II II 1 01 II 1 II II II - Interchange
IIII 1 01 II 1 II II IIControl Number: 483711 1 1 III 1 1 1 IIIIItem Number: 277Addendum StartPage: 0
iSOAH DOCKET NO. 473-18-3733 ,PUC DOCKET NO. 48371ENTERGY TEXAS INC'SSTATEMENT OF INTENT ANDAPPLICATION FOR AUTHORITYTO CHANGE RATES2t18 AUG - 1 FPI i: 31',.§§§§BEFpn JIHE t§TAIrdtilitE,F iLitio 1.A.t.KrOF ADMINISTRATIVE HEARINGSREDACTEDDIRECT TESTIMONYOFCONSTANCE T. CANNADYON BEHALF OFOFFICE OF PUBLIC UTILITY COUNSELREVENUE REQUIREMENT PHASEConstance T. CannadyNewGen Strategies & Solutions, LLC2803 Bowie StreetAmarillo, Texas 79109AUGUST 1, 2018V
SOAH DOCKET NO. 473-18-3733PUC DOCKET NO. 48371REDACTEDDIRECT TESTIMONY OF CONSTANCE T. CANNADYTABLE OF CONTENTSPageI.INTRODUCTION AND QUALIFICATIONS5II.PURPOSE AND SCOPE5III. SUMMARY OF RECOMMENDATIONS7IV.9RECOMMENDED ADJUSTMENTS TO RATE 35SUMMARY OF ADJUSTMENTS TO OPERATING INCOME361.2.3.4.5.6.37434646477.VI.DISALLOWANCE OF PTYADISALLOWANCE OF PHFUADJUSTMENT TO ACCUMULATED DEPRECIATION AND SABINE UNIT 2ADJUSTMENT TO GAS INVENTORY AT SPINDLETOPDISALLOWANCE OF NOx CREDITSADJUSTMENT TO REGULATORY ASSETS AND LIABILITIESREMOVAL OF SPINDLETOP REGULATORY ASSETADJUSTMENT TO STORM RELATED REGULATORY ASSETSADJUSTMENT TO UNPROTECTED EDIT - RETAIL REGULATORY LIABILITYADJUSTMENT TO ACCUMULATED DEFERRED INCOME TAXESADDITIONAL CAPITALIZED EMPLOYEE RELATED EXPENSE ADJUSTMENTSDISALLOWANCE OF INCENTIVE PAYDISALLOW ALL NON-QUALIFIED PENSION PLAN EXPENSEADJUSTMENT TO AMORTIZATION OF STORM RELATED EXPENSEADJUSTMENT TO ANNUAL STORM RESERVE ACCRUALSDISALLOW ADJUSTMENT TO PAYROLL TO HURRICANE HARVEYDISALLOW TCJA RIDER AND INCLUDE UNPROTECTED EDIT IN FITCALCULATIONREFUNDS OF OVERCHARGES UNDER CURRENT RATESSUMMARY OF ATTENDANT IMPACTS BASED ON S82REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 2 of 179
SCHEDULESSCHEDULE CTC-1SUMNIARY OF RECOMMENDED ADJUSTMENTS To REVENUE REQUIREMENTSSCHEDULE CTC-2SUMMARY OF RECOMMENDED ADJUSTMENTS To RATE BASESCHEDULE CTC-2ASUMMARY OF ADJUSTMENTS To NET PLANT IN SERVICESCHEDULE CTC-2BADJUSTMENT To REMOVE PTYA FROM PLANT IN SERVICESCHEDULE CTC-2cRECOMMENDED ADJUSTMENT To PLANT HELD FOR FUTURE USESCHEDULE CTC-3SUMMARY OF ADJUSTMENTS To ACCUMULATED RESERVE FORDEPRECIATIONSCHEDULE CTC-4RECOMMENDED ADJUSTMENT To GAS INVENTORY BALANCESCHEDULE CTC-4AANALYSIS OF GAS INVENTORY BALANCE AND PLANT PRODUCTIONSCHEDULE CTC-5RECOMMENDED ADJUSTMENT To ALLOWANCES FOR MCPS NOxINVENTORYSCHEDULE CTC-6RECOMMENDED ADJUSTMENT To REGULATORY ASSETS AND LIABILITIESSCHEDULE CTC-6ARECOMMENDED ADJUSTMENT To REGULATORY LIABILITIES AND ADIT ToREINSTATE UNPROTECTED EDITSCHEDULE CTC-7TOTAL RECOMMENDED ADJUSTMENT To ADITSCHEDULE CTC-8RECOMMENDED ADJUSTMENT To O&M RELATED To SHORT-TERMINCENTIVE PAYSCHEDULE CTC-8ARECOMMENDED ADJUSTMENT To CAPITALIZED SHORT-TERM INCENTIVEPAYSCHEDULE CTC-8BRECOMMENDED ADJUSTMENT TO O&M RELATED TO LONG-TERMINCENTIVE PAYSCHEDULE CTC-9RECOMMENDED ADJUSTMENT FOR OTHER NON-QUALIFIED PENSION PLANSSCHEDULE CTC-1 0RECOMMENDED ADJUSTMENT To STORM AMORTIZATION EXPENSESCHEDULE CTC-11RECOMMENDED ADJUSTMENT To STORM RESERVE BALANCE DEFICITSCHEDULE CTC-12RECOMMENDED ADJUSTMENT To REMOVE STORM PAYROLL ADJUSTMENTSCHEDULE CTC-13TOTAL RECOMMENDED ADJUSTMENT To FEDERAL INCOME TAXESSCHEDULE CTC-14RECOMMENDED ADJUSTMENT To DEPRECIATION EXPENSE FOR PTYASCHEDULE CTC-15RECOMMENDED ADJUSTMENT To REINSTATE CERTAIN PURCHASED POWEREXPENSES IN BASE RATESSCHEDULE CTC-16RECOMMENDED ATTENDANT IMPACTS FOR INCREASE IN REVENUE ATCURRENT RATESSCHEDULE CTC-17ESTIMATED IMPACT OF RECOMMENDED ADJUSTMENTS To CASH WORKINGCAPITALREDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 3 of 179
