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HomeMy WebLinkAbout20161115Compliance Filing.pdf~ PACIFl[ORP November 15, 2016 VL4 OVERNIGHT DELIVERY Idaho Public Utilities Commission 4 72 West Washington Boise, ID 83702-5983 Attention: Ms. Jean D. Jewell Commission Secretary FECE IVED Pacific Power I Rocky Mountain Power 825 NE Multnomah, Suite 2000 "' ·· ' c r]" I 5 fl M Portland, Oregon 97232 ,.ior ... .c Hn9:L,2 Re: Idaho Docket No. PAC-E-05-08 Compliance Filing To the Idaho Public Utilities Commission: PacifiCorp submits the attachments in compliance with the Commission's Order in this case issued on February 13, 2006 and amended on March 14, 2006. The Order approved the Stipulation supporting the acquisition of PacifiCorp by MidAmerican Energy Holdings Company.1 Commitment 120 of the Stipulation provides that PacifiCorp will provide to the Commission, on an informational basis, credit rating agency news releases and final reports regarding PacifiCorp when such reports are known to PacifiCorp and are available to the public. Therefore, in compliance with Commitment 120 of the Stipulation, please find the attached reports related to PacifiCorp. Very truly yours, ~w~ Bruce Williams Vice President and Treasurer Enclosures 1 On April 30, 2014, MidAmerican Energy Holdings Company changed its name to Berkshire Hathaway Energy Company. FitchRatings Berkshire Hathaway Energy Company Subsidiary of Berkshire Hathaway Inc. Full Rating Report Ratings Long-Term IDR Short-Term IDR Senior Unsecured BBB+ F2 BBB+ IDR -Issuer Default Rating. Rating Outlook Stable Financial Summary Berkshire Hathaway Energy Company LTM ($ Mil.) 6/30/16 2015 Adjusted Revenue 17,373 17,880 Operating EBITDAR 6,864 6,917 Cash Flow from Operations 6,218 6,980 Total Adjusted Debt 38,658 38,762 Total Capitalization 60,877 60,009 Capex/ Depreciation (%) 213.7 242.0 FFO Fixed- Charge Coverage (x) 3.9 4.1 FFO-Adjusted Leverage (x) 4.9 4.6 Total Adjusted Debt/EBITDAR (x) 5.6 5.6 Related Research U.S. Transmission and Distribution Utilities Handbook (A Detailed Review of Electric and Gas T&D Utilities - Second Edition) (May 2016) Analysts Philip Smyth, CFA +1 212 908-0531 philip.smyth@fitchratings.oom Kevin Beicke +1 212 908-0618 kevin.beicke@fitchratings.oom www.fitchratings.com Key Rating Drivers BRK Affiliation: Berkshire Hathaway Energy Company's (BHE) ratings consider the favorable impact of affiliation with Berkshire Hathaway Inc. (BRK; AA-/Stable). As a result, BHE is able to retain capital typically paid out in dividends by publicly held investor-owned utilities (IOUs). This dynamic is a function of BRK's strong credit profile, large cash position ($73 billion as of June 30, 2016) and investment appetite. Other benefits include BRK's ability to use tax shields and fund strategic growth opportunities. Diversified Asset Base: BHE's ratings are supported by its large, high-quality portfolio of utility and utility-like assets primarily located in the U.S., Canada and the U.K. BHE owns three large integrated electric utilities with generally constructive regulatory compacts and average to moderately above industry average growth trends, operating in the U.S. Rocky Mountain/ Pacific Northwest, Midwest and Desert Southwest regions. The highly politicized Nevada solar energy debate injects a measure of uncertainty into the state's political/regulatory environment. Mergers and Acquisitions: BHE has been an active consolidator in the utilities, power and gas (UPG) sector, acquiring high-quality, low-risk electric and gas utility, electric transmission and natural gas pipeline assets. Major acquisitions in recent years include Altalink, L.P. (ALP) and NV Energy, Inc. (NVE; BBB-/Stable) in 2014 and 2013, respectively. The impact of M&A on BHE's credit will be driven by price, asset quality and funding choices. Debt-funded transactions and/or acquisition of higher-risk businesses could challenge future credit quality. Manageable Leverage: Consolidated BHE leverage is relatively high. However, Fitch Ratings projects future cash flows from BHE's diverse portfolio of businesses to amply cover estimated parent-only obligations. BHE's parent-level debt increased sharply, reflecting the close of two major utility acquisitions in 2013 and 2014. Long-term debt at BHE topped out at $38.6 billion in 2014 before declining to $36.9 billion as of June 30, 2016. Fitch expects significant debt reduction will continue through 2020, absent further M&A activity. Rating Outlook: The Stable Outlook considers BHE's relatively high consolidated leverage, strong cash flows and cash retention, funding and tax advantages associated with BRK affiliation. The Stable Outlook also reflects BHE's portfolio of high-quality utility and utility-like businesses. Rating Sensitivities Positive Rating Action: High consolidated leverage limits positive rating actions in the near to intermediate term. Improvement in FFO-adjusted leverage to 4.0x or better on a sustained basis could result in future credit rating upgrades at BHE. Negative Rating Action: Deterioration of BHE's FFO-adjusted leverage to 5.0x-5.5x or worse on a consistent basis would likely lead to future credit downgrades. Longer term, a change in ownership structure and/or strategic direction at BRK that eliminates or diminishes capital retention and other benefits available to BHE from its affiliation with BRK would likely lead to downgrades at BHE. October 27, 2016 FitchRatings Related Criteria Criteria for Rating Non-Financial Corporates (September 2016) Parent and Subsidiary Rating Linkage (Fitch's Approach to Rating Entities within a Corporate Group Structure) (August 2016) Recovery Ratings and Notching Criteria for Utilities (March 2016) Rating U.S. Utilities, Power and Gas Companies (Sector Credit Factors) (March 2014) Berkshire Hathaway Energy Company October 27, 2016 Financial Overview Liquidity and Debt Structure BHE's liquidity is strong, with total available consolidated liquidity of $5.2 billion as of June 30, 2016. Liquidity consists of BHE's $778 million in consolidated cash and $4.4 billion of unused borrowing capacity under its $6.3 billion of committed revolving credit facilities. BHE has a $2 billion parent-only credit facility that matures in June 2019 and supports its CP program. Debt maturities are manageable, averaging $2.2 billion in 2016-2019. Debt Maturities and Liquidity ($ Mil., As of June 30, 2016) 2016 2017 2018 2019 2020 Thereafter Cash and Cash Equivalents Undrawn Committed Facilities Source: Company data, Bloomberg, Fitch. Cash Flow Analysis 268 899 3,619 4,075 2,012 27,674 778 5,203 Total Debt and Leverage -Total Adjusted Debt (LHS) ($ Mil.) 50,000 40,000 30,000 20,000 10,000 -Debt/EBITDAR (RHS) 0 2012 2013 2014 2015 LTM 6/30/16 Source: Company data, Fitch. (x) 8.0 6.0 4.0 2.0 0.0 BHE's FCF was $864 million in the L TM ended June 30, 2016, as indicated in the Peer Group Analysis table on the page 3. Notwithstanding significant asset acquisitions, including NVE and ALP, and significant capital investment, BHE was FCF positive in 2012-2015. Over that period, BHE averaged approximately $200 million in FCF annually. Fitch estimates that BHE will generate more than $1 .8 billion in average annual FCF during 2016-2020. Fitch estimates that FFO-adjusted debt will range from 4.6x-4.8x during 2016-2020. CFO and Cash Use •CFO ($ Mil.) 8,000 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 2012 Source: Company data, Fitch. 