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Midcontinent Independent System Operator, Inc. Notes to Financial Statements As of and for the years ended december 31, 2022 and 2021 (Dollars in thousands)
On December 19, 2001, Midcontinent Independent System Operator, Inc. (MISO or the Company) became the nation's first Regional Transmission Organization approved by the Federal Energy Regulatory Commission (the FERC or the Commission). As a Regional Transmission Organization, MISO provides transmission service on behalf of its members that own transmission assets. In addition, MISO is a North American Electric Reliability Corporation (NERC) certified reliability coordinator. In that capacity, MISO monitors the flow of electricity over the transmission systems of its members that own transmission assets. MISO was incorporated as a Delaware non-stock, nonprofit corporation in March 1998. The Company is governed by an independent Board of Directors. Membership in MISO is open to owners of electric transmission facilities, as well as other participants in the electric energy market. Fifty-six transmission owners with more than 68,000 miles of transmission lines and 190,000 megawatts of electric generation are currently participating in MISO. On December 15, 2001, the Company began providing reliability coordination services to the transmission-owning members of MISO and their customers. On the same date, MISO also began providing operations planning, generation interconnection, maintenance coordination, long-term regional planning, market monitoring, and dispute resolution services. The Company commenced substantially all operations on February 1, 2002, the date MISO began providing regional transmission service under its FERC-accepted Open Access Transmission and Energy Markets Tariff (the Tariff). On April 1, 2005, MISO formally began operating a market-based, congestion management system, which features the day-ahead energy market, real-time energy market, and financial transmission rights market. The day-ahead and real-time energy markets are designed to reliably make the most efficient use of all generation and transmission resources within the region based on bids and offers submitted by market participants. The day-ahead and real-time energy markets price transmission system congestion through the use of Locational Marginal Pricing algorithms. The financial transmission rights market provides a means of hedging Locational Marginal Pricing-based congestion costs. On January 6, 2009, MISO began operating a market for ancillary services, which integrates the procurement and use of regulation and contingency reserves with the existing real-time energy market. MISO also became a NERC-certified Balancing Authority on January 6, 2009.
Basis of PresentationThe accompanying financial statements have been prepared in accordance with the accounting requirements of FERC as set forth in the applicable Uniform System of Accounts and published accounting releases, which is a comprehensive basis of accounting other than general accepted accounting principles in the United States of America. The principal difference from U.S. GAAP relates to the presentation of current maturities of long-term debt and the recognition of debt issuance costs. U.S. GAAP requires that current maturities of long-term debt be reported as a current liability on the Balance Sheet and debt issuance costs related to a recognized debt liability be presented in the balance sheet as a direct deduction from the carrying amount of that debt liability. For FERC reporting, current maturities of long-term debt are included with long-term debt on the Balance Sheet and the unamortized expense of issuance shall be recorded in account 181, Unamortized Debt Expense. Another difference from U.S. GAAP is the accounting treatment of internal-use software as an intangible asset. FERC account 101 on the Balance Sheet shall include the original cost of electric plant, included in accounts 301 to 399, owned and used by the utility in its electric utility operations, and having an expectation of life in service of more than one year from date of installation. For GAAP purposes, available-for-sale investments are classified as current assets as they are available to be converted into cash to fund current operations, even though some investments have contractual maturities beyond one year from the Balance Sheet date. For FERC reporting, investments and any unrealized gains and losses are recorded in account 124, Other investments as a component of non-current assets on the Balance Sheets. The Company choose to implement guidance provided by ASU 2016-02 to report operating leases with a lease term in excess of 12 months as right of use assets, with corresponding lease obligations, in the balance sheet accounts established for capital leases (Accounts 101.1, 227, and 243). RegulationMISO is subject to regulation by the FERC and accounts for the effects of regulation in its financial statements in accordance with Accounting Standards Codification (ASC) 980,Regulated Operations. This statement sets forth the application of generally accepted accounting principles for those companies whose rates are established by, or are subject to approval by, an independent