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1 STATE OF NEW YORK PUBLIC SERVICE COMMISSION 2 ______
3 Special Meeting of the Public Service Commission
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6 WEDNESDAY, JANUARY 12, 2011 10:30 a.m. 7
8 Agency Building 3 19th Floor 9 Albany, New York
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13 COMMISSIONERS:
14 GARRY A. BROWN, Chairman PATRICIA L. ACAMPORA 15 ROBERT E. CURRY, JR. (In New York City) MAUREEN F. HARRIS (Via telephone) 16 JAMES J. LAROCCA (In New York City)
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1 D I S C L A I M E R
2 This is an unofficial transcript of a public meeting
3 of the New York State Public Service Commission held on
4 January 12, 2011 in the Commissions's Offices at Three
5 Empire State Plaza, 19th Floor Board Room, Albany, New
6 York.
7 This transcript may contain inaccuracies, and it may
8 not include all discussion conducted at the meeting.
9 The transcript is intended solely for general
10 information purposes and is not part of any formal or
11 informal record of a Commission decision of any matter
12 discussed. Expressions of opinions in this transcript
13 do not necessarily reflect final determination of
14 beliefs which are set forth in the Commission's
15 Decisions and Order.
16 No pleading or paper may be filed with the Commission
17 in any proceeding as a result of or addressed to any
18 statement or argument contained in this transcript,
19 except as the Commission may authorize.
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1 COMMISSIONER ACAMPORA: Good morning. We are
2 going to commence the beginning of this January 12, 2011
3 special session.
4 For those members of the public who are
5 viewing our webcast this morning, please be advised that
6 Commissioners Curry and Larocca are joining us from our
7 New York City office, and that Commissioner Harris is
8 joining us via telephone.
9 And Chairman Brown will join us later this
10 morning as he is with the Governor this morning at the
11 SEMO headquarters, as it is the responsibility of the
12 chair to be with the Governor and other heads of
13 agencies during such emergencies. As everyone is aware,
14 we are experiencing a really bad snow storm throughout
15 most of the state, and so, please hang in there with us
16 today. We are so happy that so much of our staff is
17 here.
18 So, today's session was called for the
19 purpose of discussing the pending rate application
20 submitted by National Grid, doing business as Niagara
21 Mohawk Power Corporation, and anticipation of our
22 consideration of this case will be next week, Thursday,
23 January 20th. We will not vote on this case today.
24 This is strictly information only.
4
1 And for purposes of our stenographer, the
2 item is 301, case 10-E-0050, proceeding on a motion of
3 the Commission as to the rates, charges, rules and
4 regulations for Niagara Mohawk Power Corporation's
5 electric service.
6 There will be several presenters today. And
7 I think our two judges, Administrative Law Judge Bill
8 Bouteiller and Judge Rudy Stegemoeller from our Office
9 of Hearings and Alternative Dispute Resolution, will be
10 leading this off.
11 Bill, I will start with you so you can start
12 introducing all the presenters this morning.
13 JUDGE BOUTEILLER: I've spoken with Rudy and
14 we have decided that I would start and he would end, so
15 you will hear from me first, and when you get to Rudy
16 you know you are close to the end.
17 COMMISSIONER ACAMPORA: We will be in
18 anticipation of that.
19 JUDGE BOUTEILLER: There is a few people in
20 between.
21 So, let me start by stating my pride to be
22 part of this ensemble presentation with some of the
23 finest hard working advisors that you have. Joe, Raj,
24 Doug, Doris and Rudy are consummate professionals, and
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1 they have made my work on this case bearable and
2 pleasurable at times.
3 The department has spent --
4 COMMISSIONER CURRY: Faint praise.
5 JUDGE BOUTEILLER: No, it's real praise and
6 this is real hard work. Your temperament goes up and
7 down with the case.
8 The department has spent about a year
9 pouring over and examining Niagara Mohawk's and National
10 Grid's electric operations. The ratemaking review has
11 been substantial, but it remains incomplete in a couple
12 of regards.
13 Depending upon how National Grid chooses to
14 go forward, this round of rate review will be followed
15 by either one or two more rounds. One to cover service
16 company matters and another to finish the rate case
17 review that has begun here.
18 To cover service company matters that remain
19 open, $50 million of the proposed revenue increase
20 should either be made temporary or should be collected
21 through an adjustment clause, so when the results of the
22 service company review are known they can be implemented
23 correctly for ratemaking purposes.
24 Also in this case, National Grid asked the
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1 Commission to perform a three year review for 2011, 2012
2 and for 2013. The rate review to date has focused
3 mostly on 2011 and only in the area of capital
4 expenditures do I know that the review has
5 systematically gone beyond the rate year.
6 In the most general of terms, I believe
7 there are four major considerations coming before the
8 Commission for deliberation and your decision.
9 First, how do we wrap up the merger joint
10 proposal that is entering its tenth and final year.
11 Second, what amount of revenues is the
12 company entitled to receive in 2011. And related to
13 that question, what amounts should the company charge
14 and collect from customers in 2011.
15 Next, in this unique period of economic
16 dislocation and distress, how should the Commission
17 continue to pursue and implement your austerity
18 objectives?
19 And then fourth, how do we set the stage for
20 the rates that will be in place in 2012 and 2013 when
21 the merger joint proposal formerly ends and the company
22 stops collecting its competitive transition charges.
23 Let me go back in time. Nine years ago
24 National Grid acquired Niagara Mohawk and the delivery
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1 rates were decreased to account for the synergies
2 related to that merger. A long term rate plan was
3 introduced to regulate the upstate operations during
4 Niagara Mohawk's transition from a stand alone company
5 to part of the integrated utility system that National
6 Grid runs in New England and in New York.
7 The most noteworthy feature of that joint
8 proposal was, at least for today's discussion purposes,
9 its competitive transition charge. Nine-tenths of the
10 competitive transition charge have been worked down and
11 the last tenth will be finished in 2011.
12 The systematic elimination of the
13 competitive transition charge has taken Niagara Mohawk
14 out of its insolvency in the 1990s, and National Grid's
15 fiscal management of Niagara Mohawk's operations have
16 restored the operating company to solvency that we know
17 now.
18 Recall, please, that at the time that
19 National Grid acquired Niagara Mohawk the company could
20 not issue creditworthy debt and its equity position was
21 largely depleted. Now, the company has an A minus
22 rating and it is issuing debt on its own.
23 And now we also are debating the question of
24 whether or not for ratemaking purposes we should
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1 recognize a 46 percent or a 48 percent or a 50 percent
2 equity position. That has been built up over the last
3 nine years with the retained earnings and the
4 operations.
5 So, in general, I believe that the 10 year
6 merger joint proposal has been a successful regulatory
7 approach primarily due to the dedication of a small team
8 of staff accountants, engineers, financial experts and
9 economists working out of Syracuse and Albany who have
10 overseen over the last nine years the operation of this
11 plant.
12 Joe Lochner, and he will be our first
13 presenter, will high light for you the development of
14 the competitive transition charge over the past decade
15 and how the deferral accounting system has been used
16 during this period.
17 National Grid began this rate case with an
18 expectation that it would obtain between $360- to 390
19 million in additional revenues. We have completed a
20 financial review for 2011, and we the judges, have found
21 support for only a revenue increase around or about
22 $110- to $115 million.
23 If this were one of the other rate cases
24 that the Commission has recently handled, at this point
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1 in the process you would be trying to figure out how
2 much of that revenue increase to include in current
3 delivery rates, and you would be in the process of
4 introducing customers to the rates and the bill impacts
5 that would begin in February, and they would continue at
6 that higher level in succeeding months.
7 Last year, in January 2010, National Grid
8 proposed to avoid a delivery rate increase in 2011.
9 This element of the company's proposal survives.
10 Delivery rate, under the proposals from all the parties
11 here, will not increase in 2011.
12 There has been substantial amounts of
13 accounting and rate engineering that has gone into the
14 cost allocations and to the revenue assignments to the
15 service classifications to accomplish this result.
16 Raj Addepalli will lay out for you the
17 revenue allocation and rate design that gets us to a
18 zero bill impact. Raj will also show you where rates
19 are headed for 2012 at the end of the merger joint
20 proposal when the competitive transition charges end.
21 Both Raj and Doug Elfner will summarize for
22 you the uncontested matters in this case and the
23 parties' stipulations. We have several significant
24 matters that were settled out and were not the subject
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1 of litigation.
2 Then, as I promised, Rudy will be our final
3 presenter, and he will identify all the litigated issues
4 of noteworthiness, and most of them are in the expense
5 and the cost savings area. Those remain for you to
6 resolve and we have tentative recommendations on all
7 those matters for you, or will continue to work on them,
8 and we promise to bring them back to you for that
9 January 20th session when you take your action.
10 So, at this point, I believe Joe is ready to
11 present his presentation. And if you have questions or
12 inquiries of us, please don't wait until the end. We
13 will be far past the point and we might not remember
14 them. So, please interrupt us and interject yourself as
15 points are raised which are of interest to you.
16 MR. LOCHNER: Good morning, Commissioners.
17 The purpose of this presentation is to
18 provide background, to provide understanding of the rate
19 history of Niagara Mohawk, and particularly as how the
20 competitive transition charge amounts were resulted from
21 events in the past, and a discussion of the merger joint
22 proposal rate plan and the deferral mechanism that was
23 allowed under that.
24 The purpose of this is to understand how we
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1 come to the point we are in time, and how we understand
2 those issues when we make our decision on this rate
3 application.
4 So, let's start from the very beginning.
5 This starts a little bit in the past. Before the 1990s,
6 Niagara Mohawk had some of the lowest rates for
7 electricity in New York State. However, in the 1980s,
8 they entered into purchase power contracts with
9 independent power producers, mandated contracts under
10 the New York six cent law, and the Federal Public
11 Utilities Regulatory Practices Act. Entering into these
12 contracts caused Niagara Mohawk's rates to increase
13 between 1990 and 1995 by 25 percent.
14 And this was a difficult situation for
15 Niagara Mohawk because at this time the electric market
16 was beginning to restructure, and large industrial
17 customers had other alternatives for receiving
18 electricity or to locate their operations in other
19 states and countries.
20 This put pressure on Niagara Mohawk to
21 obtain some type of negotiation and resolution of these
22 increasing payments. In 1990, the payments were --
23 totalled over a billion dollars to these independent
24 power producers.
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1 Starting in 1994, Niagara Mohawk began
2 negotiations with the independent power producers to
3 resolve this issue. In 1997, Niagara Mohawk entered
4 into the master restructuring agreement with these
5 independent power producers.
6 It was with 16 of the independent power
7 producers composing 30 of these various contracts. And
8 they entered into a restructuring or elimination of
9 these contracts.
10 And it represented approximately 80 percent
11 of the above market price contracts. However, under
12 this contract, under the MRA, Niagara Mohawk was
13 required to pay, as you can see, $3.6 million in cash to
14 these IPPs to close out or modify these contracts to
15 moderate the purchase power cost under the contracts and
16 issue 48 million of its shares to these independent
17 power producers.
18 Right after that, in 1998, of course,
19 Niagara Mohawk had come to the Commission to reflect
20 these costs in rates. In 1998, the Commission approved
21 Niagara Mohawk's Power Choice, a five year rate plan.
22 There were rate reductions in the first
23 three years of this plan to pass through the reduced
24 power costs resulting from the MRA. It also allowed or
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1 recognized, over a 10 year period, these competitive
2 transition charge costs as regulatory assets. That this
3 was a prudent expenditure to resolve this contractual
4 issue. And it allowed the recovery of these costs over
5 10 years.
6 Also in this proceeding, they also
7 determined that they were allowed to -- the company was
8 allowed to include prudent net losses -- the sale, the
9 divestiture of its generation during the restructuring
10 operations going on in New York State, and include that
11 in this regulatory asset in the competitive transition
12 charges.
13 However, a full return was not being --
14 wasn't going to be provided on this deferral balance,
15 this amount of stranded costs, being the MRA costs of
16 approximately 3.6 billion. And later, as we see, $1
17 billion of net losses from the sale of its own
18 generation plant, that there was not going to be a full
19 return provided on that.
20 As a result, the company absorbed a
21 significant amount of stranded costs, the return costs
22 on financing that cost of that regulatory asset but not
23 provided in rates.
24 COMMISSIONER LAROCCA: Do we have a figure
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1 -- is there a figure on what the total of those stranded
2 costs that they absorbed?
3 MR. LOCHNER: Yes. Actually in the Power
4 Choice order the estimate over the five year period was
5 $2 billion. Because Power Choice didn't operate for the
6 entire five years, only four of the years, we could
7 probably estimate it ran around one and a half billion
8 dollars that the company absorbed of lost return costs
9 they didn't receive in rates.
10 COMMISSIONER LAROCCA: Thank you.
11 MR. LOCHNER: So, at the end of 2001, the
12 competitive transition charge balance was totalled at
13 approximately $4.3 billion regulatory asset.
14 Enter National Grid. As you know, in 2001
15 National Grid petitioned to acquire Niagara Mohawk. In
16 December of 2001, the Commission approved National
17 Grid's acquisition of Niagara Mohawk and the associated
18 merger joint proposal plan. It was a 10 year rate plan
19 from 2000 to the end of 2011.
20 At the start of the rate plan, the beginning
21 of 2002, delivery rates were reduced by a little over
22 four percent on total bill, and nine percent on
23 delivery. This reduction was funded primarily by the
24 customer's share of efficiency gains that resulted from
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1 divestiture of the generation plant, and also the merger
2 synergy savings, and also by Niagara Mohawk writing off
3 almost a billion dollars of CTCs at the start of this
4 rate plan.
5 By reducing -- writing off those CTCs, they
6 are not in rate base and you don't have to pay the
7 return on them.
8 COMMISSIONER LAROCCA: Is that part of the
9 figure that goes into the 1.5 billion absorption?
10 MR. LOCHNER: So, this is additional. This
11 billion dollar write off was in addition to the lost
12 return costs during the four years of the Power Choice.
13 The remaining $3.3 billion of competitive
14 transition charge regulatory balance was allowed
15 recovery with a full return, in other words, included in
16 rate base, for the 10 years of this rate plan.
17 Another element of this merger joint
18 proposal, because of its long period, 10 years, there
19 was a mechanism, deferral mechanism, that allowed the
20 deferrals of up to 20 specific items.
21 The company was allowed to defer changes in
22 costs and revenues of greater or lesser than reflected
23 in the annual revenue requirements during the 10 years
24 of the merger joint proposal.
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1 The purpose of this was really to avoid the
2 need for the company to file a rate case if certain
3 costs that they don't always have under full control
4 would change significantly from that assumed in rates.
5 During the 10 years, there were significant
6 increases in certain costs that required deferrals to be
7 recorded and for the company to recover these costs.
8 The mechanism to recover the costs was in every two
9 years the company could come forward and present the
10 deferrals.
11 Those amount of net deferrals above $100
12 million would be recovered in the next two years. The
13 amount of the net deferrals became significant, such
14 that in 2006 there was a delivery rate adjustment
15 increase on an annual basis of $100 million to recover
16 these accumulated deferral costs. It was increased to
17 $200 million annually in 2007.
18 At the beginning of 2008, the amount was
19 reduced to an annual amount of $123 million that
20 continues to today on an annual basis and will be to the
21 end of 2010.
22 Just so we have an idea of the size of these
23 merger joint proposal deferrals, what we are talking
24 about and how much the ratepayer had to pay of these
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1 costs, on slide five shows it shows that at this point
2 in time the estimated total net deferral of costs
3 between -- for the nine years of the plan between 2002
4 and 2010 was $834 million. That through the end of
5 2010, the recovery of those in rates are approximately
6 $670 million.