2013 •Capex •Dividends 2014 2015 LTM 6/30/16 2 FitchRatings Peer Group Issuer Country A- Southern Company U.S. NextEra Energy, Inc. u.s BBB+ Duke Energy Corporation U.S. Issuer Rating History LTIDR Outlook/ Date (FC) Watch May 5, 2016 BBB+ Stable Nov.24,2015 BBB+ Stable April 24, 2015 BBB+ Stable Dec. 1, 2014 BBB+ Stable Oct. 3, 2014 BBB+ RWN May 6, 2014 BBB+ RWN April 7, 2014 BBB+ Stable Sept. 16, 2013 BBB+ Stable May 30, 2013 BBB+ Stable Sept. 17, 2012 BBB+ Stable Sept. 29, 2011 BBB+ Stable Oct. 1, 2010 BBB+ Stable Oct. 2, 2009 BBB+ Stable Sept. 18, 2008 BBB+ Stable Aug. 13,2008 BBB+ Stable July 13, 2007 BBB+ Stable March 9, 2006 BBB+ Stable Dec.6.2005 BBB Stable May 24, 2005 BBB Stable Feb. 10,2004 BBB Stable Nov.27, 2002 BBB Stable Sept. 26, 2002 BBB Stable March 7, 2002 BBB Stable Jan. 31 ,2002 BBB Stable May 9, 2000 BBB Stable March 11, 1999 BBB- Feb. 10, 1998 BB+ Oct. 8, 1997 BBB- March 14, 1994 BB- LT IDR -Long-term Issuer Default Rating. FC -Foreign currency. RWN -Rating Watch Negative. Source: Fitch. Berkshire Hathaway Energy Company October 27, 2016 Peer and Sector Analysis Peer Group Analysis Berkshire Hathaway Southern NextEra Duke Energy ($ Mil.) Energy Company Company Energy, Inc. Corporation As of 6/30/16 6/30/16 6/30/16 6/30116 IDR BBB+ A-A-BBB+ Outiook Rating OuUook Rating OuUook Rating Outiook Rating OuUook Stable Stable Stable Negative Fundamental Ratios (x) Operating EBITDAR/ (Gross Interest Expense+ Rents) 3.3 6.2 4.1 4.4 FFO Fixed-Charge Coverage 3.9 6.0 4.3 3.8 Total Adjusted Debt/Operating EBITDAR 5.6 5.8 4.0 4.6 FFO/Total Adjusted Debt(%) 20.5 17.6 26.2 18.7 FFO-Adjusted Leverage 4.9 5.7 3.8 5.4 Common Dividend Payout(%) 84.7 58.7 65.7 Internal Cash/Capex (%) 116.1 65.8 45.8 63.5 Capex/Depreciation (%) 213.7 257.5 384.4 200.1 Return on Equity(%) 10.5 10.9 11.5 6.6 Financial Information Revenue 17,373 17,393 16,588 23,017 Revenue Growth(%) (1.5) (2.7) (6.3) 0.0 EBITDA 6,703 6,866 7,532 9,242 Operating EBITDA Margin(%) 38.6 39.5 45.4 40.2 FCF 864 (2,225) (5,765) (2,700) Total Adjusted Debt with Equity Credit 38,658 40,280 30,321 44,310 Readily Available Cash 778 1,897 730 676 Funds Flow from Operations 5,880 5,939 6,228 6,107 Capex (5,354) (6,514) (10,636) (7,398) IDR -Issuer Default Rating. Source: Company data, Fitch. Key Rating Issues Ownership BHE is 90% owned by BRK. Ownership of BHE by BRK affords the former with the ability to retain capital typically paid out in the form of dividends by publicly held IOUs. This dynamic is a function of BRK's strong credit profile, large cash position ($73 billion as of June 30, 2016) and investment appetite. The higher relative cash flows and liquidity, all else equal, compared with the typical IOU, provides a distinct competitive advantage, in Fitch's opinion. Other benefits include BRK's ability to use tax benefits and willingness to provide competitive funding to support BHE's strategic growth initiatives, including M&A. Diverse Asset Base BHE's ratings are supported by its large, high-quality portfolio of utility and utility-like assets primarily located in the U.S., Canada and the U.K. Consolidated BHE leverage is relatively high. However, Fitch projects future cash flows from BHE's diverse portfolio of businesses to amply cover its estimated parent-only obligations. Fitch calculates BHE's U.S. utility operations represented 61% of consolidated 2015 EBITDAR, with global utility and utility-like businesses accounting for 89%. The remainder of 2015 EBITDA was provided by BHE's renewables 3 FitchRatings Berkshire Hathaway Energy Company October 27, 2016 business, which invests in projects that have negotiated long-term contracts with creditworthy counterparties in place, and its relatively small real-estate brokerage business. PacifiCorp PacifiCorp (PPW, A-/Stable), with its six-state Pacific Northwest/Rocky Mountain region service territory, is the largest of BHE's three U.S. integrated utility operations. PPW accounted for 30% of BHE's consolidated 2015 EBITDA. By comparison, BHE subsidiaries NVE and MidAmerican Funding accounted for 18% and 13% of consolidated 2015 EBITDA, respectively. Regulation across PPW's service territory is generally balanced, with the exception of Washington, which has been somewhat challenging and represents a relatively small slice of jurisdictional revenue. PPW's Washington operations represented approximately 8% of consolidated 2015 kWh sales. By comparison, Utah, Oregon and Wyoming represent 44%, 24% and 17% of kWh sales, respectively. Fitch believes that PPW's most recent Washington jurisdictional general rate case (GRC) was more constructive from a credit perspective than two previous GRC decisions. In September 2016, the Washington Utilities and Transportation Commission approved a two-phase rate increase totaling $13.7 million based on a 9.5% authorized ROE. Regulatory outcomes across the remainder of PPW's service territory have been and are expected to continue to be balanced. Various riders are in place to facilitate recovery of certain costs outside of GRCs, including fuel-adjustment clauses that mitigate commodity price exposure in all of PPW's regulatory jurisdictions. PPW's capex in 2015 declined 14% to $916 million from $1 .07 billion in 2014 and was 32% below 2012 capex of $1 .3 billion. By comparison, PPW capex averaged $1 .5 billion per year in 2010-2012, while projected 2016-2018 capex approximates $807 million per year on average. Lower capex levels at PPW in recent years reflect completion of large projects, including major transmission and renewables investments. In addition, capex incorporates slower PPW service territory load growth and efforts by management to minimize customer rate increases. Efforts by management to minimize customer rate