onNovember 4, 2021 . Several parties have filed petitions for review of theFERC's orders in this proceeding, which remain pending before theCourt of Appeals for the Third Circuit . Constellation Energy is strenuously opposing these appeals. 39 -------------------------------------------------------------------------------- Assuming the continued effectiveness of theIllinois zero emission standard, Constellation Energy no longer considersQuad Cities Station to be at heightened risk for early retirement. However, to the extent theIllinois zero emission standard does not operate as expected over its full term,Quad Cities Station would be at heightened risk for early retirement. TheFERC's December 19, 2019 order on the PJM MOPR may undermine the continued effectiveness of theIllinois zero emission standard unless the PJM adopts further changes to the MOPR orIllinois implements an FRR mechanism, under whichQuad Cities Station would be removed from the PJM's capacity auction.
Regulatory Matters
BHE's regulated subsidiaries and certain affiliates are subject to comprehensive regulation. The discussion below contains material developments to those matters disclosed in Item 1 of each Registrant's Annual Report on Form 10-K for the year endedDecember 31, 2021 and new regulatory matters occurring in 2022.
InMarch 2022 ,PacifiCorp filed a general rate case requesting an overall rate change of$82 million , or 6.6%, to become effectiveJanuary 1, 2023 , that includes cost increases associated with the implementation ofPacifiCorp's wildfire mitigation and vegetation management plans. Parties to the case filed testimony inJune 2022 .PacifiCorp filed reply testimony inJuly 2022 supporting an overall rate increase of$94 million but proposing that the request be capped atPacifiCorp's original request. A hearing in the rate case will be held inSeptember 2022 with an order expected inDecember 2022 . InMay 2022 ,PacifiCorp filed its 2021 power cost adjustment mechanism ("PCAM"), which is the first time since the mechanism has been in place that a rate change has been warranted. After consideration of the mechanism's deadband, sharing band and earnings test,PacifiCorp is requesting recovery of$52 million , or a 4.2% increase, to become effectiveJanuary 1, 2023 . This request is incremental to the rate change sought in the general rate case. InJuly 2022 ,PacifiCorp filed an application requesting approval of an automatic adjustment clause with a balancing account to recover costs associated with implementingPacifiCorp's wildfire protection plan inOregon . OregonSenate Bill 762 provides for utilities to timely recover these costs through an automatic adjustment clause. The filing requests a rate increase of$20 million , or 1.6%, to recover incremental costs in 2022. WhilePacifiCorp requested an effective date ofAugust 24, 2022 , the OPUC has suspended the filing for further review.Washington InJune 2021 ,PacifiCorp filed a power cost only rate case to update baseline net power costs for 2022.PacifiCorp requested a$13 million , or 3.7%, rate increase with an effective date ofJanuary 1, 2022 . InNovember 2021 ,PacifiCorp reached a proposed settlement with most of the parties, which includes an agreement to adjust the PTC rate in base rates and apply a production factor and to include a net power cost update as part of the compliance filing. A hearing was held inJanuary 2022 and the WUTC issued an order approving the settlement inMarch 2022 . A compliance filing reflecting a$43 million , or 12.2%, increase was filed inApril 2022 with rates effectiveMay 1, 2022 . InJune 2022 ,PacifiCorp filed its 2021 PCAM and the new tracking mechanism for PTCs approved in the 2021 general rate case. For the 2021 PCAM,PacifiCorp is requesting recovery of$26 million , or a 6.5% increase.PacifiCorp proposed that the 2021 PCAM be amortized over two years, rather than the one-year period required under the current terms of the PCAM. For the new 2021 PTC tracker,PacifiCorp is seeking recovery of$3 million , or an 0.8% increase. Should the WUTC approve the proposal to extend the amortization period of the 2021 PCAM from one to two years, the combined annual increase would be$16 million , or 4.0%, effectiveJanuary 1, 2023 .
InMay 2022 ,PacifiCorp filed a general rate case requesting an overall rate change of$28 million , or 25.7%, to become effectiveJanuary 1, 2023 . InJune 2022 , a proposed procedural schedule was developed that would result in a decision inAugust 2023 . 40 --------------------------------------------------------------------------------
In
Wind PRIME
InJanuary 2022 ,MidAmerican Energy filed an application with the IUB for advance ratemaking principles for Wind PRIME. If approved,MidAmerican Energy expects to proceed with Wind PRIME, which consists of up to 2,042 MWs of new wind generation and up to 50 MWs of solar generation. If all of Wind PRIME generation is constructed,MidAmerican Energy will own over 9,300 MWs of wind generation and nearly 200 MWs of solar generation. Wind PRIME is projected to allowMidAmerican Energy to generate renewable energy greater than or equal to all of itsIowa retail customers' annual energy needs.MidAmerican Energy secured sufficient safe harbor equipment necessary to remain eligible for 60% PTCs under current tax law. Procedural hearings with the IUB are scheduled to begin inOctober 2022 .