third-party regulator. Under ASC 980, regulated companies defer costs and credits on the balance sheets as regulatory assets and liabilities when it is probable that those costs and credits will be recognized in the rate-setting process in a period different from the period in which they would have been reflected in income and expense by an unregulated company. These deferred regulatory assets and liabilities are then reflected in the statements of operations and changes in net assets in the period in which the same amounts are reflected in rates charged for service. Use of EstimatesThe preparation of financial statements in conformity with FERC requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities, disclosure of contingent assets and liabilities at the date of the financial statements, and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. Cash, Cash Equivalents and Restricted CashThe Company considers all highly liquid investments with a maturity of ninety days or less from the date of purchase to be cash equivalents. Cash and cash equivalents consist of checking accounts, money market accounts, money market mutual funds, and certificates of deposit with a maturity date of ninety days or less. The carrying values of cash and cash equivalents approximate the fair market value. Certificates of deposit, commercial paper, corporate notes and corporate bonds with a maturity date of more than ninety days from the date of purchase are classified separately as investments on the balance sheet. Restricted Cash is further discussed in Note 5. Concentration of Credit RiskFinancial instruments that subject the Company to credit risk consist primarily of accounts receivable and uninsured cash balances. The Company maintained cash balances in excess of insured Federal Deposit Insurance Corporation limits at December 31, 2022 and 2021, and from time to time through December 31, 2022. No allowance has been recorded for accounts receivable at December 31, 2022 and 2021, as management considers all accounts receivable reported in these financial statements to be probable of collection. Furthermore, MISO, per the Tariff, limits distribution of funds owed to market participants to the amount received from market participants. As such, MISO is not exposed to nonpayment for Tariff services. InvestmentsInvestment securities may consist of investments in U.S. Treasuries, various U.S. governmental agency debt securities, corporate bonds, certificates of deposit, and other fixed income securities that have initial maturities of greater than ninety days from date of purchase. Management classifies the Company's investments as available-for-sale. Such securities are carried at fair value based upon prices for identical or similar items on the last day of the fiscal period, with any unrealized gains or losses reported as a deferred regulatory asset or liability, and realized gains and losses included in the statement of operations and changes in net assets. Dividend and interest income is recognized as interest income when earned. Management uses the specific identification method to determine the cost of securities sold. There were no investments recorded as of December 2022 and December 31, 2021. Intangible AssetsIntangible assets primarily include capitalized software of $470,353 and $445,206 and its corresponding accumulated amortization of $368,328 and $351,537, as of December 31, 2022 and 2021, respectively. Amortization expense was $17,494 and $17,991 for the years ended December 31, 2022 and 2021, respectively. The Company retired $702 and $445 of intangible assets in 2022 and 2021 that were fully amortized. The average remaining amortization period for these assets is 2.5 years. Costs incurred prior to the determination of feasibility of developed software and following the in-service date of developed software are expensed. Fixed AssetsFixed assets, consisting primarily of telecommunications equipment, computer equipment, buildings, leasehold improvements, and furniture and fixtures, are recorded at cost and are depreciated on a straight-line basis over the estimated useful lives of the assets. The major classes and lives include the following: buildings and improvements, 20 years; computer hardware, 3 years or 6 years; furniture and fixtures, 7 years; and telecommunications equipment, 7 years. Cost consists of materials and supplies, labor, related taxes, and capitalized interest. There was $2,643 and $2,353 of interest capitalized in fixed assets for the years ended December 31, 2022 and 2021, respectively. The depreciation policy for leaseholds is the shorter of the life of the asset or the remaining term of the lease. Maintenance and repair costs are charged to expense when incurred. Effective January 31, 2015, the Company received approval from the FERC to amortize the cost of land on straight-line basis over a five-year period. PensionMISO accounts for its defined benefit pension plan (the MISO floor offset plan) in accordance with ASC 715,Retirement Benefits. This standard requires employers to fully recognize the obligations associated with single-employer, defined benefit pension, retiree health care, and other postretirement plans in their financial statements. Rate-regulated entities