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Federal Register / Vol. 86, No. 15 / Tuesday, January 26, 2021 / Notices RECs that are purchased or generated should be recorded in Account 158.1
Allowance Inventory and expensed to Account 509 Allowances as they are utilized.8 In addition to examining the issues identified above, we believe further consideration of whether to clarify and codify this accounting practice by modifying the account instructions of these inventory and expense accounts to explicitly include RECs is warranted at this time.
II. Discussion A. Creation of New USofA Accounts 5. Currently, electric utilities record non-hydro renewable assets, and associated operations and maintenance O&M expenses, in the Other Production function within the USofA.9 Within the USofA, the existing plant and associated O&M account definitions do not provide instructions or examples of items that are used in non-hydro renewable energy production, specifically for wind and solar powered production.10 This may be viewed as either a problem of insufficient account instructions, insufficient existing accounts, or insufficient existing functional categories.
6. For instance, there is no account that clearly captures solar panels. Solar panels are not fuel holders Account 342, prime movers Account 343 or generators Account 344.11 Account 342 includes:
The cost installed of fuel handling and storage equipment used between the point of 8 Ameren
Illinois Co., 170 FERC 61,267 at P 52.
CFR part 101 Other Production includes the following Plant in Service Accounts: 340 Land and Land Rights, 341 Structures and Improvements, 342 Fuel Holders, Producers, and Accessories, 343
Prime Movers, 344 Generators, 345 Accessory Electric Equipment, 346 Miscellaneous Power Plant Equipment, 347 Asset Retirement Costs for Other Production Plant, and 348 Energy Storage EquipmentProduction. Also included are the following O&M Accounts: 546 Operation Supervision and Engineering, 547 Fuel, 548
Generation expenses Major only, 548.1 Operation of Energy Storage Equipment, 549 Miscellaneous Other Power Generation Expenses Major only, 550 Rents, 550.1 Operation Supplies and Expenses Nonmajor only, 551 Maintenance Supervision and Engineering Major only, 552
Maintenance of Structures Major only, 553
Maintenance of Generating and Electric Plant Major only, 553.1 Maintenance of Energy Storage Equipment, 554 Maintenance of Miscellaneous Other Power Generation Plant Major only, and 554.1 Maintenance of Other Power Production Plant Nonmajor only.
10 In contrast, geothermal and biomass generation generally operate based on either floor mounted steam turbines or floor mounted fuel cycle turbines much like buried hydrocarbon generation, and thus, these plant in service assets can be fitted more readily into the existing descriptions of production accounts.
11 18 CFR part 101, Instructions for Accounts 342, 343, and 344.
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fuel delivery to the station and the intake pipe through which fuel is directly drawn to the engine, also the cost of gas producers and accessories devoted to the production of gas for use in prime movers driving main electric generators.12

Solar panels do not store sunlight, and they have no moving parts; instead, solar energy is captured passively as radiation and is then converted electrochemically into electricity.
Therefore, solar panels are not fuel holders. Similarly, Account 343
includes the cost installed of Diesel or other prime movers devoted to the generation of electric energy, together with their auxiliaries, while Account 344 includes the cost installed of Diesel or other power driven main generators. 13 Both of these accounts describe equipment that operates like a diesel-powered turbine. Solar panels, which capture and convert a radiated energy source, are not prime movers or power-driven main generators.
7. Photovoltaic PV inverters also do not fit within any of the definitions of the Other Production accounts. Inverters convert the direct current output of a PV
solar panel into alternating current.
None of the existing Other Production accounts accommodate such a component in their current form.
8. Similarly, there is no account that includes wind generation towers. Such towers do not meet the definition of structures and improvements Account 341, miscellaneous power plant equipment Account 346 or accessory electric equipment Account 345.14
Specifically, the height of wind generation towers is central to the capture of wind energy; therefore, it is not simply a sheltering structure or a miscellaneous or accessory system.
While wind generation towers do provide structural support for the turbine and blades, this is only a part of the towers function, not its primary role. The Commission has previously created separate categories for plant assets that did not fit into existing accounts due to unique features or functionality; such an approach may be appropriate here as well.15
12 Id.,
Instructions for Account 342.
Instructions for Accounts 343 and 344.
These are not defined in the USofA, but from common usage a prime mover would be the source of the initial force that moves the turbine or similar device the diesel here. The power driven main generator would be the turbine, from the tines or blades to the dynamo, including the pressure casing and the shaft.
14 Id., Instructions for Accounts 341, 345, and 346.
15 The Hydraulic Production category contains accounts created for hydro-related items that do not fit in as sheltering structures, such as a hydro dam that is central to the capture of the flow of water 13 Id.,
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9. Additionally, there are no accounts for computer hardware and software required to operate wind and solar generation remotely. Also, Account 553, major maintenance of generating and electric plant, which only includes costs associated with Accounts 343, 344, and 345, does not accommodate costs to record maintenance of solar panels, wind turbine blades, or wind generation towers.16 Similarly, some of the O&M
accounts do not apply to the related non-hydro renewable energy assets. For example, Account 547 Fuel is not applicable to wind and solar generation.17
10. Because the Commissions USofA
does not include accounts that clearly accommodate non-hydro renewable generating plants and associated O&M
expenses, we seek input from interested entities on whether to create new accounts to accommodate these resources. If the Commission determines that non-hydro renewables should be recorded as separate generating functions, then plant and O&M accounts for each new generation function will need to be developed where appropriate. This is necessary both for the correct categorization and correct cost causation attributes of the accounts.
11. Within each item below, interested entities should specify whether the response applies to wind, solar, other, or some combination of these technologies.
Q1 Interested entities should comment on whether the Commission should establish separate plant and O&M expense accounts for each major type of non-hydro renewable plant, including separate accounts for solar, wind, and other non-hydro renewable technologies.
Q2 Interested entities should provide examples of proposed new accounts related to non-hydro renewable plant and related O&M
expenses for the Commission to consider. Interested entities should also include proposed examples of the corresponding account instructions.
Q3 Creating new accounts related to non-hydro renewable plant would require reclassification of assets from existing accounts to newly created plant asset accounts. This would also require includable in Account 332 Reservoirs, Dams, and Waterways. The instructions to Account 332 state:
This account shall include the cost in place of facilities used for impounding, collecting, storage, diversion, regulation, and delivery of water used primarily for generating electricity. For Major utilities, it shall also include the cost in place of facilities used in connection with a the conservation of fish and wildlife, and b recreation.
16 18 CFR part 101, Instructions for Account 553.
17 Id., Instructions for Account 547.

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