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****PRELIMINARY AND TENTATIVE FINDINGS**** <br />11ie PGP's acquisition activities are organized by gas supply pools, and FMPA members elected to participate in two <br />gas supply pools. Each gas supply- pool stands alone with rights and obligations separate from the PGP's other pools. <br />As a member of the PGP, the FMPA is obligated to pay its share of all common costs and 100 percent of any costs <br />incurred by the PGP on FMPA's behalf. By contract, FMPA also has accepted a step-up provision that requires a <br />maximum additional exposure of 25 percent of its original contracted amount if other PGP members default on any <br />of their obligations. No rights exist to withdraw from the PGP without the unanimous consent of the PGP <br />Operating Committee and the subsequent unanimous consent of the PGP Board of Directors. <br />In calendar years 2004 and 2005, the FMPA's ARP became a participant in PGP Gas Supply Pool 1 (PGP1) and PGP <br />Gas Supply Pool 2 (PGP2). Section 12.2 of the PGP agreements indicates that the PGP will acquire interests in gas <br />reserves and that the member shall be responsible for paying its participation share of all such capital expenditures. <br />Pursuant to its participation in the pools, the FMPA has issued ARP revenue bonds as described in Table 8. <br />Table 8 <br />Calendar Bond Issuance <br />Year <br />2006 $45,000,000 (1) <br />2008 60,000,000 <br />2009 15,000,000 <br />2013 15,000,000 <br />Total $135.000.000 <br />Note (1): The original bond issuance <br />amount was $50,000,000; however, <br />$5,000,000 was refunded by the 2008 <br />issue. <br />Source: FMPA Records <br />Participation in a natural gas development project, similar to FMPAs' participation in the PGP, should fix gas costs at <br />a rate equal to operational expenses plus depletion of gas properties, less revenues (e.g., the sale of nonmethane <br />products like ethane and liquid petroleum), such that PGP participation is reasonably expected to be a natural physical <br />hedge to the price of natural gas. An analysis of 17 comparable JAAs- disclosed that only one of those JAAs was <br />involved in similar natural gas pool activity. The results of this analysis indicate that the FMPA's investment in natural <br />gas exploration and production via its participation in PGP was not a common industry practice or common form of <br />fuel hedging, with the most typical forms of such hedging consisting of a combination of long and short-term natural <br />gas purchases, contracted storage, and use of financial hedges. The natural gas procurement strategy most similar to <br />the FMPA's PGP participation is a prepaid natural gas contract. Table 9 compares the relative risk characteristics of <br />the two natural gas procurement strategies: <br />2 Comparability to the FMPA was based on reported peak MW load, wholesale electric revenues, the number of member <br />municipalities, total number of retail customers served, and the generation fuel types employed. <br />10 <br />12 <br />