7 Niagara Mohawk, in this proceeding, has
8 estimated that at the end of 2010 there will be a net
9 cost deferral balance remaining of $164 million left to
10 recover.
11 To get a sense of what was the cause of this
12 significant deferral activity and recovery to customers
13 above what was assumed for the costs in the rates for
14 the 10 years of the merger joint proposal, the big
15 ticket items were pensions and OPEBs, pensions and other
16 post retirement employee benefits of $561 million during
17 this time period.
18 Storm restoration, major storm restoration
19 costs were another large item of $173 million included
20 in this deferral balance. That included a very large
21 Buffalo storm and a storm in the Capital District that
22 were very significant.
23 Finally, the other major cost item in the
24 deferral is the environmental clean up of Site
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1 Investigation and Remediation Act. That was about $98
2 million.
3 COMMISSIONER CURRY: In looking at storms,
4 is this figure 173 net of whatever benefits would accrue
5 from repairing or replacing equipment that might have
6 been on the capital or under the O&M budget?
7 MR. LOCHNER: Yes, it did. In fact, as part
8 of the deferral mechanism in the MJP, the deferral
9 mechanism, the terms and conditions, every storm that
10 was a major storm -- and by the way, the requirement for
11 major storms under this deferral mechanism is more
12 strict than under the rules and regulations.
13 So, first of all, for the storm to be first
14 a deferrable event it had to be a much larger storm,
15 longer period for people to be out.
16 Secondly, for every storm that did occur,
17 major storm, total costs had to be above $2 million for
18 the storm, and there was an automatic deductible of $2
19 million for those costs of a major storm that were for
20 this offset.
21 As you are suggesting, that there is avoided
22 O&M costs when the storm occurs and restoration work is
23 performed, such as tree trimming, and replacing guide
24 wires on pole lines and things of that nature.
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1 So, there was built into this, in the terms
2 and conditions of the MJP, a $2 million deductible for
3 every major storm that was a deferrable event.
4 Does that help you?
5 COMMISSIONER CURRY: Was the $2 million a
6 plug number or was it just --
7 MR. LOCHNER: Yes. Basically it was an
8 agreed to number. The reason that they use a $2 million
9 amount is because of the amount of effort and time to
10 argue over what was avoidable costs in every one of
11 these storm categories, as I remember, I think there was
12 67 storms that were reflected in this -- during this
13 time period as part of the deferral mechanism.
14 To go through every one of the storm work
15 orders where they accumulate all the transactions and
16 determine how much was avoidable, and how much was
17 incremental costs for the storm, would be a Herculean
18 activity. And the parties agreed to two million.
19 COMMISSIONER CURRY: I agree. I wouldn't
20 have contemplated that there were 167 storms in that
21 category.
22 MR. LOCHNER: No. I said 67.
23 There is a few very large storms over --
24 well, there is three storms during this time period that
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1 were over $20 million, but there are a lot of small
2 storms, smaller than $20 million but still significant.
3 COMMISSIONER CURRY: Thank you.
4 MR. LOCHNER: So, that gives you a sense of
5 what's composed of this large additional cost amount
6 that ratepayers pay during this time period.
7 COMMISSIONER LAROCCA: Joe, on the SIR
8 number, we were looking at it statewide in a briefing
9 the other day, and the dramatic history there is that
10 every one of these numbers has grown over the course of
11 the program, from the earliest estimates to when these
12 things get through their characterization phases and the
13 actual realities of clean up and so forth.
14 I'm just wondering: This 98 million, that
15 is a retrospective number?
16 MR. LOCHNER: That is the amount of site
17 investigation remediation costs for the nine years. So,
18 it was above the allowance, the annual allowance that
19 was allowed in rates.
20 So, it's not a representation of the full
21 amount, but the excess. I believe, I will check if I am
22 wrong, but I think it was in the $12 million range that
23 we allowed annually in rates for SIR costs in the
24 ongoing delivery rates during the time period. So, this
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1 is in addition to that during the nine years.
2 COMMISSIONER LAROCCA: And looking forward,
3 I presume we are -- this may not be the place for this,
4 but I presume we are taking account of what the actual
5 history has been, compared to the kind of good faith
6 estimates you were able to make 10 years ago in this and
7 all the companies. That the numbers in every case have
8 turned out to be bigger than were anticipated.
9 MR. LOCHNER: Well, I think that you could
10 say there is that trend. I am not certain every project
11 is that way, but there is that trend.
12 COMMISSIONER LAROCCA: I understand, but
13 overall these numbers have grown right around the state.
14 MR. LOCHNER: Right.
15 COMMISSIONER LAROCCA: So, in going --
16 projecting what needs to happen in 2011, 2012 and
17 forward, we are working from the experience numbers
18 rather than the original numbers.
19 MR. LOCHNER: Yes, we are. We are looking
20 at the current level of these costs. That's the overall
21 purpose of the rate case, based on what's the current
22 and projected levels they expect to incur through this
23 activity.
24 JUDGE BOUTEILLER: Commissioner, we could
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1 probably pull out from the rate case the current
2 ratemaking allowance and tell you whether or not that
3 number is greater or the same as the number that we have
4 seen previously in rates. We could probably get that
5 information for you between now and the next session.
6 COMMISSIONER LAROCCA: Okay, because just
7 trying to link the lessons of the other briefing is that
8 we have seen significant growth. You take an overall
9 picture there may be individual projects, that wasn't
10 the case, but overall and around the state this has
11 grown into a significant cost factor in many places.
12 MR. LOCHNER: Just as a final point,
13 Commissioner, the current allowance in this rate case
14 for SIR activity, for site investigation remediation, is
15 $30 million. So, as I understand it, as I remember,
16 it's a significant increase from what was reflected
17 annually in the MJP, in the merger joint proposal, back
18 in 2002.
19 COMMISSIONER LAROCCA: Obviously the 30
20 would be an updating of the 12 then.
21 MR. LOCHNER: The 30 is -- yes. The 30 is
22 based on what the current level of costs the company
23 expects to incur versus what was expected back in
24 2000-2001 when they presented the revenue requirements
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1 under the merger joint proposal, yes.
2 COMMISSIONER CURRY: Is the universe of
3 sites to be remediated static or has it changed since
4 the original calculation?
5 MR. LOCHNER: I really can't speak to that
6 myself. I am not expert on the engineering of that
7 number of sites.
8 COMMISSIONER CURRY: Bill, it might be
9 helpful after session if you could catch us up on that.
10 JUDGE BOUTEILLER: Okay, we will.
11 COMMISSIONER CURRY: Thank you.
12 MR. LOCHNER: So, now, we are now on slide
13 six.
14 So, we have these two regulatory assets, the
15 competitive transition charge that's being recovered
16 over 10 years, and the deferral recoveries. And the
17 rates in this proceeding that we are setting now will
18 provide for $573 million recovery of CTCs in 2011, which
19 will be completed at the end of the year 2011.
20 All those CTCs that we started back in --
21 way back in time, and which we started with 4.3 billion,
22 we removed a billion that the company ate, absorbed, 3.3
23 billion at the beginning of 2002 we have amortized in
24 rates and the customers have paid off with return the
24
1 full amount, will pay out the full amount by the end of
2 2011.
3 To be able to keep the rates, however, as we
4 are discussing, the rate increase, 114 million rate
5 increase reflected in delivery rates, not increased the
6 customers' bills. Recovery of the current level of
7 deferrals that are in rates will have to be suspended
8 for the period of 2011. As I mentioned before, there's
9 about $123 million that's being recovered in rates for
10 deferrals.
11 Of course, at the end of 2011, the amount in
12 rates, the $573 million of competitive transition charge
13 revenues, will be available since there will no longer
14 be a need to recover that IOU from customers. And but
15 that amount, that revenue stream, could be available to
16 provide for recovery of the estimated $205 million of
17 deferrals that the company, Niagara Mohawk, is
18 estimating will be in the balance at the end of 2011.
19 Now, let me point out, too, though, that the
20 -- all these deferral balances are company amounts
21 estimated, and staff will audit them completely. And
22 even in this rate case staff has disagreements with some
23 of the company's deferral balances.
24 So, I'm using per company estimated amounts,
25
1 but that is not the final word. We still have to audit
2 them.
3 Now, so as you can see, at the end of 2011
4 there's a potential for a large amount of revenues
5 available either to recover the remaining deferrals
6 and/or reduce rates.
7 COMMISSIONER LAROCCA: I realize from
8 yesterday I had a question. In the bottom bullet item
9 there on six, if in 2012 the company needs new revenues,
10 and it's the first year they are operating without the
11 CTC revenues, the way you've expressed this is that the
12 new revenue requirement can be met by the newly
13 available CTC revenues if we continued to collect them?
14 MR. LOCHNER: No. What I'm trying to say is
15 --
16 COMMISSIONER LAROCCA: You're missing an
17 offset. I want to understand the mechanism.
18 MR. LOCHNER: Basically, at the end of 2011,
19 approximately $573 million of revenue -- you could
20 actually reduce rates by $573 million, but for the fact
21 that you still owe the company an IOU approximately 205
22 million.
23 In effect, at the end of 2011 you could
24 reduce rates by the difference and recover in one year
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1 the remaining deferrals of 205 and then reduce rates
2 again by 205 million. Now, of course, that's supposing
3 the company doesn't file for rates in the interim.
4 COMMISSIONER LAROCCA: This is after the
5 treatment of the 573.
6 MR. LOCHNER: Right. In other words, the
7 573 basically, as you can see, a large piece of that
8 will fall off at the end of 2011. And I don't think the
9 company will be able to file a rate case and get it
10 completely through the 11 month suspension period by the
11 end of 2011 such that we would be able -- such that the
12 rate increase -- the rate reduction will happen
13 automatically at the end of 2011.
14 COMMISSIONER LAROCCA: The amount that falls
15 off, is it the full 573 that falls off?
16 MR. LOCHNER: When we get to the end of 2011
17 that's going to be something that I think the Commission
18 has to speak to because they will determine over what
19 time period those deferrals, the $205 million deferrals,
20 will be recovered.
21 If you decide to cover the full amount in
22 one year, of course you will only be able to reduce
23 rates by the difference between the 573 and 200.
24 JUDGE BOUTEILLER: Commissioner, the short
27
1 answer to your question is: The 573 does, in fact, fall
2 off. However, we have taken something out of rates
3 during 2011 that needs to get back into rates under a
4 schedule or amortization schedule that you will have to
5 determine upon.
6 There will be a filing anticipated before
7 this fall off occurs, and we will have approximately
8 five months to examine the company's proposal as to how
9 to manage that fall off. And you will have to take a
10 look at that and approve that compliance filing before
11 these events occur.
12 COMMISSIONER CURRY: One follow on question.
13 Does the last bullet point, 205 million in
14 deferrals, encompass the 114 that's not being passed
15 through 2011 or is that in addition to the 114?
16 MR. LOCHNER: When you say -- the 205, yes,
17 that includes the amount that's not being recovered. In
18 other words --
19 COMMISSIONER CURRY: Plus other matters.
20 JUDGE BOUTEILLER: It's the 114 plus other
21 things that are occurring during the course of 2011 that
22 have to be added to the 114.
23 MR. LOCHNER: Let's make this perfectly
24 clear: We believe -- the company has estimated at the
28
1 end of 2010 that the $164 million of regulatory assets,
2 IOUs we owe them. We are not going to give them a dime
3 in 2011 to recover any of that. The company believes
4 that in 2011 that deferral balance activity will
5 increase from 164 to 205.
6 At the end of 2011, there will be an IOU now
7 of 205 million that will owe the company. That's the
8 basic explanation of it.
9 So, at that point in time we can determine
10 -- the Commission can determine over what time period it
11 wants to provide recovery of that IOU the customer owes
12 the company.
13 COMMISSIONER CURRY: Thank you.
14 MR. LOCHNER: And the final segment on page
15 seven of the presentation just discusses the very large,
16 the significant drivers of this rate case. There are
17 really two main drivers of the rate case.
18 One is decreased O&M, which we estimate to
19 be about $97 million. It's important to remember,
20 though, that this increase in O&M that's driving the
21 need for increased rates has been moderated by the
22 merger savings that have occurred both for the original
23 2002 National Grid merger, but also the follow on
24 mergers in 2006 with Narragansett and the 2007 KeySpan
29
1 mergers.
2 In 2002, we didn't reflect the full amount
3 of the estimated merger savings in rates. The customer
4 only got immediately in rates in 2002 one half, 50
5 percent share. The other 50 percent share was allowed
6 to be kept by the company if they could earn them, if
7 they could achieve the savings during the time period.
8 That amounted to about $69 million. So, if
9 the company achieves those savings that has helped to
10 moderate the overall increase in O&M.
11 The other one, of course, is the other two
12 follow on mergers where there has been estimated
13 savings, and the customer obtains the full share of
14 those savings because the rates are now being reset at
15 the end of this rate plan.
16 Because they got out of the plan the last
17 year, we automatically pick up all the savings in the
18 new set of rates, and that's worth about $60 million of
19 savings between Narragansett and KeySpan. So, that
20 gives you a sense of the level of savings.
21 COMMISSIONER CURRY: Again, are these plug
22 numbers or are these estimates subject to truing up?
23 MR. LOCHNER: To a great extent you can
24 never measure these savings to the exacting degree. I
30
1 mean it's a differential of costs you incurred before
2 versus later. And it's impossible to trace it down to
3 every single dollar. It's not possible, no.
4 This is what was estimated and this is what
5 we believe has affected the overall level of costs.
6 JUDGE STEGEMOELLER: There is no true up on
7 these.
8 MR. LOCHNER: No, not at all. The point
9 really being is that, for example, we estimated level of
10 savings in the 2002 rate case. And we, of course,
11 immediately reduced the rates by one half of that
12 savings amount.
13 Now, if the company achieved more than that
14 they got to keep it. If they didn't achieve it, they
15 lost. So, it was on their risk to achieve those
16 savings. They had every incentive to do it during that
17 time period.
18 COMMISSIONER CURRY: Right.
19 MR. LOCHNER: Now, to continue, the other
20 very large major driver of the rate increase was
21 approximately $140 million for the return on a higher
22 rate base. This was basically caused by the fact that
23 there is $1.2 billion increase in net plant above what
24 was expected in rates or forecast in rates during the
31
1 merger joint proposal period for 2011.
2 As we all know, the company has been
3 required out of the KeySpan merger agreement to fund
4 $1.4 billion of additional plant and at this point the
5 balance they have included is $1.2 billion.
6 So, basically, the company has placed into
7 service a significant amount of plant greater than what
8 was reflected during the merger joint proposal in rates.
9 There was also a minor increase in earnings
10 based capitalization but it's not significant to
11 mention, worth mentioning.
12 Finally, there was one major offset to these
13 two cost drivers or cost increases, and that was the
14 lower rate of return. Just on a very macro basis, as
15 you can see in this proceeding we are suggesting or
16 considering providing the company an overall rate of
17 return on its rate base in delivery rates of 6.42
18 percent versus the 8.62 percent that was allowed under
19 the MJP revenue requirements during those years that it
20 operated.
21 What's the big drivers? The big drivers in
22 that lower rate of return are, at this point in time in
23 the MJP we are providing the company a return on equity
24 of 10.6 percent during the 10 years of the rate plan.
