Portland General Electric Company (POR)
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Earnings Call: Q3 2020

Oct 30, 2020

Operator

Good morning, everyone, and welcome to Portland General Electric Company's third quarter 2020 earnings results conference call. Today is Friday, October 30th, 2020. This call is being recorded, and as such, all lines have been placed on mute to prevent any background noise. After the speaker's remarks, there will be a question -and-answer period. If you would like to ask a question during this time, simply press star then the number one on your telephone keypad. If you would like to withdraw your question, press the pound key on your telephone keypad. If you do intend to ask a question, please avoid the use of speakerphones. For opening remarks, I will turn the conference call over to Portland General Electric's Senior Director of Investor Relations, Jardon Jaramillo. Please go ahead, sir.

Jardon Jaramillo
Senior Director of Investor Relations, Portland General Electric

Thank you, Jimmy. Good morning, everyone. I'm pleased that you're able to join us today. Before we begin this morning, I'd like to remind you that we have prepared a presentation to supplement our discussion, which we'll be referencing throughout the call. The slides are available on our website at investors.portlandgeneral.com. Referring to slide two, some of our remarks this morning will constitute forward-looking statements. We caution you that such statements involve inherent risks and uncertainties, and actual results may differ materially from our expectations. For a description of some of the factors that could cause actual results to differ materially, please refer to our earnings press release and our most recent periodic reports on forms 10-K and 10-Q, which are available on our website. Leading our discussion today are Maria Pope, President and CEO, and Jim Lobdell, Senior Vice President of Finance, CFO, and Treasurer.

Following their prepared remarks, we will open the line for your questions. Now, it's my pleasure to turn the call over to Maria.

Maria Pope
President and CEO, Portland General Electric

Thanks, Jardon, and thank you all for joining us today. I hope that you and your families are staying safe and healthy during what continues to be a very challenging time. Portland General Electric and all of us here have been put to the test several times this quarter. Our team has tackled difficult issues head-on and took swift actions. I'd like to discuss each of these two events. First, at the end of August, we announced that energy trading activity in certain wholesale electricity markets would result in significant losses. Upon learning of the issue, our board of directors immediately formed a special committee to review the energy trading situation. This review is ongoing. At the time, our team worked quickly, and in early September, we announced that we no longer had net market exposure. I want to make two things clear.

This effect of trading losses was isolated to the third quarter, and the trading losses had no impact on our operations. Second, we experienced one of the most destructive wildfire seasons on record. In responding to the wildfires, the entire organization demonstrated resilience and unwavering focus on customer safety. At the onset of a historic windstorm and high-risk wildfire conditions, we worked in partnership with local authorities and emergency responders to proactively shut off power in several high-risk areas. During the course of the week, we not only enacted public safety power shutoffs, but we also restored power to about 250,000 customers. Over the last several years, our investments in new resources, vegetation management, as well as inspection and maintenance of our equipment, enabled us to act swiftly, which helped emergency responders safely fight the wildfires.

We continue to invest in improving our system, including steel poles, substation upgrades, distribution automation, and other equipment. These and other initiatives build on our strong operational foundation. With growing demand in the Pacific Northwest, these needs are more important now than ever. Our vision for a clean energy future drives our strategy. There's a clear need for urgency in addressing climate change and to meet our customers' desire to be served with increasingly clean, renewable energy. We are building on our 11-year track record of having the largest renewable energy program in the United States, with over 25% of customers buying 100% green energy. Today, we have a number of projects and initiatives underway. Our agreement with Avangrid to source power from the largest solar facility in Oregon will serve an equivalent of 40,000 homes. We're furthering our investment in battery storage, testing several projects across our service territory.

Between the Wheatridge wind, solar, and battery storage project and these other investments, we have a lot of important work underway throughout our state. With year-to-date earnings of $1.15, we're on track to finish at the upper end of our guidance range of $1.40-$1.60 per share. Our underlying operations remain strong, and we continue to find efficiencies and reduce costs throughout our organization. Finally, I want to recognize the hard work of our coworkers and first responders who, in the middle of a pandemic, went above and beyond to protect our community. Before I turn the call over to Jim, I would like to take a moment to thank him.

