BEFORE THE CORPORATION COMMISSION OF THE STATE OF OKLAHOMA

IN THE MATTER OF THE APPLICATION OF ) OKLAHOMA GAS AND ELECTRIC ) FOR AN ORDER OF THE COMMISSION ) CAUSE NO. PUD 202000021 APPROVING A RECOVERY MECHANISM FOR ) EXPENDITURES RELATED TO THE ) OKLAHOMA GRID ENHANCEMENT PLAN )

RESPONSIVE TESTIMONY

OF

JOHN GIVENS

AUGUST 25, 2020 BEFORE THE CORPORATION COMMISSION OF THE STATE OF OKLAHOMA

RESPONSIVE TESTIMONY

OF

JOHN GIVENS

AUGUST 25, 2020

TABLE OF CONTENTS EXECUTIVE SUMMARY ...... 3 INTRODUCTION...... 4 PURPOSE ...... 6 PUD’S REVIEW PROCESS ...... 6 AGING -RELATED SAIDI ...... 7 ASSUMED RELIABILITY IMPROVEMENT AND QUANTIFIABLE BENEFITS ...... 12 RECOMMENDATION ...... 17 LIST OF EXHIBITS...... 19

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 2 of 20

1 EXECUTIVE SUMMARY

2 On February 24, 2020, Oklahoma Gas and Electric Company (“OG&E” or “Company”)

3 filed an Application with the Oklahoma Corporation Commission (“Commission”) in

4 Cause No. PUD 202000021, seeking an order of the Commission approving a recovery

5 mechanism for its Oklahoma Grid Enhancement Plan (“Plan”). The Commission’s Public

6 Utility Division (“PUD”) reviewed the Application, Direct Testimony, Errata to Direct

7 Testimony, and Supplemental Testimony filed in the Cause, along with all supporting

8 workpapers provided by the Company. PUD communicated with the Company by email,

9 issued data requests and reviewed the responses, and reviewed responses to data requests

10 issued by intervenors. Finally, PUD conducted multiple audit conferences with Company

11 personnel to discuss the Plan and review confidential information.

12 The Company’s Testimony and workpapers contain statistical and economic models to

13 estimate the reliability and financial impacts of the Plan. The review discussed in this

14 Responsive Testimony focuses on the relative accuracy and reasonableness of those models

15 and estimates, including the Company’s Aging Infrastructure-Related System Average

16 Interruption Duration Index (“SAIDI”) forecast, Monte Carlo analysis of possible SAIDI

17 reduction, and estimates of quantifiable ratepayer benefits under the Plan.

18 As the result of this review, PUD recommends that the Commission adopt the following

19 positions:

20 (1) The regression model used by OG&E to develop its Aging Infrastructure- 21 Related SAIDI forecast produces a much higher growth estimate from 2019 to 22 2026 than any of seven similar models studied by PUD;

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 3 of 20

1 (2) While OG&E’s Aging Infrastructure-Related SAIDI has trended upward since 2 2008, its overall SAIDI does not show a clear upward or downward trend over 3 the same period; 4 (3) There is not sufficient evidence in the record to support the model ranges used 5 by OG&E in its Monte Carlo analysis of possible SAIDI reductions; 6 (4) Both OG&E’s Monte Carlo analysis and its 60% SAIDI reduction assumption 7 are based on review of 14 upgraded circuits in Arkansas, which may have very 8 different reliability and operating characteristics than OG&E’s Oklahoma 9 circuits; 10 (5) The impact of changing the 60% SAIDI reduction assumption on the avoided 11 cost of and avoided economic harm estimates is unknown; and 12 (6) The Interruption Cost Estimate calculator inputs used by OG&E to develop its 13 $1.4 billion estimate of avoided economic harm are unreasonable.

14 Because of the uncertainty highlighted by these recommendations, relative to both the

15 immediate need for the Plan and the level of quantifiable benefit it would provide to

16 ratepayers, PUD finds the request for a recovery mechanism for Plan expenditures is not

17 supported as filed.

