Regulation and Rates | 4) Regulation and Rates Regulatory Assets and Liabilities Regulatory accounting allows PSE to defer certain costs that would otherwise be charged to expense, if it is probable that future rates will permit recovery of such costs. It similarly requires deferral of revenues or gains that are expected to be returned to customers in the future. The net regulatory assets and liabilities at December 31, 2024, and 2023, are included in the following tables: Puget Sound Energy Remaining Amortization Period December 31, (Dollars in Thousands) 2024 2023 PCA unrealized loss N/A $ 284,166 $ — Environmental remediation (a) 180,245 182,697 Storm damage costs electric 1 to 4 years 120,431 95,754 Automated meter reading 19 years 98,572 104,159 Energy conservation costs (a) 75,373 37,560 PGA unrealized loss N/A 66,929 80,376 PCA mechanism N/A 61,202 48,427 Baker Dam licensing operating and maintenance costs (b) 56,201 55,641 Deferred Washington Commission AFUDC 30 years 55,427 58,648 Decoupling deferrals and interest Less than 2 years 51,838 31,398 Chelan PUD contract initiation 6.8 years 48,435 55,523 Climate Commitment Act auction proceeds N/A 43,538 186,550 Washington Commission LNG N/A 38,070 42,247 Washington Commission COVID-19 N/A 37,089 17,097 Lower Snake River 12.4 years 35,429 43,220 Unamortized loss on reacquired debt 3 to 43 years 29,680 31,626 Regulatory filing fee deferral (c) 2 years 26,543 14,582 Various other regulatory assets (a) 107,325 126,473 Total PSE regulatory assets $ 1,416,493 $ 1,211,978 Cost of removal (d) $ (748,095) $ (682,058) Deferred income taxes (e) N/A (722,558) (761,621) Repurposed production tax credits N/A (110,746) (126,482) Climate Commitment Act recovery N/A (97,694) (84,485) Decoupling liability Less than 2 years (63,890) (60,664) PGA liability 2 years (58,657) (132,082) Bill discount rate deferral N/A (20,567) (6,579) Various other regulatory liabilities (a) (33,435) (60,925) Total PSE regulatory liabilities $ (1,855,642) $ (1,914,896) PSE net regulatory assets (liabilities) $ (439,149) $ (702,918) __________________ (a) Amortization periods vary depending on the timing of underlying transactions. (b) The FERC license requires PSE to incur various O&M expenses over the life of the 50 year license for Baker. The regulatory asset represents the net present value of future expenditures and will be offset by actual costs incurred. (c) Amortization period approved in 2024 GRC, beginning January 29, 2025. (d) The balance is dependent upon the cost of removal of underlying assets and the life of utility plant. (e) For additional information, see Note 14,"Income Taxes" to the consolidated financial statements included in Item 8 of this report. Puget Energy Remaining Amortization Period December 31, (Dollars in Thousands) 2024 2023 Total PSE regulatory assets (a) $ 1,416,493 $ 1,211,978 Puget Energy acquisition adjustments: Regulatory assets related to power contracts 3 to 30 years 4,779 6,266 Total Puget Energy regulatory assets $ 1,421,272 $ 1,218,244 Total PSE regulatory liabilities (a) $ (1,855,642) $ (1,914,896) Puget Energy acquisition adjustments: Deferred income taxes 651 660 Regulatory liabilities related to power contracts 3 to 30 years (30,566) (46,924) Various other regulatory liabilities Varies (1,193) (1,264) Total Puget Energy regulatory liabilities $ (1,886,750) $ (1,962,424) Puget Energy net regulatory asset (liabilities) $ (465,478) $ (744,180) ____________________ (a) Puget Energy’s regulatory assets and liabilities include purchase accounting adjustments under ASC 805. If the Company determines that it no longer meets the criteria for continued application of ASC 980, the Company would be required to write off its regulatory assets and liabilities related to those operations not meeting ASC 980 requirements. Discontinuation of ASC 980 could have a material impact on the Company's financial statements. In accordance with guidance provided by ASC 410, “Asset Retirement and Environmental Obligations (ARO),” PSE reclassified from accumulated depreciation to a regulatory liability $748.1 million and $682.1 million in 2024 and 2023, respectively, for the cost of removal of utility plant. These amounts are collected from PSE’s customers through depreciation rates. General Rate Case Filing PSE filed a GRC, which included a two year MYRP with the Washington Commission on February 15, 2024, requesting an overall increase in electric and natural gas rates of 6.7% and 19.0% respectively in rate year one (expected to approximate calendar year 2025) and 8.5% and 2.1%, respectively in rate year two (expected to approximate calendar year 2026). PSE requested a return on equity of 9.95% for rate year one beginning in 2025 and 10.5% for rate year two, beginning in 2026. PSE requested an overall rate of return of 7.65% in rate year one and 7.99% in rate year two. The filing requests recovery of forecasted plant additions through 2024 as required by RCW 80.28.425 as well as forecasted plant additions through 2026, the final year of the MYRP. On January 15, 2025, the Washington Commission issued an order on PSE's 