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Comment letters to proposed statement of position: Accounting for certain costs and activities related to property, plant, and equipment, volume 3

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              ESTERN OOPERATIVE LECTRIC
Western Cooperative Electric Association, Inc. 635 S. 13th Street, P.O. Box 278, WaKeeney, KS 67672 785-743-5561 800-456-6720 (Kansas) westem@ruraltel.net www.westemcoop.com
November 8 2001
Marc Simon
Technical Manager, Accounting Standards File 4210.CC
American Institute of Certified Public Accountants 1211 Avenue of the Americas New York NY 10036-8775
Regarding Exposure Draft - Proposed Statement of Position, “Accounting for Certain Costs and Activities Related to Property, Plant, and Equipment”
Western Cooperative Electric Association Inc appreciates the opportunity to submit written comments regarding the above captioned Proposed Statement of Position (PP&E Accounting Proposal) to the Accounting Standards Executive Committee (AcSEC) of the American Institute of Certified Public Accountants (AICPA).
Western is a rural electric cooperative in the state of Kansas providing electricity to 2,205 rural consumer-owners using 4,575 meters in eight northwestern counties. Western holds the dubious honor of having the state’s lowest density of service: 1.5 meters per mile of line. Operating within the capital-intensive electric utility industry, the PP&E Accounting Proposal would significantly impact accounting policy, practices, and Western’s members.
Western is required to follow accounting requirements established by the Rural Utilities Service (RUS) of the United States Department of Agriculture. The PP&E Accounting Proposal raises significant ratemaking, operational, and accounting concerns. The most significant of these concerns arise due to accounting inconsistencies between the RUS Uniform System of Accounts and attendant RUS regulations and interpretations (collectively, Electric Cooperative Accounting Requirements), and the PP&E Accounting Proposal. The PP&E Accounting Proposal and the attendant detrimental impacts to Western Cooperative Electric Association Inc include the following:
• Electric Cooperative Accounting Requirements specify capitalization of overheads in support of construction projects and permit capitalization of an
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Title	Comment letters to proposed statement of position: Accounting for certain costs and activities related to property, plant, and equipment, volume 3
Author	American Institute of Certified Public Accountants. Accounting Standards Board Western Cooperative Electric Consolidated Electric Cooperative Maquoketa Valley Electric Cooperative Indian Electric Cooperative Loyola Marymount University CarrAmerica Realty Corporation Valley Electric Association American Electric Power Company Habersham Electric Membership Corporation Energy Association of Pennsylvania Sears, Roebuck and Company Butler Rural Electric Cooperative Association Shenandoah Valley Electric Cooperative Sayers, P. Wabash Valley Power Association Weingarten Realty Investors Canadian National National Association of Real Estate Investment Trusts American Institute of Certified Public Accountants Private Companies Practice Section. Executive and Technical Issues Committees PriceWaterhouseCoopers Royal Caribbean Cruises Heartland Rural Electric Cooperative US Airways Arkansas Valley Electric Cooperative Corporation Ninnescah Rural electric Cooperative Northeast Utilities System Mirant Corporation Duke University Southwest Airlines Duke Energy Corporation Reliant Resources Singing River Electric Power Association Olsen Thielen & Company Consolidated Edison ALLTEL Corporation BellSouth Corporation Cincinnati Bell Telephone Qwest Communications International SBC Communications Verizon Communications Enbridge Peoples Energy Upper Cumberland Electric Membership Corporation Institute of Management Accountants. Financial Reporting Committee Nemaha-Marshall Electric Cooperative Association Baltimore Gas and Electric Company Abbott National Association of Regulatory Utility Commissioners IMC Global USX Corporation U. S. Department of Agriculture. Rural Utilities Service Doniphan Electric Cooperative Host Marriott NiSource Progress Energy Jewell-Mitchell Cooperative Middle Tennessee Electric Membership Corporation Prairie Land Electric Cooperative Equity Office Properties Trust Principal Financial Group CSX Corporation Bowater Caney Fork Electric Cooperative National Lease Advisors IBM ProLogis Trust Columbia Helicopters Exelon Corporation Eli Lilly and Company United States Postal Service Microsoft WPS Resources Corporation Rouse Company Cornell University Federal Energy Regulatory Commission Michigan Electric Cooperative Association University of Rochester Grant Thornton Massachusetts Society of Certified Public Accountants. Accounting Principles and Auditing Procedures Committee
Subject	Assets (Accounting) Accounting Employee fringe benefits -- United States -- Auditing Exposure draft (American Institute of Certified Public Accountants), 2001, June 29
Abstract	The comment letters have been dvided into 4 volumes.
Date-Issued	2001
Source	Originally published by: American Institute of Certified Public Accountants
Rights	Copyright and permission to reprint held by: American Institute of Certified Public Accountants
Type	Text
Format	PDF text file scanned at 400 dpi with corrected OCR
Digital Publisher	University of Mississippi Library. Accounting Collection
Date-Digitally Created	2017
Language	eng
Identifier	comment letters 2001 june 29 v3 whole

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Comment letters to proposed statement of position: Accounting for certain costs and activities related to property, plant, and equipment, volume 3

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