32
1 Here we are talking about a much lower
2 allowed return on equity of 9.1, in that range. That's
3 a major reduction in cost. Also, the cost of debt is
4 significantly lower currently than what was reflected --
5 what the company was experiencing in 2002, and also what
6 was estimated.
7 It was estimated that the cost of debt was
8 approximately seven percent back in 2002, during the
9 rate plan. Now we are talking about an actual cost of
10 debt of 4.1 percent. So, there has been a significant
11 reduction in the cost of debt for the company also. So,
12 that's another major element.
13 That basically concludes the presentation.
14 MR. ADDEPALLI: Good morning, Commissioners.
15 Is Commissioner Harris on the line?
16 COMMISSIONER HARRIS: Yes, I am. I thought
17 I would spare everyone, since I have the flu, both the
18 contact with me and the incessant coughing. So, I can
19 hear everything fine. Thank you.
20 MR. ADDEPALLI: I'm going to discuss some of
21 the stipulations that have been agreed to by the
22 parties. First, let me commend the parties for taking
23 the time and doing pretty good hard work on some of
24 these complicated and technical and difficult issues in
33
1 reaching the stipulations.
2 I am going to touch on three of the
3 stipulations -- the capital investment and O&M spending,
4 the revenue decoupling mechanisms, and some of the rate
5 design issues. And then Doug is going to discuss low
6 income and economic development stipulation.
7 The other stipulations, in my view, don't
8 need to be discussed at this time. Also, while there's
9 not a stipulation on the revenue allocations there is a
10 broad consensus among parties that was filed in the
11 briefs on exception and reply brief on exceptions. I
12 will discuss that as well.
13 Going to the first stipulation on the capex
14 capital expenditures. This, I will also tie this into
15 the management audit that the commissioners are familiar
16 with. The management audit identified on capital some
17 of the issues that the company needs to be looking at.
18 The parties have taken note of the findings
19 from the management audit, and have addressed them in
20 the context of the stipulation.
21 One of the things, as Joe mentioned just
22 before, National Grid has committed to KeySpan merger
23 case to spend about one and a half billion in capital
24 expenditures over a five year period that ends in March
34
1 2011. As of now, we expect the company to meet that
2 commitment on capital expenditures that they made.
3 Staff has been meeting with the company
4 periodically for the last several years, and we have
5 spent considerable time reviewing company plans, capital
6 expenditure plans, the planning processes, and we have
7 been providing input to the company even before it filed
8 its rate case in this rate case, as a result of the
9 stipulation for the rate year calendar 2011 on the level
10 of capital spending and projection also of what staff
11 and the company believed would be the future for the
12 following two years.
13 In addition, coming out of management audit,
14 and based on the findings there, there are new
15 performance metrics for cost estimation that the parties
16 agreed to in this case to address the findings from the
17 management audit.
18 The next slide, please.
19 COMMISSIONER CURRY: Raj, before you leave
20 that slide could you please take a minute and describe
21 to me how, in that last bullet point, how changing
22 metrics helps to solve that problem. And I guess there
23 is also some construction planning issues that may be
24 involved there as well, I don't know.
35
1 MR. ADDEPALLI: The management audit
2 findings are pretty broad, consistent or similar to what
3 you will find in the Con Ed audit. The management audit
4 asked the utility to take long range view of its
5 construction planning and programs and expenditures,
6 having a vision of where the company is going in the 10
7 to 20 year range, integrate the transmission and
8 distribution planning and capital spending programs more
9 closely, and optimize those programs, considering risk
10 metrics, and also identified more specific concerns of
11 how the company estimates the costs for the projects and
12 how it needs to improve on the cost estimation
13 procedures.
14 So, what the capital -- the stipulation
15 deals with is looking at all those collectively and
16 coming up with what makes sense not only just for the
17 rate year, while that's the one that is agreed to, also
18 looking forward how should the company progress on its
19 planning and spending for capital.
20 Staff's review included many elements,
21 Commissioner, not only planning criteria that the
22 utility uses. I think the examination has been pretty
23 thorough in this particular case.
24 In addition, staff also looks at the needs
36
1 for the various projects and programs that the company
2 has proposed, the timing of these projects and programs,
3 the adequacy of the justification provided by the
4 company. It also looked at historical performance of
5 the company.
6 So, taking into account all these factors
7 and, as I said, we have been meeting with them
8 periodically so we have a good handle on what is going
9 on.
10 So, based on this collective experience,
11 staff has come up -- proposed this rate year spending.
12 And that's what the basis is for the stipulation.
13 Does that answer your question?
14 COMMISSIONER CURRY: Stipulation in this
15 context means that there is agreement between staff and
16 NIMO as to how to approach these issues.
17 MR. ADDEPALLI: That's correct. Also there
18 is specific programs and projects in the spending levels
19 for calendar year 2011.
20 COMMISSIONER CURRY: Okay, good. Thank you.
21 MR. ADDEPALLI: The next slide actually does
22 show that. As Joe said, the company has committed in
23 the last merger case one and a half billion over the
24 next five years, and that's one of the reasons you would
37
1 see that line going up, reflecting the company's
2 commitment to meet the one and a half billion over five
3 years, which was higher than what was built into rates
4 before in the MJP.
5 Also, a point in the MJP, to the extent the
6 company has spent more money than what was built into
7 the rates they are not allowed carrying charges for a
8 number of years, so it was on them.
9 For the calendar year 2011, the stipulation
10 calls for spending of about $400 million. The major
11 drivers are the projects or programs to serve new loads,
12 to replace aging infrastructure, and to help -- programs
13 to help maintain reliability. This level is less, about
14 60 million less than what the company has projected in
15 its rate case filing.
16 Also, while it's not a binding estimate
17 going forward beyond the rate year, for the following
18 two years as well staff has reviewed the projects that
19 the company filed and gave its view of what the company
20 should be looking at. And that estimate is about $290
21 million less than what the company is projecting.
22 Unless there are some significant new
23 projects or programs that we are not aware of, we
24 believe that will be the path going forward at a much
38
1 lower level than what the company has projected.
2 So, this is a huge area of investigation
3 where staff has spent significant amount of time looking
4 at the company's projects and programs and assuring the
5 reasonableness of the spending.
6 As we have been doing in most of the
7 electric rate cases now, going forward, in the
8 stipulation there is a one way downward reconciliation.
9 What that simply means is, to the extent the utility
10 does not spend the amount allowed, the customers would
11 get the benefit of the carrying charges for the
12 underspending of the capital budgets. In addition, the
13 reporting requirements that the company has agreed to
14 before would continue.
15 The stipulation also includes metrics for
16 utility performance on reliability, the two standard
17 measures of the SAIFI and CAIDI, the interruption and
18 the duration measures. And there are negative revenue
19 adjustments of up to $6 million each for failure to meet
20 the metrics.
21 If you remember, for the period between 2004
22 and 2007, the company was not meeting the reliability
23 metrics. In the merger proposal, KeySpan merger, the
24 Commission has upped the ante and doubled the penalties
39
1 or negative revenue adjustments if they don't meet the
2 metrics.
3 Since then, in 2008 and 2009, the company
4 has met the reliability metrics, and in 2010, based on
5 the information we have, we believe they will meet the
6 metrics for 2010 as well.
7 A couple of other performance metrics beyond
8 reliability. As I said before, the cost estimation
9 function was identified in the management audit as weak,
10 and there's a performance metric on how well the company
11 performs going forward.
12 Separate and apart, there's increased
13 penetration of net metering, behind the meter
14 generation, particularly for renewables coming out of
15 the legislation and Commission policies. Based on the
16 concerns expressed by parties, there are two new metrics
17 that are being included in the stipulation to ensure
18 that the company does a good job on meeting the needs of
19 the applicants coming in for net metering. Those are $2
20 million apiece for two of those metrics.
21 So, collectively these are the reliability
22 and performance metrics that have been agreed to in the
23 stipulation.
24 The others, this is a separate stipulation
40
1 on revenue decoupling mechanism for the delivery
2 revenues. You are familiar with these RDMs. This is
3 probably the last utility we are putting an RDM in
4 place. All the other utilities already have an RDM.
5 Revenue by class. This mechanism is pretty
6 consistent with what you have seen in other utilities.
7 There will be several reconciliation groups for the RDM.
8 There are a couple of contested issues.
9 Although some parties signed this RDM, MI excepted a
10 couple of issues that Judge Rudy will be going over and
11 staff excepted to one element of the RDM.
12 The last stipulation on the next page. This
13 deals with some of the rate design issues. Mandatory
14 hourly pricing that the Commission has been promoting
15 for all large customers in the state. The threshold for
16 the MHP, there is an agreement to reduce it 250 kw.
17 This would be the lowest threshold in the
18 state among all the utilities, and lowering the
19 threshold to 250 kw would add over a thousand customers
20 to this group, and over 500 megawatts to the default
21 mandatory hourly pricing tariff.
22 What that means is the customers in this
23 group would be facing New York ISO hourly day ahead
24 market prices and the utility would not be providing any
41
1 hedges for reducing volatility going forward for this
2 group.
3 The second issue deals with flex rates.
4 There are about 65 or so flex rate contracts that are in
5 place from number of years. These flex rate contracts
6 have been agreed to from an economic development
7 perspective either to attract or retain customers. It
8 typically will provide a benefit to customers in some
9 form.
10 Once the flex rate contracts expire at the
11 end of 2011, and many will, and if they are not
12 continued into 2012, the stipulation calls for not
13 excluding the CTCs, competitive transition charges,
14 automatically. There is a disagreement from MI on this
15 issue.
16 However, depending on how we deal with the
17 CTCs, this issue may become moot. If the CDCs do expire
18 in 2011 as we propose here, this may become a moot
19 issue.
20 The final issues, the exit fees, this is
21 sort of unique to Niagara Mohawk coming out of its
22 history. It was designed to recover lost revenues due
23 to customers bypassing the company's delivery service
24 without physically relocating.
42
1 Exit fees are retained in this stipulation
2 by limited to recovery of CTCs. And again, if the CTCs
3 go away in 2011, this issue also may become moot.
4 Although MI has contested one element of this, they
5 would like the exit fees to be eliminated in 2011
6 itself.
7 The last few slides, while there is no
8 stipulation, there is broad consensus on a proposal that
9 I will discuss now. On this slide, first to give you a
10 perspective of the magnitude of the CTC relative to the
11 delivery revenues, what you see on this graph is the
12 service classes. SC-1 being residential class; SC-2
13 non-demand meters; SC-2 demand class; and SC-3 and
14 SC-3A, the large commercial industrial classes.
15 And if you notice on the first bar, SC-1,
16 the CTCs amount about $116 million whereas the delivery
17 revenues are $758 million. So, the CTCs are a smaller
18 piece of the total revenues being collected from this
19 service class group.
20 But if you go to the last bar, the other
21 extreme, SC-3, the very large C&I customers, the
22 delivery revenues are only 55 million but the CTCs are
23 over 73 million. So, the CTCs comprise a bigger amount
24 of the bill that they are paying more than the delivery
43
1 revenues itself.
2 This illustrates, the last two bars,
3 particularly SC-3 and SC-3A, why CTC is such a big issue
4 for the very large customers, C&I customers, and they
5 have been expecting that the CTCs would drop off at the
6 end of this plan. And those two red bars will not be
7 collected anymore from that customer group going
8 forward.
9 The next slide then shows what would happen
10 under the recommended decision based revenue allocation
11 versus what we are calling the modified proposal that
12 parties have filed in the briefs on exceptions and reply
13 briefs on exceptions.
14 Under the RD, if that were to be adopted,
15 there are some classes that would see a small decrease
16 in rates in 2011, the SC-1 and the SC-2 demand class;
17 and two large classes, SC-3 and 3A, would see an
18 increase. Under this, also, the CTCs under the RD
19 proposal would extend into 2012 for the SC-2 demand
20 class.
21 So, after the RD, the modified proposal that
22 the parties have come up with would reallocate a piece
23 of the CDCs in such a manner that no class would see a
24 rate increase in 2011.
44
1 So, the modified proposal next to the bars
2 shows a small blip there. It's zero, so no class would
3 see a rate increase as a result of this modified
4 proposal. In addition, it also accomplishes the goal of
5 eliminating CTCs by the end of 2011 for all service
6 classes.
7 So, the two key elements of the modified
8 proposal are no rate increase for any class, and
9 elimination of CTCs for end of 2011 for all classes, and
10 this has been supported by MI and NYPA as well in their
11 comments.
12 So, if we apply the modified proposal, then
13 what happens in 2012 and beyond? The next slide shows
14 an illustration of what might happen. Rate year 2011,
15 as I just said, the delivery increase for the modified
16 proposal, the second bucket of lines, are zero rate
17 increase. And going from 2011 to 2012, the CTCs would
18 drop off.
19 And this illustration assumes that all the
20 deferrals that Joe mentioned before, about 200 million,
21 would be fully amortized in 2012. If that's the case,
22 then the very large classes, SC-3 and 3A, to the right
23 you would see decreases in the range of 40 plus percent
24 in 2012. That's a meaningful and significant number, 40
45
1 plus percent reduction for the large classes.
2 For example, for a very large SC-3A customer
3 this would mean a reduction in dollar terms of over
4 $200,000 in electric delivery bills. So, for the very
5 large customers it's a meaningful, significant amount of
6 reduction in their delivery part of the bill in 2012.
7 All else equal.
8 If there is a rate filing in 2011 by the
9 company for new rates in 2012, then clearly the rate
10 impacts would be different than what you see here. But
11 then you get -- look at the $200 million deferrals as to
12 how to amortize them, whether to do it in one year or a
13 number of years. You have the option to do that now and
14 still ameliorate any potential rate impacts from future
15 rate case rate increases.
16 So, the modified proposal is what many of us
17 are recommending and are comfortable with to provide the
18 twin goals of not increasing the rates in 2011 for any
19 service class, and to allow expiration of CTCs for all
20 classes by the end of 2011.
21 That concludes my presentation. Doug Elfner
22 will discuss --
23 JUDGE STEGEMOELLER: Can I just -- just one
24 little -- can you go back to that last slide for a
46
1 second. We don't need the slide.
2 Just a footnote to that. It showed in 2012,
3 all other things being equal, a very small increase for
4 residential customers. But in the order where it
5 instructs the company to file a process for bringing
6 that surcharge into rates, it will specify that the
7 Commission intends to hold those rates flat during 2012.
8 So the Commission is instructing the company
9 that it intends to tweak the deferral recovery so that
10 that 1.7 becomes zero.
11 MR. ELFNER: Good morning, Chairman Brown
12 and Commissioners. I'm going to continue the discussion
13 of significant items that are before you that -- for
14 which there is no major disagreement or no disagreement
15 whatsoever.
16 Beginning with low income program. And
17 there is a substantial increase in the funding, as you
18 see, 3.7 million. Before I get into the components of
19 that, let me just review briefly the structure of the
20 company's low income program.
21 There's two main components. The first part
22 of the program is broad based discount program. The
23 gateway is participation in the HEAP program, Home
24 Energy Assistance Program, which is -- the
47
1 qualifications for that are family income. Family
2 income constraints, a family of household size one, for
3 example, has an income limitation of about $25,000.
4 Family size four is about $48,000 a year.
5 The program provides a $5 discount now for
6 all low income customers. That is, all customers who
7 receive a HEAP benefit. The proposal here is to
8 increase the funding or the discount for heating
9 customers up to $15 a month.
10 That's very consistent with what you have
11 done in the last series of rate cases where we have
12 expanded funding for heating uses, recognizing that it's
13 for the heating use where the customer has a larger bill
14 to begin with and for the obvious public health and
15 safety issues concerned with heating.