2024 GRC that approved a weighted cost of capital of 7.52% in 2025 and 7.64% in 2026, a capital structure of 49.0% in common equity in 2025 and 50.0% in 2026, and a return on equity of 9.8% in 2025 and 9.9% in 2026. On January 28, 2025, the Washington Commission approved PSE's electric and natural gas rates in its compliance filing with an overall net revenue change for electric of $378.2 million or 13.3% in 2025 and $191.0 million or 5.9% in 2026 and an overall net revenue change for natural gas of $110.0 million or 10.6% in 2025 and $20.0 million or 1.8% in 2026, with an effective date of January 29, 2025. PSE filed a petition for reconsideration on January 24, 2025 and multiple parties filed petitions for reconsideration and a motion for clarification on January 27, 2025. The Washington Commission will determine what, if any, further action will be taken with respect to these petitions by March 17, 2025. On April 24, 2024, the Washington Commission issued Final Order 07 under Docket No. UG-230393. The order determined that PSE acted prudently in developing and constructing the Tacoma LNG Facility after the initial decision to build in September 2016. Further, there were two main outcomes that resulted from the order. First, the Washington Commission did not authorize recovery of the portion of the Company’s deferred return on its investment in the Tacoma LNG Facility that was recorded between February 1, 2022, the date the facility was placed into service, and January 11, 2023, the date PSE’s 2022 GRC rates went into effect. Second, the Washington Commission directed PSE to increase the allocation of distribution pipeline investment to Puget LNG. The Washington Commission determined that the allocation should be tied to the relative flow of natural gas across these facilities, resulting in a higher allocation to Puget LNG than was originally filed. On May 3, 2024, PSE made the compliance filing required by Final Order 07. On May 24, 2024, Public Counsel and the Puyallup Tribe of Indians each filed a petition for judicial review of the Washington Commission’s Final Order 07. The petitions were filed in Thurston County Superior Court and are expected to be consolidated. Both petitions allege that the Washington Commission (i) failed to properly apply the updated public interest standard, (ii) failed to disallow all costs related to PSE’s redesign of the pipeline and development of waste gas disposal methods, and (iii) failed to conduct an independent determination of reasonable attorney fees. On December 22, 2022, the Washington Commission issued an order on PSE’s 2022 GRC, which was filed on January 31, 2022, that approved a weighted cost of capital of 7.16%, or 6.62% after-tax, a capital structure of 49.0% in common equity in 2023 and 2024, and a return on equity of 9.4%. On January 6, 2023, the Washington Commission approved PSE’s natural gas rates in its compliance filing with an overall net revenue change of $70.8 million or 6.4% in 2023 and $19.5 million or 1.7% in 2024, with an effective date of January 7, 2023. On January 10, 2023, the Washington Commission approved PSE’s electric rates in its compliance filing with an overall net revenue change of $247.0 million or 10.8% in 2023 and $33.1 million or 1.3% in 2024 with an effective date of January 11, 2023. Per the 2022 GRC Final Order in Docket No. UE-220066, rates approved in PSE's PCORC were set to zero as of January 11, 2023, and PSE agreed not to file a PCORC during 2023 and 2024, the period covered by the two-year rate plan agreed to in the GRC settlement. Per the 2022 GRC Final Order in Docket No. UG-220067, PSE was authorized to seek recovery of the costs related to the Tacoma LNG Facility concurrent with its 2023 PGA filing. Prior rates were subject to the 2019 GRC and included a weighted cost of capital of 7.39% or 6.8% after-tax, and a capital structure of 48.5% in common equity with a return on equity of 9.4%. The annualized overall rate impacts were an electric revenue increase of $48.3 million, or 2.3%, and a natural gas increase of $4.9 million, or 0.6%, effective October 1, 2021. For further information, see Note 4, "Regulation and Rates" to the consolidated financial statements included in Item 8 of the Company's Form 10-K for the period ended December 31, 2022. PCA and PGA Unrealized Loss On December 19, 2024, the Washington Commission approved the Company's accounting petition in Docket No. UE-240773 to offset any derivative assets or liabilities, entered into in order to serve electric customers, with a regulatory asset or liability, thus deferring the unrealized gains or losses. For additional information, see Note 10, "Accounting for Derivative Instruments and Hedging Activities" to the consolidated financial statements included in Item 8 of this report. Climate Commitment Act Deferral On December 29, 2022, PSE filed accounting petitions with the Washington Commission requesting authorization to defer costs and revenues associated with the Company’s compliance with the CCA codified in law within Revised Code of Washington (RCW) 70A.65. On February 28, 2023, in Order 01 under