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MICHAEL CARMODY's avatar

Additional Issues the Report Should Address

Electric Reserves Were Used in the Leffingwell Acquisition

The analysis does not address the effect of the Leffingwell/Public Works property acquisition on the Electric Department’s reserves and liquidity.

City Electric capital records contain a specific FY2024 entry of $5,278,663 identified as:

“Leffingwell PW site – building.”

That expenditure must be included in any serious analysis of why Electric lacked sufficient liquidity when purchased-power costs increased.

The central question is not simply whether the Leffingwell expenditure was authorized or classified as a capital asset. The relevant financial questions are:

How much unrestricted Electric cash was used at closing?

What was Electric’s reserve balance immediately before and after the transaction?

Was a minimum reserve or liquidity requirement in place?

Did staff evaluate whether Electric could afford to use approximately $5.28 million while simultaneously funding an accelerated system-modernization program?

Was the approaching Rush Island retirement and associated capacity exposure considered before the money was committed?

Were Electric customers and the City Council told that utility resources had been used for the acquisition?

Was there a documented plan and deadline to restore Electric’s reserves?

Without a reserve bridge showing Electric’s cash position before and after Leffingwell, the public cannot determine how much the property acquisition weakened the utility’s ability to withstand the later power-cost increase.

Public Records Do Not Show That the COP Proceeds Repaid Electric

The City subsequently issued approximately $5.73 million in Series 2024B Certificates of Participation connected to the Public Works project. Those proceeds were deposited into a trustee-held project fund, and nearly all of the proceeds were later disbursed.

However, the available public records do not contain the requisition-by-requisition disbursement trail necessary to establish that the COP proceeds reimbursed the Electric Fund for the approximately $5.28 million Leffingwell expenditure.

A debt issuance is not, by itself, proof that Electric was repaid.

To establish repayment, the City must produce:

trustee account statements;

COP requisitions;

wire confirmations;

City general-ledger postings;

Electric Fund cash receipts;

pooled-cash entries; and

the complete closing and reimbursement ledger.

The public record does not presently establish that Electric received reimbursement from the Series 2024B COP proceeds for the approximately $5.28 million Leffingwell expenditure.

The Full Leffingwell Financing Structure Was Not Addressed

The report should also explain that the Leffingwell acquisition involved more than the approximately $5.28 million Electric entry.

Audited records identify a separate $7 million advance from the Park Capital Improvement Fund to the Electric Fund for the acquisition, construction and furnishing of the Public Works facility. Electric carried the corresponding long-term payable.

The FY2026/27 budget shows a planned multi-year repayment stream from Electric to Parks. That continuing obligation indicates that Electric remained financially burdened by the project after the COP financing was issued.

Therefore, the analysis should not treat Leffingwell as an unrelated real-estate transaction. The acquisition affected Electric through:

the approximately $5.28 million Electric capital entry;

the $7 million Park Capital advance carried as an Electric obligation;

COP-related debt-service costs;

internal rental arrangements intended to offset those costs; and

the resulting reduction in Electric’s financial flexibility.

The Report Does Not Reconcile Reserve Depletion by Cause

The City’s $15.6 million explanation combines:

Electric’s prior unrestricted cash;

advances from other City funds; and

the later negative cash balance.

But the report does not provide a reserve reconciliation identifying how much cash was consumed by:

Leffingwell;

accelerated line and substation work;

transformer orders;

other capital projects;

purchased-power costs;

capacity costs;

overtime;

transfers to other City purposes;

debt service; and

operating expenses.

Without that reconciliation, the report cannot establish which decisions depleted Electric’s reserves or when the Department lost the ability to absorb a market shock.

A complete after-action report should contain a month-by-month reserve bridge beginning before the October 2023 Leffingwell acquisition and continuing through the 2025–2026 financial crisis.

Capital Spending Should Be Measured Against Cash and Liquidity, Not Only Budget Authority

The outside report appropriately questions whether capital spending exceeded identifiable budget authority. But legal or budgetary authority is only one issue.

Even an authorized project can create a financial crisis when:

cash is not available;

reserves fall below prudent levels;

contractual obligations are not fully recorded;

several years of work are accelerated;

power-market exposure is increasing; or

no cost-to-complete forecast exists.

The review should therefore determine not only whether the projects were authorized, but whether the City had sufficient liquidity to undertake them.

The Acceleration of Five to Seven Years of Work Was Not Properly Explained

The After-Action Report states that five to seven years of planned capital investment were advanced into approximately two fiscal years.

That statement requires much more detail.

The City should identify:

every project accelerated;

its original scheduled year;

its revised construction year;

its original budget;

its actual and committed cost;

who authorized the acceleration;

the operational reason for accelerating it;

whether Council approved the revised schedule;

and the effect on reserves and purchased-power liquidity.

Without a project-by-project schedule, the statement that future work was merely “advanced” risks becoming a broad explanation for spending that cannot otherwise be reconciled.

The Report Does Not Establish a Functioning Progress-Review Process

A capital program of this size should have included scheduled monthly or quarterly reviews comparing:

approved budget;

actual expenditures;

outstanding commitments;

percentage complete;

projected cost to complete;

revised completion dates;

available cash;

reserve balances; and

future power-purchase obligations.

