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Earnings Call: Q1 2022

Apr 28, 2022

Operator

Good morning everyone and welcome to Portland General Electric Company's first quarter 2022 earnings results conference call. Today is Thursday, April 28, 2022. 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 Q&A 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. If you do intend to ask a question, please avoid the use of your speaker phones. For opening remarks, I will turn the conference over to Portland General Electric's Senior Director of Investor Relations, Finance, and Risk, Mr. Jardon Jaramillo. Please go ahead, sir.

Jardon Jaramillo
Senior Director of Investor Relations, Finance, and Risk, Portland General Electric Company

Thank you, Raul. Good morning everyone. I'm happy you can join us today. Before we begin this morning, I would like to remind you that we have prepared a presentation to supplement our discussion, which we will 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 Ajello, Senior Vice President of Finance, CFO and Treasurer.

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

Maria Pope
President and CEO, Portland General Electric Company

Good morning, and thank you Jardon. Thank you everyone for joining us today. Turning to slide four. For the first quarter, we reported net income of $60 million or $0.67 per share, compared with net income of $96 million or $1.07 per share in the first quarter of last year. To start, I would like to address the 2022 general rate case order issued earlier this week, which finalizes customer prices and resolves all remaining regulatory issues. Including power costs, customer prices will increase an average of 3.2%. The order also establishes an earnings test for the treatment of certain deferrals arising in 2020 and 2021. The application of these tests resulted in the reduction of 2020 wildfire and COVID deferral expenses. As such, we are reducing earnings by $17 million or $0.14 per share.

While we were surprised by the establishment of an earnings test for these items within the GRC, rather than via separate deferral dockets, the rate case, in its entirety, is positive with key elements that include our previously discussed 50/50 capital structure, unchanged 9.5% return on equity, an average rate base that is now $5.6 billion. As you will recall, we filed this case last July with a revenue requirement request of $59 million, which was reduced through settlement proceedings. Key aspects of this include the removal of the Faraday facility, as it's now expected to be complete around the end of the year. Lower costs of debt to reflect our very attractive $400 million long-term debt issuance, increased load forecasts, and keeping the collection for level three outages.

All but about $5 million of these settlements were constructive, representing operational improvements and the delayed timing of the Faraday repowering. Ultimately, we achieved a $10 million revenue requirement increase, reflecting our shared interests with the OPUC in keeping customer prices low while providing clarity and certainty as we continue to invest in advancing the reliability and resiliency of our system. Unfortunately, as a result of the establishment of the earnings test for major deferrals and the subsequent reversal, as well as wildfire and vegetation management and other operating costs, which Jim will cover later in the call, we've revised our guidance from $2.75-$2.90 down to $2.50-$2.65 per share.

Overall, we are reaffirming our long-term earnings growth of 4%-6% off of the 2019 base year and dividend growth of 5%-7% annually. Turning to operational highlights and the RFPs. We continue to experience strong growth in energy deliveries, which increased 4.4% weather adjusted, led by high-tech and digital customers. Our regional economy continues to trend very strong with in-migration, commercial recovery from the pandemic, and new cloud computing and semiconductor operations, all driving rising demand. Today, our unemployment rate is 3.5%. Our investments in transmission and distribution infrastructure improve reliability and support this growth.

We are also seeing operational improvements and significant efficiency gains resulting in getting more work done, especially in our reliability and in particular compliance work. Through advanced data analytics and smart grid technologies, we're increasing the reliability of our system and even under uncertain and extreme weather conditions. Over the last couple of years, we've also made increasing investments in technology that enables the integration of greater amounts of renewable energy, increasing system flexibility and resiliency. We are pleased to announce that the shortlist for the RFP that we initiated in 2021. Final bids were submitted in January, and the shortlist is included in today's press release. As expected, the RFP process was extremely competitive with over 8,000 MW of energy and over 3,000 MW of capacity. These bids include a variety of technologies, including wind, solar, batteries, and pumped storage.

Throughout this competitive process, we remain focused on keeping costs low as possible while selecting bids that improve the best possible mix of reliability and zero-emissions power. The shortlist will be submitted to the PUC on May 6, and the process will turn to finalizing the bids with the selection of the winning bids later this year. This RFP represents the first of several stages of resource acquisition as we seek to reduce our greenhouse gas emissions to meet the 2030 emissions targets and beyond. Following the completion of this RFP, we expect to issue an updated integrated resource plan in spring of 2023. Finally, last month, we released our 2021 Environmental, Social and Governance report, our ESG report, which demonstrates our progress towards a more equitable, sustainable future for customers, employees, and the communities we serve.