NV Energy (Nevada Power and Sierra Pacific)
Regulatory Rate Review
InJune 2022 , Sierra Pacific filed a regulatory rate review with the PUCN that requested an annual revenue increase of$88 million , or 9.7%. In addition, a filing was made to revise depreciation rates based on a study, the results of which are reflected in the proposed revenue requirement. An order is expected by the end of 2022 and, if approved, would be effectiveJanuary 1, 2023 .
Senate Bill 448 ("SB 448")
SB 448 was signed into law onJune 10, 2021 . The legislation is intended to accelerate transmission development, renewable energy and storage, and accelerate transportation electrification within the state of Nevada. InSeptember 2021 , theNevada Utilities filed an amendment to the 2021 Joint IRP for the approval of their Transmission Infrastructure for a Clean Energy Economy Plan that sets forth a plan for the construction of high-voltage transmission infrastructure, Greenlink North among others, that will be placed into service no later thanDecember 31, 2028 , and requires the IRP to include at least one scenario that uses sources of supply that will achieve certain reductions in carbon dioxide emissions. InSeptember 2021 , theNevada Utilities filed an application for the approval of their Economic Recovery Transportation Electrification Plan to accelerate transportation electrification in the state of Nevada. The plan establishes requirements for the contents of the transportation electrification investment as well as requirements for review, cost recovery and monitoring. The plan covers an initial period beginningJanuary 1, 2022 and ending onDecember 31, 2024 . InNovember 2021 , the PUCN issued an order granting the application and accepting the Economic Recovery Transportation Electrification Plan with some modifications. The PUCN opened rulemakings to address other regulations that resulted from SB 448. InFebruary 2022 , the PUCN adopted regulations regarding theEconomic Development Electric Rate Rider Program to revise the discounted electric rates to ease the economic burden on small businesses who take advantage of the discounted rates under the tariff. The remaining two SB 448 rulemakings are ongoing.
ON Line Temporary Rider ("ONTR")
InOctober 2021 , Sierra Pacific filed an application with the PUCN for approval of the ONTR with corresponding updates to its electric rate tariffs to authorize recovery of the One Nevada Transmission Line ("ON Line") regulatory asset being accumulated as a result of the ON Line cost reallocation as well as the related on-going reallocated revenue requirement. Sierra Pacific's application would have, if approved by the PUCN as filed, resulted in a one-time rate increase of$28 million to be collected over a nine-month period starting onApril 1, 2022 . InMarch 2022 , the PUCN issued an order directing Sierra Pacific to recover$14 million of the ON Line regulatory asset as a one-time rate increase collectable over a nine-month period effectiveApril 1, 2022 , with the expected remaining balance atDecember 31, 2022 to be included in rate base in the 2022 regulatory rate review for inclusion in the rates set in that case. 41 --------------------------------------------------------------------------------
Merger Application
InMarch 2022 , theNevada Utilities filed a joint application with the PUCN for authorization to merge Sierra Pacific with and into Nevada Power, with Nevada Power being the surviving entity. If approved by the PUCN as filed, Nevada Power will have two distinct electric service territories in northern and southern Nevada each with their own rates and one natural gas service territory in theReno andSparks area. An order is expected in 2022.
Northern Powergrid Distribution Companies
GEMA , through Ofgem, is undertaking its scheduled review of the electricity distribution price control to put in place a new price control at the end of the current period that endsMarch 2023 . The new price control ("ED2") will run for five years fromApril 2023 toMarch 2028 . InDecember 2020 andMarch 2021 ,GEMA published its decision on the methodology it will use to set ED2. This confirmed that Ofgem will maintain many aspects of the current price control and that the changes being made will generally follow the template that was set by the price controls implemented inApril 2021 for transmission and gas distribution inGreat Britain . Specific changes include new service standard incentives and mechanisms to adjust cost allowances in specific circumstances, while others will be discontinued, and partially updating the allowed return on equity within the period for changes in the interest rate on government bonds. InDecember 2021 ,Northern Powergrid published and filed its business plan with Ofgem, setting out its detailed approach for 2023-2028 including the cost allowances this approach would require. InJune 2022 , Ofgem published its draft determinations, which included an allowed cost of equity of 4.75% plus inflation (calculated using theUnited Kingdom's consumer price index including owner occupiers' housing costs). When placed on a comparable footing, by adjusting for differences in the assumed equity ratio and the measure of inflation used, this working assumption is approximately two percentage points lower than the current cost of equity for electricity distribution. Ofgem's proposals also set out cost allowances and associated expectations. Final values from Ofgem are expected in late 2022.BHE Pipeline Group BHE GT&S InSeptember 2021 , EGTS filed a general rate case for itsFERC -jurisdictional services, with proposed rates to be effectiveNovember 1, 2021 . EGTS' previous general rate case was settled in 1998. EGTS proposed an annual cost-of-service of approximately$1.1 billion , and requested increases in various rates, including general system storage rates by 85% and general system transportation rates by 60%. InOctober 2021 , theFERC issued an order that accepted theNovember 1, 2021 effective date for certain changes in rates, while suspending the other changes for five months following the proposed effective date, untilApril 1, 2022 , subject to refund and the outcome of hearing procedures. InJune 2022 , the parties reached an agreement in principle and the litigation procedural schedule was ordered held in abeyance for 90 days to enable the parties to finalize a settlement. The settlement is expected to be filed bySeptember 30, 2022 . As ofJune 30, 2022 , EGTS' provision for rate refund forApril 2022 throughJune 2022 totaled$35 million and was included in other current liabilities on the Consolidated Balance Sheet.