16 The second part of the program is a more
17 targeted program called an affordability program. There
18 is less than 4,000 participants in this. This is for
19 the most vulnerable low income customers.
20 In particular, it's customers who not only
21 qualify for the general low income program, but who have
22 failed to comply with the minimum deferred payment
23 agreement. That is, broken a commitment to pay the
24 current bill plus $10 a month in order to run down their
48
1 arrears.
2 This program accepts such customers.
3 There's a few other eligibility criteria, but such
4 customers are then provided a credit against their
5 arrears for each month in which they pay their bill in
6 full and on time.
7 So, it's designed to encourage complete and
8 timely payment practices. It's been in place for quite
9 a few years. It's been working very well. In the last
10 gas rate case it was increased the arrears forgiveness
11 credit from $20 to $30 a month for gas payment
12 customers, and the recommendation here is that you do
13 the same for electric heating customers.
14 Other components of the low income proposal
15 are to waive the reconnection fee for low income
16 customers whose service was disconnected for non-payment
17 and to hire an additional consumer advocate. Consumer
18 advocates, the company has about -- has nine of these
19 employees right now. This would be the tenth.
20 And I am sure Sandra Sloane and people in
21 the call center will echo this, that we have found these
22 employees to be extremely valuable in assisting the most
23 vulnerable customers on a one on one basis. It's really
24 to assist customers with special needs, either in
49
1 identifying all sorts of assistance that's available to
2 them, or helping them understand their rights, and so
3 on.
4 So, again, this is a very important part of
5 the low income stipulation. The stipulation, again, is
6 supported by staff, the company, and CPB, and there is
7 no opposition by any parties.
8 The next stipulation is economic
9 development. This is supported by staff, the company
10 and Multiple Intervenors.
11 The funding would be 9.1 million in the rate
12 year. Last year you approved funding of $9 million for
13 Grid's economic development program, so it's right in
14 line with that. Provides a lot of flexibility. If the
15 company underspends, obviously, the dollars are returned
16 to the benefit of customers or held for the benefit of
17 customers.
18 If the company overspends or seeks to
19 overspend, there's an explicit recognition that they can
20 come to you to ask for such authority. And as Raj
21 alluded to earlier, there was some questions or some
22 concerns by some parties, particularly Multiple
23 Intervenors, regarding the large number of flex rate
24 tariffs that will be expiring in the coming year.
50
1 And there's some concern that some of those
2 tariff provisions may be viewed by some as overly
3 burdensome. So, a key part of this stipulation is a
4 collaborative proceeding among the parties in order to
5 address those kind of issues. Collaborative will begin
6 very shortly, within 30 days of the beginning of the
7 rate year, and end in six months, at which time you will
8 have a report and recommendations about how to proceed.
9 So, again, this stipulation deals with
10 funding and essentially process. I want to distinguish
11 this just to help you out. There will be an item on the
12 next session, expected to be on the next session, that
13 deals with the company's economic development plan for
14 2011.
15 Under the current rate plan, they create
16 such a program working with staff and present it to your
17 approval annually. The report that we are contemplating
18 here at the end, the final bullet on the stipulation,
19 would be for the following year. Or if the parties have
20 a consensus that they want you to act sooner, so be it.
21 So, again, this covers funding and
22 procedures. It doesn't deal with programs specifically.
23 Will come to you separately.
24 COMMISSIONER LAROCCA: Doug, I have a
51
1 question. Can the history of this concept we call
2 economic development, this vocabulary is relatively
3 recent in time, and before we spoke about economic
4 development all the regulated utilities in New York had
5 good old fashioned marketing and salesmanship and any
6 number of activities that were related to building a
7 bigger base of customers, similar to what you would find
8 in almost any business.
9 And I am curious to know how we are defining
10 "economic development" and what's embraced in this 9.1
11 million, and to distinguish that from the conventional
12 historic activities that these companies would engage
13 in.
14 MR. ELFNER: I will start and then I am
15 going to quickly turn to Michael Corso for -- and maybe
16 others -- for a little bit more of the history, but I
17 can tell you a little bit about what's baked into the
18 9.1, what's contemplated in the 9.1, and what the
19 company has been doing in recent years.
20 Three of the main components of the way this
21 9.1 and grant programs for economic development is
22 spent. One is capital investment programs. The best
23 example was one last year where there was a facility
24 that had been vacant since 2003 that was being
52
1 refurbished and used as manufacturing facilities for,
2 among other things, batteries for electric vehicles.
3 So, the company provides funding through
4 this ratepayer source to offset the costs of improving
5 the energy infrastructure associated with that project.
6 Another example is when small customers --
7 COMMISSIONER LAROCCA: Then the form it
8 takes is a grant to a developer, an entrepreneur, a
9 company?
10 MR. ELFNER: To the industrial customer,
11 that's right.
12 COMMISSIONER LAROCCA: It is a grant.
13 MR. ELFNER: Yes, that's my understanding.
14 MR. CORSO: That's correct.
15 MR. ELFNER: Another example. For smaller
16 customers, smaller customers who want to expand their
17 facilities and create their electric service from a
18 single phase to a three phase power, Grid has incentive
19 program for those companies as well.
20 There's also a program to provide incentives
21 to a company or matching grant to companies who --
22 manufacturing companies who enhance their productivity
23 in some means.
24 So, it's a variety of grant programs.
53
1 Again, you will see those specific proposals for
2 calendar year 2001 next session, and six months after
3 the rate year you will see another proposal for how to
4 spend this 9.1 million in the following year.
5 COMMISSIONER LAROCCA: What's the
6 justification for, if I understand it, a hundred percent
7 of the 9.1 million being chargeable to ratepayers as
8 opposed to shareholders? Because theoretically
9 ratepayers will benefit, perhaps indirectly, by these
10 economic development activities, but so will
11 shareholders if these companies become better customers.
12 MR. ELFNER: Well, it's a use and more
13 effective use of the company's fixed costs and the
14 infrastructure that exists. And therefore, it benefits
15 ratepayers as a whole, general body of ratepayers, not
16 only in the sense that they expand the economy and may
17 lead to more customers later, but in and of themselves
18 they are making -- having the utility's distribution
19 infrastructure be used more effectively.
20 MR. CORSO: I would add to that,
21 Commissioner, as well, that the company does some
22 activity on its own through shareholder contribution
23 that is not reflected in rates.
24 But more specifically to the question about
54
1 the ratepayer funding, it utilizes fixed assets that the
2 company has or does not generate any revenue or in some
3 cases some revenue, and the activity that they bring
4 into the service territory benefits the ratepayer, of
5 course and the company, but directly the ratepayer
6 because they are having an increased load and sharing
7 the fixed costs of those expenses across a larger base
8 rate of customers.
9 CHAIRMAN BROWN: Raj, does the revenue
10 decoupling kind of take away a lot of the incentive that
11 would have -- to Commissioner Larocca's point -- that
12 would have normally really helped the shareholders, but
13 with revenue decoupling does that disconnect that to
14 some degree?
15 MR. ADDEPALLI: Revenue decoupling, to the
16 extent sales vary from the forecast for whatever reason,
17 the company is made whole. However, I think the company
18 has a larger interest in attracting new customers or
19 keeping existing customers for the vitality of the
20 region.
21 COMMISSIONER LAROCCA: Respectfully,
22 everything everybody has answered could as well be said
23 as in the interest of shareholders as well as in the
24 interest of ratepayers, but the accounting is entirely
55
1 on the ratepayer side, if I understand it.
2 CHAIRMAN BROWN: I think Michael said there
3 are some shareholder programs as well.
4 MR. CORSO: There are. I can do a little
5 work between now and next week for you, Commissioner,
6 just find a little bit more about how that works, but we
7 are, of course, paying attention to the ratepayer funded
8 programs.
9 COMMISSIONER LAROCCA: I would like to see
10 that. Thank you.
11 MR. ELFNER: The next slide deals with
12 customer service quality. This was not explicitly a
13 stipulation. In fact, there was some vigorous
14 litigation regarding this at the beginning of the case,
15 and at the end there is no disagreement.
16 The first element is that we are reducing,
17 that is focusing, the performance measures from six to
18 four. We have got the core measures, what the
19 department considers as the core measures of customer
20 service quality, which is the complaint rate and
21 customer satisfaction surveys. We have got surveys from
22 both residential and consumer -- and commercial and
23 industrial.
24 CHAIRMAN BROWN: Doug, I'm curious. What
56
1 two got eliminated?
2 MR. ELFNER: Percent of meters read on time.
3 Again, with the move to AMR and so on that's just less
4 important. And also, previously we had provided the
5 company an incentive to enroll customers into their low
6 income affordability program that I talked about before.
7 So, for both of those the company has
8 already clearly demonstrated that it's willing and able
9 to meet our targets and meet the standards and we don't
10 believe an incentive is --
11 CHAIRMAN BROWN: Seems like a good core.
12 MR. ELFNER: Right.
13 Now, the call answer response also is
14 something we want to keep a close eye on. The targets
15 -- and this is where some of the dispute was originally
16 in the litigation phase -- was on tightening the
17 customer complaint target. That's a substantial
18 tightening. Historically they have been performing even
19 better than the 1.5.
20 And the second change here is to update the
21 form of the customer satisfaction survey. Previously,
22 the form had been through mail, and now it will be done
23 by telephone. There's just a lot of benefits of
24 telephone. It's much quicker response.
57
1 The company can pursue, after they answer
2 the questions and form the basis for our survey, they
3 can then pursue the issue a little bit further depending
4 on the customer's response to learn more, really, about
5 how to improve their operations.
6 To give you a little background on the
7 company's performance on service quality in recent
8 years, we've had some difficulty in '06, '07, and '08 on
9 the residential customer satisfaction survey. '06, they
10 also had difficulty on the commercial and industrial
11 satisfaction survey, meaning that they did not meet the
12 expected results and incurred a negative revenue
13 adjustment.
14 2009 and 2010 they have met all the
15 standards on all the measures for which we have
16 financial consequences. Nevertheless, the financial
17 consequences overall have not been adjusted since 2002.
18 And what we seek to do here is provide a
19 somewhat standard across utilities impact on -- in terms
20 of basis points on equity, to provide a kind of standard
21 incentive to provide customer service, good customer
22 service.
23 So, in order to achieve the financial
24 consequences in the range of what the Commission has
58
1 adopted for other utilities, we are increasing the
2 maximum here up to 15.2 million. So, again, no
3 disagreement on this currently.
4 All the three programs I described, really
5 very consistent with what the Commission has done in the
6 recent series of rate increases, low income, economic
7 development and customer service.
8 COMMISSIONER ACAMPORA: Doug, just a
9 question. You had said the surveys are done by phone.
10 Is anybody doing surveys or gathering information with
11 smart phones and computers on putting something on the
12 bill if we would like to contact you through e-mail or
13 something like that? Is anyone moving in that direction
14 that you are aware of?
15 MR. ELFNER: There is a lot of thought to
16 that. I am not aware that utilities have adopted that
17 yet.
18 COMMISSIONER ACAMPORA: So many other
19 companies are communicating with customers via e-mail.
20 MR. ELFNER: Again, there's a lot of
21 increased awareness of that. Now, the e-mail
22 communications in certain circumstances, storms and so
23 on, we know some utilities who are embracing that, but
24 for general communications, again, there is movement
59
1 toward. It's not been widely used yet.
2 CHAIRMAN BROWN: Before we continue, why
3 don't we take a five minute break here. Begin again at
4 noon.
5 (Recess taken.)
6 CHAIRMAN BROWN: Why don't we get started.
7 JUDGE STEGEMOELLER: Welcome back. As I
8 said, there are a number of issues here and these are
9 the issues that survived the stipulation process and had
10 to be litigated.
11 What I will do is I will just give you a
12 very high flyover through these issues, and just jump in
13 if you have questions or comments or you would like more
14 detail on any of them. Again, I am going to move
15 through them very quickly, and essentially stick with
16 the results.
17 COMMISSIONER LAROCCA: We are not working
18 with the handout now, right?
19 JUDGE STEGEMOELLER: No. You can probably
20 -- this will follow pretty closely with the draft order
21 or the table of comments for the draft order.
22 Beginning with service companies, this
23 occupied a huge amount of time and attention, but it's
24 largely been removed from the case thanks to the audit
60
1 proceeding. What remains for us is the issue of what to
2 do pending the results of the audit.
3 We recommend $50 million in temporary rates.
4 This has not been opposed by staff or the company.
5 Intervenors are still arguing for immediate adjustment,
6 but since all rates are being held to zero, there's not
7 much gain from that approach.
8 So, the recommendation is to stay with $50
9 million. It would either be temporary rates or an
10 adjustment clause. That's a sort of technical detail
11 that we are still working out.
12 Revenue decoupling mechanism, that has
13 mostly been stipulated, as you have heard, except for
14 two issues that have been raised by MI. First, they
15 would like large customers to be exempt from the RDM.
16 The order provides that no customer classes will be
17 exempt.
18 COMMISSIONER LAROCCA: Rudy, can I back you
19 up a second? Just go back to the 50 million connected
20 to the audit. Exactly how does that work?
21 JUDGE STEGEMOELLER: You mean the actual
22 mechanism? We are -- that's under discussion right now.
23 There are two approaches. The temporary rate approach
24 is to simply declare that 50 million of the revenue
61
1 requirement that the company is getting is temporary,
2 pending further Commission action to certify the results
3 of the audit.
4 CHAIRMAN BROWN: Rudy, does that mean that
5 monies should be collected from customers but be subject
6 to refund, in simple terms?
7 JUDGE STEGEMOELLER: Correct, subject to
8 refund. Whether it's temporary rate or an adjustment
9 clause, essentially it's subject to refund. The
10 difference is how it would -- how it might be refunded
11 and what the Commission's options might be in the
12 refunding process.
13 COMMISSIONER LAROCCA: The premise coming
14 out of the audit that it would justify the return of
15 this money in some form to customers is what?
16 JUDGE STEGEMOELLER: Is that -- well, there
17 are a variety of things the audit is looking at, but for
18 example, if expenses were not allocated properly to
19 Niagara Mohawk, as compared -- as opposed to other
20 affiliates, that Niagara Mohawk was overcharged.
21 Or if it's found that some of the historic
22 test year costs were exaggerated because they should
23 have been normalized out. The range of issues that the
24 audit is looking at, that will come back to the
62
1 Commission. The Commission will make findings.
2 JUDGE BOUTEILLER: One of the categories of
3 costs which were excluded during the course of this case
4 were what were called the expatriates, which is really a
5 term, an ill stated term.
6 But for the officers and employees who come
7 from Great Britain and serve into the operations in
8 Massachusetts or in New York, that category of costs was
9 quantified and the total amount of that was excluded
10 from the rates here. So, these rates don't include any
11 allocations there. However, we can't anticipate the
12 results of the service company audit, and the number
13 that's there is reserved to cover whatever results may
14 come out of there.
15 So, from that sense, there is no opportunity
16 for the newly set rates to have included in them any
17 amounts that would have been more properly allocated to
18 other companies using different allocation factors or
19 looking at the amounts incurred. If those amounts are
20 not recoverable in rates, they, too, can be eliminated
21 from the existing rates we are setting here. And that's
22 the intent and the purpose of the process.
23 COMMISSIONER LAROCCA: So, it's a reserve
24 based on an assumption that everything -- if there is
63
1 nothing untoward coming out of the audit, then these --
2 or this number would be justified. But it's reserved
3 because if there is any element that we learned out of
4 the audit that questions or negates the justification on
5 any number of subjects, then customers would be entitled
6 to a credit or some recovery of that number.