ATTACHMENTSATTACHMENT ARESUME AND RECORD OF TESTIMONY OF CONSTANCE T. CANNADYATTACHMENT BETI RESPONSE To CITIES RFI 8-7ATTACHMENT CETI RESPONSE To OPUC RFI 6-3ATTACHMENT DDOCKET No. 37744, RATE FILING PACKAGE, SETTLEMENT PLANT INSERVICE AND SCHEDULE D-3ATTACHMENT EETI RESPONSE To CITIES RFI 10-1ATTACHMENT FETI RESPONSE To STAFF RFI 5-5ATTACHMENT GETI RESPONSE To OPUC 2-15.ATTACHMENT HETI RESPONSE To OPUC 2-4cATTACHMENT IETI RESPONSE To OPUC RFI 6-1ATTACHMENT JETI RESPONSE To TIEC RFI 3-14ATTACHMENT KETI RESPONSE To OPUC RFI 8-5ATTACHMENT LENTERGY 2017 PROXY STATEMENT To SHAREHOLDERS, MARCH 21, 2017ATTACHMENT METI CONFIDENTIAL RESPONSE To OPUC 8-2 (HSPM)AT1'ACHMENT NETI CONFIDENTIAL RESPONSE To OPUC RFI 2-13. ADDENDUM I,ATTACHMENT 2016 INCENTIVE COMPENSATION PRESENTATION (HSPM)ATTACHMENT 0ETI CONFIDENTIAL RESPONSE To OPUC RFI 2-2, ATTACHMENT E(HSPM)ATTACHMENT PETI RESPONSE To STAFF RFI 3-10ATTACHMENT QETI RESPONSE To CITIES RFI 8-15ATTACHMENT RETI RESPONSE To OPUC RFI 2-9ATTACHMENT SETI RESPONSE To OPUC 4-11REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733 ; PUC Docket No. 48371Page 4 of 179
1I.INTRODUCTION AND QUALIFICATIONS2Q. PLEASE STATE YOUR NAME, OCCUPATION, AND BUSINESS ADDRESS.3A.My name is Constance T. Cannady. I am an Executive Consultant with NewGen4Strategies and Solutions, LLC. My office is located at 2803 Bowie Street, Amarillo,5Texas 79109.6Q. ON WHOSE BEHALF ARE YOU PRESENTING TESTIMONY IN THIS7PROCEEDING?8A.I am presenting testimony on behalf of the Office of Public Utility Counsel (OPUC").9Q. PLEASE OUTLINE YOUR EDUCATIONAL AND PROFESSIONALBACKGROUND.1011A.12Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE A REGULATORY AGENCY?13A.14Attachment A provides a description of my qualifications and education.Yes, I have. Attachment A includes a listing of dockets in which I have provided experttestimony before this Commission and other regulatory bodies.15II.PURPOSE AND SCOPE16Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING?17A.The purpose of my testimony is to present my analysis, findings, and recommendations18with respect to Entergy Texas, Inc.'s ("ETr) proposed adjustment to base rates,19including certain adjustments to rate base, operating expense, and federal income taxes.20My testimony will also include my recommendations for regulatory treatment of impacts21from the passage of the Tax Cuts and Jobs Act of 2017 ("TCJA"), including my proposedREDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 5 of 179
1methodologies for ensuring any refunds are flowed back to ratepayers over a reasonable2period of time.3Mr. Clarence Johnson concerning ETI's proposed Federal Energy Regulatory4Commission (TERC") Rider and adjusted revenues at current rates. For purposes of5presenting the overall impacts of these adjustments to revenue requirements, I have used6the rate of return recommended by Ms. Cynthia Zamora.7More specifically, I address the following issues:In addition, I have incorporated recommendations from8 ETI' s proposed post-test year adjustment ("PTYA");910 ETI's proposed inclusion of certain plant held for future use("PHFU") ;1112 ETI's proposed return on the undepreciated balance of Sabine Unit2;13 ETI s proposed level of gas inventory at Spindletop;1415 ETI's proposed nitrogen oxides (NOx) Credits inventory related tothe planned Montgomery County Power Station (MCPS");16 ETI' s proposed recovery of a regulatory asset related to Spindletop;171819 ETI' s proposed rate base removal of the unprotected excess deferredincome taxes (EDIr) resulting from the TCJA and amortization ofthe balance;2021 ETI's proposed short-term incentive ( STI") pay included in thefiling;2223 ETI's proposed non-qualified pension plan expense including in thefiling;2425 ETI' s proposed amortization of storm related expenses, includingHurricane Harvey;26 ETI's proposed change in the storm reserve accruals;REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 6 of 179