18 INTRODUCTION

19 Q: Please state your name and your address.

20 A: My name is John Givens. My business address is Oklahoma Corporation Commission,

21 Division, Jim Thorpe Office Building, Room 580, 2101 North Lincoln

22 Boulevard, Oklahoma , Oklahoma 73105.

23 Q: Have you previously testified before the Commission and were your qualifications

24 accepted?

25 A: Yes. I have previously testified before the Commission and my qualifications were

26 accepted at that time.

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 4 of 20

1 Q: Who employs you and what is your position?

2 A: I am employed by the Oklahoma Corporation Commission Public Utility Division as a

3 Senior Public Utility Regulatory Analyst.

4 Q: How long have you been so employed?

5 A: I have been employed by the Commission since April 2014.

6 Q: What are your duties and responsibilities with PUD?

7 A: I conduct research and perform comparative analysis of utility applications, reports,

8 financial records, and workpapers to ensure that PUD can make accurate recommendations.

9 Prior to working on -related causes and projects, I was assigned to the Oklahoma

10 Universal Service Fund (“OUSF”) Monthly Payment Team, where I was responsible for

11 reviewing Monthly Payment Request and Change Request submissions, ensuring that

12 disbursements from the OUSF were made properly and timely, coordinating development

13 and maintenance of the OUSF Funding Database with the Fund Manager, and preparing

14 special reports and analyses as needed for OUSF analysts and PUD staff. For a complete

15 list of my history and educational background, please review the attached curriculum

16 vitae.1

1 Exhibit JTG-1. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 5 of 20

1 PURPOSE

2 Q: What is the purpose of your Responsive Testimony regarding the Application filed by

3 OG&E in Cause No. PUD 202000021?

4 A: The purpose of my Responsive Testimony is to present PUD’s analysis and recommendations

5 regarding the Company’s Aging Infrastructure-Related SAIDI forecast, Monte Carlo analysis

6 of possible SAIDI reduction, and estimates of quantifiable ratepayer benefits under the Plan.

7 PUD’S REVIEW PROCESS

8 Q: Please explain PUD’s review process in this Cause.

9 A: PUD reviewed the Application, Direct Testimony, Errata to Direct Testimony, and

10 Supplemental Testimony filed in this Cause, along with all supporting workpapers

11 provided by the Company. PUD communicated with the Company by email, issued data

12 requests and reviewed the responses, and reviewed responses to data requests issued by

13 intervenors. Finally, PUD conducted multiple audit conferences with Company personnel

14 to discuss the Plan and review confidential information.

15 The Company’s Testimony and workpapers contain statistical and economic models to

16 estimate the reliability and financial impacts of the Plan. The review discussed in this

17 Responsive Testimony focused on the relative accuracy and reasonableness of those

18 models and estimates.

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 6 of 20

1 AGING INFRASTRUCTURE-RELATED SAIDI

2 Q: Please describe the Aging Infrastructure-Related SAIDI forecast presented in the

3 Company’s Direct Testimony.

4 A: The Aging Infrastructure-Related SAIDI forecast is presented on page 7 of the Direct

5 Testimony of Company witness Zachary Gladhill. Mr. Gladhill states, “[S]ince 2014,

6 OG&E has realized significant increases in outage minutes due to aging equipment failures

7 at an average rate of 10% per year. As forecasted, years 2021-2025 the trend will increase

8 as assets continue to age and deteriorate if OG&E does not accelerate its infrastructure

9 upgrades and replacements.”2 The Testimony also includes a chart3 that shows Aging

10 Infrastructure-Related SAIDI increasing dramatically in the future, from 37.87 minutes in

11 2019 to a forecasted 64.85 minutes in 2026,4 an increase of 71.2%.

12 Q: How was the Aging Infrastructure-Related SAIDI forecast developed?

13 A: The forecast was developed using regression analysis. Regression analysis is a statistical

14 method of finding a “best-fit curve” of a given shape to model a set of actual observed data.

15 These model curves can then be used to identify trends and make estimates and forecasts

16 of data not yet observed. The simplest and most well-known form of regression analysis,

17 known as simple linear regression, produces a best-fit “curve” in the shape of a straight

18 line, but there are many different forms based on different mathematical curves.