7 JUDGE STEGEMOELLER: Right. I don't believe
8 the company actually holds a reserve fund but I could be
9 wrong about that.
10 MR. LOCHNER: They don't record a reserve
11 fund. They collect the revenues and record the revenues
12 and this is just subject to refund if, after the
13 investigation, we find that the revenues were -- the
14 rates were overstated because of unreasonable costs,
15 basically.
16 COMMISSIONER LAROCCA: If we weren't doing
17 it this way, if we were going ahead and withholding the
18 50 million now, and there was no justification in the
19 audits for withholding that money over time, then we
20 would conversely look to ratepayers for a jump to
21 capture that money.
22 MR. MCGOWAN: Correct.
23 COMMISSIONER LAROCCA: With interest,
24 perhaps.
64
1 So, finally, how do we get to 50 million?
2 Why that number?
3 JUDGE STEGEMOELLER: It's roughly twice the
4 amount that staff had recommended as a macro adjustment
5 which, by staff's admission, was not a real firm number.
6 It's a balance between, you know, you
7 estimate what's the reasonable outside likelihood of
8 what you might find in the way of an adjustment versus
9 the impact on the company's cost of capital by creating
10 that much increased risk.
11 So, it's a balancing number.
12 MR. LOCHNER: Just to give you an idea, an
13 indication, the total service company charges in the
14 revenue requirement for 2011 are about $350 million.
15 So, that gives you an idea of the comparison of the 50
16 million to 350, what's the percentage of the total bill
17 that we want to hold, retain, more or less through the
18 temporary rates process, while we examine the legitimacy
19 of the costs.
20 COMMISSIONER LAROCCA: So, even though it's
21 not specifically segregated or reserved by the company,
22 it would be understood that this is subject to recall.
23 MR. LOCHNER: Yes.
24 JUDGE STEGEMOELLER: Basically, as a legal
65
1 matter, we are placing a finger -- placing a thumb on
2 the $50 million of what the company is getting in this
3 proceeding.
4 COMMISSIONER LAROCCA: The only thing I
5 would like to see between now and next week then is some
6 breaking out of that 50 million, to show us how you got
7 there. Because thinking back to some of the audit
8 issues and the dimensions on the -- just on some of the
9 matters that came up, I would have thought the number
10 would have been bigger, but that could just be my feeble
11 memory. So, I would like to just see how we got to 50.
12 JUDGE STEGEMOELLER: Okay. We were on
13 revenue decoupling mechanism.
14 MI questioned whether there should be only
15 one reconciliation group for large customers. I believe
16 they asked for four. The order will provide for two
17 reconciliation groups for large customers, class 3 and
18 -- the 3 classes and the 3A classes.
19 So, now we will turn to imputed savings.
20 And this is a bucket that includes merger synergies,
21 business initiatives, productivity and austerity.
22 The KeySpan merger savings, the company
23 committed to $200 million in efficiencies when the
24 merger was approved. That doesn't all go to Niagara
66
1 Mohawk. That's allocated out.
2 Staff argued that the company's actual
3 internal target is $247 million, and savings should be
4 calculated from the actual target. The order adopts
5 staff's position.
6 Narragansett merger savings is a $4 million
7 issue with RD is reversed. The order excepts the
8 company's showing that the savings were all realized in
9 the historic test year.
10 There are three business initiatives savings
11 totalling $17 million. The company argues that $8
12 million of the savings are a double count with KeySpan
13 savings. And the company argues the other $9 million
14 should be counted as general productivity.
15 The RD agreed with staff that the entire $17
16 million should be imputed as savings, but the RD invited
17 the company to clarify its position with respect to the
18 $8 million KeySpan overlap.
19 The company did that and the order reverses
20 the RD on the $8 million. It finds that those savings
21 were included in the savings that were imputing to the
22 KeySpan merger. So, we can't impute them twice.
23 That leads to the productivity discussion.
24 The company included the standard one percent
67
1 productivity adjustment, which in this case is about $6
2 million. The Company argued that that was sufficient,
3 that we should not further count the business
4 initiatives.
5 Staff agreed with the one percent, but added
6 the business initiative savings. MI argued that there
7 should be a three percent adjustment, and thus cited the
8 increased capital spending and management audit as
9 sources of efficiencies.
10 The order would agree with the RD that in
11 this situation a one percent adjustment, plus the
12 business initiative savings, reflects the right balance.
13 The last of the imputed savings is
14 austerity. Staff proposed a $7.6 million adjustment,
15 which was derived from the Commission's actions with Con
16 Ed and Central Hudson. Intervenors urged a larger
17 adjustment. The RD, which considered all the other
18 imputed savings, reduced staff's number to $5 million.
19 The order, because it reduces the
20 Narragansett and the -- and one of the business
21 initiatives, reduces the imputed savings by $12 million.
22 The order adopts staff's austerity number of 7.6
23 million. That's a 2.6 million increase in the austerity
24 adjustment from where the RD was.
68
1 The next issue is variable pay, which was --
2 it's a very difficult issue so I'm not even going to
3 try. I am going to refer to Bill.
4 JUDGE BOUTEILLER: There has been a
5 discussion with the advisory staff, and we have been
6 analyzing the past Commission determinations in this
7 case.
8 And the salient point which comes out, which
9 is something that's impressed upon me by the advisory
10 staff, was not well impressed upon me by the trial staff
11 or the parties in the case, is that the Commission
12 really went through the theoretical underpinnings for
13 your variable pay adjustment in the 2009 Consolidated
14 Edison case, and stated there that it's who benefits
15 from the incentives that will control the determination
16 with respect to whether or not we include in rates or
17 exclude from rates the variable pay component.
18 There is an assumption about cost savings
19 associated with the variable pay, but if the benefits
20 from the incentives enure to ratepayers, by having
21 either service quality or service reliability indices
22 related to the variable pay, then it becomes a candidate
23 for inclusion in rates.
24 On the other hand, if the criteria is
69
1 improved financials of the company, which enures
2 directly to the shareholders, then that is a strong
3 candidate for exclusion in rates. And that's been
4 bolstered by the notion that the efficiencies in cost
5 reductions enure to the shareholders and improves their
6 earnings. There's no need for including that variable
7 pay in rates.
8 That's my gained understanding on the issue
9 after reading the briefs and dealing with the advocacy
10 of the parties. With that understanding, I form a basis
11 of being more aligned with the advisory staff, and we
12 don't necessarily need to cut this issue down variable
13 pay for management versus variable pay for union
14 employees, which is the cut that I made.
15 The controlling rationale in 2009 is the
16 superior analysis, and it avails and applies to both
17 contexts. Even with respect to union employees, if the
18 incentives that are being paid is to benefit ratepayers
19 then we might include in rates. If the incentives are
20 being paid as to benefit shareholders it's still
21 excludable.
22 So, that would be the refinement on the
23 analysis made by the RD. That would be the analysis
24 included in the write up. And that means we are leaning
70
1 towards treating as a whole all the incentive
2 compensation, and we are not talking about breaking it
3 into two components.
4 CHAIRMAN BROWN: Makes sense.
5 JUDGE STEGEMOELLER: Moving on.
6 Labor and fringe benefit capitalization
7 rates. These are two separate $3 million adjustments
8 where the order reverses the RD. The RD used updated
9 numbers but did not reflect the change in the relevant
10 amounts of labor and capital.
11 JUDGE BOUTEILLER: This is another one being
12 reversed, and I'm agreeing to the reversal. I took a
13 hard look at the methodologies that were employed, and I
14 focused in on the difference between the historic test
15 period information and the substitution of intervening
16 fringe -- fiscal year.
17 And staff gained an adjustment by going to
18 the intervening fiscal year. And we do a lot of updates
19 in the case, and there's a lot of discretion provided to
20 the parties for updating clauses, so I didn't see this
21 to be objectionable on its face.
22 So, this was an instance, rare instance
23 where staff proposes the update and I went with the
24 staff. Joe Lochner then assisted me in further
71
1 analyzing what's going on with the changes to the
2 recovery of capital items, the changes in recovery with
3 the labor costs, and he's pointed me to a further
4 assessment of these items, which indicate that we are
5 far better off sticking with the historical test period
6 because we are introducing some anomalies here.
7 I didn't find creditable too much the
8 company's claim that we are tracking and double counting
9 synergy savings, but the treatment being provided to the
10 capital items is not reflected comparable to the
11 treatment going on on the labor side.
12 And Joe high lighted that for me. I see
13 that as a significant point for purposes of the proposed
14 adjustment here. So, this is another well reasoned
15 purpose or reason why the judge should lose and the
16 advisory staff should win.
17 CHAIRMAN BROWN: Let's not look at it as
18 wins and losses.
19 JUDGE STEGEMOELLER: Storm expense.
20 COMMISSIONER CURRY: Rudy, can I stop you
21 for a second.
22 JUDGE STEGEMOELLER: Certainly.
23 COMMISSIONER CURRY: In the table of
24 contents, the KeySpan Service Company pension and OPEBs.
72
1 JUDGE BOUTEILLER: That was a --
2 COMMISSIONER CURRY: Can I just ask a
3 threshold question, Bill?
4 I thought that the KeySpan operations didn't
5 relate to the electrical world, and I am not quite
6 certain how, therefore, any KeySpan service company
7 concerns spill over.
8 Now, so, could you just inform me. I
9 understand what you concluded in your RD. I just don't
10 understand why KeySpan is in the mix at all.
11 JUDGE BOUTEILLER: I'm going to shift to
12 Joe.
13 MR. LOCHNER: Actually, there are four
14 service companies in the National Grid system, and the
15 KeySpan service company is allocating, and is projected
16 to allocate charges to Niagara Mohawk electric in this
17 rate case, and so that's why that --
18 COMMISSIONER CURRY: The question, Joe, is
19 why. Why would a company dealing with gas be allocating
20 to an electric company?
21 MR. LOCHNER: Well, remember, the company is
22 -- KeySpan service company is not the same as KeySpan
23 distribution company. And the KeySpan system did have
24 electric generation. So, they provide management and
73
1 administrative services together with the National Grid
2 service company, the other large --
3 COMMISSIONER CURRY: We require them to sell
4 the generation as a condition for the acquisition of the
5 gas service -- the gas provision companies, and they
6 made a fairly healthy profit on the disposition of
7 Ravenswood.
8 So, I'm just, I'm still a little bit
9 confused as to why the talent that would be resonant in
10 that service company would have any impact on NIMO.
11 MR. LOCHNER: It's not a significant impact.
12 $350 million in the rate year, it's a small portion of
13 that. As I remember, I think it's like 25 million of it
14 of allocated charges.
15 The KeySpan service company provides, for
16 example, accounting services, various other services.
17 It provides human resource services. National Grid has
18 determined this was the best configuration of providing
19 services to its affiliates.
20 Now, of course, these charges are going to
21 be examined in the service company audit in exactly
22 whether they were necessary, reasonable and properly
23 allocated. So, in fact, with this item, in fact, the
24 KeySpan service company pension costs are the amounts
74
1 being recorded to the deferrals.
2 And at this point the staff does not
3 recommend any adjustment because those costs will be
4 examined in the service company audit. If we find them
5 to be unreasonable, we will make the adjustment.
6 COMMISSIONER CURRY: Okay, thank you.
7 JUDGE STEGEMOELLER: All right.
8 Storm expense. The item in dispute was
9 whether to retain the $2 million per storm deductible,
10 which was discussed earlier. It reflects the fact that
11 storm repairs tend to offset ordinary maintenance and
12 the deductible will be retained in the order.
13 Storm reserve, the company proposed creating
14 a $30 million reserve fund. This is not adopted.
15 Instead, we will use reserve accounting, which is a form
16 of deferral accounting.
17 Please don't ask me the difference between
18 reserve accounting and deferral accounting. I am sure
19 somebody here could explain it.
20 CHAIRMAN BROWN: Could you just explain why
21 we have different policies, if it's true, if we have
22 different policies, for example, NYSEG?
23 MR. LOCHNER: Actually, I believe NYSEG,
24 RG&E and Consolidated Edison do provide some reserve
75
1 accounting. So, we are consistent in that mode.
2 Basically, reserve accounting simply is, if
3 you want it to be a simple way, is two sided deferral
4 accounting. We establish an amount that we allow in
5 rates and we require the company to defer amounts above
6 or below that.
7 In other words, if they incur greater storm
8 costs during the year, then we allow in rates for that
9 particular year. If they defer, recover from ratepayers
10 in the future. If they incur a less amount of storm
11 costs in the year, they defer that as a liability owed
12 to ratepayers in the future. So, it basically is a true
13 up mechanism.
14 JUDGE BOUTEILLER: And the intent here is to
15 conform Niagara Mohawk to the more general practice as
16 you have been employing with other companies. They have
17 been out for eight years.
18 CHAIRMAN BROWN: This actually brings them
19 back in alignment.
20 JUDGE BOUTEILLER: That is correct.
21 CHAIRMAN BROWN: Thank you.
22 JUDGE STEGEMOELLER: Allocation of
23 uncollectible write-offs is an $11 million issue. The
24 question is which set of data to use in allocating the
76
1 write-offs between gas and electric.
2 The order agrees with staff that the more
3 recent data should be used, even though the older data
4 were used in the last gas case.
5 Property taxes. The order adopts a 1.6
6 percent escalation factor. The RD recommended that true
7 up process but that will not be adopted.
8 Most of the rate base issues have been
9 stipulated but there are a few that were litigated.
10 Working capital. The order finds that the
11 merchant function charge should contain a working
12 capital component and the lead lag study may be used.
13 Depreciation, which is a large item,
14 involves staff adjustments of $25 million in net salvage
15 and $10 million in service lives. Question is really a
16 question of methodology in each case. The order would
17 support staff's methodology as reasonable.
18 Pace and NRDC raised two issues in the case.
19 The first is the Jamestown transmission tie. There is a
20 constraint that would prevent Jamestown right now from
21 retiring its 50 megawatt coal plant. Pace and NRDC
22 asked that the company be required to remove the
23 constraint.
24 The order would adopt the company's proposal
77
1 for a study. And obviously the order finds that it's
2 too early to mandate any particular action, but there is
3 a timetable for a study.
4 The second proposal of Pace and NRDC
5 involves non-wireless alternatives. That is, energy
6 efficiency, demand response, distributed generation.
7 The proposal is that non-wireless alternatives should be
8 fully considered before major T&D projects are
9 undertaken.
10 The order includes a process where the
11 company, consulting with Pace and NRDC, will develop a
12 pilot proposal and that will come to staff and then we
13 will have more process on that.
14 Smart grid. This was a late action by the
15 company asking for $1.5 million to be added to revenues.
16 It's an expense that has already been approved, but the
17 request came too late for staff to examine it or audit
18 it. So, staff argues that the expense should be
19 deferred. I don't believe that at this point that there
20 is a consensus recommendation on this issue.
21 JUDGE BOUTEILLER: It might be a hill of
22 beans issue, but the symbolism associated with it is
23 getting us very polarized arguments. Should you audit
24 the numbers before they are allowed, and given the
78
1 deferral mechanism that you have in place, and also
2 given the overall what's happened in this case as well,
3 where we are holding the rate increase down to zero and
4 we are pushing off for another year amounts that need to
5 be amortized over time. And these kinds of costs would
6 fall into that kind of category.