increases while maintaining system reliability, safety and customer service have resulted in generally flat O&M expense. Slowing PPW service territory load growth trends are driven primarily, in Fitch's view, by energy efficiency gains and are a source of some uncertainty, along with the impact of environmental rules and regulations on PPW's coal-fired generation. Fitch believes these dynamics are manageable within the regulatory compact and unlikely to meaningfully weaken PPW's creditworthiness in the near to intermediate term. Conversely, legislation enacted this year in Oregon and Utah is credit supportive, in Fitch's opinion. Oregon Senate Bill (S.B.) 1547-B, phasing out coal-fired generation by 2035 while sharply increasing Oregon's renewable standard, was signed into law March 2016 by Gov. Kate Brown. The law sets firm milestones for the elimination of coal generation for the state's two largest electric utilities, Portland General by 2035 and Pacific Power (which is a division of PPW), by 2030. S.B. 1547-B also sets a significantly higher renewable portfolio standard (RPS), requiring that 35% of retail load is sourced from qualifying renewables by 2030, 45% in 2035 and 50% by 2040. Oregon's 2007 RPS required that 25% of retail customer power needs be met by qualifying renewables by 2025. S.B. 1547-B is the result of a collaborative process of stakeholders, including PPW and environmental groups, and will help the state achieve its ambitious carbon reduction goal of 75% below 1990 levels by 2050. PPW estimates that the legislation will save consumers up to $600 million compared with a ballot initiative sponsored by Renew Oregon 4 FitchRatings Berkshire Hathaway Energy Company October 27, 2016 that was withdrawn as part of the settlement. Fitch expects the legislation will bring pressure PPW cost structure. Costs related to the legislation are expected to be recoverable in rates. In Utah, Gov. Gary Herbert signed Utah Senate Bill 115 on March 30, 2016. Enactment of S.B. 115 is a constructive development that includes, among other things, authorization of recovery of 100% of net power costs outside of GRC proceedings. The law also requires the Utah Public Service Commission to establish a fund through a change in accounting for energy-efficiency programs as a reserve for coal plant exposure. In addition, S. B. 115 establishes and funds a pilot for investment in electric vehicle infrastructure and clean coal research. MFIMEC MidAmerican Funding LLC (MF; BBB+/Stable) is an intermediate holding company that owns all of MidAmerican Energy Company's (MEC; A-/Stable) equity and accounted for approximately 13% of BHE's proforma 2015 EBITDA. MEC is headquartered in Des Moines, IA, and operates in four Midwestern states. The utility's Iowa service territory accounts for the vast majority of MEC and MF's consolidated earnings and cash flows. The regulatory regime in Iowa is balanced from a credit point of view. In MEC's last GRC, the Iowa Utilities Board (IUB) authorized a stipulation that increased MEC's base rates by $266 million, representing 100% of MEC's request. The rate order included revenue sharing based on specific ROE hurdles and authorized energy and transmission cost adjustment mechanisms. Separately, the IUB, in an August 2016 order approving ratemaking principles for the planned construction of MEC's 2,000-MW Wind XI project, modified MEC's sharing mechanism. The modified mechanism would recalculate the sharing trigger annually using a weighted average of all rate-making principle equity returns and all other rate base. All other rate base, including Wind XI, would be calculated based on the 30-year single-A utility bond yield plus 400 basis points with a minimum 9.5% ROE sharing trigger. The current threshold would be 10.7%. If approved by the IUB, MEC would use 100% of net income in excess of the weighted average ROE sharing trigger to reduce coal and nuclear rate base, in effect, reducing future rates to customers. Currently, the revenue sharing mechanism trigger is an 11 % ROE with 80% of MEC net income over the 11% ROE used to reduce rate base and 20% retained by the company up to a 14% ROE. Over 14%, all earnings are used to reduce rate base. MEC has significantly diversified its fuel mix in recent years via meaningful new-build wind generation while maintaining rates that are competitive regionally and compared with the national average. With anticipated completion of Wind XI in 2019, MEC's wind generating capacity will increase to more than 6,000 MW from 3,448 MW at year-end 2015. Nonetheless, compliance with EPA's Clean Power Plan's carbon-reduction targets is a source of some uncertainty. NV Energy NVE's operating subsidiaries, Nevada Power Company (NPC; BBB/Stable) and Sierra Pacific Power Company (SPPC; BBB/Stable), provide utility service to the greater Las Vegas area, Reno and northern Nevada. NVE accounted for 18% of BHE's 2015 EBITDA. In Fitch's view, recent developments in Nevada, including New Energy Industry Task Force (NETF) recommendations to Gov. Brian Sandoval, turnover at the commission and a highly politicized debate regarding net energy metering (NEM) inject a level of uncertainty into the state's regulatory compact. Fitch believes regulation in Nevada has been and is likely to continue to remain credit supportive. 5 FitchRatings Berkshire Hathaway Energy Company October 27, 2016 Under Nevada regulation, GRC filings are required at least every three years. The Public Utilities Commission of Nevada (PUCN) is required to issue a final decision within seven months of the filing date. Nevada regulation allows inclusion of known and measurable adjustments to the test year; preapproval of capex; and mechanisms for the timely recovery of fuel and purchase power, energy efficiency and conservation program costs. Twenty-year integrated resource plans are filed every three years and are subject to PUCN review with regard to ultimate inclusion in base rates. SPPC filed its electric and gas GRC in June 2016 and Fitch expects NPC to file its next GRC in 2017, consistent with the mandatory three-year cycle for base electric rate case filings in effect in Nevada. NVE management is focussed on minimizing cost inflation and providing stable customer rates. In its filing , SPPC is seeking no change in electric rates, but indicates a $21 million revenue deficiency. SPPC also filed a natural gas GRC seeking an $8,000 revenue reduction. The electric and gas filings are based on a calendar 2015 test years updated for known and measurable changes through May 31, 2016. The PUCN staff filed