2 Direct Testimony of Zachary Gladhill, page 7, lines 9-12. 3 Id., Chart 1. 4 Company response to PUD Data Request ZJQ-2-2. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 7 of 20

Figure 1. An example of a best-fit line generated by simple linear regression.

1 Q: Did OG&E use simple linear regression to develop its Aging Infrastructure-Related

2 SAIDI forecast?

3 A: No. OG&E used a different form of regression analysis known as second-degree

4 polynomial regression, or quadratic regression, which produces a best-fit curve of the

5 form:

6 푦 = 푎푥 + 푏푥 + 푐.

7 Curves of this form can vary—they may be wide, narrow, short, tall, or even upside-

8 down—but just as simple linear regression always produces a straight line, quadratic

9 regression always produces the same basic shape: a “U”-shape known as a parabola.

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 8 of 20

Figure 2. A parabola (y = x2).

1 Q: What actual observed data did OG&E use to develop its regression model?

2 A: OG&E used annual statewide SAIDI scores from outages caused by aging equipment from

3 2008 to 2019 to develop its regression model.5 In other words, the model produces

4 estimates of SAIDI from aging equipment failures (the y variable) in any given year (the x

5 variable).

6 Q: Does PUD have any concerns about the use of a quadratic regression model in this

7 forecast?

8 A: Yes. Because the parabolic shape is inherent to the quadratic regression method, any data

9 that exhibits slightly accelerated growth in the short term is likely to produce a model that

10 forecasts greatly accelerated growth into the future. This is precisely what happened in

11 OG&E’s quadratic regression model, which makes the dire prediction that Aging

12 Infrastructure-Related SAIDI minutes will grow by 71.2% from 2019 to 2026.

5 Company response to Attorney General Data Request AG-OGE-4-20. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 9 of 20

1 Furthermore, because SAIDI decreased from the first to second year of the model6 before

2 starting to trend upward, the resulting parabola was much steeper than it might otherwise

3 be. Essentially, in order to account for the quick change from decreasing to increasing

4 observed SAIDI values, the best-fit curve included portions of both the left (decreasing)

5 and right (increasing) halves of the parabola; if the model began in a later year with a more

6 clear and consistent upward trend, it would likely include only portions of the right half of

7 a much shallower, more gradually increasing parabola.

8 Q: Did PUD compare the results of OG&E’s quadratic regression to any alternative

9 models?

10 A: Yes. PUD created several regression models using the same observed data as OG&E. The

11 results are summarized in Table 1 below. Table 1 also includes the r2 statistic, a value

12 between 0 and 1 which measures how closely the model fits the observed data.

Table 1: Comparison of Aging Infrastructure-Related SAIDI Forecasts Regression Method7 Starting r2 2026 Projected Increase, Year Projection 2019 – 2026 Quadratic (from Company 2008 0.606 64.85 71.2% Direct Testimony) Quadratic 2009 0.647 55.30 46.0% Exponential 2009 0.633 52.15 37.7% Exponential 2008 0.506 46.41 22.6% Linear 2009 0.637 46.33 22.3% Linear 2008 0.528 43.24 14.2% Power 2009 0.518 36.58 −3.4% Logarithmic 2009 0.515 36.18 −4.5%

6 Ibid. Aging Infrastructure-Related SAIDI decreased from 27.22 minutes in 2008 to 22.21 minutes in 2009. 7 PUD also created logarithmic and power regression models beginning in 2008, but excluded them from Table 1 due to their low r2 values, each less than 0.35. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 10 of 20

1 As Table 1 shows, the Company’s model yields a much higher predicted increase in Aging

2 Infrastructure-Related SAIDI than any of the similar models studied by PUD.

3 Q: Is the Company’s overall SAIDI score in Oklahoma increasing?

4 A: No. As shown below in Figure 3, the Company’s overall SAIDI (exclusive of major events,

5 such as long outages from ice storms or severe weather outside the Company’s control) has

6 fluctuated since 2008,8 but unlike the Aging Infrastructure-Related SAIDI, it does not

7 display a clear upward or downward trend.