As I'm sure many of you have seen, yesterday afternoon, we announced that after a long and successful career at PGE, Jim plans to retire at the end of the year. I can't overstate what Jim has done for PGE throughout his 36-year career at the company. He actively lives our company values, and his dedication and leadership have been instrumental in driving financial improvements and strategic initiatives. Jim is well-recognized as a leader across the West and played an important role alongside other utility leaders in creating the western wholesale financial power markets. On a personal note, his camaraderie and counsel have meant the world to me and the officer team. In connection with Jim's retirement, Jim Ajello, the former Executive Vice President and CFO of Hawaiian Electric Industries, has been appointed Senior Advisor, effective November 30th. He'll step into the CFO role on January 1st.

We are excited to have Jim on board. We also announced that Brett Sims, our Senior Director of Strategy, Commercial and Regulatory Affairs, has been appointed Vice President of Strategy, Planning, and Energy Supply effective today. A top priority for Jim and me, as well as the entire management team, is to ensure a smooth transition. Finally, I want to add that we're pleased to welcome Michael Lewis and Jim Torgerson to our board of directors. Both Michael and Jim bring valuable skills and extensive utility experience that will support our efforts to ensure a clean energy future for Oregonians. Now let me turn it over to Jim. Thank you.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thank you, Maria, and thank you for those comments. Good morning, everyone. Before we discuss our financial results, I'd like to recognize the resiliency and focus the company has maintained throughout this quarter's challenges, ensuring that we deliver on our commitments and continue to invest in safe, clean, reliable, and affordable energy for our customers. Turning to slide six, I'll walk through our quarter-over-quarter results. As Maria mentioned earlier, our earnings this quarter were impacted by the losses associated with our energy trading activity. Despite this impact, our core operational results were strong, and there were several items to highlight. For the walk, I'll start with $0.61 for the third quarter of 2019. Excluding the impact of the energy trading loss on our purchase power and fuel expense, gross margin decreased by $0.09. This includes a $0.02 increase in total revenues.

Retail deliveries increased 4% compared to the third quarter of 2019, as deliveries to both residential and industrial customers showed considerable growth over the prior year. The impacts of increased residential usage are largely offset by the decoupling mechanism. Commercial deliveries, which declined, exceeded their 2% on collections this quarter. In 2021, our decoupling mechanism will reset again. This increase in revenue was offset by a $0.11 decrease attributable to higher power costs, partially driven by an increase in the average price for purchased power. Second, there's a $0.11 increase for lower plant and transmission and distribution operating expense, which was primarily driven by reductions in outside services, increased capital work relative to O&M, and reduced maintenance at our generation facilities.

Third, a $0.12 increase from reduced administrative and general expenses, which includes a $0.06 increase from expenses that did not reoccur, primarily associated with the stabilization of our billing system in 2019. A $0.06 increase from lower administrative expenses due to reduced incentives in health insurance premiums. A $0.04 increase due to efficiencies at Boardman as we finalized operations leading up to the coal-fired plant's shutdown in October. Next, a $0.04 increase in other income from AFDC equity associated with ongoing construction of our integrated operations center and Wheatridge facilities, and an increase in non-qualified benefit trust from investment returns. There was a $0.05 increase from lower tax expense, primarily driven by lower pre-tax book income following revisions to our forecast after the impact of the energy trading losses. Finally, there was a $0.02 increase from lower miscellaneous expenses.

Energy trading losses represented a negative impact of $1.09 per diluted share. This amount represents the $127 million impact from the energy trading losses, net of $30 million tax impact in the quarter. This brings our GAAP net income to a loss of $0.19 per diluted share. After adjusting for the impact of the trading losses, non-GAAP earnings per diluted share was $0.90. On to a regulatory update. Last week, the Oregon Public Utility Commission approved two of our outstanding deferrals. First, the commission approved our application for deferral of certain incremental costs related to COVID-19. The final stipulation among parties related to the deferral has been filed with the commission. The stipulation includes dates for restarting disconnects, late fees, and extended time payment agreements.