7 On the other hand, the Commission supports
8 these kinds of projects. Other companies are involved
9 in some of these projects as well, and sending a correct
10 signal for the continuing support that the Commission
11 has for these projects is something that I don't want to
12 get lost in the presentation.
13 CHAIRMAN BROWN: If I understand the
14 history, I want to make sure that we are not sending
15 mixed signals to companies. I believe this was a
16 project that the NYISO proposed that are allocating
17 costs to the capacitor bank project that won the federal
18 stimulus money. So, there was the matching money that
19 came from the feds and then each of the utilities had to
20 contribute their portion of the share.
21 And I believe this one and a half is Grid's
22 portion of the share. We strongly encourage the
23 utilities to go out there and try to get those matching
24 grants that they were aggressive in going after.
79
1 Michael Corso, I think we had $800 million
2 of -- he's shaking his head yes. $800 million of grant
3 applications. So, now that they won, I just want to be
4 sure -- a million and a half, you are right, Bill, it's
5 not anything that's going to make or break. I want us
6 to think about the consistency of our message in terms
7 of go get it, go get it, go get it. They get it and
8 say, yeah, pay you later. I just want to make sure we
9 are all comfortable with that.
10 MR. CORSO: Just a quick comment to the
11 Chairman. We will follow up on that in this week period
12 to just find out the nature of those dollars and what
13 the impact is and get a clear answer to the Commission.
14 CHAIRMAN BROWN: I know perhaps we need to
15 also be consistent between service territory, because I
16 think we may have ruled on a couple of other instances
17 already in recent rate cases where other utilities had
18 the same expense. So, kind of working against each
19 other to some degree to be consistent.
20 MR. ADDEPALLI: Chairman, you are right.
21 The two big projects, dollars of the PMUs, phasor
22 measurement units and capacitor bank, the concern came
23 up filing was made too late in December and the
24 offsetting benefits are not necessarily completely
80
1 accounted for.
2 CHAIRMAN BROWN: Another issue.
3 COMMISSIONER HARRIS: The one and a half
4 million dollars that National Grid is requesting smart
5 grid for the capacitor bank, my recollection is that
6 there was more than one project that National Grid had
7 received for the federal stimulus money, and I think
8 this is only one of the projects.
9 Do you know what the status is of the other
10 project that was awarded to National Grid, and whether
11 or not they are seeking recovery for that project as
12 well?
13 MR. CORSO: Commissioner Harris, my
14 recollection is they did get another award, but after
15 they agreed to participate they backed away from it
16 because of costs. They didn't find that project, which
17 was jointly being done with a California entity, I
18 believe it was SMUD, and I think they backed away from
19 that project.
20 I will follow up to be sure about that, but
21 I think the money that we are talking about now is just
22 the two that the Chairman addressed and Raj confirmed,
23 the PMUs, the phasor measurement units, which are large
24 meters on the transmission system, as well as the cap
81
1 bank.
2 COMMISSIONER HARRIS: When we ruled a few
3 months ago we issued an order allowing recovery for Con
4 Edison's project, smart grid project. My understanding
5 was that we instructed National Grid that they had to
6 get a deferral for the other project.
7 So, again, I guess just along the lines of
8 being consistent, if we are going to allow for recovery
9 for one project in one territory, but deferral in
10 another territory for another project, I just want to
11 make sure that we include all of those projects when we
12 review it.
13 MS. STOUT: The company is going to be
14 allowed deferral regardless. The question is whether to
15 include the one and a half million now, before we know
16 what the offsetting benefits of the projects were, or to
17 do that analysis and then include what the correct
18 number is, whether it's one and a half million or one
19 million or whatever it is, and subject to deferral and
20 adjustment.
21 The problem is the information came in so
22 late that it couldn't be audited and that the offsetting
23 benefits fully addressed.
24 CHAIRMAN BROWN: I'm going to take this as I
82
1 think there's some curiosity what's happened in the
2 past, since this is coming to us late, in the next week
3 if you can just do a little background for us on how we
4 dealt with it elsewhere, what are the issues related to
5 doing it now as opposed to deferring it, so that we all
6 have a little more analysis.
7 I know it's not staff's fault because this
8 got to us late, or whether it was just so late that we
9 should say --
10 JUDGE STEGEMOELLER: Just from a process
11 standpoint, not faulting the company, but it's tough to
12 manage a rate case when you have new proposals coming in
13 after the briefs on exceptions have been filed.
14 JUDGE BOUTEILLER: The fact that this was
15 coming in, which the company is aware of the actions
16 they are taking, leads me to conclude that there might
17 be some noise or some confusion off our record behind
18 the scenes.
19 We should use this as an opportunity to
20 clarify that noise factor, whatever it might be, by
21 addressing the issue here. I think Michael Corso has
22 volunteered to try to get to some of that smoke and see
23 if it's meaningful or irrelevant to our actions here.
24 CHAIRMAN BROWN: Commissioner Harris, we
83
1 will try to test your consistency question and get some
2 answers.
3 COMMISSIONER HARRIS: Okay. Thank you.
4 JUDGE STEGEMOELLER: Revenue allocation was
5 a highly contentious issue, but I think it has been
6 resolved to everybody's satisfaction, as Raj outlined.
7 I would just note that you will have this
8 filing coming to you in 2011. At least five months
9 before the end of the year the company will file its
10 mechanism for CTCs to drop out, and for the deferral
11 recoveries to be added in as a surcharge. The schedule
12 for amortizing those deferral recoveries will be an open
13 issue that you will deal with at that time.
14 Cost of capital. I will --
15 CHAIRMAN BROWN: Before you leave that.
16 JUDGE STEGEMOELLER: Sure.
17 CHAIRMAN BROWN: At this point the
18 recommendation -- the CTCs will be paid off at the end
19 of 2011.
20 JUDGE STEGEMOELLER: Yes.
21 CHAIRMAN BROWN: Nobody at this point is
22 suggesting any stretching beyond 2011.
23 JUDGE STEGEMOELLER: Right.
24 CHAIRMAN BROWN: So, what's coming back to
84
1 us in seven months?
2 JUDGE STEGEMOELLER: A filing, which is
3 largely mechanical, to establish the mechanism for CTCs
4 to fall out of the rates. Right now they are in the
5 rates, so rates have indefinite duration until we change
6 them. So, the Commission will have to take action.
7 CHAIRMAN BROWN: By approving the rates they
8 are in effect until another rate case comes along and
9 changes the rate.
10 JUDGE STEGEMOELLER: Exactly.
11 CHAIRMAN BROWN: So, on January 1, 2012,
12 suddenly they are going to have $750 million less to
13 collect that we already authorized them to collect. And
14 so what we are doing is saying you got to come back in
15 the middle this year and tell us how we are going to
16 reduce the 750.
17 JUDGE BOUTEILLER: The company has got the
18 sets of tariffs out there, and we need to confirm that
19 tariffs and tariff languages and all the mechanisms, so
20 they conform with the current circumstances. So, that's
21 housekeeping sort of matters that need to be taken care
22 of.
23 JUDGE STEGEMOELLER: As the CTCs come out,
24 those deferral recoveries that we are postponing in
85
1 order to get rates down to zero this year, those
2 deferral recoveries go in as a surcharge.
3 CHAIRMAN BROWN: They go in. This comes
4 out. Sort that all out.
5 JUDGE STEGEMOELLER: Right. That will be a
6 little bit more than just ministerial because the
7 schedule for that will be --
8 CHAIRMAN BROWN: So, we're not opening up a
9 rate case. We are just going to figure out all those
10 adjustments and it's going to part of this order that
11 says you got to do that.
12 JUDGE STEGEMOELLER: Correct.
13 Cost of capital, I am just very briefly just
14 going to run through the numbers and I suspect you might
15 want to have some discussion.
16 Capital structure, the company proposed a 50
17 percent equity ratio. The RD agreed with that. Staff
18 argued that 46 percent would be sufficient. And the
19 draft order adopts a 48 percent equity ratio.
20 On short term debt, the order adopts staff's
21 method of referencing the rates at the time of decision
22 as opposed to a projection.
23 CHAIRMAN BROWN: Of course we are talking
24 about the draft order when you talk about this.
86
1 JUDGE STEGEMOELLER: Precisely.
2 Return on equity, the company's proposal was
3 10.85 percent. Staff and CPB argued for 9 percent. The
4 RD recommended 9.3 percent. And the draft order states
5 9.1 percent.
6 COMMISSIONER ACAMPORA: So, could we get
7 into some of the particulars of the differential between
8 a 9.1 and a 9.3, and the view of the street on the ROE,
9 and why New York is different again, because we have to
10 go through this every time we do a rate case.
11 MS. STOUT: Sure.
12 COMMISSIONER ACAMPORA: For our friends out
13 there at the rating agencies who I hope are listening
14 in.
15 MS. STOUT: Right. The RD recognized the
16 value of our continued and consistent allocation of the
17 Commission's well established precedent for setting ROE.
18 The Commission's approach over, say, the
19 past 15 years has been to apply a very detailed ROE
20 methodology which looks at the results of a DCF and a
21 CAPM methodology, discounted cash flow and capital asset
22 pricing models, that are applied to a proxy group of
23 utility companies. And then those results are weighted
24 two thirds toward the DCF and one third towards the
87
1 CAPM.
2 That result, because it's for a proxy group
3 of utilities that don't necessarily match the risk of
4 the utility that we are examining here in New York
5 State, is then adjusted for what we call the credit
6 quality adjustment.
7 That's a surrogate for the risk differential
8 that we see in these companies. We turn to bond ratings
9 for that surrogate because that's the best available
10 information that we have.
11 While the RD recognized the appropriateness
12 of applying this methodology, they ultimately concluded,
13 let's look at the Con Ed decision that the Commission
14 just made in September, which is for the gas and steam
15 operations. And the Commission decided there to set the
16 ROE at 9.6 percent.
17 Now, that was for a multi-year settlement.
18 So, I somewhat caution the methodology that the judges
19 used because they simply took that 9.6 percent that the
20 Commission decided in September, and then subtracted off
21 what they perceived as the stayout premium that was
22 associated with that multi-year settlement. They
23 subtracted off 30 basis points to get to 9.3 percent.
24 The reason I caution that type of approach
88
1 is because in settlements there's give and take. And so
2 we don't know if that stayout premium was exactly 30
3 basis points or if it was 40 basis points. I believe at
4 the September session I described it as 40 basis. So,
5 that would actually bring it to 9.2, not 9.3.
6 But the other potential issue is that, while
7 the judges said our methodology that we have used all
8 these years is good, that they didn't fully apply it to
9 reflect current market conditions.
10 So, if you go forward and you apply it to
11 reflect current market conditions, you would be in
12 essence following the staff approach in this case, which
13 is the 9 percent that staff testified to. And then
14 staff actually updated that number in briefs to 8.7
15 percent.
16 So, in this case, I am recommending that we
17 not update the method all the way to that 8.7 percent
18 because of a recent decline in interest rates that's
19 reflected in that update. Interest rates have actually
20 rebounded to about the same level where staff had
21 testified. So, I don't recommend that we do that
22 update.
23 In addition, as part of staff's methodology,
24 they had reduced the return on equity by 8 and a half
89
1 basis points for the RDM -- implementation of the RDM,
2 and that adjustment we find is not necessary at this
3 time given the number of companies in the proxy group
4 that already have the RDM, and the fact that for Niagara
5 Mohawk we already implemented it in gas and it's in the
6 sauce, so to speak, of the bond ratings of Niagara
7 Mohawk.
8 CHAIRMAN BROWN: Doris, I got a couple
9 follow ups on that. I think one of them Patty was
10 referring to was the uniqueness of some of the New York
11 utilities in terms of risk factor and forecast year,
12 etc. I want to get to that. I think that was the
13 question she was asking.
14 That you can't compare our 9.1 versus
15 another state's 10.2 if they have got all sorts of
16 commodity risk that they use at historic year, forecast
17 year. So, I want to get to that, but I also want to
18 follow up on what you just said.
19 You mentioned Con Ed at 9.6. I think we
20 recently did NYSEG 10 percent.
21 MS. STOUT: Correct. NYSEG and RG&E were
22 established at that same September session. Their ROE
23 was also based on this traditional method of using the
24 DCF and the CAPM and adjusting for credit quality and
90
1 also adjusting for the stayout premium for their
2 multi-year deals.
3 A little timing difference there in their
4 base number. And also, they also included an incentive
5 for -- incentive kind of premium in their ROE for the
6 amount of cost reductions that they had engaged in. So,
7 there was 20 basis points more in NYSEG and five basis
8 points more in RG&E's number for that as part of their
9 settlement agreement.
10 CHAIRMAN BROWN: Because this is a contested
11 litigated rate case it's essentially a one year. They
12 have got every right to come in -- the company's got
13 every right to come in tomorrow or the day after we
14 decide and move forward.
15 JUDGE BOUTEILLER: That's correct, Chairman.
16 There is no prohibition, there's no possibility of
17 precluding the company from making their next rate
18 filing at their own earliest convenience.
19 CHAIRMAN BROWN: So, there's kind of no
20 stayout bonus that made up some of the differential
21 between NYSEG with three and a half years, or somewhere
22 in that range, and Con Ed was a two year?
23 MS. STOUT: Con Ed was three years.
24 CHAIRMAN BROWN: Three year deal.
91
1 Do we have any indication, do we know -- I
2 know it's conjecture -- whether the company is planning
3 to come back very quickly after this decision?
4 MS. STOUT: It's uncertain when the company
5 would file. I mean, as Judge Bouteiller indicated, they
6 could file any day. I believe that they may not file
7 immediately because of the ongoing audit of the
8 affiliate transactions.
9 If we were able to get their commitment to
10 stayout for all of 2011, and not file until January 1,
11 2012, that would be similar to a two year agreed upon
12 deal. That kind of stayout premium you would be talking
13 about for a two year deal, rule of thumb has been to
14 look at the five year average of the spread between one
15 and two year treasuries to kind of establish that and
16 then take half of that.
17 That result right now is very low. It's
18 only 16 basis points, which half of it is eight basis
19 points. If I look at more current spreads, between one
20 and two years, we are talking about 30 basis points.
21 So, you know, stayout premium of between 10
22 and 30 basis points might be appropriate if the company
23 were to commit to not file for rates until January 1,
24 2012.
92
1 CHAIRMAN BROWN: Taking half of that,
2 coincidentally, we get to move from 9.1 to 9.3, which
3 was the RD number.
4 MS. STOUT: Correct.
5 CHAIRMAN BROWN: From a staff perspective,
6 without that stayout that, in your mind, is a little bit
7 high for at least what our formula says.
8 MS. STOUT: Correct.
9 Do you want me to address your other
10 questions about the street's view of 9.1? I mean,
11 certainly, if Wall Street were to myopically view the
12 9.1 percent, I think they would be disappointed, but the
13 fact is there is a lot of good things in this rate case
14 for investors and bond holders, a lot of protections for
15 the company.
16 The rate case is providing $114 million or
17 some more in revenue requirement than the company might
18 have otherwise attained if it had not filed this case.
19 That revenue requirement reflects the additional
20 investment that the company has made in plant over the
21 past nine years.
22 So, by reflecting those costs and the higher
23 O&M costs that Joe Lochner described, this rate plan
24 would allow the company to earn closer to its allowed
93
1 return. And we feel we are providing them that
2 opportunity here.
3 The company earned less than five percent in
4 2009 on earnings, so investors would be seeing a return
5 brought up to nine percent here.
6 The other key factor here is including that
7 RDM mechanism. That reduces earnings volatility
8 significantly, whether it comes from energy efficiency
9 or if it comes through the bad economy that is currently
10 faced by New York State in the upstate region.