Docket No. UE-220974 and UG-220975, the Washington Commission granted PSE approval to defer the cost of emission allowances to comply with the CCA and the proceeds from no-cost allowances consigned to auction beginning January 1, 2023. On August 3, 2023, the Washington Commission approved PSE's request for CCA rates in Docket No. UG-230470, subject to refund, effective October 1, 2023, to recover the estimated ongoing allowance costs and proportionate pass back of credits to customers from estimated auction proceeds during the period of August 2023 through December 2023. On October 26, 2023, the Washington Commission approved PSE's request for CCA rates in Docket No. UG-230756, subject to refund, effective November 1, 2023, to recover the estimated ongoing allowance costs and proportionate pass back of credits to customers from estimated auction proceeds during the period of January 2023 through September 2023. On November 22, 2023, PSE filed proposed revisions to its natural gas rates to incorporate allowance costs and auction proceeds in Docket UG-230968. In the filing PSE sought to update rates pertaining to amounts deferred from January 2023 through September 2023 and to add new language to the tariff that would enable PSE to fund decarbonization projects using a portion of the projected no cost allowances revenues. The request, as revised by PSE on December 19, 2023, represented a revenue increase of $29.1 million. The Washington Commission suspended the tariff sheets but allowed the rates to go into effect on an interim basis, subject to refund, on January 1, 2024. The Washington Commission had a hearing for the issue of risk sharing of CCA compliance costs on October 9, 2024 and has not yet issued an order. As of December 31, 2024, PSE has not sought cost recovery for its allowance costs for electric operations. The ongoing recovery of allowance costs and pass back of proceeds from the sale of consigned no-cost allowances for PSE's natural gas operations is consistent with the approved accounting petitions in Dockets No. UG-220975 and UG-230471. As of December 31, 2024, PSE recorded a regulatory liability of $97.7 million which represents the amounts to date collected in customer natural gas rates for CCA obligation costs, net of the expense incurred for the purchase of allowances for electric and natural gas operations. Additionally, PSE will continue to consign for auction at least the minimum amount of no-cost emission allowances allocated for natural gas operations in compliance with the CCA, the proceeds of which will continue to be used for the benefit of natural gas customers, as determined by the Washington Commission. PSE does not record a regulatory liability to defer the proceeds until consigned allowances are sold at auction. As of December 31, 2024, PSE recorded a regulatory asset of $43.5 million, which represents the proceeds from the sale of consigned natural gas GHG emission allowances passed back through customer rates, net of proceeds received from the sale of consigned allowances sold at auction. Colstrip Adjustment Rider On September 30, 2024, PSE filed proposed revisions to rates under the Colstrip Adjustment Rider Schedule 141COL with the Washington Commission, seeking to recover actual and forecasted costs for Colstrip Units 3 and 4 for calendar year 2025. The proposed revisions would increase PSE's annual revenues by $4.1 million, or 0.1%. The Washington Commission Staff identified concerns regarding certain capital investments related to the Colstrip coal-fired generating facility, particularly in light of the Clean Energy Transformation Act's mandate to remove coal-fired generation facility costs from rates by December 31, 2025. On December 23, 2024, the Washington Commission issued Order 01, requiring PSE to file revised tariff pages by December 23, 2024, with rates effective January 1, 2025, subject to refund pending final determination. The Washington Commission has set the matter for adjudication and a prehearing conference to set the procedural schedule will be held during the first quarter of 2025. The Washington Commission's order allows the rates to be collected beginning January 1, 2025, but explicitly notes this does not represent a resolution or final determination of any matter raised in Docket No. UE-240729. Revenue Decoupling Adjustment Mechanism PSE performed an analysis to determine if electric and natural gas decoupling revenue deferrals would be collected from customers within 24 months of the annual period, per ASC 980. If not, for GAAP purposes only, PSE would need to record a reserve against the decoupling revenue and regulatory asset balance. Once the reserve is probable of collection within 24 months from the end of the annual period, the reserve can be recognized as decoupling revenue. Based on the analyses as of December 31, 2024, $0.2 million and zero reserve adjustment was recorded to electric and natural gas decoupling as of December 31, 2024 and zero reserve adjustment was recorded to electric and natural gas decoupling as of December 31, 2023. Power Cost Adjustment Mechanism PSE currently has