testimony in the proceeding supporting a $4.9 million electric rate increase and a $4.4 million gas rate reduction. In addition, the Office of Attorney General Bureau of Consumer Protection filed testimony in the GRC supporting a $12.7 million electric rate reduction and a $6.7 million gas rate reduction. A final PUCN decision is expected by year end with rates effective Jan. 1, 2017. On Oct. 18, 2016, SPPC filed a stipulation with the PUCN that includes the regulatory operations staff of the PUCN and the bureau of consumer protection, among other signatories. The stipulation supports electric and gas tariff decreases of $2.9 million and $2.4 million, respectively, through existing rate design based on sales and lower volumetric rates. The settlement does not address non-grandfathered NEM rate design or optional time-of-use rate schedules for certain customer classes. Authorized returns on equity for SPPC's electric and gas operations as proposed by the stipulation are 9.6% and 9.5%, respectively. The PUCN is not bound by the agreement and the parties to the stipulation request that new rates become effective Jan. 1, 2017. In SPPC's 2013 GRC, the PUCN issued a final order in December 2014. SPPC filed the GRC in June 2013, supporting a $2.5 million net rate decrease composed of an $8.4 million electric rate reduction and a $5.9 million gas rate increase. The final PUCN order granted a $35.2 million net rate decrease, consisting of a $39.1 million electric rate reduction and a $3.9 million gas rate increase. In its last rate case, NPC reached a settlement agreement that was approved by the PUCN with modification, resulting in no change to base rates. In addition, the settlement included several rate design adjustments that are modestly constructive from a credit perspective. The authorized ROE included in the settlement was somewhat below the industry average at that time. The rate case was initiated by NPC in May 2014 and the commission order approving the settlement agreement issued October 2014. Customer choice for large commercial and industrial customers has been in effect since 2002, following enactment of enabling legislation. In 2015, the PUCN approved requests by two casinos to procure their energy supply from alternative providers contingent upon the casinos paying exit fees totalling approximately $103 million. Two large casinos, MGM Resorts International and Wynn, served notice to the PUCN and began procuring energy and ancillary services from an alternative supplier in October 2016. 6 FitchRatings Berkshire Hathaway Energy Company October 27, 2016 Net Metering Update In December 2015, the PUCN issued an order that established separate rate classes for customers with installed distributed renewable generation resources. The PUCN order also established new rates for NEM customers. The new rates include a higher basic service charge to better reflect fixed utility service costs and a lower volumetric rate. The changes in rates are revenue neutral to the utility and, combined with the cordoning off of NEM customers as a separate class, are expected to effectively mitigate cross-subsidization issues. In addition, the commission order reduced the credit for customer exports to NVE from the full retail rate to the actual value of excess generation based on the utility's avoided cost, phasing in the lower NEM customer credits over 12 years. S.B. 374 enacted in June 2015 directed the PUCN to review net metering rates and identify and eliminate unreasonable shifts in costs from net metering customers to non-net metering customers by year-end 2015. The commission's order regarding NEM was controversial , especially in light of the fact that existing distributed solar installations were not protected. The political backlash to the commission action has been strong. In September, Gov. Sandoval did not reappoint Chairman David Noble, opting instead to appoint Joe Reynolds, former general counsel for the Sandoval administration, as chairman of the PUCN. Sandoval also appointed Leo Drozdoff as acting commissioner. The appointments replace departing PUCN Chairman Noble and Commissioner Alaina Burtenshaw. Also in September, the PUCN voted to approve a net metering tariff that grandfathers existing distributed systems for a 20-year period. In addition, the New Energy Industry Task Force submitted recommendations to address long-term energy issues in Nevada to Gov. Sandoval that include reinstatement of NEM, among other things. Nevada's Nov. 8, 2016 election ballot will include a proposed constitutional amendment to implement full retail customer choice in the state. Currently in Nevada, only large commercial and industrial customers have access to retail customer choice. Modest Sales Growth Total NVE retail electricity sales rose 1.7% in 2015 compared with 2014 levels, reflecting strong residential, commercial and industrial sales at NPC and weak mining segment load at SPPC. Retail sales are expected to be essentially flat in 2016 and increase 1.6% in 2017, reflecting stronger nonresidential load growth at both NPC and SPPC. A solid service territory economy, no state income tax and low business taxes support future growth, offset in part by energy efficiency initiatives. Fitch believes competitive inroads from competing, alternative energy resources, including distributed generation and energy efficiency, are a secular credit concern for NVE that will prove manageable within the regulatory compact. NVE management is focused on working with Nevada regulators and legislators to equitably balance the interests of all constituents with regard to emerging growth in demand for distributed resources, including rooftop solar. Capex NVE capex ranged from $372 million to $572 million in 2012-2015 and totalled $1.5 billion. By comparison, capex is expected to approximate $1 .2 billion in 2016-2018. The lower 2016-2018 capex compares to NVE's prior guidance of $1 .7 billion. Lower capex reflects removal of certain projects proposed by NVE to replace coal retirements mandated by S.B. 123 and rejected by the PUCN. The commission rejected planned construction by NVE of a 570 MW combined-cycle gas turbine in 2017 and investment in a 100 MW utility-scale photovoltaic power plant in 2017. Fitch estimates NVE will be modestly FCF negative during 2016-2018. 