Second, the commission approved the deferral for incremental O&M and capital expenses related to the September wildfire events. We are continuing to assess the damage to our system and expect additional O&M and capital costs related to the wildfires to be assessed or to be addressed by the deferral. We received an order approving a renewable adjustment clause for the Wheatridge Renewable Energy Facility. The commission found that we acted prudently in our decision to select the facility in consultation with the independent evaluator. The project is scheduled to go into service by end of this year. Regarding our future resource needs, we plan to issue one or more RFPs for new non-emitting resources in the first half of next year and plan to file an IRP update before the end of 2020. On to slide seven.

Our balance sheet remains strong and has the capacity necessary to continue to invest to serve our customers. As of September 30th, 2020, we had $918 million in available short-term credit, letter of credit capacity, and cash, and $688 million of first mortgage bond issuance capacity. We plan to further strengthen our liquidity position by issuing up to $230 million of long-term debt securities later this quarter, with net proceeds being used for general corporate purposes and repayment of short-term debt borrowings. We expect to fund the remainder of the 2020 capital requirements with cash from operations and the issuance of commercial paper as needed. Moving on to slide eight, which shows our updated capital forecast. We added $100 million to our capital forecast for investments that prioritize the reliability and resiliency of our system while minimizing customer prices.

Recent weeks have demonstrated the importance of maintaining a safe and reliable grid as our system continued to perform despite facing the challenges of high wind and wildfire events. As Maria had mentioned, we're reaffirming our full year 2020 guidance of $1.40-$1.60 per share. For 2020, we're expecting to finish in the top half of our earnings guidance. We're also reaffirming a long-term EPS growth of 4%-6% and establishing 2019 as the base year for this guidance. This growth is supported by our continued focus on long-term benefits for our customers of decarbonizing our power supply, electrifying the economy, and delivering strong operational results to ensure safe, clean, and affordable energy. Now, operator, we are ready for questions.

Operator

Thank you. As a reminder, to ask a question, you will need to press star, then one on your touchtone telephone. To withdraw your question from the queue, please press the pound key. Please stand by while we compile the Q&A roster. Our first question comes from Insoo Kim with Goldman Sachs. Your line is now open.

Insoo Kim
Analyst, Goldman Sachs

Morning. Thank you. Good morning. Jim, congrats, and best of luck in the next phase.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thank you.

Insoo Kim
Analyst, Goldman Sachs

First question is on timing of rate case. Given the COVID and the wildfire deferral helped you stabilize the earnings trajectory somewhat, what are your latest thoughts on the potential timing of the next general rate case? In the scenario where you file or do not file in the next year or so, do you anticipate any need for equity?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Insoo, we always evaluate on an annual basis whether there is a need for a general rate case on a forward basis, and we're continuing to do that evaluation. As you know, we are making significant investments in our system on behalf of customers, and we will have those deferrals out there. We will most likely, if there is any news to be shared regarding a general rate case, you'll probably hear that in our fourth quarter call.

Maria Pope
President and CEO, Portland General Electric

Yeah. Insoo, we have no need for any equity financing.

Insoo Kim
Analyst, Goldman Sachs

Understood. This is a little more specific, Jim, but just for the balance of the year, based on the guidance to be at the upper half, that implies 4Q to be meaningfully lower just on a year-over-year basis or based on what you've been earning in the previous few years in the fourth quarter. Besides potential demand for COVID or net variable power cost differences, what else is driving some of that?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

You ought to keep in mind that while revenues are doing well, when you get to the fourth quarter, as we've kind of pointed out in our comments, you've got several drivers that are going on. One is the decoupling mechanism has really kicked in in full force. We have a 2% cap on the amount of collections that we can do from customers. When you look at the residential side, it's basically being decoupled away. On the commercial side, we've hit that cap, and now we're absorbing the continued decrease in commercial loads. The other thing is that on the power cost side, as we've always pointed out, we were way down below the baseline in prior quarters, and now we're moving up into the dead bands.

That really is being driven by flows of energy in the market, given the fact that there's been some transmission that's been taken out of the marketplace and caused some constraints along with hydro. We moved the outage associated with the Coyote Springs facility from earlier in the year into the fourth quarter. You've got that. The other items are a bunch of miscellaneous ones associated with things like the COVID deferral. Because of the fact that we cannot do disconnects until we get, let's see, for commercial, till the first of December, and then in April of next year, when we get to residential, that we can't charge late fees. Late fees have always been part of our revenue on all the prior quarters that we have out there. As I mentioned, there's a bunch of miscellaneous stuff.