11 There is also other risk reducing mechanisms
12 being put into place here. We have that storm reserve
13 accounting to protect against major expenses in the
14 storm area, and we have continued reconciliation
15 mechanisms that are beneficial to investors to ensure
16 that earnings are achieved on this company.
17 So, there is a lot of good things in this
18 plan for investors from both the equity side and also
19 from the bond side. I think that Niagara Mohawk has a
20 very low cost of debt, 4.1 percent embedded cost of
21 debt. I don't think any other utility is that low. And
22 I think, with the revenue requirement we are setting
23 here, there should be very easily coverage levels over
24 five times interest coverage levels.
94
1 So, I think it's a very healthy proposal for
2 a company that has such low interest costs.
3 CHAIRMAN BROWN: I am concerned about the
4 perception. So, I think we will be following this 9.1
5 -- I am not sure if any other commissioners want to
6 comment on this at this point, but if there is a way
7 that we could possibly ascertain the company's intention
8 about coming back.
9 I mean this is generally a very good news
10 case. We are going to be able to freeze rates. We are
11 going to be able to have a significant reduction in
12 rates in 2012. Boy, if that could be sustainable for a
13 couple years, then I think we want to send the signal to
14 the company that that is a good thing.
15 I think, you know, you kind of suggested a
16 way of getting there, and maybe if we can figure out a
17 way in the next week of following up on that to find out
18 their intentions it might be worthwhile.
19 COMMISSIONER ACAMPORA: Can I just ask what
20 the downside would be if the company immediately filed
21 after a decision next week? Would there be a downside?
22 JUDGE BOUTEILLER: A downside to whom, the
23 company?
24 COMMISSIONER ACAMPORA: Yes.
95
1 CHAIRMAN BROWN: Or the ratepayers.
2 COMMISSIONER ACAMPORA: And the ratepayers.
3 JUDGE BOUTEILLER: For the ratepayers, they
4 would be exposed to whatever amounts they asked for if
5 it survived the rate case. Looking at the degree of
6 litigation in this case, you've seen the matters that
7 would get settled out, and you've seen the kinds of
8 matters that would come back to you.
9 So, the downside to the company would be is
10 could they sustain the effort necessary to be able to
11 capture dollars in categories which were recently
12 reviewed by you and found to lack the support to make
13 the -- could they support depreciation adjustment based
14 upon consideration here. Could they support higher
15 amounts or anything?
16 They need to meet that, and those are major
17 hurdles for them. So, they can't just slap together a
18 rate case filing to get the clock running. They have to
19 consider the quality of the filing.
20 And litigation in this case was quite
21 arduous. You know, it was very good that we settled as
22 many things as we did. What remained for litigation was
23 very difficultly fought out through this case. We had
24 large briefs, a large amount of time. It took two
96
1 judges to do this.
2 So, the company would have to make an
3 assessment for themselves of how successful they could
4 be with that case. Also, during this time period
5 there's still the outstanding service company studies
6 which need to have resolution. If they triggered
7 another rate case, they would be retriggering
8 consideration of all those matters in the case again.
9 So, those are some of the risks to the
10 company were there to be more litigation.
11 COMMISSIONER ACAMPORA: Thank you.
12 CHAIRMAN BROWN: Any other comments on this
13 issue before we move on?
14 Commissioner Curry.
15 COMMISSIONER CURRY: Doris, when you are
16 addressing the issue of credit quality, to what extent
17 does National Grid's parentage affect the low cost of
18 debt they currently enjoy?
19 I have asked point blank both Moody's and
20 Standard and Poor's whether they take parent company
21 wellbeing into account, and I have gotten non-answers
22 that only the Chinese in a diplomatic exchange could
23 duplicate, so, I appreciate your views as to how you see
24 this affecting things.
97
1 MS. STOUT: Niagara Mohawk raises its own
2 debt, long term debt, and they also participate in the
3 National Grid money pool. On the long term debt side of
4 the equation, they are receiving interest rates that are
5 reflective of their A minus, A3 bond ratings.
6 The actual written reports from Moody's and
7 Standard and Poor's heavily reflect the influences of
8 National Grid on their bond rating determinations. I
9 have a quote here. Standard & Poor's actually starts
10 its analysis and says, the ratings on Niagara Mohawk are
11 based on the consolidated credit profile of its ultimate
12 parent. That's the very first sentence in their
13 analysis.
14 Then, when they talk about the outlook for
15 the company, they focus that outlook on the National
16 Grid consolidated metrics.
17 On the Moody's side of the equation, they
18 specifically note in their analysis that the Niagara
19 Mohawk credit rating is capped at the overall credit
20 quality of the National Grid group, which they currently
21 assess as a low A. So, that's like the highest they
22 could go. When they talk about the outlook being stable
23 in the bond rating, they say that -- they focus again on
24 National Grid, the credit quality of National Grid group
98
1 as a whole, and the deterioration of the consolidated
2 credit quality of National Grid group.
3 Even if, unrelated to Niagara Mohawk, which
4 results in the consolidated credit profile being viewed
5 as below A, it would be likely to negatively Niagara
6 Mohawk's ratings.
7 COMMISSIONER CURRY: Did you say or did
8 someone say earlier that Niagara Mohawk could actually
9 borrow at a more advantageous rate than the parent, or
10 did I misunderstand that?
11 MS. STOUT: Currently, Niagara Mohawk raises
12 its long term debt from the market directly, and its
13 bond ratings differ slightly from the National Grid
14 group.
15 Niagara Mohawk's ratings are A minus, A3;
16 and the Grid PLC ratings are BBB+, Baa1; and Grid USA
17 are BBB+, A3. So, in theory, yes, Niagara Mohawk should
18 be able to raise debt by itself at a lower rate than
19 going through the parent. When they borrow from the
20 money pool they pay a low commercial paper rate, I
21 believe.
22 COMMISSIONER CURRY: Thank you.
23 CHAIRMAN BROWN: Any other comments or
24 questions on this?
99
1 Judge, shall we continue?
2 JUDGE STEGEMOELLER: We genuinely are in the
3 home stretch now. Just a few more items.
4 Deferral accounting, a change in federal tax
5 law increased the company's cash flow by $29 million.
6 And the issue was applicability and the interpretation
7 of the merger joint proposal. The order finds that this
8 benefit should be credited to ratepayers.
9 MR. LOCHNER: Correct you on that. It
10 wasn't a change in the federal law. In this case, they
11 prepared a deduction, the IRS prepared a deduction. The
12 company elected internally to change its federal income
13 tax accounting as applied to the IRS. There wasn't a
14 change in the law that allowed that additional
15 deduction. That's important because...
16 JUDGE STEGEMOELLER: Thank you.
17 Merchant function charge. This was all
18 covered by stipulation except for two issues. First,
19 the company proposes a true up of the purchase of
20 receivables discount rate. The ESCOs opposed this on
21 grounds that it would increase volatility for them. The
22 RD agreed with the ESCOs.
23 The order reverses the RD. So, the company
24 will perform monthly recalculations and annual true ups
100
1 of that discount rate.
2 Second issue on merchant function charge
3 involves dual billing on consolidated bills. The ESCOs
4 want to have this choice on a per customer basis. Other
5 parties were opposed. The order would not require the
6 company to offer this option.
7 Finally, site investigation and remediation.
8 Staff advocated an 80/20 sharing mechanism. The order
9 would not adopt that change.
10 And that completes the summary of the
11 litigated issues.
12 CHAIRMAN BROWN: Thank you. You know, I
13 think with the time period, the reason we do two of
14 these, what the judge just described was what the draft
15 order is currently recommending for us to consider as a
16 Commission.
17 All these contested issues, I think what we
18 get is eight days to ask a lot of questions, and to
19 think through some of these contested issues, and
20 whether we agree with the recommendations that we just
21 heard, or whether we believe other parties' points --
22 further consideration in the matter.
23 So, the next time, unless we hear from any
24 commissioners, in my mind, I'm not sure we need to do
101
1 this all again issue by issue. I would rather focus on
2 the places that -- where we still would like more
3 discussion.
4 And I think there is a few that have already
5 been high lighted today. And if there are others that
6 you didn't say anything today but still have questions
7 on, tell Bill or Doris or whoever that you would like
8 further discussion on that next time around, so we can
9 continue that. Otherwise, I am going to take complete
10 silence as we don't need to go over that again.
11 COMMISSIONER LAROCCA: Mr. Chairman, to
12 break the silence for a moment, can we just back up
13 again just for a minute to the last item, the 80/20
14 mechanism, because of my recent preoccupation with this
15 issue. Just explain why, just take us back through
16 again the evolution of how you got there and why.
17 JUDGE BOUTEILLER: The recommendation, we
18 have a very aggressive staff here on many of the issues,
19 and so some of it is their gut reaction to where they
20 think action should be taken. And I don't disagree with
21 that necessarily. But on the site investigation and
22 remediation, the practice there has been fairly uniform
23 and consistent by the Commission throughout all the
24 cases.
102
1 This is the first instance where I'm seeing
2 the staff proposing a 20/80 sharing mechanism. And I'm
3 being somewhat conservative here. I am looking at the
4 information staff provided in support of the proposal,
5 and the proposal really asks a lot in terms of the
6 ratemaking here.
7 We have costs that are moving from one
8 period to the other. There is a lot of flexibility in
9 the periods of these costs. I know to some degree that
10 the site investigation and remediation are matters that
11 are not entirely within the company's control. Here I
12 think they try and work with the DEC and with the EPA in
13 a cooperative mode.
14 So, that can lead to variances in cost
15 estimates and timing differences in the occurrence of
16 costs. So, all that, seems to me as a ratemaker, is
17 difficult to apply 80/20 sharing mechanism just as a
18 general principal, as a rule of thumb. I would look to
19 staff to either have a more refined mechanism or
20 stronger support for the implementation of this
21 mechanism right here.
22 So, I'm more or less saying that until I see
23 a little bit more, I'm inclined to stay with the
24 Commission's standard approach which doesn't involve
103
1 incentive mechanism, sharing mechanism like this. It
2 could be very unwieldy in its application, and that's
3 why I am fearing.
4 COMMISSIONER LAROCCA: Bill, just to make
5 sure our record reflects what we are talking about, the
6 80/20, who is who in that --
7 JUDGE BOUTEILLER: Company would get 80
8 percent of the cost overrun and receive recovery of it.
9 It would not receive 20 percent of any costs that vary
10 from the amount included in the estimate as a reason or
11 an incentive for it to try to stick very closely to the
12 estimates that they provide for ratemaking purposes.
13 COMMISSIONER LAROCCA: Let's be clear.
14 There is a base number established in some earlier
15 process in time that represents the cost of this
16 activity. In the base number, 100 percent of the cost
17 is on ratepayers.
18 JUDGE BOUTEILLER: There is an amount built
19 into rates which ratepayers will be paying on a
20 recurring basis. We apply deferral accounting here to
21 true up the differences between the rate allowance and
22 the amounts the company actually incurs. That's another
23 general practice we apply here.
24 On top of that, staff was proposing this
104
1 incentive mechanism.
2 COMMISSIONER LAROCCA: So, the only place in
3 this scenario where a portion, in this case 20 percent,
4 would not go to ratepayers, but would go to the company,
5 would be in any excess over a previously established
6 number. And in the previously established number, the
7 formula is 100 percent on ratepayers.
8 JUDGE BOUTEILLER: Yes. Given the nature of
9 these kinds of projects and the history of it, I could
10 regale you in that.
11 COMMISSIONER LAROCCA: Just clarifying not
12 the rationale, just the outcome.
13 JUDGE BOUTEILLER: That's right.
14 COMMISSIONER LAROCCA: The outcome is the
15 general underlying policy measured over the cost of this
16 history has been a hundred percent on ratepayers with a
17 mechanism for dealing with any excess over prior
18 established number. Proposal was to go to a sharing
19 mechanism on the overage, and the order would reject
20 that.
21 JUDGE BOUTEILLER: You have got it perfectly
22 understood.
23 COMMISSIONER LAROCCA: I just want to
24 register my continuing concern about this, and the
105
1 examination that I am trying to provoke where we would
2 look at these cost sharing arrangements on a statewide
3 basis and a policy basis.
4 Because one of the factors in my mind is the
5 growth in this -- the number of projects, and the cost
6 of these remediations is to the point where they are
7 beginning to have significant rate impacts on
8 ratepayers. I am just airing that concern at this
9 point.
10 JUDGE BOUTEILLER: Decision as taking a
11 position contrary to your examination on a statewide
12 basis or on a generic basis, the position in the RD is
13 only dealing with the quality of the proposal as made by
14 the trial staff here. So, it doesn't really address
15 your broader perspective at all.
16 COMMISSIONER LAROCCA: It is choosing not to
17 embrace a cost sharing mechanism at this time.
18 CHAIRMAN BROWN: I'm just going to say there
19 is three options I think we can move forward with. One
20 would be if you impose the sharing mechanism here I
21 think we are setting some precedent for others in the
22 future.
23 Two, we could stick with where we have been.
24 Or three, on a more generic basis, we could
106
1 take a look at this issue, which I think is probably not
2 best solved on a case by case basis because it's much
3 broader than any one utility.
4 I don't want to start, and we get in trouble
5 when we do something in one utility, then we get to the
6 next utility and we decide the issue in a different
7 direction, which unfortunately we do once in awhile.
8 MR. DVORSKY: The Commission had done it
9 once before. It was Coney Island site, where the exact
10 type of -- my understanding, the exact type of incentive
11 mechanism was put in place. So we have done it.
12 CHAIRMAN BROWN: We have done it once, but
13 on a particular site. This sounds like a little more
14 generic here.
15 MR. DVORSKY: If you do it statewide.
16 COMMISSIONER LAROCCA: Mr. Chairman, I see
17 inconsistency in two ways. One is, as between electric
18 and gas, because arguably these facilities served in
19 combination of companies, both constituencies, and we do
20 have some variance from one place to the next on what
21 the sharing is between the two forms.
22 And then, two, the second question with
23 regard -- without regard to however the first is met,
24 which is that sharing between ratepayers and the
107
1 company. So it's two sets, two bundles of questions,
2 but we don't have -- perhaps to your point about not
3 doing this on a case by case basis, one of the outcomes
4 of having had some case by case history is that we do
5 have some inconsistency throughout the state.
6 COMMISSIONER CURRY: I guess I have one
7 additional observation, Mr. Chairman, and that is:
8 Whenever you don't have someone with skin in the game
9 for overruns, it becomes harder to rationalize after the
10 fact the expenditures made. If a good faith effort has
11 been made to guesstimate the cost of a given site
12 remediation situation, and there are overruns,
13 disciplining those overruns has to be somebody, and it
14 doesn't appear to be DEC, doesn't appear to be us.
15 So, what was suggested initially, and
16 perhaps as you suggest it might be best to consider it
17 across the board in this state, there has to be some
18 incentive for the supervising entity, the utility, to
19 contain the costs.
20 CHAIRMAN BROWN: There is certainly a good
21 argument for sharing. I just want to make sure that we
22 go into it with our eyes wide open and recognizing the
23 potential precedent we will be setting. So, this will
24 remain on the list of unresolved issues for next week
108
1 and then suggest some options at that point.
2 JUDGE STEGEMOELLER: Before we --
3 COMMISSIONER LAROCCA: Mr. Chairman. I was
4 just saying thank you.