may recognize regulatory assets or liabilities as a result of timing differences between the recognition of costs and costs recovered through the rate-making process. PrepaymentsThe Company considers any expenditure greater than five thousand dollars that will provide future benefits for at least three months as a prepaid asset. Prepaid assets are amortized to expense over the useful life of the asset. Fair Value MeasurementsThe Company uses a three-tier fair value hierarchy in accordance with ASC 820,Fair Value Measurement, which prioritizes the inputs used in measuring fair value. Hierarchical levels, as defined in Financial Accounting Standards Board (FASB) guidance and explained in the following paragraphs, are directly related to the amount of subjectivity associated with the inputs to fair valuation of these assets and liabilities: Level 1Inputs are unadjusted quoted prices in active markets for identical assets or liabilities that the reporting entity can access at the measurement date. The Company's investments associated with its pension plan and Supplemental Executive Retirement Plan, along with its investments in U.S. treasuries are categorized as Level 1. Level 2Inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either directly or indirectly. The Company holds investments that consist of certificates of deposit, corporate bonds and other fixed income securities and are categorized as Level 2. Level 3Unobservable inputs for the asset or liability, which include management's own assumption about the assumptions market participants would use in pricing the asset or liability, including assumptions about risk. The Company did not hold any investments in Level 3 securities as of December 31, 2022 and 2021, respectively. Fair values of investments are estimated using public market prices, quotes from investments and other available information. The estimated fair value of notes payable is discussed in Note 13. Revenue RecognitionThe Company adopted the requirements of Accounting Standards Update (ASU )2014-09,Revenue from Contracts with Customers (Topic 606), under the modified retrospective approach effective January 1, 2019. The Company adopted this standard for interim periods beginning January 1, 2020. The adoption did not have a material impact on the amount or timing of revenue recognized. The Company's operating revenues are derived primarily from recovery of administrative costs under the Tariff, with no defined contractual term. Under ASC 606, revenue is to be recognized when performance obligations are satisfied. Pursuant to the Tariff, MISO recognizes as revenue amounts both billed and unbilled for which MISO has incurred costs as of the period-end. The Schedule 10ISO Cost Recovery Adder, Schedule 16Financial Transmission Rights Administrative Service Cost Recovery Adder, and Schedule 17Energy Market Support Administrative Service Cost Recovery Adder of the Tariff provide for recovery of all costs, including capital and operating expenses, of MISO. MISO also recognizes as revenue amounts billed to participants for initial membership, training, and annual dues. Performance obligations are satisfied over time as Transmission and Administrative Services are delivered, with billings generally occurring monthly and related payments due within seven days. MISO records revenue and an offsetting expense for the annual FERC Assessment Fee (the Assessment Fee). The annual fee is assessed on the megawatt hours of transmission usage for each transmission provider as reported on FERC Form 582. The FERC generally invoices transmission providers in July of each year, and payment is due in August. MISO bills the Assessment Fee monthly in advance based on an estimated rate per megawatt hour applied to each individual transmission customer's actual megawatt hours of transmission usage for that month. MISO recognizes the revenue and an offsetting expense each month as the Assessment Fee is billed. Assessment Fee revenue of $68,171 and $64,073 was recorded in 2022 and 2021, respectively. MISO performs engineering studies on behalf of its customers. MISO is reimbursed for its costs of performing the studies and recognizes revenue as the costs are incurred, subject to a recoverability assessment. The amounts of $20,810 and $18,438 were recognized as revenue from engineering studies for the years ended December 31, 2022 and 2021, respectively. MISO has been awarded a number of economic development grants by the state of Indiana, as well as a United States Department of Energy (DOE) grant. Revenue is recognized on these grants based on the terms of the agreement, which generally are based on a percentage of program costs incurred. MISO recognized revenue associated with these programs of $102 and $394 in 2022 and 2021, respectively. The Company recorded deferred revenue associated with withdrawal obligations paid by transmission owners that have withdrawn from MISO. Each transmission owner can receive credits for service up to the amount of the original exit fee until the year expiring, noted in the table below. Amounts are amortized ratably over the period from the year of withdrawal through expiration. The table also notes the exit fees and remaining balances in the current and prior years.