7 FitchRatings Berkshire Hathaway Energy Company October 27, 2016 S.B. 123 S.B. 123, enacted in 2013, mandates retirement of approximately 800 MW of generating capacity starting in December 2014. The retired coal-fired generating capacity will be replaced with a mix of renewable and natural gas-fired generation. NPC filed its emissions reduction and capacity replacement (ERCR) plan in May 2014, which was approved by the PUCN in October 2014. Under the PUCN-authorized ERCR plan, NPC will retire 812 MW of coal generation and replace the coal generation retirements with a mix of renewable energy, primarily through purchase power agreements. NPC retired Reid Gardner Generating Station units 1, 2 and 3 in 2014 and plans to close unit 4 in 2017. In addition, NPC will eliminate its ownership interest in the Navajo Generating Station in 2019. Enactment of S.B. 123 and PUCN authorization of NPC's ERCR is a constructive development, in Fitch's view, that is reflected in the company's current ratings. Gas Transmission Business BHE's gas transmission business is composed of Northern Natural Gas (NNG; A/Stable) and Kern River Funding Corp. (KRF; A-/Stable), and delivers approximately 8% of the natural gas consumed in the U.S. NNG and KRF contributed approximately 9% to BHE's consolidated EBITDA in 2014. NNG's natural gas transportation system is an essential source of contracted supply to its Upper Midwest utility customer base and its reticulated system is well positioned, in Fitch's view, with low business risk. Counterparty credit risk is ameliorated by the pipeline's diverse group of primarily highly rated offtakers with multiyear contracts. NNG's ratings also consider the pipeline operator's constructive regulatory compact and consistent ability to earn reasonable ROEs. KRF transports competitive Rocky Mountain natural gas to large-volume end users in Utah, southern Nevada and Southern California. Recontracting risk and more stringent rules regarding pipeline integrity and related issues are potential sources of concern for NNG and KRF. However, Fitch believes these concerns are manageable within the pipelines' current rating categories, given their strong competitive positions in their respective markets and ongoing infrastructure investment by management. Northern Powergrid Holdings Company Northern Powergrid Holdings Company (NPG; BBB+/Stable) is a UK-based electricity distribution group that is wholly owned by BHE. NPG, through its distribution network operator (DNO) subsidiaries Northern Powergrid (Northeast) Limited (NPN; A-/Stable) and Northern Powergrid (Yorkshire) pie (NPY; A-/Stable), serves a 10,000-square-mile service area in Britain. NPG accounted for approximately 11 % of BHE's consolidated 2015 EBITDA. The UK's low-carbon energy policy, integration of increasing distribution generation production and efforts to modify consumer behavior will add a level of complexity to DNO operations. Nonetheless, the DNOs are stable regulated businesses with growing, relatively predicable, inflation-protected revenue and cash flow. British energy regulator Office of Gas and Electricity Markets finalized its RI IO-ED1 (ED1) price controls effective April 1, 2015 through March 31, 2023. Fitch believes ED1 is tougher than its predecessor DPCR5, but considers ED1 to be credit neutral. ED1 authorizes a significantly lower ROE and requires delivery of higher outputs with greater efficiency. NPN and NPY delivered strong operating performance under DPCR5, and Fitch expects them to outperform ED1 targets. Fitch's March 2016 rating affirmation of NPG and its subsidiaries with a Stable 8 FitchRatings Berkshire Hathaway Energy Company October 27, 2016 Outlook considers the companies solid incentive performance under the new price control and greater confidence that company performance will be consistent with ratio guidance, among other things. SHE Transmission BHE Transmission represented approximately 8% of consolidated 2015 BHE EBITDA and is comprised of BHE Canada Holdings Corp., including ALP and BHE U.S. Transmission. ALP is an Alberta, Canada-based transmission operator with a proscriptive, credit-supportive regulatory regime and low business risk profile. BHE completed the acquisition of ALP on Dec. 1, 2014, acquiring the company's equity for approximately $2.7 billion. Factoring in assumed debt, the transaction's enterprise value was approximately $7 billion. ALP operates solely in the Alberta transmission market, where it provides access to wholesale markets to power generators, utilities, retailers and industrial users. ALP, along with BHE's other transmission assets, accounted for approximately 7.6% of consolidated 2014 BHE pro forma EBITDA. ALP is not subject to commodity or volumetric risk. Counterparty credit risk is significantly reduced by exclusive billings to the Alberta Electric System Operator (AESO), a financially robust offtaker. Rate shock concerns associated with the large build cycle underway in Alberta are mitigated by a highly standardized, transparent provincial regulatory process. ALP is regulated by the Alberta Utilities Commission (AUC), which under the Electric Utilities Act is charged with providing ALP with a reasonable opportunity to recover prudently incurred and forecast costs and a fair return on investment. Rates are established based on a forecast test year on a cost-of-service basis. Once approved, revenue is paid to ALP by the AESO in monthly installments. Cost of capital issues are bifurcated from GRCs in generic cost of capital (GCOC) proceedings. In its most recent GCOC proceeding , the AUC authorized an 8.3% ROE effective 2013-2015, 45 bp below the placeholder ROE included in ALP's last GRC of 8.75%. In addition, the AUC reduced ALP's authorized common equity ratio to 36% from 37%. In Fitch's view, the sharp reduction in ROE and lower equity ratio are concerns for investors from a credit perspective. Renewables Business BHE has invested in several utility-scale wind and solar generation projects that have long-term purchase power agreements in place with creditworthy counterparties, and remains committed to further development on a diversified basis. Future viable potential renewables investment includes tax equity and distributed generation. In addition to renewables, BHE owns 10 geothermal facilities and a real estate brokerage, among other investments. Renewables and other investments represented just less than 10% of consolidated EBITDA in aggregate. Mergers and Acquisitions BHE has been an active consolidator in the UPG sector, acquiring high-quality, low-risk electric and gas utility, electric transmission and natural gas pipeline assets. Large acquisitions in recent years include ALP for $7 billion enterprise value in December 2014, NVE for $10 billion enterprise value in December 2013; and PPW for $9.5 billion enterprise value in 2006. Future debt-financed transactions and/or acquisition of businesses with relatively high business risk could pressure BHE's credit ratings. 