1 ETI's proposed adjustment to payroll for Hurricane Harvey;2 ETI'S proposed amortization of unprotected EDIT; and34 ETI'S proposed treatment of overcharges in current rates due to theTCJA.5Q. DOES YOUR TESTIMONY INCLUDE REVIEW AND COMMENT ON ALL67ISSUES IDENTIFIED IN ETI'S FILING?A.No. However, any cost or adjustment included in ETI's cost of service that is not8addressed in my testimony does not indicate my acquiescence to ETI's proposal.9III. SUMMARY OF RECOMMENDATIONS10Q. PLEASE SUMMARIZE ETI'S REQUEST.11A.As shown on Schedule CTC-1, ETI is requesting base revenue requirements of12 818.9 million' However, the filing also includes requested additional revenue of13 138.6 million to be recovered through the proposed FERC Rider,2 offset by a return of14unprotected EDIT in a TCJA Rider of approximately 100.8 million for each of the next15two years.' The sum of these proposed rate components is an annual increase to16ratepayers of approximately 59.7 million.4 It is necessary to point out, however, that the17increase to ratepayers significantly increases in the third year, subsequent to the two-year18amortization of the proposed TCJA Rider. The revenue requirements in year three jumps12Rate Filing Package, Schedule A.Direct Testimony of Kristine T. Jackson, page 9.3 DirectTestimony of R. Phillip Griffin, Workpaper TCJA Rider backup (201,053,652 / 2 100,526,826).4Excludes impacts of other riders and fuel related revenue and based on total current revenues of 797.0million.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 7 of 179
1to 957.6 million; a 160.6 million annual increase.' Additionally, ETI proposes to retain2the refund due to ratepayers for any overcharges resulting from the passage of the TCJA3beginning January 25, 2018 through the time rates are changed in this proceeding. ETI' s4rationale is that it needs these funds to improve its fmancial health and they will be used5for its planned investments.6 By not refunding the overcharges, ETI's proposal6effectively results in a total request that includes these overcharges through the time7when the rates in this proceeding become effective. Overcharges through June are8already over 10.8 million,' before interest, and are likely to be double that by the time9new rates are implemented.10Q. PLEASE SUMMARIZE YOUR OVERALL RECOMMENDED CHANGE TOREVENUE FROM CURRENT RATES.1112Based on my recommended adjustments to rate base, operating expenses, and taxes;A.13Mr. Johnson's proposed disallowance of the FERC Rider and updates to weather14normalization; and Ms. Cynthia Zamora's proposed rate of return, I am recommending15revenue requirements of 848.6 million. My recommendation does not include any other16riders or charges. With the adjusted current revenue of 802.5 million, resulting from17Mr. Johnson's proposed change in weather normalization and disallowance of the FERC18Rider, my recommendation is an increase to total current revenue of approximately19 46.1 million, exclusive of the additional amounts associated with the refund for TCJA20overcharges to be flowed through to ratepayers during the first year rates from this5As compared to ETI proposed total current revenue of 797 million.6Direct Testimony of Sallie T. Rainer, page 20.7See Attachment B, ETI Response to Cities RFI 8-7.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 8 of 179
1proceeding are in effect. Assuming a 20 million refund, my recommendation results in2a revenue requirement for the first year rates of 828.6 million; a 26.1 million increase3over adjusted current revenue.8IV. RECOMMENDED ADJUSTMENTS TO RATE BASE45Q. PLEASE SUMMARIZE YOUR OVERALL RECOMMENDATIONS THATIMPACT THE COMPANY'S PROPOSED LEVEL OF INVESTED CAPITAL.67A.I am recommending that ETI's proposed rate base be reduced by 254,847,444 as shown8on Schedule CTC-2. The adjustments include the following:91. Disallowance of ETI's proposed PTYA.2. Removal of certain PI-IFU for which a 10-year planned usage has not1011been supported.123. Removal of the undepreciated balance of the retired Sabine Unit 2.134. Adjustment to gas inventory to reflect expiration of the Purchase14Power Agreement (PPA") with Entergy Gulf States Louisiana15(EGSL”) for usage from Sabine and Lewis Creek stations.165. Removal of the NOx credit allowance related to the planned MCPS.176. Disallowance of the regulatory asset related to the remaining18investment in Spindletop.197. Adjustment to the unamortized balances of storm related reserves.208. Reinstatement of the balance of unprotected EDIT in regulatory21assets and liabilities as an offset to rate base.8See Schedule CTC-1.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 9 of 179