Of the $12,362, $3,460 is recorded as current deferred revenue and is expected to be amortized to revenue in 2023. Subsequent EventsManagement has evaluated events and transactions occurring since December 31, 2022. There are no events or transactions that have occurred that require additional disclosure in these financial statements after December 31, 2022 through March 22, 2023, the date the financial statements were available to be issued. New Accounting GuidanceInFebruary 2016, the FASB issued ASU 2016-02,Leases (Topic 842), whichrequires lessees to recognize most leases on the balance sheet and disclose keyinformation to help investors and other financial statement users betterunderstand the amount, timing, and uncertainty of cash flows arising fromleases.The new standard required thatlessees recognize the following for all leases (with the exception ofshort-term leases, as that term is defined in the standard) at the leasecommencement date: (1) a lease liability, which is a lessee's obligation tomake lease payments arising from a lease, measured on a discounted basis; and(2) a right-of-use asset, which is an asset that represents the lessee's rightto use, or control the use of, a specified asset for the lease term.Leases will be classified as finance oroperating, with classification affecting the pattern and classification ofexpense recognition in the income statement. On July 30, 2018, the FASB issued ASU 2018-11 to provide entities provides an adoption method that allows companies to apply the new guidance to the financial statements in the period of adoption and thereafter, and not apply the new guidance to comparative periods presented. ASU 2018-11 allows an entity to use either (1) its effective date or (2) the beginning of the earliest comparative period presented in the financial statements as its date of initial application. MISO adopted the provision of ASC 842 beginning on January 1, 2022, using the transition method provided in ASU 2018-11, which was applied to all existing leases at that date. As such, results for reporting periods beginning after January 1, 2022 will be presented under ASC 842, while prior period amounts will continue to be reported in accordance with ASC 840. Management elected the following practical expedients: Package of transition practical expedients; Short term lease expedient; Hindsight expedient. Adoption of the new standard resulted in the recording of additional lease liabilities of $30,421and a corresponding Right of Use Asset of $29,383 on our Balance Sheets as of January 1, 2022. We utilize our collateralized incremental borrowing rate commensurate to the lease term as the discount rate for all our leases. In June 2016, the FASB issued ASU 2016-13, Measurement of Credit Losses on Financial Instruments (Topic 326), which amends the Board's guidance on the impairment of financial instruments. Subsequently, the FASB has issued additional ASU which further clarify this guidance. The ASU adds to GAAP an impairment model that is based on expected losses rather than incurred losses, which is known as the current expected credit loss (CECL) model. The CECL model applies to most debt instruments (other than those measured at fair value), trade and other receivables, financial guarantee contracts, and loan commitments. ASU 2016-13 is effective for our fiscal years beginning after December 31, 2022. The Company is evaluating the effect of adopting this new accounting guidance but does not expect adoption will have a material impact on the Company's financial position or results of operations.
Some members provide a notice of withdrawal to MISO in accordance with the terms of the MISO Transmission Owners Agreement. Such notices allow these companies to preserve their options with respect to withdrawal of their facilities from MISO. Should these companies withdraw, they would then be responsible to pay their proportionate share of certain outstanding financial obligations of MISO and for certain other obligations as required by the terms of the MISO Transmission Owners Agreement and the Tariff. Below is a listing of members that provided a notice of withdrawal:
The following regulatory assets and liabilities were included in the deferred regulatory assets and liabilities lines on the balance sheets:
The Current Schedule 10, 16 and 17 rates are based on forecasted billing units and expenditures. Differences between revenue collected and actual costs for the month are included in subsequent months' rate calculations. These costs are classified as deferred regulatory assets and will be recovered in a subsequent period.
The Company considers all highly liquid investment instruments that mature within ninety days or less to be cash equivalents. Cash, cash equivalents and restricted cash had the following balances, which approximate fair value, as of December 31:
All restricted cash items are offset by liabilities on the balance sheets. The cash and cash equivalent collateral deposits less interest are offset in restricted deposits. Collection on the Assessment Fee is offset by the FERC assessment liability. The remainder of restricted cash and cash equivalents is offset in the market participant liability. Restricted cash for market funds consists of activity for two funds: the Day-Ahead Excess Congestion Fund and the Financial Transmission Rights Auction Residual Fund. The Day-Ahead Excess Congestion Fund consists of excess cash received after the funding of Financial Transmission Rights. The Financial Transmission Rights Auction Residual Fund represents excess payments received for Financial Transmission Rights sold in the monthly and annual auctions. Both funds are accumulated during the calendar month and distributed to market participants per formulas in the Tariff after the end of each calendar month. As of December 31, 2022 and 2021, the Company had collected $35,592 and $5,498, respectively, in market participant payments due to other market participants and/or MISO transmission owners. These funds are scheduled to be paid in a subsequent period. The cash collateral deposits represent funds from customers that provide cash collateral as a form of financial assurance to secure the customers' performance under the terms and conditions of the Tariff related to the purchase of transmission service, market services, ancillary services, and related products or services. Also included in this amount is interest earned on the deposits, which is paid to the customer quarterly on January 31, April 30, July 31 and October 31 of each year. As of December 31, 2022 and 2021, the Company had collected $1,499,136 and $1,088,287, respectively, of security deposits from customers. An offsetting liability is recorded in current and long-term liabilities. At December 31, 2022 and 2021, interest payable to the customers of $14,272 and $29, respectively, was recorded in accrued interest. MISO bills to its market participants the Assessment Fee monthly and accumulates the cash in a segregated account for use in paying the annual Assessment Fee in August of each year. As of December 31, 2022 and 2021, the amount restricted for this use was $25,979 and $21,507, respectively.