a PCA mechanism that provides for the deferral of power costs that vary from the “power cost baseline” level of power costs. The “power cost baseline” levels are set, in part, based on normalized assumptions about weather and hydroelectric conditions. Excess power costs or savings are apportioned between PSE and its customers pursuant to the graduated scale set forth in the PCA mechanism and will trigger a surcharge or refund when the cumulative deferral trigger is reached. Effective January 1, 2017, the following graduated scale is used in the PCA mechanism: Company’s Share Customers' Share Annual Power Cost Variability Over Under Over Under Over or under collected up to $17 million 100 % 100 % — % — % Over or under collected between $17 million - $40 million 35 50 65 50 Over or under collected beyond $40 million 10 10 90 90 For the year ended December 31, 2024, in its PCA mechanism, PSE under recovered its allowable costs by $123.3 million of which $86.5 million was apportioned to customers and $3.9 million of interest was accrued on the deferred customer balance. This compares to an over recovery of allowable costs of $51.1 million, for the year ended December 31, 2023, of which $24.9 million was apportioned to customers and accrued $3.9 million of interest on the total deferred customer balance. Power Cost Adjustment Clause PSE exceeded the $20.0 million cumulative deferral balance in its PCA mechanism in 2022. During 2022, actual power costs were higher than baseline power costs, thereby creating an under-recovery of $110.1 million. Under the terms of the PCA’s sharing mechanism for under-recovered power costs, PSE absorbed $39.0 million of the under-recovered amount, and customers were responsible for the remaining $71.1 million, or $76.4 million, including interest and adjusted for revenue sensitive items. On April 28, 2023, PSE filed the 2022 PCA report under Docket No. UE-230313 that proposed a recovery of the deferred balance, which included a revenue requirement increase of 0.9% in overall bill for all customers, with rates proposed to go into effect from December 1, 2023 through December 31, 2024. On September 29, 2023, PSE filed its variable power cost rates update as part of the 2022 GRC Order requirement under Docket No. UE-220066. The filing was approved in part on December 22, 2023, with updated rates effective January 1, 2024. PSE exceeded the $20.0 million cumulative deferral balance in its PCA mechanism in 2023. During 2023, actual power costs were lower than baseline power costs, thereby, creating an over-recovery of $51.1 million. Under the terms of the PCA’s sharing mechanism for over-recovered costs, PSE's share of the over-recovery was $26.2 million and customers were due the remaining $24.9 million, or $22.2 million, including interest and adjusted for revenue sensitive items. On April 30, 2024, PSE filed the 2023 PCA compliance report, in Docket No. 240288, that proposed to pass back 2023 deferred balances from October 1, 2024 to December 31, 2025, resulting in credits to customers of $22.2 million. Additionally, PSE requested to recover the forecasted 2024 deferred balance of $98.2 million from October 1, 2024 to December 31, 2025. On September 26, 2024, the Washington Commission approved the filing as proposed with rates going into effect October 1, 2024 and January 1, 2025. Purchased Gas Adjustment Mechanism In October 2022, the Washington Commission approved PSE's request for PGA rates in Docket No. UG-220715, effective November 1, 2022. As part of that filing, PSE requested an annual revenue increase of $155.3 million, where PGA rates, under Schedule 101, increase annual revenue by $142.1 million, and the tracker rates under Schedule 106, increase annual revenue by $13.2 million. In November 2022, the FERC approved a settlement of a counterparty, FERC Docket No. RP17-346. Under the terms, PSE was allocated $24.2 million related to PSE natural gas services which was recorded on December 31, 2022, and included below. The 2022 GRC order requires PSE to amortize the refund in 2023 as a credit against natural gas costs and therefore pass back the refund to customers through the PGA mechanism. On October 26, 2023, the Washington Commission approved PSE's request for PGA rates in Docket No. UG-230769, effective November 1, 2023. As part of that filing, PSE requested an annual revenue decrease of $309.4 million, where PGA rates, under Schedule 101, decrease annual revenue by $93.9 million, and the tracker rates under Schedule 106, decrease annual revenue by $215.5 million. The annual 2023 PGA rate decreases include the aforementioned counterparty settlement pass back of $28.1 million under Supplemental Schedule 106B. On October 24, 2024, the Washington Commission approved PSE's request for PGA rates in Docket No. UG-240708, effective November 1, 2024. As part of that filing, PSE requested an annual overall revenue increase of $124.4 million, where PGA rates, under Schedule 101, decrease annual revenue by $2.6 million and the tracker rates, under Schedule 106, increase annual revenue by $127.0 million. The revenue increase in