Obviously, we're incurring some additional costs associated with the review by the special committee and in defending ourselves in the upcoming lawsuits that we're anticipating regarding the trading that was going on.

Insoo Kim
Analyst, Goldman Sachs

Got it. Thank you for that detail. Just one more, if I could. Maria, it seems like based on the third quarter year-over-year commercial load declines, it was definitely a lot more muted than what we saw in the second quarter. Can you describe a little bit what you're seeing on the ground on the small commercial side in your neighborhood?

Maria Pope
President and CEO, Portland General Electric

Great. Thank you. With regards to commercial, it did decline much more rapidly in the beginning of the pandemic, and we have seen less decline of late. I think it's too early to call. Clearly, there's a rise in cases across the country, and Oregon is no different. What we are really pleased with is to see the continued increase in industrial customers. Last quarter, as we talked about, industrial growth can be lumpy. We had good growth in the second quarter, and that industrial growth continued to be very strong in the third quarter, up about 9% on a weather-adjusted basis.

Overall, we continue to be very optimistic about the growth in our service territory, both as a result of in-migration, which drives residential and somewhat commercial, but more importantly, around industrial, high-tech data centers, and many of the additional customers that we're seeing come into the area.

Insoo Kim
Analyst, Goldman Sachs

Got it. Thank you both.

Maria Pope
President and CEO, Portland General Electric

Thank you.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thanks, Insoo.

Operator

Thank you. Our next question comes from Julien Dumoulin-Smith with Bank of America. Your line is now open.

Julien Dumoulin-Smith
Analyst, Bank of America

Hey, good morning, team. Thanks for the time, and Jim, best of luck here.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thank you, Julien.

Julien Dumoulin-Smith
Analyst, Bank of America

Absolutely. It's been a pleasure. I wanted to come back to this board review process if we could talk about just a little bit more on the timeframe on that. Perhaps even more importantly, can you talk about your sense as to any potential process at the Oregon PUC and where that may stand now? Specifically as it relates to trading losses, but frankly, more broadly, if there's anything on the wildfire front we should be watching, too.

Maria Pope
President and CEO, Portland General Electric

Sure. Thank you, Julien. As I noted, the special committee's review is ongoing. We'll make sure that it's thorough and that we get to the bottom of all that took place, and we'll make sure that we're transparent as we learn more. I don't have anything more with regard to timing on that. I would imagine that the PUC and Chair Decker will take the appropriate actions to ensure confidence in customer pricing and our risk management philosophies. I would say with regards to wildfire recovery, with regards to COVID recovery, with regards to overall proceedings at the PUC, there's a number of dockets. It's very active; we continue to work constructively with all parties.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

We're very pleased that the Commission acted so swiftly when it came to wildfires. That was greatly appreciated.

Maria Pope
President and CEO, Portland General Electric

There's no question about it. It was an unprecedented event. We are fortunate to have taken swift action. We know of none of our equipment that contributed to any of the wildfires.

Julien Dumoulin-Smith
Analyst, Bank of America

Saw that in the 10-Q. Just a quick clarification here, if I can, just a couple of details, important ones. The baseline 2019, that's actual or is it something else? Separately, what's the thought process on the balance of the previous reduction in the CapEx? Is there a prospect to bring that back? Just curious, the 100 versus 180.

Maria Pope
President and CEO, Portland General Electric

Let me let Jim address to you the details around exactly our base for our forecast. Please know that we heard you and other investors wanting more granular detail with regards to our 4%-6% long-term growth rates. When we look at our capital, we are very attuned to the impact in customer prices. We also recognize that we are lucky to have significant customer growth in our area and new capital needs to support that customer growth. In addition, investments in infrastructure that's aging, wildfire resiliency, and others. As projects come up, as we continue to plan, there may be additional amounts, but at this point in time, it's too early to call. We are very focused on ensuring customer prices remain low and affordable across our area.

Jim, do you want to talk a little bit more about the baseline?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Yeah. Julien, the 2019, we chose that because that was the last general rate case that we had been through. That provides a cleaner look when you're trying to forecast on a forward basis. As Maria pointed out, at the capital, we've got a lot of growth going on in the service territory with additional minimum load agreements being signed by customers, increases in the digital space, and just overall in migration. We have a shortage of housing in the state of Oregon, and that is keeping a lot of people busy as homes are being bid up very quickly. Great amount of demand here, and that's really showing up in our numbers.