9 FitchRatings Organizational Structure Organizational and Debt Structure -Berkshire Hathaway Energy Company ($ Mil., As of June 30, 2016) MidAmerican Energy Company IDR -A-'Stable Total Adjusted Debt 4 300 Pac1f1Corp IDR -A-/Stable Total Adjusted Debt 7 221 IDR -Issuer Default Rating. Source: Company filings, Fitch. Berkshire Hathaway Energy Company October 27, 2016 Northern Natural Gas Company IDR -A/Stable Total Adjusted Debt 827 10 FitchRatings Definitions • Total Adjusted Debt/Op. EBITDAR: Total balance sheet adjusted for equity credit and off-balance-sheet debt divided by operating EBITDAR. • FFO Fixed-Charge Coverage: FFO plus gross interest minus interest received plus preferred dividends plus rental payments divided by gross interest plus preferred dividends plus rental payments. • FFO-Adjusted Leverage: Gross debt plus lease adjustment minus equity credit for hybrid instruments plus preferred stock divided by FFO plus gross interest paid plus preferred dividends plus rental expense. Berkshire Hathaway Energy Company October 27, 2016 Key Metrics Total Adjusted Debt/Op. EBITDAR -Berkshire Hathaway Energy Company (x) 8.0 7.0 6.0 5.0 4.0 3.0 2.0 -UPC Median 1.0 L__ 0.0 ------------- 2012 2013 2014 UPC -Ultimate parent company. Source: Company data, Fitch. FFO-Adjusted Leverage 2015 LTM 6/30/16 -Berkshire Hathaway Energy Company (x) 7.0 6.0 5.0 4.0 3.0 2.0 1.0 0.0 -UPC Median L'::::: - 2012 2013 2014 UPC -Ultimate parent company. Source: Company data, Fitch. 2015 LTM 6/30/16 FFO Fixed-Charge Coverage -Berkshire Hathaway Energy Company -UPC Median (x) 6.0 4.0 2.0 0.0 2012 2013 2014 2015 LTM 6/30/16 UPC -Ultimate parent company. Source: Company data, Fitch. Capex/Depreciation -Berkshire Hathaway Energy Company -UPC Median (%) 350 300 ~ 250 ~--........... u...a~ ~~~ L 100 50 0 2012 2013 2014 2015 UPC -Ultimate parent company. Source: Company data, Fitch. LTM 6/30/16 11 FitchRatings Berkshire Hathaway Energy Company October 27, 2016 Company Profile BHE is 90% owned by BRK and is BRK's vehicle for expansion in the utilities, power and gas sector. BHE M&A activity accelerated in 2013 and 2014 with the acquisitions of NVE and ALP. BHE acquired PPW in 2006 for $9.5 billion enterprise value. As the result of the addition of NVE, ALP and other investments, BHE revenue increased from $11 .5 billion in 2012 to $17.9 billion in 2015. Meanwhile, EBITDA increased approximately 70% from $4.0 billion in 2012 to $6.8 billion in 2015 and total adjusted debt with equity credit increased from $22 billion on Dec. 31 , 2012 to $39 billion on Dec. 31 , 2015. BHE's unregulated operations accounted for 11 % of consolidated, pro form a 2015 EBITDA and consist primarily of utility-scale wind and solar projects with long-term purchase power agreements. BHE also owns 10 geothermal facilities and a real estate brokerage, among other investments. Business Trends Revenue Dynamics -Net Revenues (LHS) -Net Revenue Growth (RHS) ($ Mil.) 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0 2012 2013 2014 2015 LTM 6/30/16 Source: Company data, Fitch. (%) 35 30 25 20 15 10 5 0 EBITDA Dynamics -EBITDA (RHS) -EBITDA Margin (LHS) ($ Mil.) (%) 8,000 39 7,000 38 6,000 37 5,000 36 4,000 35 3,000 2,000 34 1,000 33 0 32 2012 201 3 2014 2015 LTM 6/30/16 Source: Company data, Fitch. 12 FitchRatings Financial Summary -Berkshire Hathaway Energy Company ($ Mil., As of June 30, 2016, IDR -BBB+/Rating Outlook Stable) Fundamental Ratios Operating EBITDAR/(Gross Interest Expense+ Rents) (x) FFO Fixed-Charge Coverage (x) Total Adjusted Debt/Operating EBITDAR (x) FFO/Total Adjusted Debt(%) FFO-Adjusted Leverage (x) Common Dividend Payout(%) Internal Cash/Capex (%) Capex/Depreciation (%) Return on Equity(%) Profitability Revenues Revenue Growth(%) Net Revenues Operating and Maintenance Expense Operating EBITDA Operating EBITDAR Depreciation and Amortization Expense Operating EBIT Gross Interest Expense Net Income for Common Operating Maintenance Expense% of Net Revenues Operating EBIT % of Net Revenues Cash Flow Cash Flow from Operations Change in Working Capital Funds from Operations Dividends Capex FCF Net Other Investment Cash Flow Net Change in Debt Net Equity Proceeds Capital Structure Short-Term Debt Total Long-Term Debt Total Debt with Equity Credit Total Adjusted Debt with Equity Credit Total Common Shareholders' Equity Total Capital Total Debt/Total Capital(%) Common Equity/Total Capital(%) IDR -Issuer Default Rating. Source: Company data, Fitch. Berkshire Hathaway Energy Company October 27, 2016 2012 2013 3.2 3.4 4.2 4.1 5.4 7.0 24.6 17.4 4.1 5.7 128.0 108.4 232.3 276.1 9.8 9.5 11,548 12,635 3.4 9.4 8,031 8,836 (2,778) (2,794) 4,022 4,395 4,134 4,513 (1 ,455) (1,560) 2,567 2,835 (1,176) (1,222) 1,472 1,636 (34.6) (31.6) 32.0 32.1 4,327 4,669 150 491 4,177 4,178 (3,380) (4,307) 947 362 (450) (506) 534 5,079 1,000 887 232 20,735 32,012 21 ,684 30,947 22,241 31,723 15,866 18,711 37,469 49,763 58 61 42 37 2014 2016 LTM 6/30/16 3.4 3.4 3.3 4.4 4.1 3.9 6.3 5.6 5.6 20.9 21 .7 20.5 4.8 4.6 4.9 78.5 118.8 109.8 318.7 242.0 213.7 10.7 11.1 10.5 17,326 17,880 17,373 37.1 3.2 (1 .5) 11,594 12,801 12,812 (3,501) (3,732) (3,682) 6,103 6,756 6,703 6,249 6,917 6,864 (2,057) (2,428) (2,505) 4,046 4,328 4,198 (1,711) (1,904) (1,897) 2,095 2,370 2,369 (30.2) (29.2) (28.7) 34.9 33.8 32.8 5,146 6,980 6,218 (1,170) 649 338 6,316 6,331 5,880 (6,555) (5,875) (5,354) (1 ,409) 1,105 864 8 (268) (592) 3,799 (146) (455) (36) 1,445 974 1,469 38,649 37,972 36,881 38,197 37,474 37,378 39,141 38,762 38,658 20,442 22,401 23,357 58,770 60,009 60,877 63 61 60 34 37 38 13 FitchRatings The ratings above were solicited by, or on behalf of, the issuer, and therefore, Fitch has been compensated for the provision of the ratings. 