Schedule 106 is primarily due to the cessation of the counterparty refund of $28.1 million, mentioned above, that was amortized as a credit in 2023 and $142.8 million in commodity deferrals that were passed back to customers. The following table presents the PGA mechanism balances and activity as of December 31, 2024 and December 31, 2023: Puget Energy and (Dollars in Thousands) Year Ended December 31, PGA (liability)/receivable balance and activity 2024 2023 PGA (liability)/receivable beginning balance $ (132,082) $ (3,536) Actual natural gas costs 416,067 404,897 Allowed PGA recovery (336,170) (521,882) Interest (6,472) (7,639) Refund from counterparty settlement — (3,922) PGA (liability)/receivable ending balance $ (58,657) $ (132,082) Storm Loss Deferral Mechanism The Washington Commission has defined deferrable weather-related events and provided that costs in excess of the annual cost threshold may be deferred for qualifying damage costs that meet the modified Institute of Electrical and Electronics Engineers outage criteria for system average interruption duration index. For the year ended December 31, 2024, PSE incurred $74.5 million in weather-related electric transmission and distribution system restoration costs, of which the Company deferred $58.9 million and zero as regulatory assets related to storms that occurred in 2024 and 2023, respectively. This compares to $8.1 million incurred in weather-related electric transmission and distribution system restoration costs for the year ended December 31, 2023, of which the Company deferred zero and $2.1 million as regulatory assets related to storms that occurred in 2023 and 2022, respectively. Under the 2017 GRC Order, the storm loss deferral mechanism approved the following: (i) the cumulative annual cost threshold for deferral of storms under the mechanism at $10.0 million; and (ii) qualifying events where the total qualifying cost is less than $0.5 million will not qualify for deferral and these costs will also not count toward the $10.0 million annual cost threshold. Environmental Remediation The Company is subject to environmental laws and regulations by federal, state and local authorities and is required to undertake certain environmental investigative and remedial efforts as a result of these laws and regulations. The Company has been named by the Environmental Protection Agency (EPA), the WDOE and/or other third parties as potentially responsible or liable at several contaminated sites, including former manufactured gas plant sites. In accordance with the guidance of ASC 450 “Contingencies,” the Company reviews its estimated future obligations and will record adjustments, if any, on a quarterly basis. The adjustments recorded are based on the best estimate or the low end of a range of reasonably possible costs expected to be incurred by the Company based on its currently understood legal exposure at applicable sites. It is reasonably possible that incurred costs exceed the recorded amounts due to changes in laws and/or regulations, higher than expected costs due to changes in labor market or supply chain, evolving technology, unforeseen and/or the discovery of new or additional contamination. The Company currently estimates that a significant portion of its past and future environmental remediation costs are recoverable from insurance companies, from third parties, and/or from customers under a Washington Commission order. The Company is subject to cost-sharing agreements with third parties regarding environmental remediation projects in Seattle, Tacoma, Everett, and Bellingham, Washington. As of December 31, 2024, the Company’s share of future remediation costs is estimated to be approximately $73.0 million. The following table summarizes changes in the Company's environmental remediation regulatory assets for the years ended December 31, 2024, and 2023: Puget Energy and Year Ended December 31, (Dollars in Thousands) 2024 2023 Environmental remediation regulatory asset beginning balance $ 182,697 $ 141,893 Remediation cost amortization, net of recoveries (3,732) (4,521) Changes in estimates 1 1,280 45,325 Environmental remediation regulatory asset ending balance $ 180,245 $ 182,697 _______________ 1 . The 2023 change was driven in significant part by the Quendall Terminals site on Lake Washington in Renton, Washington. The site represents contaminated facilities from a long defunct creosote manufacturer, which had purchased waste products from PSE predecessors. In addition, it was driven by an increase in estimate at the shared site of Gas Works Park on Lake Union in Seattle, Washington, which was previously a gas manufacturing plant. The following table summarizes changes in the Company's environmental remediation liabilities for the years ended December 31, 2024, and 2023: Puget Energy and Year Ended December 31, (Dollars in Thousands) 2024 2023 Environmental remediation liabilities beginning balance $ 180,440 $ 135,052 Payments made, net of recoveries (10) (495) Changes in estimates 1 725 45,883 Environmental remediation liabilities ending balance $ 181,155 $ 180,440 _______________ 1. |