19. Adjustments to accumulated deferred income taxes ("ADIT") to2reinstate balance of unprotected EDIT taxes as an offset to rate base.310. Removal of certain employee expense related ADIT balances.411. Recommendation to include matching capital adjustments for5operations and maintenance expense (O&M") disallowances.61. DISALLOWANCE OF PTYA7 Q. WHAT IS YOUR UNDERSTANDING OF THE REQUIREMENTS FOR89INCLUDING A PTYA WHEN ESTABLISHING BASE RATES?A.16 TAC §25.231(c)(2)(F) specifies the requirements for including a PTYA in a base rate10proceeding. The rule states that a PTYA to the historical test year rate base will be11considered only if the following requirements are met:121.Plant is included in FERC account 101 or 102;132.Each addition accounts for at least 10% of the requested rate base,exclusive of the PTYA;14153.Plant will be in service prior to the date rates are implemented; and164.All attendant impacts on all aspects of the utility's operations can bereasonably identified, quantified and matched.1718Q. DOES ETI'S REQUESTED PTYA MEET THESE REQUIREMENTS?19A.No. ETI's proposed PTYA does not comply with all of these requirements and,20therefore, it should be disallowed. First, ETI's request does not meet the minimum 10%21threshold for consideration. ETI' s PTYA is comprised of plant additions that were in22service by February 2018 or estimated to be placed into service between March 1, 2018,REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 10 of 179
1to June 30, 2018. The known amount of plant additions at the time of the filing is2 28,604,914. The estimated additional plant through June 30, 2018 is 100,088,581, for3a total increase in plant in service of 128,693,495. The entire amount of the PTYA falls4short of the 10% rule in that it represents approximately 2.8% of the test year end plant in5service balance and approximately 5% of the total test year end rate base.6Second, ETI does not comply with the portion of the rule that requires7identification and quantification of the attendant impacts that would "reasonably follow8as a consequence of the post test year adjustment being proposed."9 In fact, when9requested to provide attendant impacts, ETI responded as follows:10111213"To be clear, ETI has not undertaken and does not propose to make anymodifications to the post-Test Year Adjustment that ETI has requested inthis matter to update its number of customers, associated kWh sales,and/or base revenues for the period January through June 2018. 1014In an addendum to response to OPUC RFI 6-3, ETI provided the actual plant15additions through June 30, 2018, which were 88,784,180, or only 70% of the PTYA16originally requested. The percentage of rate base resulting from the actual plant additions17is less than 5%.1118Q. DID ETI REQUEST A GOOD CAUSE EXCEPTION TO THE SUBSTANTIVERULE?1920Yes. ETI recognizes that its proposed PTYA will require a good cause exception andA.requests one for the 10% rule!' In addition, ETI requests a good cause exception to the21916 TAC §25.231(F)(i)(IV).10 See Attachment C, ETI Response to OPUC RFI 6-3.11 See12Attachment C, Addendum 1.Direct Testimony ofJess K. Totten, page 22, lines 2-6.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 11 of 179
1requirement in 16 TAC §25.231(c)(2)(F)(ii)(I) that the amounts for a PTYA must be2based on the construction work in progress ("CWIP") balances at the end of the test3year." For plants closed by February 2018, ETI proposes to use the actual balances at the4time of closing, as well as estimates for all additions through June 30, 2018. According5to Mr. Totten's testimony:"Moreover, when rates are put into effect, customers will be benefitingfrom the use of these capital investments to provide safe and reliableelectric service. Therefore, I see no reason why ETI should not bepermitted to include those actual balances."'678910 Q. DO YOU AGREE THAT ETI SHOULD BE GRANTED A GOOD CAUSE1112EXCEPTION TO THE PTYA REQUIREMENTS?A.No. 16 TAC §25.231(c)(2)(F) provides for rate relief for extraordinary circumstances13beyond the