OG&E Oklahoma SAIDI, 2008 - 2019 180

160

140

120

100

80

60

40

20

0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Figure 3. OG&E overall SAIDI shows no clear upward or downward trend.

8 OG&E Annual Reliability Reports. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 11 of 20

1 Q: Why is it important to consider the Company’s overall SAIDI?

2 A: Overall SAIDI paints a clearer picture of outages from the customer’s perspective. The

3 average customer probably does not know—and may not care about—the cause of any

4 given outage. As long as overall SAIDI remains relatively flat, increases or decreases in

5 SAIDI from a particular cause (such as aging infrastructure) should have little or no impact

6 on the customer experience.

7 ASSUMED RELIABILITY IMPROVEMENT AND QUANTIFIABLE BENEFITS

8 Q: What level of quantifiable benefits does OG&E estimate as a result of the Plan, and

9 what level of reliability improvement was assumed to reach these estimates?

10 A: OG&E estimates a benefit of $500 million in avoided cost of service,9 as well as a benefit

11 of $1.4 billion in avoided economic harm,10 over the next 30 years. These estimates are

12 based on an assumed 60% average improvement in SAIDI per circuit.11

13 Q: How was the 60% SAIDI reduction target derived?

14 A: OG&E performed a Monte Carlo analysis which produced an estimated 55% reduction,

15 then increased the target to 60% based on actual reductions of greater than 60% on

16 upgraded circuits in Arkansas.12

9 Direct Testimony of Zachary Gladhill, page 17, Table 2. 10 Id., page 18, line 29. 11 Id., page 16, line 6. 12 Id., lines 14-16. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 12 of 20

1 Q: What is Monte Carlo analysis?

2 A: Monte Carlo analysis is a statistical method that uses randomness to estimate values which

3 are difficult or impossible to calculate directly. The process involves using computer

4 programs to simulate a large number of randomized trials, then averaging the results of

5 those trials to obtain an estimate of the desired value.

6 Q: Please describe how Monte Carlo analysis was used by OG&E to estimate SAIDI

7 reduction.

8 A: OG&E developed low, middle, and high estimates (“model ranges”) of the percent

9 reduction in Customer Minutes of Interruption (“CMI”) from ten historical system projects,

10 then simulated a large number of trials in which a reduction percentage was randomly

11 selected from within the model ranges for each project and applied to the historical CMI

12 data from 14 Company circuits in Arkansas.13 The results were averaged, and the resulting

13 CMI estimate was used to calculate the estimated 55% SAIDI reduction as a final output

14 the analysis.

15 Q: How were the model ranges for CMI reduction developed?

16 A: According to Mr. Gladhill’s Direct Testimony, each of the ten historical system projects

17 “were given a range of possible improvement based on after action reviews of projects

18 historically implemented in Oklahoma.”14 However, in response to Data Request AG-

19 OGE-6-5, in which the Attorney General requested that OG&E “provide the after-action

20 reviews of projects historically implemented in Oklahoma and the output of the analysis

13 Company response to Attorney General Data Request AG-OGE-6-4. 14 Direct Testimony of Zachary Gladhill, page 16, lines 11-12. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 13 of 20

1 that provided low, middle, and high outcomes,” the Company provided after action reports

2 for only four of the ten projects, stating, “Where an assessment is not available, OGE relied

3 on subject matter experts to determine likely ranges.”15

4 Q: Did PUD review the four after action reports provided by OG&E in response to

5 Attorney General Data Request AG-OGE-6-5?

6 A: Yes.

7 Q: Was PUD able to verify that the model ranges used in the Monte Carlo analysis were

8 based on the results of these after action reports?

9 A: No. Despite the Company’s assertion that the model ranges were “based on after action

10 reviews of projects historically implemented in Oklahoma,”16 PUD was unable to verify

11 any of the model ranges against any of the after action reports. While three of the four

12 reports discuss the CMI reductions actually achieved, none provide a range of possible

13 reductions from future projects.