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Users of Fitch's ratings and reports should understand that neither an enhanced factual investigation nor any third-party verification can ensure that all of the information Fitch relies on in comection wth a rating or a report v.ill be accurate and complete. Ultimately, the issuer and its advisers are responsible for the accuracy of the information they provide to Fitch and to the market in offering documents and other reports. In issuing its ratings and its reports, Frtch must rely on the work of experts, including independent auditors wth respect to financial statements and attorneys v.ith respect to legal and tax matters. Further, ratings and forecasts of financial and other information are inherently forward-looking and embody assumptions and predictions about Mure events that by their nature cannot be verified as facts. As a result, despite any verification of current facts, ratings and forecasts can be affected by Mure events or conditions that v.ere not anticipated at the time a rating or forecast was issued or affirmed. The information in this report is provided "as is" wthout any representation or warranty of any kind, and Fitch does not represent or warrant that the report or any of its contents v.ill meet any of the requirements of a recipient of the report. A Fitch rating is an opinion as to the creditv.orthiness of a security. This opinion and reports made by Fitch are based on established criteria and methodologies that Fitch is continuously evaluating and updating. Therefore, ratings and reports are the collective work product of Fitch and no individual, or group of indMduals, is solely responsible for a rating or a report. The rating does not address the risk of loss due to risks other than credit risk, unless such risk is specifically mentioned. 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Fitch receives fees from issuers, insurers, guarantors, other obligors, and undeM1iters for rating securities. Such fees generally vary from US$1,000 to US$750,000 (or the applicable currency equivalent) per issue. In certain cases, Frtch v.ill rate all or a number of issues issued by a particular issuer, or insured or guaranteed by a particular insurer or guarantor, for a single annual fee. Such fees are expected to vary from US$10,000 to US$1,500,000 (or the applicable currency equivalent). The assigrment, publication, or dissemination of a rating by Fitch shall not constitute a consent by Fitch to use its name as an expert in connection wth any registration statement filed under the United States securities laws, the Financial Services and Markets Act of 2000 of the United Kingdom, or the securities laws of any particular jurisdiction. Due to the relative efficiency of electronic publishng and distribution, Frtch research may be available to electronic subsaibers up to three days earlier than to print subsaibers. For Australia, Nev,, Zealand, Taiwan and South Korea only: Frtch Australia Ply Ltd holds an Australian financial services license (AFS license no. 337123) v.tiich authorizes it to provide credit ratings to v.tlolesale dients only. Credit ratings information published by Fitch is not intended to be used by persons v.tio are retail dients v.ithin the meaning of the Corporations Act 2001. Berkshire Hathaway Energy Company October 27, 2016 14 FitchRatings FITCH DOWNGRADES VARIOUS NON-FI CORPORATES' S-T RATINGS Fitch Ratings-New York/Chicago-21 October 2016: Fitch Ratings has downgraded the Short-Term Issuer Default Ratings (ID Rs), commercial paper and related short-term instrument ratings for the issuers listed below. No other ratings for these issuers, including their Long-Term IDRs, issue ratings, or Outlooks have been changed. KEY RA TING DRIVERS The downgrades are a result of Fitch's updated Criteria for Rating Non-Financial Corporates master criteria, which was published on Sept. 27, 2016. The update clarifies that where there are short-term rating cusps in the 'A' category Fitch opts for the lower option. Thus, 'A+' long-term ratings have a 'Fl' short-term rating and 'A-' long-term ratings have a 'F2' short-term rating. The time horizon of short-term ratings does not explicitly relate to the 13 months immediately following a given date. Instead, it relates to the continual liquidity profile of the rated entity that would be expected to endure over the time horizon of the Long-Term IDR, typically one economic cycle. This approach places less emphasis on favourable or unfavourable features of the liquidity profile when they are considered temporary. Short-term ratings are linked to long-term ratings as liquidity and near-term concerns are part of the long-term credit profile review. Cusps exist on the short-term scale, where Fitch groups may opt to assign higher or lower short term rating equivalents. When the long-term rating is in the 'A' category, the higher short-term option is common for sovereigns and banks, which have access to fiat currency creation and discount windows. In comparison, even higher-rated corporates do not typically possess the kinds of additional liquidity options ( e.g. fiat currency creation, discount window access) available to the strongest sovereign and bank issuers. KEY ASSUMPTIONS There have been no changes to the existing rating assumptions for each issuer included in this review. Please see Fitch's previously issued press release/company report related to the issuers included in this review for Fitch's key assumptions. RA TING SENSITIVITIES There have been no changes to the existing rating sensitivities for each issuer included in this review. Please see Fitch's previously issued press releases or company reports related to the issuers included in this review for Fitch's rating sensitivities. FULL LIST OF RA TING ACTIONS Fitch has downgraded the short-term ratings for the following issuers: Gulf Power Company MidAmerican Energy Company NextEra Energy Capital Holdings, Inc. (formerly FPL Group Capital Inc.) PacifiCorp Peoples Gas Light and Coke Co. Southern Company Wisconsin Gas LLC --Short-Term IDR and short-term ratings to 'F2' from 'Fl'. Contacts: Primary Analyst (Gulf Power Company, NextEra Energy Capital Holdings, Inc. (formerly FPL Group Capital Inc.), Southern Company) Secondary Analyst (Peoples Gas Light and Coke Co., Wisconsin Gas LLC) Shalini Mahajan, CF A Managing Director + 1-212-908-0351 Fitch Ratings, Inc. 33 Whitehall St. New York, NY 10004 Primary Analyst (MidAmerican Energy Company, PacifiCorp) Philip Smyth, CF A Senior Director + 1-212-908-0531 Fitch Ratings, Inc. 33 Whitehall St. New York, NY 10004 Primary Analyst (Peoples Gas Light and Coke Co., Wisconsin Gas LLC) Philippe Beard Director + 1-212-908-0242 Fitch Ratings, Inc. 33 Whitehall St. New York, NY 10004 Secondary Analyst (Gulf Power Company, Southern Company) Julie Jiang Director + 1-212-908-0708 Secondary Analyst Kevin Beicke, CFA (MidAmerican Energy Company, PacifiCorp) Director + 1-212-908-0618 Secondary Analyst (NextEra Energy Capital Holdings, Inc. (formerly FPL Group Capital Inc.) Maude Tremblay, CFA Director + 1-312-368-3203 Committee Chairperson Rolando Larrondo Group Credit Officer + 1-212-908-9189 Media Relations: Alyssa Castelli, New York, Tel: +1 (212) 908 0540, Email: alyssa.castelli@fitchratings.com. Date of Relevant Rating