historical test year amounts. Such relief is for large capital projects that14already have significant construction costs as of the end of the test year and are expected15to be in service by the time the rates are in effect. ETI is not requesting a PTYA, but16rather is requesting that the Commission allow for updates to normal additions to plant in17service well beyond the test year end.18Furthermore, ETI has requested the good cause exception primarily on the basis19of eliminating the effects of regulatory lag." As noted in the Proposal for Decision20("PFD") in Docket No. 43695, the 10% threshold of the PTYA rule "was established with21the utilities overall financial integrity in mine and to "eliminate litigation related to13Direct Testimony of Richard E. Lain, page 18, lines 18-22.14Direct Testimony of Jess K. Totten, page 22, lines 24-27.15Direct Testimony of Jess K. Totten page 22, lines 20-22.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 12 of 179
1immaterial adjustments."16 With respect to regulatory lag as a basis for a good cause2exception, the Administrative Law Judge (ALJ) found that reducing regulatory lag3associated with an investment that comprises less than 10% of rate base does not4constitute good cause.175Even if the Commission were to consider ETI's request for a good cause6exception to the 10% rule, ETI's failure to satisfy the rules requirement to identify,7quantify, and match any attendant impacts also supports rejection of the request. It is a8well understood accounting principle that requires companies to report the revenues in9the same period as the associated expense. This principle has carried over to regulation10when allowing known and measurable changes to test year actuals as evidenced by the11specific requirement in the PTYA rules. ETI offers no justification as to its failure to12comply with this portion of the rule and, therefore, fails to meet its burden for its13requested PTYAs.14Finally, ETI has offered no testimony as to the need for a PTYA due to financial15integrity measures. In Docket No. 43695, the All stated the following:16171819"Fourth, financial integrity might provide the basis for a good causeexception to the PTYA rule, but unusual factors are required. For example,the Commission might find good cause where, without a PTYA, utilitycould not fund rate base additions needed to provide adequate service.'20Therefore, ETI's proposal does not meets the requirements of 16 TAC21§25.231(c)(2)(F), nor has ETI provided sufficient justification to receive a good cause16Application of Southwestern Public Service Company for Authority to Change Rates, Docket No. 43695,PFD at 23 (October 12, 2015), citing the preamble to the PTYA rule.17Docket No. 43695, PFD at 26.18Docket No. 43695, PFD at 26.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 13 of 179
1exception. The additions to plant and all other attendant impacts included in the filing2related to the PTYA should be disallowed. The components of the disallowance are:34 Remove 128,693,495 from plant in service (reduction to ratebase);1956 Remove 44,134,452 from accumulated depreciation (increase torate base);2 78 Remove 586,265 from accumulated deferred income taxes(increase to rate base);21910 Remove 7,148,496 from depreciation expense on the proposedplant additions;221112 Remove 979,400 from ad valorem taxes on the proposed plantadditions;23 and13 Remove related federal income tax (FIT) expense.142. DISALLOWANCE OF PHFU15Q. WHAT IS ETI REQUESTING WITH RESPECT TO PHFU?16A.ETI is requesting to include 5,753,394 of PHFU in rate base. ETI witnesses state that17this plant is expected to be in service within the next 10 years based on engineering18analysis.' Schedule D-3 of the rate filing provides a listing of all PHFU and those19parcels that are proposed to be included in this case.19See Schedule CTC-2B.20See Schedule CTC-3.21See Schedule CTC-7.22See Schedule CTC-14.23See Schedule CTC-2B.24Direct Testimony of Kristine T. Jackson, pages 25 and 29.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 14 of 179