Julien Dumoulin-Smith
Analyst, Bank of America

Got it. Excellent. All right, I'll leave it there. Thank you all very much.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thanks, Julien.

Julien Dumoulin-Smith
Analyst, Bank of America

Ciao.

Operator

Thank you. Our next question comes from Sophie Karp with KeyBanc. Your line is now open.

Sangita Jain
Analyst, KeyBanc

Hi. Good morning. Thanks for taking my question. This is Sangita on for Sophie.

Maria Pope
President and CEO, Portland General Electric

Good morning.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Good morning.

Sangita Jain
Analyst, KeyBanc

If you could give us a little bit more color on the magnitude of the wildfire cost that you will be deferring, what the recovery mechanisms are in the state of Oregon, if you plan to fold them into your GRC, or if it's going to be a separate proceeding. Any color on that would be greatly helpful.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Yeah. When it comes to the wildfires, we're about $10 million in cost right now. The mechanism is a 12-month period that the deferral runs. We're currently trying to assess the additional damage to some of our transmission lines that are out in rural areas. We don't have cost estimates associated with those at this particular point in time. There's more to be figured out. There's more capital that we're anticipating that we're going to have to spend to recover some of this infrastructure, and we'll know those numbers when we get done with those assessments.

Sangita Jain
Analyst, KeyBanc

A little bit more on that: do you think you're going to fold it into a GRC, or is it more likely to be a separate proceeding?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

This would be separate. The fact that it is a deferral at this particular point in time, the period of recovery hasn't been determined as of yet.

Sangita Jain
Analyst, KeyBanc

Okay, that's great. Thanks so much.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thank you.

Operator

Thank you. Our next question comes from Anthony Crowdell with Mizuho. Your line is now open.

Anthony Crowdell
Analyst, Mizuho

Hey, good morning.

Maria Pope
President and CEO, Portland General Electric

Good morning.

Anthony Crowdell
Analyst, Mizuho

Jim, congratulations. Best of luck in the next phase. Great career with 36 years at Portland.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thank you. It's been a long haul.

Anthony Crowdell
Analyst, Mizuho

Apologies for just looking to get more in the weeds on the guidance; just to follow up on Julien's question earlier, the base is 2019. I have earnings in 2019 at $2.39; the thought is that every year post-2019 is going to be between that 4%-6% growth. It's not something that some will be out, some will be above. It's each year will fall within that range.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Correct.

Anthony Crowdell
Analyst, Mizuho

Great. If I could transition to O&M. This quarter, I think I lost what slide it was, but on the waterfall chart there was $0.20-something you guys took for not only distribution and transmission, O&M savings, but also some G&A savings. Is that something we can bake in more sustainable going forward?

Maria Pope
President and CEO, Portland General Electric

Sure. As Jim mentioned, there were a number of issues that took place in the quarter that were favorable and some issues that were just reflective of significant moves like our Colstrip outage. While we have made significant productivity and performance improvements across our operations, we had a particularly good quarter this year, and you're going to need to sort of look a little bit more long-term as the improvements relate to investments in capital, they relate to investments in technology, and those don't necessarily just all happen all at once, but they take a while to really become embedded in our operations. We're grateful for the great third quarter O&M experience, but muted as we move forward, and really focused on continuing to improve our operating performance and productivity.

Anthony Crowdell
Analyst, Mizuho

Great. Then just lastly on the trading loss, just thinking about anything that you could talk about that has maybe changed, like who did trading report to, who does it report to now, or any type of safeguards that are in place now versus what was there before? I know there's a report coming out or there's an independent review of it. I'm just curious what you could tell us now.

Maria Pope
President and CEO, Portland General Electric

Sure. First of all, as I noted, and we've been very clear on, we moved very swiftly to consolidate and isolate the events associated with the trading losses, and their impact is just to the third quarter. We have made a number of reporting changes and taken other actions. First and foremost, as I mentioned in my remarks with regards to Jim's career, he has extensive knowledge across the western power markets, and our power operations currently report to him. Risk management in the company reports to myself, and we have brought in an outside expert to help us. We've also beefed up other staffing and are taking this very seriously to ensure that it never happens again. We look forward to the report being finalized. I promise you, no more Jim and I as much of our board of directors, and we will be transparent with our findings.