InJuly 2022 ,Northern Natural Gas filed a general rate case that proposed an overall annual cost-of-service of$1.3 billion . This is an increase of$323 million above the cost of service filed in its 2019 rate case of$1.0 billion . Depreciation on increased rate base and an increase in depreciation and negative salvage rates account for$115 million of the$323 million increase in the filed cost of service.Northern Natural Gas has requested increases in various rates, including transportation reservation rates ranging from approximately 45% in theField Area to 120% in the Market Area to be implemented, subject to refund, onAugust 1, 2022 . InJuly 2022 , theFERC issued an order that suspended the rates proposed for five months following the proposed effective date, untilJanuary 1, 2023 , subject to refund and the outcome of hearing procedures. 42 --------------------------------------------------------------------------------
BHE Transmission
2022-2023 General Tariff Application
InApril 2021 ,AltaLink filed its 2022-2023 GTA delivering on the last two years of its commitment to keep rates flat for customers at or below the 2018 level ofC$904 million for the five-year period from 2019 to 2023. The two-year application achieves flat tariffs by continuing to transition to the AUC-approved salvage recovery method and continuing the use of the flow-through income tax method, with an overall year-over-year increase of approximately 2% in 2022 and 2023 revenue requirements. The application requested the approval of transmission tariffs ofC$824 million andC$847 million for 2022 and 2023, respectively. InSeptember 2021 ,AltaLink provided responses to information requests from the AUC and filed an amended application to reflect certain adjustments and forecast updates. InNovember 2021 , the AUC approved the 2022 interim refundable transmission tariff atC$57 million per month effectiveJanuary 2022 . InJanuary 2022 , the AUC issued its decision with respect toAltaLink's 2022-2023 GTA.AltaLink's 2022-2023 GTA reflected its continued commitment to provide rate stability to customers by maintaining flat tariffs and providing additional tariff relief measures, including a proposed tariff refund ofC$60 million of accumulated depreciation in each of 2022 and 2023. The AUC did not approveAltaLink's proposed refund due to an anticipated improvement in general economic conditions inAlberta . InMarch 2022 ,AltaLink filed a review and variance application requesting the AUC to review and vary its decision to denyAltaLink's proposedC$120 million refund of accumulated depreciation surplus, given material changes in circumstances since the decision was issued inJanuary 2022 . InMay 2022 , the AUC issued a decision with respect toAltaLink's application to review and vary its proposed$120 million refund of accumulated depreciation surplus. The AUC found that a material decline inAlberta's economic circumstances is not sufficient evidence to warrant the refund. InMay 2022 , the AUC approvedAltaLink's revised total 2022 and 2023 revenue requirement ofC$879 million andC$883 million , respectively, allowingAltaLink to fully deliver on its flat-for-five commitment to customers.
2023 Generic Cost of Capital Proceeding
InJanuary 2022 , the AUC initiated the 2023 generic cost of capital proceeding. The proceeding will be conducted in two stages. The first stage will determine the cost of capital parameters for 2023 and the second stage will consider returning to a formula-based approach to establish cost of capital adjustments, commencing in 2024. InMarch 2022 , the AUC issued its decision with respect to the first stage of the 2023 GCOC proceeding by approving the extension of the 2022 return on equity of 8.5% and deemed equity ratio of 37% for 2023, recognizing lingering uncertainty and continued volatility of financial markets due to the COVID-19 pandemic. InJune 2022 , the AUC initiated the second stage to explore a formula-based approach to determine the return on equity for 2024 and future test periods.