As we look to the future, we anticipate a more focused alignment of elements around our cost structure to get them in line with the realities of our commission's expectations. We're also looking at an ongoing focus on digital solutions to help drive improvements and mitigate cost pressures. We have the continuation of strong economic growth and long-term growth expectations of 1.5%. We're also developing resource plans to move to a decarbonized future and meet our commitments under the state's rules and our own decarbonization goals, and continuing to serve customers with reliable, affordable, clean energy. Now I'll turn it over to Jim. Thank you.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Thank you, Maria, and good morning, everyone. Turning to slide five. Earlier this week, as Maria mentioned, we received the OPUC's final order, adopting all stipulations resolving outstanding issues regarding our 2022 general rate case. The order authorizes a rate increase of approximately 3.2% overall. It authorized our previously disclosed capital structure, return on equity, and average rate-based results. The Faraday Repowering Project, which is not yet in service and will be covered by a separate rate proceeding, and we are now evaluating when and how we will pursue the recovery of this project. It was an update to our level three outage mechanism, which now allows PGE to establish a balancing account subject to a cap of two times the annual accrual amount. Further, it included the elimination of our existing decoupling mechanism, the application of an earnings test to certain major deferrals.

Specifically, the order authorized the application of an annual earnings test for the 2020 COVID, 2020 wildfire emergency in the 2021 ice storm deferrals, allowing collection of costs incurred related to these matters until PGE's regulated ROE reaches certain thresholds at or below our allowed ROE based on the regulatory calculation for these amounts. Recasting the deferrals with the application of the annual earnings test resulted in the reduction of $15 million of previously deferred wildfire restoration expenses and $2 million of previously deferred COVID-19 expenses, which we have now recognized in Q1 2022 earnings. While the order was constructive in its tone, we were surprised that the commission disallowed a portion of costs related to this unique and unprecedented circumstances of 2020.

The final recovery of these deferrals will be adjudicated in the existing dockets, and we will continue to work with stakeholders through prudency reviews to address recovery of these costs. Holistically, the GRC resolution represents a step forward in our regulatory journey and provides clarity as we move forward under a new rate structure. Moving on to slide six. Our first quarter results reflect the opportunities of our region, the challenges of the current economic landscape, as well as the developments stemming from the recent finalization of the 2022 rate case. We continue to witness strong growth fundamentals in our service territory, highlighted by high growth in the commercial and industrial sectors. Overall, Q1 2022 loads increased by 4.4%, weather adjusted, compared to Q1 2021. Residential loads increased 1.8% weather adjusted.

Usage remains elevated when compared to pre-pandemic levels, but we are beginning to see usage patterns normalize. Residential customer count remains steady at 1.1% quarter-over-quarter. Commercial load increased 3.2% weather adjusted as we continue to see recovery from the impact of the pandemic. The high tech and digital services sectors are continuing to grow at a rapid pace as we saw over 10.4% higher industrial loads, weather adjusted. Milder weather had a 1.4% impact on the overall load growth rate of 3% in Q1 2022. Looking beyond the growth in our service territory, inflation pressures on the macroeconomic front are impacting our year-over-year costs, driven by elevated raw material prices and supply chain constraints, which have been significant across all major commodity categories, including material and labor, as well as service costs.

I'll now cover our financial performance quarter-over-quarter. As previously discussed, we experienced a $0.14 decrease to EPS as a result of the application of the earnings test on major 2020 deferrals established in the final GRC order. We experienced a $0.01 increase in total revenues. While load was up 3% quarter-over-quarter, the significant increases in industrial load growth were partially offset by a 1% decrease in residential load, non-weather adjusted, resulting in some offsetting effects due to the composition of customer prices and mix. On a weather adjusted basis, revenue contributed $0.04. Weather was milder quarter-over-quarter, with warmer weather resulting in a $0.03 decrease to revenue. Offsetting this increase was $0.06 of unfavorable power costs, due primarily to serving higher customer demand compared to the previous quarter.

There was a $0.06 decrease to EPS from higher operating and maintenance expense. As a reminder, in 2021, O&M included $11 million of storm restoration costs that were offset in the storm collection balance and are normalized from this comparison. Q1 2022 O&M drivers include $0.02 of additional vegetation management, reflecting incremental work performed in 2022, $0.02 of additional outside service and labor costs for grid reliability and resiliency, and $0.02 decrease from higher administrative expense, primarily driven by wage and benefit increases quarter over quarter. There was a $0.03 decrease due to higher D&A, due to larger plant balances in 2022, and then a $0.02 decrease from the impact of higher interest expenses due to larger long-term debt balances from the Q3 2021 debt issuance of $400 million.

There was a $0.03 decrease due to lower returns on the non-qualified benefit trust compared to Q1 2021. A $0.09 decrease driven by a local flow-through tax adjustment recognized in 2021, which did not recur in 2022. Finally, we achieved a $0.02 increase in EPS due to $0.03 increase for capital cost deferrals for wildfire and storm restoration, and then a $0.01 decrease from other miscellaneous items. Turning to slide seven, which shows our capital forecast through 2026. We increased our capital expenditure forecast for 2022 by $25 million. This reflects additional opportunity for system resiliency investment. While our current investment plan calls for $3.3 billion investment over the next five years, primarily related to grid resiliency and transportation electrification, this number does not include any expenditures related to possible RFP ownership options.