14 Q: Does PUD agree with OG&E’s estimate of 60% SAIDI reduction as a result of the

15 Plan?

16 A: No. PUD believes that OG&E’s 60% SAIDI reduction estimate may be reasonable;

17 however, PUD also believes that OG&E has failed to provide sufficient support for the

18 estimate in the record. PUD was unable to ascertain with specificity the source of the

19 model ranges in the Monte Carlo estimate. Further, both the Monte Carlo analysis and the

15 Company response to Attorney General Data Request AG-OGE-6-5. 16 Supra note 14. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 14 of 20

1 actual historical results used to justify the 60% SAIDI reduction estimate were based on a

2 review of 14 circuits in Arkansas that may have very different reliability and operating

3 characteristics than the Company’s Oklahoma circuits. For these reasons, PUD cannot

4 support the 60% SAIDI reduction estimate.

5 Q: If a SAIDI reduction of less than 60% were assumed, what effect would this have on

6 the $500 million estimate for avoided cost of service?

7 A: This is unknown. A small change in the SAIDI improvement assumption may have a

8 minimal impact on ratepayers, or it may have a severe impact. OG&E did not perform a

9 sensitivity analysis to determine the effect of changing the SAIDI improvement

10 assumption.17

11 Q: How was the $1.4 billion estimate for avoided economic harm calculated?

12 A: According to Mr. Gladhill’s Direct Testimony,18 OG&E used the Department of Energy’s

13 Interruption Cost Estimate (“ICE”) calculator19 to generate an estimate of avoided

14 economic harm. The ICE calculator generated an estimate of approximately $1.915 billion

15 for all of the Company’s Oklahoma circuits,20 which was then allocated on an outage-per-

16 circuit basis to only include circuits to be enhanced under the Plan.21

17 Company response to PUD Data Request ZJQ-2-13. 18 Page 17, lines 16-20. 19 www.icecalculator.com. 20 Company response to Attorney General Data Request AG-OGE-3-8. 21 Company response to Attorney General Data Request AG-OGE-7-20. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 15 of 20

1 Q: Does PUD agree with the $1.4 billion estimate for avoided economic harm?

2 A: No. PUD believes that the inputs used in the ICE calculator to develop the estimate are

3 not reasonable, so the Commission should not rely upon the resulting estimate.

4 Q: Why does PUD believe that the inputs used in the ICE calculator are not reasonable?

5 A: PUD believes that the inputs used in the ICE calculator are not reasonable for two reasons.

6 First, the inputs fail to match the analysis described in the Company’s Direct Testimony;

7 and second, the inputs assume identical SAIDI levels (both with and without Plan

8 ) in each year of the model.

9 Q: Please describe how the ICE calculator inputs fail to match the analysis described in

10 the Company’s Direct Testimony.

11 A: The Company’s Direct Testimony represents that the avoided economic harm calculation,

12 like the avoided cost of service calculation, is premised upon a 60% improvement in

13 SAIDI22 and a 30-year timeframe for benefits to accrue,23 beginning in 2020 (the first year

14 of the Plan). The inputs to the ICE calculator, on the other hand, show a 40% reduction in

15 SAIDI and a 20-year timeframe, beginning in 2019.24

22 Direct Testimony of Zachary Gladhill, page 16, line 6; Direct Testimony of Kandace Smith, page 5, line 21. 23 Direct Testimony of Zachary Gladhill, page 18, line 30; Direct Testimony of Kandace Smith, page 5, line 26. 24 Company response to Attorney General Data Request AG-OGE-3-8. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 16 of 20

1 Q: Please explain why PUD believes it is unreasonable to assume identical SAIDI levels

2 in each year of the ICE calculator model.