Jim, anything else you want to add?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

No, just to clarify that these management changes where power operations reports to me is something that happened post the event.

Maria Pope
President and CEO, Portland General Electric

Yes.

Anthony Crowdell
Analyst, Mizuho

Okay, great. Lastly, will that report be issued to investors, or is that just something that will stay internal to the board?

Maria Pope
President and CEO, Portland General Electric

I don't know how the board will handle that. It's up to them and their decision-making. Please know that they are proceeding through a thorough process.

Anthony Crowdell
Analyst, Mizuho

Great. Maria, Jim, thanks for taking my questions.

Maria Pope
President and CEO, Portland General Electric

Thank you.

Operator

Thank you. Our next question comes from Brian Russo with Sidoti.

Maria Pope
President and CEO, Portland General Electric

Morning, Brian.

Brian Russo
Analyst, Sidoti

Hi, good morning. Hey, just to follow up on the CapEx question. The $100 million of incremental CapEx that you're laying in through 2021, are you essentially just adding back what was reduced in April? How does that play into maybe an improving economic outlook in your service territory from April?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Well, Brian, you've got it spot on. Those are hand in hand. We're continuing to see growth in the service territory. As I mentioned earlier, we've got strong residential growth that's going on, strong housing market, in-migration, and then a lot of growth in the digital space. We continue to invest in the resiliency and aging infrastructure that we have in the system. What isn't there is, there is no amount associated with any renewable resources that we plan on adding to the system if they were to come out of the RFP process. We've still got investments in the restoration of the system associated with the wildfires. As we've always done, we will evaluate on a quarterly basis.

We have a gating process that I've mentioned previously, that we're making sure that every project goes through a due diligence phase before it gets moved forward to be included in our SEC capital expenditure updates.

Brian Russo
Analyst, Sidoti

Okay, got it. Thanks. Then just on the fourth quarter, year-over-year, it looks like headwind in power supply costs. I think according to the Q, as of September, you were $27 million below the baseline, and the comment is that you'll be within the deadband range. The $27 million below will go to at least $15 million below, but still below zero. Is that the way to look at it?

Maria Pope
President and CEO, Portland General Electric

Yes. One thing I want to note is that we closed Oregon's only coal-fired generation facility a number of days ago. The Boardman plant has ceased its operations. We've also seen higher gas prices throughout the Pacific Northwest as a result of pipeline issues in Canada and elsewhere. We're watching the hydro and precipitation issues pretty closely. Jim, anything else you want to add?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

No. Brian, I think you've got the math right. We, on a year-to-date basis, $27 million below, and then we will be up near the base, somewhere in the collar by year-end.

Brian Russo
Analyst, Sidoti

Right. Got it. Your guidance for 2020 includes anywhere between $0 and $15 million of power supply cost benefits for the year.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Yes, that's correct.

Brian Russo
Analyst, Sidoti

Okay, just one more clarification. Did you guys defer $6 million of bad debt expense in the third quarter so that $6 million did not hit the expense line? Is that the way to look at it, or is that still pending to be deferred?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Well, in our general rate case, we generally assume about $6 million worth of bad debt. We had talked previously about bad debt expense that we would be incurring, and we are now deferring. The amount associated with our deferral right now is probably around the $8 million range.

Brian Russo
Analyst, Sidoti

Okay. In the third quarter reported results, you were still expensing the bad debt expense, correct?

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Yes.

Brian Russo
Analyst, Sidoti

Yes, got it. Okay. Thank you very much. Good luck, Jim.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Okay. Thank you, Brian.

Operator

Thank you. Our next question comes from Travis Miller with Morningstar. Your line is now open.

Travis Miller
Analyst, Morningstar

Good morning. Thank you for taking my questions. Again, I'll echo Jim: congratulations and best of luck.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thank you, Travis.

Travis Miller
Analyst, Morningstar

Wanted a little bit more on the trading losses. One, I'm thinking, how should we think about putting that number in perspective relative to your purchase power costs and other fuel costs? Is this something that would be put in perspective over a quarter or over a year, over a couple of years? How should we think about that $127 million ? And that'd be after tax, right? Relative to the $292 purchase power cost in the quarter, $554 over the nine months. Can you give me a sense of that?