Turning to slide eight. We continue to maintain a solid balance sheet, including strong liquidity and investment-grade ratings, accompanied by a stable credit outlook. Total available liquidity at March 31 is $905 million, and we remain one of the least levered companies in the sector. We plan to fund investments with cash from operations and the issuance of up to $250 million of debt in the second half of 2022. This debt is expected to be issued under our Green Financing Framework as we continue to seek out opportunities to tie our long-term debt to our sustainability strategy through capital investments. On to slide nine. We published the short list of bids for the 2021 RFP within our earnings release today.

The competitive process included specific evaluation criteria that resulted in a short list containing experienced project sponsors with good track records deploying proven technologies. We believe this diverse array of bids will lead to a cost-effective resources to serve our customers and contribute to our decarbonization targets. While we are pleased that some PGE investment opportunities are included in the short list, it's very early in the process, and the final outcome remains subject to commercial and regulatory processes that will unfold during the balance of 2022. Company-owned opportunities for individual renewable resource projects range from 120 MW to 350 MW, and from 50 MW to 125 MW for individual non-emitting dispatchable capacity resource projects. All projects with company-owned components anticipate a build transfer approach.

Due to the confidential nature of the bids, we are unable to share additional specific details on the short list of bids. For clarity, as you examine the list of projects and those identified as company-owned, there are many permutations and there are overlapping capacity, capacities between certain proposals. Next steps in the process include OPUC acknowledgment of the short list targeted for July. At the same time, we plan to begin negotiations with shortlisted bidders. We expect to finalize contracts with the winning bidders in Q4. All projects other than long lead time pumped hydro are expected to be in service by the end of 2024. As we move through the process, we are paying special attention to supply chain and inflation challenges facing renewable development, particularly the challenges in the solar industry.

The combination of diverse technologies and project sponsors will allow us to balance potential development issues as we look to achieve low cost and low risk in these projects. We expect to release our next IRP in the spring of 2023, which will generate additional decarbonization options. Our first quarter performance reflected strong load growth balanced against operating cost challenges as well as deferral reverses. As we look ahead to the balance of 2022, we are revising our full year guidance from $2.75-$2.90 per share to $2.50-$2.65 per share.

This reflects a reduction to the full-year guidance for the adjustment of the 2020 deferral amounts and a revision to full-year O&M guidance from $590 million-$610 million to $620 million-$640 million, which includes the $17 million impact from the change in regulatory deferrals, with the remaining increase attributed to higher wildfire mitigation expenses resulting from more work as a result of cost pressures for the full year. We expect continued growth in our economy with a strong pipeline of high tech and digital growth and continued in-migration, driving weather-adjusted load growth of 2%-2.5%.

While commodity prices have increased significantly in the first quarter, our power cost framework establishes a strong hedging strategy that limits the impact of the run-up of commodity prices in the current year. Cost pressure challenges are likely to continue. We are taking the following steps to manage O&M for the remainder of 2022. We have placed orders for the entirety of forecasted 2022 and 2023 demand for transformers, wire, and cables. We're going to continue to focus our O&M efforts on high return risk mitigation activities. We're going to continue deployment of distribution automation technology, and we're gonna optimize our supply chain processes to balance customer needs with cost challenges. We have to continue to identify and implement efficiencies in 2022, which, coupled with continued low growth, will allow us to achieve our long-term earnings guidance of 4%-6%.

Finally, with respect to dividends, earlier this week, the board approved a dividend increase of $0.09 per share on an annualized basis, which represents a 5.2% increase. This increase is consistent with our long-term dividend growth guidance of 5%-7% while observing a dividend payout ratio of 60%-70%. We also completed our limited share buyback program in Q1 to offset any dilutive effects of shares issued under our compensation programs. Looking ahead, we anticipate customer growth, ambitious decarbonization efforts, and increasing opportunities to invest in our customers' electrification needs. These themes lay the foundation to deliver value by providing clean, affordable, safe, reliable, and equitable energy to execute long-term financial targets for customers and investors alike. Now, operator, we're ready for questions.

Operator

Thank you, sir. Once again, as a reminder, if you wish to ask a question, simply press star then the number one on your telephone keypad. If you would like to withdraw your question, press the pound key. Your first question is from the line of Insoo Kim from Goldman Sachs. Your line is now open.

Insoo Kim
Equity Research Analyst, Goldman Sachs

Thank you.

Maria Pope
President and CEO, Portland General Electric Company

Good morning, Insoo.

Insoo Kim
Equity Research Analyst, Goldman Sachs

Morning, Maria. First question, on inflation. You know, I think it's just impacting the whole industry, the whole world, right now. Just as you think about whether it's labor or materials and whatnot, beyond 2022, any, I guess, insight right now as to how sustained, you know, those pressures could be, and, you know, depending on your view of that, any initial look into whether, you know, the next rate case timing could be sooner rather than later?

Maria Pope
President and CEO, Portland General Electric Company

Sure. That's a great question. The adjustments that we made to this year, as well as to this year's guidance, as Jim noted in his comments, are really quantity of work related versus inflationary. They're focused in primarily wildfire and vegetation management areas. As we look farther out, inflation, particularly because much of it is related to hard goods and construction, is going to impact our capital costs more than it will actually even impact our O&M costs. Obviously, both will be affected, but we're looking more at 2023, 2024. I think this is gonna be with us for actually quite a while.