Environmental Laws and Regulations
Each Registrant is subject to federal, state, local and foreign laws and regulations regarding climate change, RPS, air and water quality, emissions performance standards, coal combustion byproduct disposal, hazardous and solid waste disposal, protected species and other environmental matters that have the potential to impact each Registrant's current and future operations. In addition to imposing continuing compliance obligations, these laws and regulations provide regulators with the authority to levy substantial penalties for noncompliance, including fines, injunctive relief and other sanctions. These laws and regulations are administered by various federal, state, local and international agencies. Each Registrant believes it is in material compliance with all applicable laws and regulations, although many are subject to interpretation that may ultimately be resolved by the courts. The discussion below contains material developments to those matters disclosed in Item 1 of each Registrant's Annual Report on Form 10-K for the year endedDecember 31, 2021 , and new environmental matters occurring in 2022. 43 --------------------------------------------------------------------------------
Climate Change
Affordable Clean Energy Rule
InJune 2014 , theEPA released proposed regulations to address greenhouse gas emissions from existing fossil-fueled generating facilities, referred to as the Clean Power Plan, under Section 111(d) of the Clean Air Act. TheEPA 's proposal calculated state-specific emission rate targets to be achieved based on the "best system of emission reduction." InAugust 2015 , the final Clean Power Plan was released, which established the best system of emission reduction as including: (a) heat rate improvements; (b) increased utilization of existing combined-cycle natural gas-fueled generating facilities; and (c) increased deployment of new and incremental non-carbon generation placed in-service after 2012. The Clean Power Plan was stayed by theUnited States Supreme Court inFebruary 2016 while litigation proceeded. OnJune 19, 2019 , theEPA repealed the Clean Power Plan and issued the Affordable Clean Energy rule. In the Affordable Clean Energy rule, theEPA determined that the best system of emission reduction for existing coal-fueled generating facilities is limited to actions that can be taken at a point source facility, specifically heat rate improvements, and identified a set of candidate technologies and measures that could improve heat rates. Measures taken to meet the standards of performance must be achieved at the source itself. The Affordable Clean Energy rule was challenged by environmental and health groups in the D.C. Circuit. OnJanuary 19, 2021 , the D.C. Circuit vacated and remanded the Affordable Clean Energy rule to theEPA , finding that the rule "rested critically on a mistaken reading of the Clean Air Act" that limited the best system of emission reduction to actions taken at a facility. InOctober 2021 , theUnited States Supreme Court agreed to hear an appeal of that decision. Arguments in the case were heldFebruary 28, 2022 , and onJune 30, 2022 , theUnited States Supreme Court issued its decision regarding the scope of theEPA 's authority to regulate greenhouse gas emissions under the Clean Air Act. TheUnited States Supreme Court held that the "generation shifting" approach in the Clean Power Plan exceeded the powers granted to theEPA byCongress , although the court did not address whether theEPA may only adopt measures applied at the individual source as it did in the Affordable Clean Energy rule. A key area where theEPA went astray was using the Clean Power Plan to give states the option to promulgate regulations that would encourage "generation shifting," or moving away from higher-polluting power sources like coal to lower-polluting sources like natural gas or renewables. TheUnited States Supreme Court found that type of regulation, which would impact larger economic forces beyond the fence lines of individual generating facilities, is not permitted under Section 111(d) of the Clean Air Act. TheUnited States Supreme Court reversed the D.C. Circuit's vacatur of the Affordable Clean Energy rule and remanded the case for further proceedings. The ruling has no immediate impact on the Registrants, as there is no Section 111(d) rule currently in effect. The Biden administration plans to propose byMarch 2023 its own rule to replace the Clean Power Plan and Affordable Clean Energy rule.Clean Air Act Regulations The Clean Air Act is a federal law administered by theEPA that provides a framework for protecting and improving the nation's air quality and controlling sources of air emissions. The implementation of new standards is generally outlined in SIPs, which are a collection of regulations, programs and policies to be followed. SIPs vary by state and are subject to public hearings andEPA approval. Some states may adopt additional or more stringent requirements than those implemented by theEPA . The major Clean Air Act programs most directly affecting the Registrants' operations are described below.