3 A: PUD believes this assumption is unreasonable because it fails to account for either the

4 gradual accrual of reliability improvement benefits over the five years of the Plan, or for

5 the gradual degradation of benefits as Plan assets deteriorate and fail over the life of the

6 model. It may arguably be reasonable to hold constant the input for SAIDI without

7 improvement (i.e., what the SAIDI level would be under a “business as usual” approach)

8 as a way to compare apples to apples and avoid complex forecasting. However, opting to

9 also hold constant the input for SAIDI with improvement results in a model that assumes

10 that all reliability improvements of the Plan will be realized instantaneously. Furthermore,

11 the resulting model assumes that the economic benefits of such improvements will continue

12 to accrue to ratepayers unchanged for a period of decades. These assumptions are

13 unreasonable and contrary to fact. Mr. Gladhill even states in his Direct Testimony that

14 “The model allows each year of the reliability numbers to be modified, which enables the

15 utility to reflect what is expected over periods of time,”25 yet OG&E did not make use of

16 this functionality in any way.

17 RECOMMENDATION

18 Q: What is the Public Utility Division’s (“PUD”) finding concerning Oklahoma Gas and

19 Electric Company’s (“OG&E”) Aging Infrastructure-Related System Average

20 Interruption Duration Index (“SAIDI”) forecast and the assumed reliability

25 Direct Testimony of Zachary Gladhill, page 18, lines 17-19. Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 17 of 20

1 improvements and quantifiable benefits of its proposed Oklahoma Grid

2 Enhancement Plan (“Plan”)?

3 A: PUD finds the following:

4 (1) The regression model used by OG&E to develop its Aging Infrastructure- 5 Related SAIDI forecast produces a much higher growth estimate from 2019 to 6 2026 than any of seven similar models studied by PUD; 7 (2) While OG&E’s Aging Infrastructure-Related SAIDI has trended upward since 8 2008, its overall SAIDI does not show a clear upward or downward trend over 9 the same period; 10 (3) There is not sufficient evidence in the record to support the model ranges used 11 by OG&E in its Monte Carlo analysis of possible SAIDI reductions; 12 (4) Both OG&E’s Monte Carlo analysis and its 60% SAIDI reduction assumption 13 are based on review of 14 upgraded circuits in Arkansas, which may have very 14 different reliability and operating characteristics than OG&E’s Oklahoma 15 circuits; 16 (5) The impact of changing the 60% SAIDI reduction assumption on the avoided 17 cost of service and avoided economic harm estimates is unknown; and 18 (6) The Interruption Cost Estimate calculator inputs used by OG&E to develop its 19 $1.4 billion estimate of avoided economic harm are unreasonable.

I state, under penalty of perjury under the laws of Oklahoma, that the foregoing is true and correct to the best of my knowledge and belief.

______/s/ John Givens John Givens

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 18 of 20

Oklahoma Gas and Electric Company – Cause No. PUD 202000021

LIST OF EXHIBITS

JTG-1 Curriculum Vitae

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 19 of 20 Exhibit JTG-1

John T. Givens Curriculum Vitae

Contact [email protected] 580 Jim Thorpe Building Tel: 405-521-4114 P.O. Box 52000 Oklahoma City, OK 73152

Work Oklahoma Corporation Commission 2014 – Present Experience Public Utility Division, Rates and Group – Senior Public Utility Regulatory Analyst  Conduct research and perform comparative analysis of utility applications, reports, financial records, and workpapers.  Draft pre-filed testimony and serve as an expert witness in court proceedings.  Lead analyst in PUD Cause Nos. 201900083 and 201900094.  Support analyst in PUD Cause Nos. 202000021, 202000022, 202000028.

Public Utility Division, OUSF Monthly Payment Team – Public Utility Regulatory Analyst  Reviewed and processed Monthly Payment Request and Change Request submissions from eligible Oklahoma Universal Service Fund (“OUSF”) providers.  Verified and approved hundreds or thousands of individual pending payment records each month prior to monthly OUSF disbursement.  Coordinated development and maintenance of the OUSF Database with contracted Fund Manager, including developing SQL queries and reports.  Analyzed pending and historical payment records to ensure compliance with state and federal law, as well as Commission orders, rules, and policies.  Performed cost-per-megabit benchmarking analysis in PUD Cause Nos. 201400115, 201400116, 201600345, 201600362.  Analyzed data and prepared exhibits for filing in PUD Cause Nos. 201200183 and 201500075.