We have been talking about this since after our last February ice storm, where we were confronted in March and April with particularly tight supply chains. I think at every turn, it's gotten a little worse than we expected. I would add to that, a real focus on our RFPs. They're clearly coming in at higher costs than we would have thought, and clearly higher than our last projects we brought into customer prices. Then finally, gas prices. We have a muted impact on our customer prices because of our hedging that we do. Longer term, you'll continue to see the much higher gas prices roll forward as we continue.

Insoo Kim
Equity Research Analyst, Goldman Sachs

Understood. That's helpful. You've alluded to it, but on that RFP shortlist, did see the schedule out there on your slides of what will happen for the remaining portion of the year. Just given the circumvention investigation that's going on and a lot of the shortlist projects, including solar in most of them, do you see the potential for this process being pushed out a little bit? I know the actual in-service date is not until 2024, but that's just in terms of getting more certainty around which projects are the ultimate winners, just timing-wise.

Maria Pope
President and CEO, Portland General Electric Company

Sure.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Hi. Hi, Insoo. It's Jim. I think that's a very good question. That's entirely up to the PUC. You know, the question now arises, you know, to what extent you can delay the process, still hold these bids firm, get underway with them. You'll note that in the schedule you'll see a series of other types of projects, not only solar, but wind and battery capacity. There are some hybrid projects as well. There exists an opportunity for the reconfiguration of some projects to eliminate solar and just do the wind parts or the battery parts. There's a lot of permutations. But supply chain is affecting every single one of them. There's no question about that. It really depends on what the PUC and its independent evaluator surmise about these projects.

It also depends on whether folks are able to hold their bids and pricing and timing when we go about the process of negotiating with them in the second half of the year. Some of it is on the actual proponents themselves of the projects. As I mentioned in the remarks, these are larger, sophisticated project sponsors, good track records, proven technologies. Nonetheless, there are some forces that are now impacting everyone's ability to execute. We've decided to take a build transfer approach in terms of a risk management strategy here, really to answer you know the kind of question that you're raising. It all depends on what the PUC wants to do and how the project sponsors show up.

I think there's enough time, towards the end of 2024 to get these projects in service in terms of the PTCs and the ITCs that folks are going after to make the economics work. Bottom line, it's too hard to call right now. We're just early on in the process. We don't know what the Department of Commerce investigation will yield in August at that first checkpoint. There's a lot of uncertainty. I really wanna stress that. There's a lot of uncertainty on how we go forward here. At the same time, I'll conclude by saying this is just one of a series of processes that we'll be heading towards at the end of this decade, a series of procurement efforts that we'll have to complete.

In a way, we're dollar cost averaging these decarb goals towards 2030, and there's an opportunity here to redo perhaps two, maybe three more RFPs as we get to the end of the decade. That's the color I would give you, Insoo. Hope that helps.

Insoo Kim
Equity Research Analyst, Goldman Sachs

Yeah. No, that definitely does. I'll pass it on. Thank you.

Maria Pope
President and CEO, Portland General Electric Company

Thank you, Insoo.

Operator

Your next question is from the line of Peter Bourdon from Mizuho. Your line is now open.

Peter Bourdon
Equity Research Associate, Mizuho

Hi. Thanks for taking my question. Just trying to understand the deferral situation a little bit better. Is the $17 million that is being released this quarter, is that related to a disallowance or an actual earnings test? Going forward, how will the discretion with the commission work? Is that gonna be on a quarterly basis or an annual basis?

Maria Pope
President and CEO, Portland General Electric Company

The disallowance that took place relates to 2020 activity. It is the entirety of our wildfire expenses that we incurred in that year, and it is about $2 million of the COVID expenses that we incurred that year. It's based on an earnings test of the regulated ROE, which is sort of a formulaic regulated set of calculations. As you'll remember, we had our energy trading issues that year, and we reduced our equity, meaning that our regulated equity popped up. While it was a terrible year for the company, the mathematical calculations result in the write-off of that $17 million.

As we move forward, the test will be applied on an annual basis, and it's for the wildfire and the ice storm deferral amounts.

Peter Bourdon
Equity Research Associate, Mizuho

Okay. Thank you. Maybe just to confirm, so the remaining amounts, I guess, of deferrals, is it correct, it's $71 million for the ice storm and then $23 million for the wildfires?

Maria Pope
President and CEO, Portland General Electric Company

Yes, that's schedules and the materials. Yep.

Peter Bourdon
Equity Research Associate, Mizuho

Okay.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Peter, I just

Peter Bourdon
Equity Research Associate, Mizuho

This is-

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Peter, it's Jim. I just wanna make sure that we clearly answer your question. There's no disallowance per se as a result of what you may be thinking of as a prudence test. This is really about the operation of the formula around the regulated ROE. Is that clear?