National Ambient Air Quality Standards
Under the authority of the Clean Air Act, theEPA sets minimum NAAQS for six principal pollutants, consisting of carbon monoxide, lead, NOx, particulate matter, ozone and SO2, considered harmful to public health and the environment. Areas that achieve the standards, as determined by ambient air quality monitoring, are characterized as being in attainment, while those that fail to meet the standards are designated as being nonattainment areas. Generally, sources of emissions in a nonattainment area that are determined to contribute to the nonattainment are required to reduce emissions. Currently, with the exceptions described in the following paragraphs, air quality monitoring data indicates that all counties where the relevant Registrant's major emission sources are located are in attainment of the current NAAQS. 44 -------------------------------------------------------------------------------- OnJune 4, 2018 , theEPA published final ozone designations for much of theU.S. Relevant to the Registrants, these designations include classifyingYuma County, Arizona ;Clark County, Nevada ; and theNorthern Wasatch Front ,Southern Wasatch Front andDuchesne andUintah counties inUtah as nonattainment-marginal with the 2015 ozone standard. These areas were required to meet the 2015 standard three years from theAugust 3, 2018 , effective date. All other areas relevant to the Registrants were designated attainment/unclassifiable with this same action. However, onJanuary 29, 2021 , the D.C. Circuit vacated several provisions of the 2018 implementing rules for the 2015 ozone standards for contravening the Clean Air Act. TheEPA and environmental groups finalized a consent decree inJanuary 2022 that sets deadlines for the agency to approve or disapprove the "good neighbor" provisions of interstate ozone plans of dozens of states. Relevant to the Registrants, theEPA must, byApril 30, 2022 , propose to approve or disapprove the interstate ozone SIPs ofAlabama ,Iowa ,Maryland ,Michigan ,Minnesota , NewYork, Ohio ,Pennsylvania ,Texas ,West Virginia andWisconsin . OnFebruary 22, 2022 , theEPA published a series of proposed decisions to disapprove the SIPs for interstate ozone transport of 19 states. Relevant to the Registrants, these states includeAlabama ,Maryland ,Michigan ,Minnesota , NewYork, Ohio ,West Virginia andWisconsin . TheEPA also proposed to approveIowa's SIP after re-analyzing the state's data. TheEPA must finalize the proposed rules byDecember 15, 2022 . In addition, theEPA must, byDecember 15, 2022 , approve or disapprove the interstate plans ofArizona ,California , Nevada andWyoming . OnApril 15, 2022 , theEPA issued its final rule approvingIowa's SIP as meeting the good neighbor provisions for the 2015 ozone standard. OnMay 24, 2022 , theEPA disapproved theUtah andWyoming interstate ozone SIPs. Until theEPA takes final action consistent with this decree, additional impacts to the relevant Registrants cannot be determined. Separately, onMarch 28, 2022 , theEPA proposed determinations as to whether certain areas have achieved levels of ground-level ozone pollution that meet the 2008 and 2015 ozone NAAQS. Relevant to the Registrants, theSouthern Wasatch Front inUtah andYuma, Arizona are proposed to have met the 2015 ozone standard; and theCincinnati area ofOhio andKentucky and theNorthern Wasatch Front inUtah are proposed to have not met the 2015 ozone, will be reclassified as Moderate Non-Attainment, and will have untilAugust 3, 2024 to meet the standard. Until theEPA takes final action on the proposal and the affected states submit any required SIPs, the relevant Registrants cannot determine the impacts of the proposed rule.
Cross-State Air Pollution Rule
TheEPA promulgated an initial rule inMarch 2005 to reduce emissions of NOx and SO2, precursors of ozone and particulate matter, from down-wind sources in the easternU.S. , includingIowa , to reduce emissions by implementing a plan based on a market-based cap-and-trade system, emissions reductions, or both. After numerous appeals, the CSAPR was promulgated to address interstate transport of SO2 and NOx emissions in 27 eastern and Midwestern states. The first phase of the rule was implementedJanuary 1, 2015 . InNovember 2015 , theEPA released a proposed rule that would further reduce NOx emissions in 2017. The final "CSAPR Update Rule" was published in theFederal Register inOctober 2016 and required additional reductions in NOx emissions beginning inMay 2017 . OnDecember 6, 2018 , theEPA finalized a rule to close out the CSAPR, having determined that the CSAPR Update Rule for the 2008 ozone NAAQS fully addressed Clean Air Act interstate transport obligations of 20 eastern states. TheEPA determined that 2023 is an appropriate future analytic year to evaluate remaining good neighbor obligations and that there will be no remaining nonattainment or maintenance receptors with respect to the 2008 ozone NAAQS in the easternU.S. in that year. Accordingly, the 20 CSAPR Update-affected states would not contribute significantly to nonattainment in, or interfere with maintenance of, any other state with regard to the 2008 ozone NAAQS. Both the CSAPR Update and the CSAPR Close-Out rules were challenged in the D.C. Circuit. The D.C. Circuit ruledSeptember 13, 2019 , that because theEPA allowed upwind states to continue to significantly contribute to downwind air quality problems beyond statutory deadlines, the CSAPR Update Rule provided only a partial remedy that did not