Unbilled revenues are recognized by applying tariffed rates to the usage incurred but not yet billed. The accrual for unbilled revenues is reversed in the subsequent accounting period when customers are billed. MISO's receivables at December 31, 2022 and 2021, consist of the following:
Fixed assets at December 31, 2022 and 2021, consist of the following:
Total depreciation and amortization expense related to fixed assets was $14,325 and $14,460 for 2022 and 2021, respectively. At December 31, 2022 and 2021, the balance of projects in development was $5,708 and $10,033, respectively. These amounts included funds expended to develop projects to improve internal business processes, improve IT infrastructure, and enhance operations systems.
Current and long-term accrued liabilities at December 31, 2022 and 2021, consist of the following: Market participants that request a generation interconnection or facility upgrade study must pay the costs incurred to perform an impact assessment study. Furthermore, a deposit is required before the study is undertaken. At December 31, 2022 and 2021, the engineering study deposits balance was comprised of $1,276,676 and $873,204, respectively, for generation interconnection studies and facility upgrade studies. These balances are held within various accounts as cash and cash equivalents and short-term investments. As expenses are incurred, revenue is recognized and deducted from the deposits, and liabilities, for services performed by MISO for these impact assessment studies.
The Company offers a defined contribution 401(k) retirement plan for all full-time employees as of their date of hire. The Company currently matches 50% of the first 6% of the employee contribution. For December 31, 2022 and 2021, the Company match was $3,387 and $3,668, respectively. Employees are 100% vested in the employer's contribution after two years of employment. The Company also has a defined contribution retirement plan covering all full-time employees. The Company contributes an amount equal to 6% of an employee's salary into the plan for the employee's retirement. For December 31, 2022 and 2021, the cost of this plan was $7,046 and $6,587, respectively. Contributions are subject to a vesting schedule. Employees are 100% vested after five years of employment. The Company has a Supplemental Executive Retirement Plan for officers and a plan under Section 457(b) of the Internal Revenue Code. Benefits payable under these plans are based upon the participant's salary and age. The investment balance at December 31, 2022 and 2021, is $12,183 and $12,931, respectively, and is recorded in other assets. An offsetting liability is also recorded in accrued liabilities. Expense relating to the Supplemental Executive Retirement Plan of $1,381 and $1,340 was recorded for the years ended December 31, 2022 and 2021, respectively. MISO assumed a defined benefit pension plan (the MISO Floor Offset Plan) established for Mid-Continent Area Power Pool (MAPPCOR) employees who became employees of MISO under the terms and conditions of an asset purchase agreement completed in November 2001. Effective April 15, 2006, the MISO Floor Offset Plan was frozen. The Company made the decision to terminate the plan effective December 31, 2021. On July 15, 2021, the Company transferred $2,307 from the MISO Floor Offset Plan to Mutual of Omaha, who will administer the payment of benefits to the 15 individuals currently receiving benefits starting September 1, 2021. The Company contributed $455 to bring the plan to fully funded status. The remaining plan participants received lump sum distributions on December 31, 2021, which brought the fair value of plan assets to $0.
The Company has received approval for its not-for-profit status under Section 501(a) of the Internal Revenue Code and is tax-exempt as an organization described in Internal Revenue Code Section 501(c)(4).