Peter Bourdon
Equity Research Associate, Mizuho

Yes, thank you. Just to confirm, this is a non-cash issue, right? It's really just impacting the balance sheet?

Maria Pope
President and CEO, Portland General Electric Company

Correct.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

It's a non-cash issue, right? It's a 2020 adjustment that we have to take now, of course, because we're reporting now.

Peter Bourdon
Equity Research Associate, Mizuho

Okay. Maybe just one other last one. Just on the PCAM, looks like you guys are showing in the benefit position of $10 million. Is that the amount that is baked into the updated guidance for the rest of the year?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Yes.

Maria Pope
President and CEO, Portland General Electric Company

Yes.

Peter Bourdon
Equity Research Associate, Mizuho

Okay, thank you.

Operator

Your next question is from the line of Ryan Greenwald from Bank of America. Your line is now open.

Ryan Greenwald
Equity Analyst, Bank of America

Hey, good morning, everyone.

Maria Pope
President and CEO, Portland General Electric Company

Good morning.

Ryan Greenwald
Equity Analyst, Bank of America

Good morning. Maybe just piggybacking off the deferral question here. How are you guys kind of thinking about treatment of any additional wildfire costs going forward, given the decision by the commission?

Maria Pope
President and CEO, Portland General Electric Company

The wildfire costs going forward are not subject to the earnings test, but we do have additional wildfire and vegetation management costs, and those are reflected in our revised guidance for the year.

Ryan Greenwald
Equity Analyst, Bank of America

Got it. It's really all just historical in terms of the look at the earnings tests?

Maria Pope
President and CEO, Portland General Electric Company

Yes, which is one of the reasons why you'll see we did not make an adjustment for 2021, and we don't expect to have an adjustment for 2022. However, let me just add one note of caution. Jim did note that this was not related to any prudence review. We haven't gone through that step yet, which is one of the reasons why we were surprised that this became a two-step process.

Ryan Greenwald
Equity Analyst, Bank of America

Got it. With rate case resolution, how are you guys kind of thinking about when you may revisit the longer-term growth trajectory? Is this ultimately contingent on generation wins, or is this something that you think you have enough clarity now that you can maybe pivot to look at again later this year?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Ryan, I think that we need to see more progress on the company-owned assets in the RFP. That's going to be the main driver here. We now have the rate case in front of us, so we're obviously able to model that in. The other important variable is how we come out on the RFP. If you look at the schedule, there's a lot of variability here, and as Peter was asking about earlier, a lot of uncertainty around the timing on the resolution of the RFP. That's really gonna be our next catalyst, I would say.

Ryan Greenwald
Equity Analyst, Bank of America

Got it. Maybe just lastly, any reason in particular for including the deferral in operating guidance, given it's more one time in nature and non-cash?

Maria Pope
President and CEO, Portland General Electric Company

Oh, we had a long discussion on that. We could have gone either way, and there are pluses and minuses to either. We ended up showing it this way, you know, largely because of the size and sort of some issues around sort of, you know, accounting treatment and keeping it sort of all within the same. It all gets adjusted out anyway.

Ryan Greenwald
Equity Analyst, Bank of America

Gotcha. Sorry, maybe just one more follow-up to that. Would you guys have reduced guidance if this deferral was excluded in adjusted numbers?

Maria Pope
President and CEO, Portland General Electric Company

You know, that's a good question. It all relates to how we interpreted and looked through the order as well as the work that we're doing as it relates also to the wildfire plan that was recently approved. It's hard to separate it all as you look at it all coming from one commission.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

I'll add to something here, Ryan, to Maria's comment. If you take the additional part of the guidance that is reduced other than the deferral amounts, right? You accumulate those, call it midpoint to midpoint, about a 25% reduction. The question arose for us. How much can we absorb overall and keep the prior guidance? If it were just one of those things or the other, we would say we could manage that. When you have the accumulation of those additional cost pressures, mostly additional volume and wildfire mitigation and the like, plus the deferral, that got to be too much for us to absorb and offset. It was really the accumulation, Ryan, that caused us to move in that direction.

Maria Pope
President and CEO, Portland General Electric Company

Good point.

Ryan Greenwald
Equity Analyst, Bank of America

Got it. Thank you very much for the time. I'll leave it there.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Thank you.

Maria Pope
President and CEO, Portland General Electric Company

Thank you.

Operator

Your next question is from the line of Shahriar Pourreza from Guggenheim. Your line is now open.

James Kennedy
VP, Guggenheim

Good morning, guys. It's actually, James for Shar. Thanks for taking our questions.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Sure.

Maria Pope
President and CEO, Portland General Electric Company

Thank you.

Peter Bourdon
Equity Research Associate, Mizuho

I just found Faraday. Is there an option to pursue a limited issue rider, or will it just have to be the next GRC?

Maria Pope
President and CEO, Portland General Electric Company

That's what we asked for. We had done that previously in the past with a very complicated system connected to our Pelton Round Butte facilities. That was not the decision that was ultimately made.

James Kennedy
VP, Guggenheim

Okay.