1Q. DO YOU AGREE THAT ETI SHOULD BE ALLOWED TO INCLUDE THESE23PARCELS IN RATE BASE AT THIS TIME?A.No. The vast majority of the parcels proposed for inclusion were acquired between 19834and 1994. Many of these same parcels were already included in rate base in Public5Utility Commission of Texas (PUCT") Docket No. 37744 based on a settlement6agreement identifying the transmission plant to be included in rates. This proceeding had7a June 2009 test year.' Therefore, the engineering plans at that time would have to have8shown use by June 2019. In the instant case, ETI provided no such plans with its filing to9have any PHFU in service by 2019. ETI states only that these parcels will be in service10within the next 10 years. Furthermore, ETI offers no explanation other than the singular11clause 'based on engineering analysis or why its present request is credible.12Q. ETI DID PROVIDE ESTIMATED IN-SERVICE DATES THROUGH13DISCOVERY THAT SHOWED EARLY 2018 DATES. HOW DID YOU14INCORPORATE THIS RESPONSE INTO YOUR RECOMMENDATION?15In response to Cities RFI 10-1 dated July 18, 2018, ETI states that the estimated in-A.16service date for all but the Porter-Grimes Substation is by May 2018.26 However, on July1719, 2018, ETI filed a response to Staff RFI 5-5 regarding the actual amounts closed to18plant in service through June 2018.2' If the PHFU had been included in these plant19closings, then the response to Cities 10-1 should have included the actual in-service date20and not an estimated in-service date. Based on the data provided by ETI, the25See Attachment D, Docket No. 37744, Rate Filing Package, Settlement plant in service and Schedule D-3.26See Attachment E, ETI Response to Cities RFI 10-1.27See Attachment F, ETI Response to Staff RFI 5-5.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 15 of 179
12Commission should find that ETI has not met the burden of proof.Q. BASED ON YOUR ANALYSIS, WHAT ADJUSTMENT ARE YOU34RECOMMENDING TO PHFU?A.I recommend that the PHFU that was proposed for inclusion in rate base in 2009, which5is also being proposed for inclusion in this case, be disallowed. ETI stated that these6parcels would be in service within 10 years of June 2009 but have offered no definitive7support that they will be in service by June 2019, nor have they provided any evidence8regarding this discrepancy. Ratepayers have been providing a return on these amounts9with the expressed understanding that they would be used and useful by June 2019. As10such, these parcels should not be given an additional 10 years on their in-service timing11and should only be included herein with assurances from ETI that they will be in service12by June 2019. Schedule CTC-2C shows the specific parcels and amounts requested in132009 that I recommend be disallowed in this case. I recommend that 917,022 of PHFU14be included in rate base. This is 4,836,372 less than ETI's request.'153. ADJUSTMENT TO ACCUMULATED DEPRECIATION AND SABINE UNIT 216Q. PLEASE EXPLAIN YOUR RECOMMENDED ADJUSTMENT TO ETI'S1718PROPOSED RESERVE FOR ACCUMULATED DEPRECIATION.A.I am recommending that the accumulated depreciation reserve be reduced by19 33,676,864, as shown on Schedule CTC-3. My adjustment includes removing the20amounts related to the PTYA as identified above, removing the amounts related to the21PHFU that I recommend be excluded, and removing the undepreciated balance of Sabine28See Schedule CTC-2A.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Utility CounselSOAH Docket No. 473-18-3733; PUC Docket No. 48371Page 16 of 179