fully address interstate ozone transport, and remanded the CSAPR Update Rule back to theEPA . The D.C. Circuit issued an opinionOctober 1, 2019 , finding that because the CSAPR Close-Out Rule relied on the same faulty reasoning as the CSAPR Update Rule, the CSAPR Close-Out Rule must be vacated. OnOctober 15, 2020 , theEPA proposed to tighten caps on emissions of NOx from generating facilities in 12 states in the CSAPR trading program in response to the D.C. Circuit's decision to vacate the CSAPR Update Rule. The rule is intended to fully resolve 21 upwind states' remaining good neighbor obligations under the 2008 ozone NAAQS. Additional emissions reductions are required at generating facilities in 12 states, includingIllinois ; theEPA predicts that emissions from the remaining nine states, includingIowa andTexas , will not significantly contribute to downwind states' ability to attain or maintain the ozone standard. TheEPA accepted comment on the proposal throughDecember 15, 2020 . OnMarch 15, 2021 , theEPA finalized the Revised CSAPR Update Rule largely as proposed. Significant new compliance obligations are not anticipated as a result of the rule. InJune 2021 , a new lawsuit was filed that challenges the Revised CSAPR Update Rule. Litigation is ongoing in theD.C. Circuit Court . Until litigation is exhausted, the relevant Registrants cannot determine whether additional action may be required. 45 -------------------------------------------------------------------------------- InMarch 2022 , theEPA released its Good Neighbor Rule, which contains proposed revisions to the CSAPR framework and is intended to address ozone transport for the 2015 ozone NAAQS. The rule focuses on reductions of NOx, precursors to ozone formation and covers 26 states. Relevant to the Registrants, four states are included in the cross-state program for the first time -California , Nevada,Utah andWyoming. Iowa is not included in the proposal. In a separate but related action inFebruary 2022 , theEPA proposed to approve the good neighbor provisions ofIowa's SIP addressing ozone transport and the 2015 ozone standard. TheEPA proposes to retain emissions allowance trading for generating facilities. Beginning in 2023, emissions budgets would be set at the level of reductions achievable through immediately available measures such as consistently operating existing emissions controls. Starting in 2026, emissions budgets would be set at levels achievable by the installation of SCR controls at certain generating facilities. The proposal also includes additional industries beyond the power sector for the first time, with a focus on the top NOx emitting stationary source categories. These include natural gas pipeline compressor stations, pulp and paper mills, cement production, iron and steel boilers and furnaces, glass furnaces, chemical manufacturing and petroleum and coal product manufacturing. These sources will not have access to trading and will instead be subject to rate-based limits that are assigned for each source category. TheEPA accepted comments on the proposal throughJune 21, 2022 . Until theEPA takes final action consistent with this decree, impacts to the relevant Registrants cannot be determined. Regional Haze TheEPA 's RegionalHaze Rule , finalized in 1999, requires states to develop and implement plans to improve visibility in designated federally protected areas ("Class I areas"). Some ofPacifiCorp's coal-fueled generating facilities inUtah ,Wyoming ,Arizona andColorado and certain of Nevada Power's and Sierra Pacific's fossil-fueled generating facilities are subject to theClean Air Visibility Rules . In accordance with the federal requirements, states are required to submit SIPs that address emissions from sources subject toBART requirements and demonstrate progress towards achieving natural visibility requirements in Class I areas by 2064. 46 -------------------------------------------------------------------------------- The state ofUtah issued a regional haze SIP requiring the installation of SO2, NOx and particulate matter controls on Hunter Units 1 and 2 andHuntington Units 1 and 2. InDecember 2012 , theEPA approved the SO2 portion of theUtah regional haze SIP and disapproved the NOx and particulate matter portions. Subsequently, theUtah Division of Air Quality completed an alternativeBART analysis for Hunter Units 1 and 2 and Huntington Units 1 and 2. InJanuary 2016 , theEPA published two alternative proposals to either approve the Utah SIP as written or reject the Utah SIP relating to NOx controls and require the installation of SCR equipment at Hunter Units 1 and 2 and Huntington Units 1 and 2 within five years. TheEPA 's final action on theUtah regional haze SIP was effectiveAugust 4, 2016 . TheEPA approved in part and disapproved in part theUtah regional haze SIP and issued a FIP requiring the installation of SCR equipment at Hunter Units 1 and 2 and Huntington Units 1 and 2 within five years of the effective date of the rule.PacifiCorp and other parties filed requests with theEPA to reconsider and stay that decision, as well as filed motions for stay and petitions for review with theTenth Circuit Court of Appeals ("Tenth Circuit") asking the court to overturn theEPA 's actions. InJuly 2017 , theEPA issued a letter indicating it would reconsider its FIP decision. In light of theEPA 's grant of reconsideration and theEPA 's position in the litigation, the Tenth Circuit held the litigation in abeyance and imposed a stay of the compliance obligations of