Maria Pope
President and CEO, Portland General Electric Company

We will need to either file a single issue rate case or a regular rate case.

James Kennedy
VP, Guggenheim

Okay. Then the queue mentioned a subpoena from the Department of Forestry. Can you provide any color on what they're looking at there?

Maria Pope
President and CEO, Portland General Electric Company

Oh, no. I think that goes way back to, when we had the wildfires and just some information that they were seeking. There's nothing active at all on that. I think it goes back to September 2020.

James Kennedy
VP, Guggenheim

Okay. Thank you.

Maria Pope
President and CEO, Portland General Electric Company

Thank you.

Operator

Your next question is from the line of Sophie Karp from KeyBanc. Your line is now open.

Sophie Karp
Senior Equity Analyst, KeyBanc

Hi, good morning. Thank you for taking my question. I'd like to go back real quick to the deferral issue. Right. If I'm hearing correctly, what you guys are saying is that, the earnings test, the ROE test was applied this one time, and, because of the way the formula works from formulaically, it was optically higher ROE. This is why you got this. You had to effectively remove the deferral, right? There's no proactive application of this prospective application of this earnings test. Can you give us a little bit more background on, legal basis for the ROE test in the first place? Like, what would stop the commission from deciding to apply it again next time you come for a rate case, for example? It seems a little arbitrary.

Has it always been a part of their thinking process, or is it like a one-time issue for some reason? Like, what is the legal kind of foundation of all of this?

Maria Pope
President and CEO, Portland General Electric Company

You know, that's a really good question. You know, obviously there's standards with regards to prudence reviews and just reasonable rates. Periodically, but not in every circumstance, our commission has discussed and has applied an earnings test. We have it on some other areas that are pretty minor. We've not seen something like this as broad as this one was. Particularly on events that have been disaster related. In the testimony, there was a discussion by the commission with regards to 50/50 sharing on this, which is why they also put the earnings test not at the 9.5%, which is where our allowed is, but at 9.3%.

Sophie Karp
Senior Equity Analyst, KeyBanc

Technically, they could potentially do it again, in the next rate case.

Maria Pope
President and CEO, Portland General Electric Company

Yes, they could.

Sophie Karp
Senior Equity Analyst, KeyBanc

Okay. Fair enough. Now on the RFPs, a couple of questions I have there. I guess the world we live in has changed significantly between January 20, you know, when the bids were maybe processed and today, given all of the evolution of supply chain and solar regulatory landscape and all of that, is there a scenario where some of those RFPs would need to be rebid?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Can you repeat, Sophie, the last part of the question?

Sophie Karp
Senior Equity Analyst, KeyBanc

Is there a scenario where some of those bids would need to be revised? Like, you know, the bidder would have to come in with a revised bid and do it all over again.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Yes. Quite clearly, because when we're negotiating with the bidders, including relative to our own bids across the Chinese wall, so to speak, all bidders will be treated the same. They will be asked to confirm their pricing and their schedule. We want to make absolutely sure in this scenario, given the headwinds that you talked about, that everybody is firm and is committed before we sign contracts.

Maria Pope
President and CEO, Portland General Electric Company

Yeah. Sophie, technically speaking, the terms of the RFP were to submit binding bids. It is fairly clear from both the instructions from the company, but also the independent evaluator. It's, you know, would be common practice for firm bids to be submitted. That does not mean that you've had all of the contractual terms negotiated.

Sophie Karp
Senior Equity Analyst, KeyBanc

What is the process then if, let's say, a bidder from a shortlist is unable to live up to the commitment of the binding bid, right? Like, what's the process for the commission? Like, do you go back to square one and kinda go through the process again to recompose the shortlist, et cetera? Or is that kind of a different process there?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

It may be the case that some bidders are not able to perform and they drop out.

Sophie Karp
Senior Equity Analyst, KeyBanc

Mm-hmm.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

You know, that's gonna be up to them. As your first question implied, we'll have to make sure that they are confirmed. Maria said those are the bidding rules. You know, considering the environment that we're in, there's a lot of fluidity here, right? Both in terms of price and schedule. That's why we're gonna make sure that folks can, at the end of this process, while we're negotiating contracts, live to their commitments. Some of them may not be. You notice the schedule in the earnings release. You know, there's 8,000 MW, not unique megawatts , I wanna stress that, but 8,000 MW proposed and 3,000 MW of capacity. The goals, as you may recall, are about 500 and 375 respectively.

There's a great deal of oversubscription here and a great deal of permutations. I think we go into this process in the second half of the year, you know, with some opportunity for both folks to come forward. There also may be some scenarios where some drop out. We'll find out, and that's what this next phase is all about. First of all, the PUC, with the help of its independent evaluator, has to confirm the shortlist, right? That's job number one. There's still a funnel here that we have to go through, and then we'll get to the phase of dealing with the issues that you just talked about, I would say in the summertime, starting in July.