The Company is the lessee for substantially all its leasing activity, which includes operating leases for business offices, hardware, and IT assets. The average remaining lease terms for the Company's business office leases is 5 years. The Company's leased IT assets and hardware have a remaining average lease term of 2 years. The weighted average remaining lease term as of December 31, 2022 is 3 years. The weighted-average discount rate as of January 1, 2022, was 2.0%. The rate implicit in the lease is not readily determinable in the lease agreements; therefore, the Company estimated the incremental borrowing rate, at the commencement date of each lease, which is the rate of interest it would have to borrow on a collateralized basis over a similar term with similar payments. Total expenses incurred under all operating leases were $6,816 and $4,979 for the years ended December 31, 2022 and 2021, respectively. The components of lease expense for the year ended December 31, 2022, were as follows:
As of December 31, 2022, the Company had a Right of Use Asset of $24,560 and a corresponding lease liability of $25,510. Maturities of operating lease liabilities as of December 31, 2022:
The Company has a credit agreement with PNC Bank and JPMorgan Chase Bank, N.A. The credit agreement is set to expire on February 15th, 2023. On February 16, 2023, the FERC approved the Company's issuance of long-term debt which allows the Company to continue to incur indebtedness under its credit agreement for an additional two-year period. The maximum amount available under the line was $50,000 at December 31, 2022. There was no outstanding balance at December 31, 2022 or 2021. Borrowings are payable on demand. Advances bear interest at either the floating rate or Eurodollar rate. The line of credit contains certain restrictive financial and other covenants, including limitations on indebtedness, participation in mergers, sale of assets, investments, acquisitions, liens, and prepayment of indebtedness. The Company incurred closing fees of $189 to renew the credit agreement and recognized the expense in 2021.
Long-term debt consisted of the following:
Maturities of long-term debt are as follows:
On March 26, 2013, the Company issued notes with a face value of $100,000 to a group of institutional lenders. The notes are unsecured senior obligations of the Company that mature on March 26, 2033, with mandatory principal payments of $20,000 payable beginning on March 26, 2029, and on each March 26 thereafter, up to and including March 26, 2033, and bear interest at 3.96% per annum, payable semiannually on March 26 and September 26 of each year, commencing September 26, 2013. The notes have no mandatory sinking fund requirement but are redeemable, in whole or in part, at the option of the Company. The notes contain certain restrictive covenants, including limitations on payments, liens, leases, distributions, purchases, and certain investments. The Company incurred note offering fees aggregating $412 and amortized as a component of interest expense over the term of the notes. On October 5, 2017, the Company issued notes with a face value of $175,000 to a group of institutional lenders. The notes are unsecured senior obligations of the Company that mature on October 5, 2047, with mandatory principal payments of $17,500 payable beginning on October 5, 2038, and on each October 5 thereafter, up to and including October 5, 2047, and bear interest at 3.91% per annum, payable semiannually on April 5 and October 5 of each year, commencing April 5, 2018. The notes have no mandatory sinking fund requirement but are redeemable, in whole or in part, at the option of the Company. The notes contain certain restrictive covenants, including limitations on payments, liens, leases, distributions, purchases, and certain investments. The Company incurred note offering fees aggregating $525 and amortized as a component of interest expense over the term of the notes. Management has estimated the fair value of each of the notes payable based on the trading prices of similarly rated securities at December 31, 2022 and 2021. The fair values for each note payable are presented in the following table:
On August 5, 2022, MISO received notification that an employee filed a charge of age and disability discrimination against MISO with the Equal Employment Opportunity Commission (EEOC). The EEOC issued a Notice of Right to Sue on December 24, 2022 without making a determination. On January 25, 2023, MISO was served with a complaint filed against the Company by the same employee in federal court, containing the same allegations as those in the EEOC charge. Management estimates that MISO's total costs, including a judgement in favor of the employee and attorneys' fees for both parties, would fall in the range of $2,800 - $3,000. MISO has Employment Practices Liability Insurance coverage that is expected to apply to any amount paid related to a court ordered obligation or a separate settlement. MISO is estimating its liability at no greater than $1,000 based on the deductible and terms of the policy. The insurance policy is an indemnity-based policy, which means MISO would pay the funds directly and then obtain recovery through a claim under the policy related to any obligation incurred by MISO in connection with the lawsuit. There are various other claims against the Company incident to its operations. It is the opinion of management that, while unable to predict the outcome of these matters, the ultimate resolution of these matters will not have a material adverse effect on the Company's financial position or results of operations. The Company self-reports noncompliance with the North American Electric Reliability Corporation Standards throughout the year. In management's opinion, these self-reports will not result in a material impact to the financial statements. ****** |
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