1Unit 2. The impacts of each component are as follows:2 Remove 44,134,452 related to PTYA (increase to rate base);3 Remove 250,984 related to PHFU (increase to rate base); and4 Remove 10,708,572 related to Sabine Unit 2 (reduction to ratebase).6Q. WHAT IS ETI'S PROPOSAL WITH RESPECT TO SABINE UNIT 2?7A.ETI's proposal with respect to Sabine Unit 2 is two-fold. First, ETI proposes to include8the undepreciated balance of the retired plant in rate base in order to include a retlirn on9this balance. Secondly, ETI has included depreciation expense on the undepreciated10balance.'11Q. DO YOU AGREE WITH ETI'S PROPOSED TREATMENT?12A.No. I recommend that the Commission disallow a return on the undepreciated balance13but allow the recovery of the remaining Sabine Unit 2 undepreciated balance through14depreciation expense. My recommendation removes the 10,708,572 remaining balance15from rate base but does not adjust ETI's proposed depreciation expense." ETI should be16allowed to establish a regulatory asset that is not included in rate base, but which17provides for inclusion of depreciation/amortization expense in rates.18Q. PLEASE PROVIDE THE RATIONALE FOR YOUR RECOMMENDATION.19A.In general, rate base treatment for utility assets requires that they be in service as of the20end of the test year or by the time rates go into effect. The very definition of rate base in2116 TAC §25.231(c)(2) includes the phrase "used and useful in rendering service to the29Direct Testimony ofJess K. Totten, page 32, lines 3-8.30See Schedule CTC-3.REDACTED Direct Testimony of Constance T. CannadyOn Behalf of the Office of Public Uti
attachment a resume and record of testimony of constance t. cannady attachment b eti response to cities rfi 8-7 attachment c eti response to opuc rfi 6-3 attachment d docket no. 37744, rate filing package, settlement plant in service and schedule d-3 attachment e eti response to c
learn essential blues shuffle riffs on guitar. There are 10 riffs in this section, 5 in open position to get you started, and 5 with barre chords to move around the fretboard in different keys. These riffs can be used over any blues song you jam on, which you choose depending on the groove, tempo, and feel of the tune.
N. Sharma, M. P. Rai* Amity Institute of Biotechnology (J-3 block), Amity University Uttar Pradesh, Sector-125, Noida, India A B S T R A C T P A P E R I N F O Media requirement for microalgae cultivation adds most to the cost of biodiesel production at Paper history: Received 30 July 2015 Accepted in revised form 6 September 2015 Keywords: - Chlorella pyrenoidosa Cattle waste Lipid content .
1 "# %!&'()* ,-!./%!01 0/1 &!23!-# ! 4 1 ,/-/5!6 ,-/5!7 /5-#!41'8 (-9!!!!"# %&'()*" ( "# ,"--' )( ./'0(' ," )0,) &(1 ! "# %&'! ()*! ,-!).!/01!021,!
Chapter 3: Basic Counseling Skills and Techniques 33 Attending 33 Attire 33 Preparation of the room 34 Body language and voice tone 34 Interest shown to the client 35 Maintaining focus in the client’s world 36 Active listening 37 Benefits of active listening 37 Good active listening 39 Starting and ending a session 44 Beginning the session 45 Bringing the session to close 46 The last session .
The Solution Architecture for Energy and Utilities Framework The Solution Architecture for Energy and Utilities Framework (SAFE) is an innovative, powerful software platform, uniquely designed to provide network visibility and control, process automation and business collaboration for solutions across the energy and utility value chain.
The best outcomes for children’s learning occur where most of the activity within a child’s day is a mixture of: child-initiated play, actively supported by adults focused learning, with adults guiding the learning through playful, rich experiential activities. This can be illustrated as a continuum of approaches as seen below. Unstructured Child-initiated play Focused learning .
Since the end of the Cold War, China has also abandoned its decades-old total war doctrine by embracing a limited war doc-trine, which is more suitable for its new political aims. Second, though China is a major power in North and Southeast Asia, the time is not yet ripe for it to be a global military power that can project its military capability beyond its nearby seas. China’s most recent .
Climate change will affect human and natural systems in many ways, disrupting food and water supply, exposing them to deadly heat, destroying infrastructure, flooding homes, changing infectious disease vectors, eroding livelihoods, and decreasing economic opportunities, especially in agriculture. Figure 1 shows some of