the FIP for the number of days the stay is in effect while theEPA conducts its reconsideration process. To support the reconsideration,PacifiCorp undertook additional air quality modeling using the Comprehensive Air Quality Model with Extensions dispersion model. OnJanuary 14, 2019 , the state ofUtah submitted a SIP revision to theEPA , which includes the updated modeling information and additional analysis. OnJune 24, 2019 , theUtah Air Quality Board unanimously voted to approve theUtah regional haze SIP revision, which incorporates aBART alternative intoUtah's regional haze SIP. TheBART alternative makes the shutdown ofPacifiCorp's Carbon generating facility enforceable under the SIP and removes the requirement to install SCR equipment on Hunter Units 1 and 2 and Huntington Units 1 and 2.The Utah Division of Air Quality submitted the SIP revision to theEPA for approval at the end of 2019. InJanuary 2020 , theEPA published its proposed approval of theUtah Regional Haze SIP Alternative, which makes the shutdown of the Carbon generating facility federally enforceable and adopts asBART the existing NOx controls and emission limits on the Hunter andHuntington generating facilities. The proposed approval withdraws the FIP requirements to install SCR equipment on Hunter Units 1 and 2 and Huntington Units 1 and 2. TheEPA released the final rule approving theUtah Regional Haze SIP Alternative onOctober 28, 2020 . With the approval, theEPA also finalized its withdrawal of the FIP requirements for the Hunter andHuntington generating facilities. TheUtah Regional Haze SIP Alternative took effectDecember 28, 2020 . As a result of these actions, the Tenth Circuit dismissed theUtah regional haze petitions onJanuary 11, 2021 . OnJanuary 19, 2021 , Heal Utah,National Parks Conservation Association ,Sierra Club and Utah Physicians for a Healthy Environment filed a petition for review of theUtah Regional Haze SIP Alternative in the Tenth Circuit.PacifiCorp and the state ofUtah moved to intervene in the litigation. After review of the rule by the Biden administration, theEPA determined it would defend the rule, and briefing in the case is ongoing. A date for oral arguments has not been scheduled. The Utah Air Quality Board approved theUtah Division of Air Quality's SIP for the regional haze second planning period onApril 6, 2022 . The public comment period is anticipated to begin in earlyMay 2022 . The proposed plan sets mass-based emissions limits forPacifiCorp's Hunter andHuntington generating facilities to ensure reasonable visibility progress for the second planning period. The division proposes to add existing SO2 emission limits for all five Hunter andHuntington units as enforceable regional haze controls. The division also proposes new enforceable mass-based NOx emission limits for both generating facilities based on actual emissions. The state is on track to submit a final implementation plan to theEPA inAugust 2022 . 47 -------------------------------------------------------------------------------- The state ofWyoming issued two regional haze SIPs requiring the installation of SO2, NOx and particulate matter controls on certainPacifiCorp coal-fueled generating facilities inWyoming . TheEPA approved the SO2 SIP inDecember 2012 and theEPA 's approval was upheld on appeal by the Tenth Circuit inOctober 2014 . In addition, theEPA initially proposed inJune 2012 to disapprove portions of the NOx and particulate matter SIP and instead issue a FIP. TheEPA withdrew its initial proposed actions on the NOx and particulate matter SIP and the proposed FIP, published a re-proposed rule inJune 2013 , and finalized its determination inJanuary 2014 , which aligns more closely with the SIP proposed by the state ofWyoming . TheEPA 's final action on the Wyoming SIP approved the state's plan to havePacifiCorp install low-NOx burners at Naughton Units 1 and 2, SCR controls at Naughton Unit 3 byDecember 2014 , SCR controls at Jim Bridger Units 1 through 4 between 2015 and 2022, and low-NOx burners at Dave Johnston Unit 4. TheEPA disapproved a portion of the Wyoming SIP and issued a FIP for Dave Johnston Unit 3, where it required the installation of SCR controls by 2019 or, in lieu of installing SCR controls, a commitment to shut downDave Johnston Unit 3 by 2027, its currently approved depreciable life. TheEPA also disapproved a portion of the Wyoming SIP and issued a FIP for the Wyodak coal-fueled generating facility, requiring the installation of SCR controls within five years (i.e., by 2019). TheEPA action became final onMarch 3, 2014 .PacifiCorp filed an appeal of theEPA 's final action on Wyodak inMarch 2014 . The state ofWyoming also filed an appeal of theEPA 's final action, as did thePowder River Basin Resource Council ,National Parks Conservation Association andSierra Club . InSeptember 2014 , the Tenth Circuit issued a stay of theMarch 2019 compliance deadline for Wyodak, pending further action by the Tenth Circuit in the appeal. TheEPA ,U.S. Department of Justice , state ofWyoming andPacifiCorp executed a settlement agreementDecember 16, 2020 , removing the requirement to install SCR in lieu of monthly and annual NOx emissions limits. The settlement agreement was subject to a comment period which endedJuly 6, 2021 . Litigation in the Tenth Circuit remains stayed pending finalization of the settlement agreement. TheEPA did not proceed with final approval of the settlement agreement for Wyodak and is currently engaged withWyoming andPacifiCorp concerning alternative