Sophie Karp
Senior Equity Analyst, KeyBanc

Got it. Just to be clear, are you one of the bidders here on the list from, like, A to H? Are you one of those?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Yes. I can't tell you about the specific ones that we represent and what they are, but you'll notice in the schedule there is a list of company-owned megawatts on that right-hand column of appendix A, and that's for the resources, the generation resources. There are company-owned resources for the capacity side on the bottom of the page.

Sophie Karp
Senior Equity Analyst, KeyBanc

Mm-hmm.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

The answer is yes, but, you know, you have to look at the schedule to determine which.

Sophie Karp
Senior Equity Analyst, KeyBanc

All right. Thank you.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Sure.

Maria Pope
President and CEO, Portland General Electric Company

Thank you.

Operator

Once again, if you wish to ask a question, simply press star then the number one on your telephone keypad. Your next question is from the line of Travis Miller from Morningstar. Your line is now open.

Travis Miller
Senior Equity Analyst, Morningstar

Good morning. Thank you.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Sure.

Travis Miller
Senior Equity Analyst, Morningstar

Not to beat on this deferral thing, but if I could go back real quick here. You said that it wasn't a disallowance and, you know, ruled potentially prudent. Is there a prudence review going on, and would that impact the future collection of these, the 2020 costs?

Maria Pope
President and CEO, Portland General Electric Company

Yes, Travis. There are dockets set for prudence reviews of each of these. It would be our hope that we could move through that this year. That absolutely will continue to take place. Yes, that's why we were concerned and surprised that there's sort of two passes at this.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Travis, I'll just give you the numbers just to make sure it's clear. We began with a balance at the end of March before this order, as it were, at about $190 million. This change in the deferral balance given the earnings tests puts us at about $173 million. That's the $17 million difference. There'll be a prudence review as we go forward on those, on that balance.

Travis Miller
Senior Equity Analyst, Morningstar

On the $173 million, and then the $17 million-

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Right.

Travis Miller
Senior Equity Analyst, Morningstar

is gone. Okay. Regardless of

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

That's right.

Travis Miller
Senior Equity Analyst, Morningstar

Prudency. Okay. Got it.

Maria Pope
President and CEO, Portland General Electric Company

Travis, one of the things you should know that we're working collaboratively and, you know, pretty much on positive signs on all fronts with stakeholders, the PUC and others for securitization. It would be our hope that the costs you've just talked about would, while they represented extraordinary circumstances and significant natural disasters, that they would not have too great of a burden on customers in any one period. Represent really the, you know, 1-in-50 , 1-in-40 kind of time kind of events that these were.

Travis Miller
Senior Equity Analyst, Morningstar

Sure. Okay.

Maria Pope
President and CEO, Portland General Electric Company

The first of their kind.

Travis Miller
Senior Equity Analyst, Morningstar

Sure. Yep. On 2021, did I hear the number $71 million for the Ice Storm 2023 for the wildfires? Was that? Were those the correct numbers?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

The balance at the end of March, but after adjustment, went from $53 million on wildfire to $37.8 million, to be particular. That's that $15 million number. The COVID pandemic one began at just under $38 million and is now at call it $35 million.

Travis Miller
Senior Equity Analyst, Morningstar

Okay. For 2021, knowing what you earned, right, are those still available, I guess, to recover? Right? 'Cause you already you know what you earned in 2021, correct?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

That's right.

Maria Pope
President and CEO, Portland General Electric Company

Yes. We applied all the same math to 2021 as we did to 2020.

Travis Miller
Senior Equity Analyst, Morningstar

Okay.

Maria Pope
President and CEO, Portland General Electric Company

I think we have to also remember, in 2020, we had the unique and very challenging experience with our energy trading losses, which we took accountability for and expensed through the P&L and through the equity section of our balance sheet.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Just to put a fine point on this, we did the earnings test that is addressed in the order for 2020, 2021, and of course, the forecast for 2022, so that we did a thorough year-by-year look as is required here, and the result is what we've talked about, that $17 million. There were no regulated earnings that were sufficiently triggering the earnings test in 2021. That was your question, 2021?

Travis Miller
Senior Equity Analyst, Morningstar

Yeah. Yep. Got it. Okay. No, I appreciate all the technical stuff here. On a higher level, the wildfire mitigation plan that you got approved, is there any CapEx that might be added to your plan from that to your CapEx plan for 2023 and beyond?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Indeed, there is. There's a fair amount of CapEx, but also O&M as well, and the plan speaks to both elements of expenditure. I don't have that right before me, but it's been filed and, shall I say, blessed, accepted, by the PUC and, we're obviously implementing it. We're sort of on the heavier end of that right now without putting too fine a point on it. You get ready for the season, as it were, in the first half of the year, right through May and June, because that's when the risk develops, of course, in the summer. Expenditures are more skewed, as we speak right now.

Travis Miller
Senior Equity Analyst, Morningstar

Okay. Would there be upside to that $650 average number, or is this wildfire mitigation plan just for this year in terms of the CapEx?

Maria Pope
President and CEO, Portland General Electric Company

Oh, no, it'll go into next year as well. It'll go into the year after that as well and onwards. This is a permanent part of our business.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Right. It's an important part of risk mitigation, I would say. We've incorporated this as an ongoing program of risk mitigation.

