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OCC presses GenCon on Fitch/bank fees, PILOT arrangements and updates to fuel/spare-parts forecasts

Public Utilities Regulatory Authority ยท October 31, 2025

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Summary

OCC questioned GenCon about rising Fitch rating invoices and bank fees, agreed interest offsets to net bank costs, the transmission GIS tax billed by Eversource, long-term municipal payment arrangements, and requested updates to fuel price and spare-parts pricing schedules as late-file exhibits.

Office of Consumer Counsel examiner Rory Apollonia and others examined GenCon on several finance and tax items. On finance fees, OCC asked about increased Fitch (credit-rating) invoices and bank fees; GenCon said Fitch fees reflect timing (some invoiced in 2023 but expensed in 2024) and that bank fees are offset by interest earned on average cash balances, which reduces net expense. OCC requested monthly 2024 average cash balances and interest earned as a late-file exhibit to confirm how interest offsets bank fees.

On taxes, the OCC asked about property tax arrangements for the Devon (Milford) and Middletown facilities. GenCon said both facilities have long-term agreements with their host towns (a form of payment-in-lieu-of-tax or fixed assessment), and noted the transmission GIS property tax is invoiced by Eversource and paid as an expense to Eversource. OCC asked whether mill-rate changes could increase assessed taxes; company confirmed changes in millage would affect the GIS component and that challenging tax assessments would be costly and has not been pursued for these long-term agreements.

Working capital and inventory: OCC asked for an updated fuel-price assumption used in the working-capital calculation (the filing used $20.25 per gallon / $2.64 per gallon equivalent as of May 2025); company agreed to provide an updated fuel-price calculation (late-file exhibit E) using current futures and/or actuals. OCC also asked for the derivation of a spare-parts price listed as "manufacturer pricing plus anticipated price increase" (combustion turbines and generators line); the company agreed to provide the original price and the derivation as a late-file exhibit.

Follow-ups and LFEs: The record captures a set of LFE requests from OCC: (1) monthly 2024 cash balances and interest earned (for bank-fee netting); (2) updated fuel-price per gallon as of the most current date; (3) derivation and original price support for the spare-parts/compressor price line; and (4) confirmation that Eversource invoices and the fire district component were included in Middletown totals. GenCon agreed to provide the requested items.