Maria Pope
President and CEO, Portland General Electric

Thank you, Travis. The event is isolated, does not relate to our ongoing power operations. The number of $127 million is a pre-tax number. The EPS impact to the third quarter is $1.09.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Yeah, just know that those positions were all closed and netted in that quarter, so there'll be no carryover to the fourth quarter from a market exposure.

Travis Miller
Analyst, Morningstar

Okay. When you say confined to the quarter, were these costs and trading losses that happened during the quarter, or they were just booked in the quarter from past over a series of quarters, right?

Maria Pope
President and CEO, Portland General Electric

Yes

Travis Miller
Analyst, Morningstar

Your overall purchase power costs.

Maria Pope
President and CEO, Portland General Electric

They were realized 100% in the third quarter.

Travis Miller
Analyst, Morningstar

Okay. Thinking about the number be relative to that $292 of booked purchase power costs. Is that fair?

Maria Pope
President and CEO, Portland General Electric

Yeah. That's how I look at it.

Travis Miller
Analyst, Morningstar

Okay. Then you mentioned potential legal action. Do you have legal recourse to anything related to those trading losses? Any chance of recovering, not from customers, but recovering through legal means, any of that money?

Maria Pope
President and CEO, Portland General Electric

We were very clear that we're not recovering these costs from customers. In our 10-Q, we note that we have received a couple of lawsuits and have disclosed those.

Travis Miller
Analyst, Morningstar

Okay. Apologize, those are lawsuits against you guys, or you're filing lawsuits against the people?

Maria Pope
President and CEO, Portland General Electric

No.

Travis Miller
Analyst, Morningstar

Involved in the trade.

Maria Pope
President and CEO, Portland General Electric

Those are lawsuits against us.

Travis Miller
Analyst, Morningstar

I see. Okay.

Maria Pope
President and CEO, Portland General Electric

Mark, we will wait.

Travis Miller
Analyst, Morningstar

Do you have any legal recourse against the people who were doing the trading losses, who made the trading losses?

Maria Pope
President and CEO, Portland General Electric

The investigation is ongoing.

Travis Miller
Analyst, Morningstar

Okay. Very good. Any chance in discussions with the PUC about putting in some kind of wildfire mitigation plan? Like, obviously, your neighbors to the south have stuff like that. Any thoughts on doing capital through a designated program going forward?

Maria Pope
President and CEO, Portland General Electric

Sure. The Oregon Public Utility Commission has been leaning into the risks around wildfire for some time. One of the commissioners is a leader across the West in convening forums with regards to equipment, insurance, public safety power shutoffs, really bringing together the best minds across the West. Even there is collaboration with Australia and others as we figure out what the right thing to do is. We have taken a number of actions over the last couple of years to ensure that we're well-prepared, that we've invested adequately in equipment, and that work will continue, and we'll continue to work collaboratively with all stakeholders, including the commission.

Travis Miller
Analyst, Morningstar

Okay. Would you be interested in putting together some kind of multiyear plan of capital investment plan?

Maria Pope
President and CEO, Portland General Electric

As you can imagine in running a utility, most of the things that we do are multiyear in nature, and pretty extensive, as we have infrastructure throughout our service territory.

Travis Miller
Analyst, Morningstar

Okay, great. Thank you very much.

Maria Pope
President and CEO, Portland General Electric

Thank you. Thanks, Rose.

Operator

Thank you. I'm showing no further questions in the queue at this time. I'd like to turn the call back to Maria Pope for any closing remarks.

Maria Pope
President and CEO, Portland General Electric

Thank you very much for joining us today. We look forward to continuing the conversation with those of you who will participate in EEI's virtual meetings. We also look forward to talking with you in February as we close out the fourth quarter. Thank you very much, and thank you, Jim.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thanks, Maria.

Maria Pope
President and CEO, Portland General Electric

Congratulations.

Jim Lobdell
SVP of Finance, CFO, and Treasurer, Portland General Electric

Thank you.

Operator

Ladies and gentlemen, thank you for your participation on today's conference. This does conclude your program, and you may now disconnect.