Oil & Gas Conservation Division, Well Records Section – Administrative Technician  Reviewed and processed transfer-of-operator requests.  Performed both systematic and ad hoc reviews and corrections of data in Imaging and Well Data (RBDMS) systems.  Assisted operators, mineral owners, and other stakeholders with research involving imaged documents, online databases, microfilm, and hard-copy files.  Reviewed mineral leases and various other legal documents, working closely with the Office of General Counsel to ensure compliance.

Education University of Oklahoma 2005 – 2010  B.A., Multidisciplinary Studies  Minor in Mathematics

Professional  Introduction to Regional Wholesale Markets, EUCI, March 3–4, 2020 Training and  Telecom 101, Online School of Network Sciences, completed November 2019 Development  National Exchange Carrier Association Expo, November 5–8, 2017  National Regulatory Research Institute Training, March 16, 2017  Oklahoma Association Accounting Conference, November 3, 2015 and November 3, 2016  Numerous internal PUD trainings on Accounting, Accumulated Deferred Income , Cost of Capital, Cost of Service, Depreciation, the Revenue Requirement, Tariffs, Utility Operating Expenses, and other ratemaking and regulatory topics

Responsive Testimony – Givens Oklahoma Gas and Electric Company – Cause No. PUD 202000021 Page 20 of 20 Cause No. PUD 202000021 Certificate of Service

CERTIFICATE OF SERVICE

This is to certify that on August 25, 2020, a true and correct copy of the above and foregoing, was sent via electronic and/or United States Postal Service, postage fully prepaid thereon to the following interested parties:

Jared Haines Natasha Scott Chase Snodgrass Michael L. Velez Victoria Korrect Lauren Willingham Office of Attorney General Assistant General Counsel 313 NE 21st Street OKLAHOMA CORP. COMM’N Oklahoma City, OK 73105 Jim Thorpe Building [email protected] 2101 N. Lincoln. Blvd. [email protected] Oklahoma City, OK 73105 [email protected] [email protected] [email protected] William L. Humes [email protected] Dominic D. Williams [email protected] OKLAHOMA GAS AND ELECTRIC CO. P.O. Box 321, MC 1208 Curtis M. Long Oklahoma City, OK 73101 CONNER & WINTERS, LLP [email protected] 4000 One Williams Center [email protected] Tulsa, Oklahoma 74172 [email protected] [email protected]

Jack G. Clark Jr. Thomas P. Schroedter CLARK, WOOD & PATTEN, P.C. HALL, ESTILL, HARDWICK, GABLE, GOLDEN & 3545 NW 58th St., Ste. 400 NELSON, P.C. Oklahoma City, OK 73112 320 S. Boston Ave., Ste. 200 [email protected] Tulsa, OK 74103 [email protected] Ronald E. Stakem [email protected] CHEEK & FALCONE, PLLC 6301 Waterford Blvd., Ste. 320 Deborah R. Thompson Oklahoma City, OK 73118 OK ENERGY FIRM, PLLC [email protected] P.O. Box 54632 [email protected] Oklahoma City, OK 73154 [email protected]

Rick D. Chamberlain Jack P. Fite WHEELER & CHAMBERLAIN WHITE, COFFEY, & FITE PC 6 NE 63rd St., Ste. 400 2200 NW 50th St, Ste. 210E Oklahoma City, OK 73105 Oklahoma City, OK 73112 [email protected] [email protected]

Ellen Caslavka Edwards Mark A. Davidson OKLA. MUNICIPAL POWER AUTH. Scott L. Kirk P.O. Box 1960 Robert J. Friedman Edmond, OK 73013 Thomas A. Jernigan [email protected] Ebony Payton TSgt Arnold Braxton Federal Executive Agencies (FEA) [email protected] [email protected] [email protected] [email protected] [email protected] [email protected]

______TISH COATS, PUD Manager BARBARA COLBERT, Administrative Assistant SUSAN HARWELL, PUD Regulatory Analyst KELI WEBB, PUD Compliance Investigator

OKLAHOMA CORPORATION COMMISSION