The City’s own findings show incomplete encumbrances, inconsistent project tracking and suspended quarterly financial reporting.

The report should identify whether formal progress meetings occurred, who attended them, what reports were reviewed, what variances were identified and what corrective action was taken.

If no documented recurring review existed, that is a management deficiency separate from the accounting problems.

The Report Does Not Identify Responsibility at Each Decision Point

The After-Action Report describes systems and procedural failures but provides little detail regarding individual responsibility.

A meaningful after-action review should identify:

who approved individual capital projects;

who authorized acceleration of future projects;

who monitored reserves;

who approved the Leffingwell use of Electric resources;

who reviewed purchased-power exposure;

who was responsible for quarterly reporting;

who received warnings of negative cash;

when the City Administrator was informed;

and when the Council was informed.

Without that information, the report describes what went wrong but does not explain how management allowed it to continue.

The Report Does Not Evaluate Whether Electric Resources Were Used for Non-Electric Purposes

The Electric Fund was involved in financing or supporting broader municipal projects, including Leffingwell, prior advances related to KPAC/Park/community-center purposes and capital-dividend funding for streets.

The report should determine whether those uses:

were permitted by City policy and law;

were supported by written interfund agreements;

carried repayment terms;

included interest;

were approved publicly;

were disclosed to ratepayers;

and were repaid as scheduled.

The financial condition of Electric cannot be evaluated accurately without accounting for money transferred, advanced or committed outside the utility’s core electric-service function.

The Rate Increase Must Be Reconciled to the Actual Causes

The City should identify how much of the later electric-rate increase was intended to cover:

future purchased-power costs;

capacity costs;

rebuilding reserves;

repayment of interfund advances;

Leffingwell obligations;

COP debt service;

accelerated capital spending;

and ongoing operating expenses.

Electric customers should be told whether higher rates are paying for electricity service, restoring reserves depleted by prior management decisions or financing broader municipal projects.

MICHAEL CARMODY's avatar

Analysis of Electricity Costs

The report appropriately challenges the City’s explanation of the $15.6 million financial problem and raises important questions regarding capital spending. However, it does not apply the same level of scrutiny to the approximately $8.4 million increase in electricity costs.

Instead, the report largely accepts the City’s explanation that the increase resulted from “ordinary market volatility.” That conclusion is incomplete because it overlooks one of the most important questions: What did Kirkwood know in advance, and what actions did it take to prepare?

Ameren publicly announced the planned retirement of the Rush Island Energy Center approximately one year before the plant closed on October 15, 2024. The retirement of one of the region’s largest generating facilities should have prompted a comprehensive review of Kirkwood Electric’s exposure to future capacity costs.

The issue is not whether the exact market-clearing price could have been predicted. It is whether City management recognized that removing more than 1,100 MW of generation from MISO Zone 5 created a foreseeable supply-and-demand risk requiring advance planning.

The report never asks whether Kirkwood used that one-year warning period to:

* evaluate the expected impact on MISO Zone 5 capacity prices;

* forecast its future purchased-power exposure;

* secure replacement capacity through bilateral or forward contracts;

* review its hedging strategy;

* evaluate reserve adequacy and liquidity;

* prepare for potential collateral or margin requirements;

* postpone discretionary capital spending to preserve cash;

* recommend temporary rate adjustments or a power-cost adjustment mechanism; or

* provide regular risk assessments to the City Council.

These questions are central to evaluating management performance.

The After-Action Report focuses extensively on accounting deficiencies, purchase-order controls, blanket contracts and project tracking. While those findings are important, it provides very little information about the Electric Department’s power-procurement strategy or its energy risk-management practices during the period leading up to the capacity crisis.

The report also concludes that the regional capacity shortage was identified during routine contracting in the fall of 2024. If a major regional generating plant had been scheduled to close approximately one year earlier, why wasn’t that risk already part of the City’s planning process?

That omission deserves as much scrutiny as the accounting deficiencies.

The report further recommends implementing a power-cost adjustment so future market volatility can be passed through to customers. A power-cost adjustment may be appropriate, but it should not become a substitute for prudent utility management.

Customers should not automatically bear costs that may have resulted from inadequate planning, delayed procurement decisions, insufficient reserves, or failures in risk management.

The same rigorous analysis applied to capital expenditures should also be applied to purchased-power decisions.

The report carefully reconstructs the history of capital spending and asks whether expenditures exceeded public spending authority. It should ask the same questions regarding purchased power:

* What risks were identified?

* When were they identified?

* What mitigation strategies were considered?

* Which actions were approved?

* Which actions were rejected?

* Who made those decisions?

* Were those decisions consistent with the City’s energy risk-management policies?

Until those questions are answered, it is premature to conclude that the approximately $8.4 million increase in electricity costs was simply the result of ordinary market volatility.

A complete review should distinguish between unavoidable market conditions and management decisions. One is an external event. The other is a matter of governance, planning, and accountability.

The absence of this analysis is one of the most significant shortcomings of both the After-Action Report and this independent review.

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