paths for resolution. OnFebruary 5, 2019 ,PacifiCorp submitted a reasonable progress reassessment permit application and reasonable progress determination for Jim Bridger Units 1 and 2, seeking a rescission of theDecember 2017 permit requiring the installation of SCR, to be replaced with a permit imposing plant-wide emission limits to achieve better modeled visibility, fewer overall environmental impacts and lower costs of compliance. InMay 2020 , the Wyoming Air Quality Division issued a permit approvingPacifiCorp's monthly and annual NOx and SO2 emission limits on the fourJim Bridger units and submitted a regional haze SIP revision to theEPA . The revised SIP would grant approval ofPacifiCorp's Jim Bridger reasonable progress reassessment application and incorporatesPacifiCorp's proposed emission limits in lieu of the requirement to install SCR systems onJim Bridger Units 1 and 2. OnDecember 27, 2021 ,Wyoming's governor issued an emergency suspension order under Section 110(g) of the Clean Air Act, allowing the operation of Jim Bridger Unit 2 throughApril 30, 2022 , while the state, theEPA andPacifiCorp continue settlement discussions. OnJanuary 18, 2022 , theEPA proposed to reject the SIP revisions. TheEPA took comment on the proposal throughFebruary 17, 2022 . OnFebruary 14, 2022 , theFirst Judicial District Court for the State of Wyoming entered a consent decree reached between the state ofWyoming andPacifiCorp under Sections 201 and 209(a) of theWyoming Environmental Quality Act, resolving claims of threatened violations of the Clean Air Act, the Wyoming Environmental Quality Act and the Wyoming Air Quality Standards and Regulations at the Jim Bridger facility. No penalties were imposed under the consent decree. Consistent with the terms and conditions of the consent decree and as forecasted inPacifiCorp's 2021 IRP,PacifiCorp must convert both units to natural gas and begin meeting emissions limits consistent with that conversion byJanuary 1, 2024 . In addition,PacifiCorp must propose an RFP byJanuary 1, 2023 , for carbon capture technology at Jim Bridger Units 3 and 4.Wyoming issued its proposed implementation plan for second planning period reasonable progress onFebruary 18, 2022 and accepted comments throughMarch 23, 2022 . TheEPA andPacifiCorp executed an administrative order on consentJune 9, 2022 , covering compliance for Jim Bridger Units 1 and 2 under the regional haze rule. The federal order contains the same emission and operating limits as theWyoming consent decree and adds federal approval of the compliance pathway outlined in the state consent decree, including revision of the SIP to include conversion of Jim Bridger Units 1 and 2 to natural gas. The order includes a one-year deadline to complete the SIP revision. The proposed SIP revision reflecting these agreements is currently being evaluated under parallel processes by the state ofWyoming and theEPA . TheWyoming Department of Environmental Quality submitted the Jim Bridger Units 1 and 2 proposed SIP revision to federal land managers for a 60-day consultation onJune 7, 2022 . The federal land managers must complete review and provide comments byAugust 8, 2022 . For the second round of regional haze planning,Wyoming determined that no controls will be necessary on anyWyoming resources to make reasonable progress. It is estimated that the state will submit a final state-approved implementation plan to theEPA inAugust 2022 . InFebruary 2022 , NV Energy received 30-day notice letters from theNevada Division of Environmental Protection regarding the reopening and revision of the Valmy andTracy Generating Station's Title V air quality operating permits to add federally enforceable retirement dates ofDecember 31, 2028 for Valmy Units 1 and 2 andDecember 31, 2031 for Tracy Unit 4. The enforceable retirement dates will implement Nevada's SIP for the regional haze second planning period. The revised permits were received in March andApril 2022 .The Nevada Division of Environmental Protection accepted public comment on its SIP throughJuly 25, 2022 , and is on track to submit the final SIP to theEPA inAugust 2022 . 48 --------------------------------------------------------------------------------
Critical Accounting Estimates
Certain accounting measurements require management to make estimates and judgments concerning transactions that will be settled several years in the future. Amounts recognized on the Consolidated Financial Statements based on such estimates involve numerous assumptions subject to varying and potentially significant degrees of judgment and uncertainty and will likely change in the future as additional information becomes available. Estimates are used for, but not limited to, the accounting for the effects of certain types of regulation, impairment of goodwill and long-lived assets, pension and other postretirement benefits, income taxes and revenue recognition - unbilled revenue. For additional discussion of the Company's critical accounting estimates, see Item 7 of the Company's Annual Report on Form 10-K for the year endedDecember 31, 2021 . There have been no significant changes in the Company's assumptions regarding critical accounting estimates sinceDecember 31, 2021 . 49 --------------------------------------------------------------------------------PacifiCorp and its subsidiaries Consolidated Financial Section 50 -------------------------------------------------------------------------------- PART I
Item 1.Financial Statements
© Edgar Online, source