Committee: Gulf Power Company: May 12, 2016 MidAmerican Energy Company: Nov. 24, 2015 NextEra Energy Capital Holdings, Inc.: July 29, 2016 PacifiCorp: Nov. 24, 2015 Peoples Gas Light and Coke Co.: Aug. 17, 2015 Southern Company: May 12, 2016 Wisconsin Gas LLC: Aug. 17, 2015 Summary of Financial Statement Adjustments -There have been no changes to the existing financial statement adjustments for each issuer included in this review. Please see Fitch's previously issued press release/company reports related to the issuers included in this review for Fitch's financial statement adjustments. Additional information is available on www.fitchratings.com. Applicable Criteria Criteria for Rating Non-Financial Corporates (pub. 27 Sep 2016) https://www.fitchratings.com/site/re/885629 ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS. PLEASE READ THESE LIMITATIONS AND DISCLAIMERS BY FOLLOWING THIS LINK: HTTPS://WWW.FITCHRATINGS.COWUNDERSTANDINGCREDITRATINGS. IN ADDITION, RA TING DEFINlTIONS AND THE TERMS OF USE OF SUCH RA TINGS ARE AVAILABLE ON THE AGENCY'S PUBLIC WEB SITE AT WWW.FITCHRA TINGS.COM. PUBLISHED RA TINGS, CRITERIA, AND METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES. FITCH'S CODE OF CONDUCT, CONFIDENTIALITY, CONFLICTS OF INTEREST, AFFILIATE FIREWALL, COMPLIANCE, AND OTHER RELEVANT POLICIES AND PROCEDURES ARE ALSO AVAILABLE FROM THE CODE OF CONDUCT SECTION OF THIS SITE. FITCH MAY HAVE PROVIDED ANOTHER PERMISSIBLE SERVICE TO THE RATED ENTITY OR ITS RELATED THLRD PARTIES. DETAILS OF THIS SERVICE FOR RATINGS FOR WHICH THE LEAD ANALYST IS BASED IN AN EU-REGISTERED ENTITY CAN BE FOUND ON THE ENTITY SUMMARY PAGE FOR THIS ISSUER ON THE FITCH WEBSITE. Copyright © 2016 by Fitch Ratings, Inc., Fitch Ratings Ltd. and its subsidiaries. 33 Whitehall Street, NY, NY !0004. Telephone: l-800-753-4824, (212) 908-0500. Fax: (212) 480-4435. Reproduction or retransmission in whole or in part is prohibited except by permission. All rights reserved. In issuing and maintaining its ratings and in making other reports (including forecast information), Fitch relies on factual information it receives from issuers and underwriters and from other sources Fitch believes to be credible. Fitch conducts a reasonable investigation of the factual information relied upon by it in accordance with its ratings methodology, and obtains reasonable verification of that information from independent sources, to the extent such sources are available for a given security or in a given jurisdiction. The manner of Fitch's factual investigation and the scope of the third-party verification it obtains will vary depending on the nature of the rated security and its issuer, the requirements and practices in the jurisdiction in which the rated security is offered and sold and/or the issuer is located, the availability and nature of relevant public information, access to the management of the issuer and its advisers, the availability of pre-existing third-party verifications such as audit reports, agreed-upon procedures letters, appraisals, actuarial reports, engineering reports, legal opinions and other reports provided by third parties, the availability of independent and competent third-party verification sources with respect to the particular security or in the particular jurisdiction of the issuer, and a variety of other factors. Users of Fitch's ratings and reports should understand that neither an enhanced factual investigation nor any third-party verification can ensure that all of the information Fitch relies on in connection with a rating or a report will be accurate and complete. Ultimately, the issuer and its advisers are responsible for the accuracy of the information they provide to Fitch and to the market in offering documents and other reports. In issuing its ratings and its reports, Fitch must rely on the work of experts, including independent auditors with respect to financial statements and attorneys with respect to legal and tax matters. Further, ratings and forecasts of financial and other information are inherently forward-looking and embody assumptions and predictions about future events that by their nature cannot be verified as facts. As a result, despite any verification of current facts, ratings and forecasts can be affected by future events or conditions that were not anticipated at the time a rating or forecast was issued or affirmed. The information in this report is provided "as is" without any representation or warranty of any kind, and Fitch does not represent or warrant that the report or any of its contents will meet any of the requirements of a recipient of the report. A Fitch rating is an opinion as to the creditworthiness of a security. This opinion and reports made by Fitch are based on established criteria and methodologies that Fitch is continuously evaluating and updating. Therefore, ratings and reports are the collective work product of Fitch and no individual, or group of individuals, is solely responsible for a rating or a report. The rating does not address the risk of loss due to risks other than credit risk, unless such risk is specifically mentioned. 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Fitch receives fees from issuers, insurers, guarantors, other obligors, and underwriters for rating securities. Such fees generally vary from US$!,OOO to US$750,000 (or the applicable currency equivalent) per issue. In certain cases, Fitch will rate all or a number of issues issued by a particular issuer, or insured or guaranteed by a particular insurer or guarantor, for a single annual fee. Such fees are expected to vary from US$10,000 to US$1,500,000 (or the applicable currency equivalent). The assignment, publication, or dissemination of a rating by Fitch shall not constitute a consent by Fitch to use its name as an expert in connection with any registration statement filed under the United States securities laws, the Financial Services and Markets Act of 2000 of the United Kingdom, or the securities laws of any particular jurisdiction. Due to the relative efficiency of electronic publishing and distribution, Fitch research may be available to electronic subscribers up to three days earlier than to print subscribers. For Australia, New Zealand, Taiwan and South Korea only: Fitch Australia Pty Ltd holds an Australian financial services license (AFS license no. 337123) which authorizes it to provide credit ratings to wholesale clients only. Credit ratings information published by Fitch is not intended to be used by persons who are retail clients within the meaning of the Corporations Act 2001