Travis Miller
Senior Equity Analyst, Morningstar

Okay, great. I appreciate you taking all the questions and the time and details.

Maria Pope
President and CEO, Portland General Electric Company

No, thank you.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Thanks, Travis.

Operator

Your next question is from the line of Aditya Gandhi from Wolfe Research. Your line is now open.

Aditya Gandhi
Equity Research Utilities Associate, Wolfe Research

Good morning. Thanks for taking my question. Could you quickly clarify? On the 2021 deferrals, the $71 million for the ice storm and the $73 million for the wildfire, y'all already applied the same earnings test to 2021 and then your forecast for 2022. What I'm trying to get to is there should be no hit to 2023 numbers from any deferral reductions, right? Could you please clarify that?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

I'm not sure. You went from 21- 23 in between 22, so maybe you can help me understand where you're focused. I'll just offer of what I said previously, we've done extensive work around the earnings test for 21, and there is no exposure there in our view. That set of deferrals are probable of collection based on the test that we had to perform. Does that help you, Aditya?

Aditya Gandhi
Equity Research Utilities Associate, Wolfe Research

Okay. It does. That's helpful. Thank you. Then just how should we you know, given these deferrals and given the elevated inflation that you know is looking like it's gonna persist you know well into the year, how should we you know think about the 4%-6% long-term EPS growth rate that y'all have?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Yeah. You start.

Maria Pope
President and CEO, Portland General Electric Company

Yeah. As we think about it, we recognize where it is in the context of the industry and where it is in the context of our overall growth. As Jim noted, we look at it regularly, but we are waiting to see the ultimate outcome with regards to the RFP projects. That's an important component of our company in terms of decarbonizing our energy supply. There's a lot of uncertainty here, and we need to go through the process, which will take much of the year. Jim, anything you wanna add?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

No, I just actually am thinking about your prior question, Aditya. There's no 2023 impact due to the earnings test. I just wanna make sure you're aware of that. I think you were trying to get me there, but I probably skipped over your question. Just to be clear, no 2023 impact to the earnings test.

Aditya Gandhi
Equity Research Utilities Associate, Wolfe Research

Right. That's exactly what I was getting to. I should have been more clear. Thank you. That's really helpful.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

No worries.

Aditya Gandhi
Equity Research Utilities Associate, Wolfe Research

Thanks, Jim. Thanks, Maria.

Maria Pope
President and CEO, Portland General Electric Company

Thank you.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

You're welcome.

Operator

Your next question is from the line of Nicholas Campanella from Credit Suisse. Your line is now open.

Maria Pope
President and CEO, Portland General Electric Company

Morning.

Nicholas Campanella
VP, Credit Suisse

Hey, good morning, everyone. Good morning. Thanks for getting me on here. You know, I know I came on late, so I'm sorry if someone already asked, but I'm just curious, you know, there's clearly a lot of renewable opportunities in your service territory driving some outsized capital needs. You know, recognizing just kinda the balance sheet being where it is because of the legacy trading loss. Like, how do we kinda just think about growth equity versus you know, balance sheet fixing equity, if at all, if you do need it and any timing around that? Thank you.

Maria Pope
President and CEO, Portland General Electric Company

Yeah. Jim will take it.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Yeah. Thanks, Nick. Quite clearly, I would say this is a growth equity story. We will, in the process of sizing, the future growth opportunity, take into effect what you've identified here as a balance sheet matter. I will tell you that it's. As I look at the opportunities in front of us, it's mostly a growth equity story. We'll be efficient, and, you know, very thoughtful in our execution around that as we eventually get into the market. I wanna find out what the real opportunity is. As you can see in the schedule today, there's a fair amount of opportunity listed.

However, it comes with a great deal of uncertainty, just because of the macro environment that we're in with supply chain inflation, you know, partners, equipment vendors and the like. I wanna nail that first and then look at the balance sheet and come to the market efficiently.

Nicholas Campanella
VP, Credit Suisse

Yep. Okay. Definitely respect that. You know, it has been some time since you kind of just updated us on, you know, the actual kinda growth rate and rolling it forward for just another year. You know, when can investors expect to see that?

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

Well, I think it'll depend on the RFP results, right? That is, I mentioned earlier on the call that that would be the catalyst for doing that.

Nicholas Campanella
VP, Credit Suisse

Sorry to miss that. Thanks for the time today.

Jim Ajello
SVP of Finance, CFO, and Treasurer, Portland General Electric Company

You're welcome, Nick. Take care.

Maria Pope
President and CEO, Portland General Electric Company

Thank you.

Operator

There are no further questions. Presenters, please continue.

Maria Pope
President and CEO, Portland General Electric Company

Okay. Thank you very much for joining us today. We appreciate your interest in Portland General Electric, and we look forward to connecting with you one-on-one in the future as well as at conferences and then on our next quarterly conference call. Thank you.

Operator

With that, this concludes today's conference call. Thank you for attending. You may now disconnect.

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