5 JUDGE STEGEMOELLER: Before we finish, Doris
6 just suggested that, to the extent that there may be
7 some conversations with the company about maybe agreeing
8 to stay out for a year, it makes sense to just run down
9 the list of where the draft order is departing from the
10 RD, so that it's very clear where they stand as of -- at
11 least as of today.
12 So, we have got just -- this is just review
13 really. Narragansett reverses the RD, which is $4
14 million. The electric distribution transformation
15 savings, that's $8 million.
16 CHAIRMAN BROWN: When you use these numbers
17 they can go either direction, Rudy.
18 JUDGE STEGEMOELLER: As I said, Narragansett
19 reverses, so that adds $4 million to rates. The EDOT
20 savings, that adds $8 million. The labor capitalization
21 rate and fringe benefit capitalization rate combined,
22 that adds $6 million.
23 Major storm expense allowance, $5 million
24 are added. Return on equity, tentatively -- the number
109
1 I have here is at 9.1 percent it reduces rates by
2 approximately $7 million. And that setting the equity
3 ratio at 48 percent reduces by $9 million. And then you
4 have the increase in the austerity adjustment to 7.6
5 would reduce rates by $2.6 million.
6 Variable pay, we come out with -- we are
7 reducing rates by $7 million, okay. And then smart grid
8 is the $1.5 million that we don't have a decision on at
9 this point.
10 JUDGE BOUTEILLER: There's a couple of
11 updates. Did you qualify the updates?
12 MR. MCGOWAN: What about business
13 initiatives?
14 JUDGE STEGEMOELLER: Covered that. That's
15 the EDOT.
16 JUDGE BOUTEILLER: The update for inflation,
17 update for interest rate, do you have those numbers?
18 MR. LOCHNER: 700,000 is the update for
19 inflation. $700,000 for -- let me just make sure I got
20 the exact numbers here.
21 CHAIRMAN BROWN: Just while you are looking
22 up, what we are doing here is if somebody had done an
23 analysis of the RD's recommendation and added them all
24 up, and came up with a number, you are now describing
110
1 what the variances to the RD would be, both plus and
2 minus, based on discussions and recommendations that
3 were made here today.
4 MR. LOCHNER: Correct.
5 MR. MCGOWAN: In the draft order.
6 MR. LOCHNER: Just the forecast of fuel
7 costs and transportation, we are adding another $700,000
8 for the increased cost of fuel. And with inflation we
9 are adding another $200,000 to update the current
10 inflation rate.
11 CHAIRMAN BROWN: Might as well do the math.
12 I mean, are we at a net plus or a net minus when you
13 added up all those pluses and minuses?
14 I won't make you. We won't do this now.
15 MR. LOCHNER: Our view is at 111 and we are
16 now at about 109, so about $2 million.
17 CHAIRMAN BROWN: Is that at 9.1?
18 MS. STOUT: Correct.
19 CHAIRMAN BROWN: What would 9.3 bring you
20 to?
21 MR. LOCHNER: $6 million, approximately $7
22 million.
23 CHAIRMAN BROWN: So, then we would go the
24 other direction.
111
1 MR. LOCHNER: Right. Then we go up. 116.
2 CHAIRMAN BROWN: I think I got the math in
3 my head.
4 Okay. Is there anything else that we need
5 to do? Any other questions? Comments?
6 JUDGE BOUTEILLER: Just for purposes of
7 preparing you for the next session, we will take this
8 draft, with whatever inputs we receive. The items that
9 you see with bolded language, that's the language that
10 we tried to focus you on for this session.
11 What we will try to do for the next version
12 of this draft is we will try to unbold as much of that
13 language and just build it into the body. Where we
14 think it definitely doesn't warrant discussion and
15 further consideration we will do that.
16 With respect to any decisional language that
17 is new or still hangs in the balance based on the
18 conversation today, I am going to try to use a blue
19 font. So that way your eye might focus quickly to the
20 language in the various categories where you have not
21 read it before. We are asking you to take a close look
22 at that because we are trying to anticipate an ultimate
23 decision, which even we don't know until you meet next
24 week and you decide the case.
112
1 CHAIRMAN BROWN: Can we all agree on blue?
2 Good. We got consensus on that one. Thank you.
3 Madam Secretary, is there anything else to
4 come before us today?
5 SECRETARY BRILLING: Nothing further today.
6 Thank you.
7 We will next meet next week on Thursday, the
8 20th of January, here in Albany beginning at 10:30 a.m.
9 for the regularly scheduled January session.
10 CHAIRMAN BROWN: Thank you. The meeting is
11 adjourned.
12 (Meeting adjourned at 1:16 p.m.)
13
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17
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20
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1
$ 1 2000-2001 [1] - 22:24 3.6 [2] - 12:13, 13:16 8 2001 [4] - 14:11, 3.7 [1] - 46:18 14:14, 14:16, 53:2 30 [9] - 12:7, 22:19, $10 [2] - 47:24, 76:15 1 [4] - 13:16, 84:11, 2002 [11] - 14:21, 17:3, 22:21, 50:6, 87:23, 8 [6] - 66:11, 66:18, $100 [2] - 16:11, 16:15 91:10, 91:23 22:18, 23:23, 28:23, 88:2, 91:20, 91:22 66:20, 88:24, $11 [1] - 75:23 1.2 [2] - 30:23, 31:5 29:2, 29:4, 30:10, 301 [1] - 4:2 108:15, 108:20 $110 [1] - 8:22 1.4 [1] - 31:4 32:5, 32:8, 57:17 350 [1] - 64:16 8.62 [1] - 31:18 $114 [1] - 92:16 1.5 [4] - 15:9, 56:19, 2003 [1] - 51:24 390 [1] - 8:18 8.7 [2] - 88:14, 88:17 $115 [1] - 8:22 77:15, 109:8 2004 [1] - 38:21 3A [3] - 43:17, 44:22, 80 [2] - 12:10, 103:7 $116 [1] - 42:16 1.6 [1] - 76:5 2006 [2] - 16:14, 28:24 65:18 80/20 [4] - 100:8, $12 [2] - 20:22, 67:21 1.7 [1] - 46:10 2007 [3] - 16:17, 101:13, 102:17, $123 [2] - 16:19, 24:9 10 [15] - 8:5, 13:1, 28:24, 38:22 4 103:6 $140 [1] - 30:21 13:5, 14:18, 15:16, 2008 [2] - 16:18, 39:3 $15 [1] - 47:9 15:18, 15:23, 16:5, 2009 [5] - 39:3, 57:14, 9 4 [3] - 66:6, 108:13, $164 [2] - 17:9, 28:1 17:14, 21:6, 23:16, 68:13, 69:15, 93:4 108:19 $17 [2] - 66:11, 66:15 31:24, 35:6, 89:20, 2010 [9] - 9:7, 16:21, 4,000 [1] - 47:18 9 [5] - 49:12, 66:13, $173 [1] - 17:19 91:21 17:4, 17:5, 17:8, 4.1 [2] - 32:10, 93:20 86:3, 88:13, 109:3 $20 [3] - 20:1, 20:2, 10-E-0050 [1] - 4:2 28:1, 39:4, 39:6, 9.1 [17] - 32:2, 49:11, 48:11 10.2 [1] - 89:15 57:14 4.3 [2] - 14:13, 23:21 40 [4] - 44:23, 44:24, 51:10, 51:18, 51:21, $200 [3] - 16:17, 10.6 [1] - 31:24 2011 [56] - 1:6, 2:4, 53:4, 53:7, 86:5, 45:11, 65:23 10.85 [1] - 86:3 3:2, 6:1, 6:3, 6:12, 88:3, 88:4 86:8, 89:14, 92:2, $200,000 [2] - 45:4, 100 [2] - 103:16, 104:7 6:14, 7:11, 8:20, 9:8, 46 [2] - 8:1, 85:18 92:10, 92:12, 94:4, 110:9 109 [1] - 110:16 9:11, 14:19, 21:16, 48 [4] - 8:1, 12:16, 109:1, 110:17 $205 [2] - 24:16, 26:19 10:30 [2] - 1:6, 112:8 23:18, 23:19, 24:2, 85:19, 109:3 9.2 [1] - 88:5 $247 [1] - 66:3 11 [1] - 26:10 24:8, 24:11, 24:18, 9.3 [6] - 86:4, 86:8, $25 [1] - 76:14 111 [1] - 110:15 25:3, 25:18, 25:23, 5 87:23, 88:5, 92:2, 114 [5] - 24:4, 27:14, 26:8, 26:11, 26:13, $25,000 [1] - 47:3 110:19 $29 [1] - 99:5 27:15, 27:20, 27:22 26:16, 27:3, 27:15, 5 [3] - 47:5, 67:18, 9.6 [3] - 87:16, 87:19, 116 [1] - 111:1 27:21, 28:3, 28:4, $290 [1] - 37:20 108:23 89:19 $30 [3] - 22:15, 48:11, 12 [4] - 1:6, 2:4, 3:2, 28:6, 31:1, 34:1, 50 [12] - 8:1, 29:4, 98 [1] - 20:14 22:20 34:9, 36:19, 37:9, 74:14 29:5, 60:19, 60:24, 15 [1] - 86:19 41:11, 41:18, 42:3, $350 [2] - 64:14, 73:12 63:18, 64:1, 64:15, 42:5, 43:16, 43:24, A $360 [1] - 8:18 15.2 [1] - 58:2 65:6, 65:11, 76:21, 44:5, 44:9, 44:14, $400 [1] - 37:10 16 [2] - 12:6, 91:18 85:16 164 [1] - 28:5 44:17, 45:8, 45:18, a.m [2] - 1:6, 112:8 $48,000 [1] - 47:4 500 [1] - 40:20 167 [1] - 19:20 45:20, 50:14, 64:14, [3] $50 [4] - 5:19, 60:3, 55 [1] - 42:22 A3 - 97:5, 98:15, 173 [1] - 18:4 83:8, 83:19, 83:22, 98:17 60:8, 65:2 573 [5] - 26:5, 26:7, 91:10 $561 [1] - 17:16 1980s [1] - 11:7 26:15, 26:23, 27:1 able [11] - 21:6, 24:3, 2012 [19] - 6:1, 6:20, $573 [4] - 23:18, 1990 [2] - 11:13, 11:22 26:9, 26:11, 26:22, 9:19, 21:16, 25:9, 24:12, 25:19, 25:20 1990s [2] - 7:14, 11:5 56:8, 91:9, 94:10, 41:12, 43:19, 44:13, 6 $60 [1] - 29:18 1994 [1] - 12:1 94:11, 95:10, 98:18 44:17, 44:21, 44:24, $670 [1] - 17:6 1995 [1] - 11:13 absorbed [4] - 13:20, 45:6, 45:9, 46:2, $69 [1] - 29:8 1997 [1] - 12:3 6 [4] - 38:19, 67:1, 14:2, 14:8, 23:22 46:7, 84:11, 91:11, $700,000 [2] - 109:19, 1998 [2] - 12:18, 12:20 108:22, 110:21 absorption [1] - 15:9 91:24, 94:12 110:7 19th [2] - 1:8, 2:5 6.42 [1] - 31:17 ACAMPORA [11] - 2013 [2] - 6:2, 6:20 $750 [1] - 84:12 1:16 [1] - 112:12 60 [1] - 37:14 1:14, 3:1, 4:17, 58:8, 205 [7] - 25:21, 26:1, $758 [1] - 42:17 65 [1] - 41:4 58:18, 86:6, 86:12, 26:2, 27:13, 27:16, $800 [2] - 79:1, 79:2 67 [2] - 19:12, 19:22 94:19, 94:24, 95:2, 2 28:5, 28:7 $834 [1] - 17:4 96:11 20th [3] - 3:23, 10:9, $97 [1] - 28:19 7 accepts [1] - 48:2 2 [9] - 14:5, 18:17, 112:8 $98 [1] - 18:1 accomplish [1] - 9:15 [2] 18:18, 19:2, 19:5, 25 - 11:13, 73:13 accomplishes [1] - 7 [3] - 109:2, 109:7, 19:8, 39:19, 74:9, 250 [2] - 40:16, 40:19 44:4 ' 110:21 110:16 account [4] - 7:1, 2.6 [2] - 67:23, 109:5 3 7.6 [3] - 67:14, 67:22, 21:4, 36:6, 96:21 109:4 '06 [2] - 57:8, 57:9 20 [5] - 15:20, 35:7, accountants [1] - 8:8 700,000 [1] - 109:18 '07 [1] - 57:8 90:7, 103:9, 104:3 accounted [1] - 80:1 [4] 3 - 1:8, 65:17, 73 [1] - 42:23 '08 [1] - 57:8 20/80 [1] - 102:2 accounting [15] - 65:18, 70:7 750 [1] - 84:16 200 [2] - 26:23, 44:20 8:15, 9:13, 54:24, 3.3 [2] - 15:13, 23:22 2000 [1] - 14:19 73:16, 74:15, 74:16,
2
74:18, 75:1, 75:2, adds [3] - 108:19, agree [4] - 19:19, 16:13, 16:18, 16:19, appreciate [1] - 96:23 75:4, 93:13, 99:4, 108:20, 108:22 67:10, 100:20, 112:1 19:9, 20:5, 20:16, approach [8] - 8:7, 99:13, 103:20 adequacy [1] - 36:3 agreed [14] - 19:8, 20:21, 24:1, 24:11, 36:16, 60:7, 60:23, accrue [1] - 18:4 adjourned [2] - 19:18, 32:21, 34:16, 24:15, 25:4, 26:14, 86:18, 87:24, 88:12, accumulate [1] - 112:11, 112:12 35:17, 38:13, 39:22, 26:21, 27:17, 29:2, 102:24 19:15 adjusted [2] - 57:17, 41:6, 66:15, 67:5, 30:12, 31:7, 38:3, approaches [1] - accumulated [1] - 87:5 80:15, 85:17, 91:11, 38:10, 42:16, 42:23, 60:23 16:16 adjusting [2] - 89:24, 99:22 45:5, 59:23, 62:9, appropriate [1] - achieve [4] - 29:7, 90:1 agreeing [2] - 70:12, 64:4, 75:4, 75:10, 91:22 30:14, 30:15, 57:23 adjustment [24] - 108:7 90:6, 95:24, 103:10, appropriateness [1] - achieved [2] - 30:13, 5:21, 16:14, 57:13, agreement [6] - 12:4, 103:18 87:11 93:16 60:5, 60:10, 61:8, 31:3, 36:15, 40:16, amounted [1] - 29:8 approval [1] - 50:17 achieves [1] - 29:9 64:4, 64:8, 67:1, 47:23, 90:9 amounts [15] - 6:13, approve [1] - 27:10 acquire [1] - 14:15 67:7, 67:11, 67:14, agrees [1] - 76:2 9:12, 10:20, 24:20, approved [5] - 12:20, acquired [2] - 6:24, 67:17, 67:24, 68:13, ahead [2] - 40:23, 24:24, 62:17, 62:19, 14:16, 49:12, 65:24, 7:19 70:17, 71:14, 74:3, 63:17 70:10, 73:24, 75:5, 77:16 acquisition [2] - 74:5, 81:20, 87:6, airing [1] - 105:8 78:4, 95:4, 95:15, approving [1] - 84:7 14:17, 73:4 89:2, 95:13, 109:4 Albany [4] - 1:9, 2:5, 103:22 arduous [1] - 95:21 act [1] - 50:20 adjustments [5] - 8:9, 112:8 AMR [1] - 56:3 area [4] - 6:3, 10:5, Act [2] - 11:11, 18:1 38:19, 39:1, 70:7, aligned [1] - 69:11 analysis [9] - 69:16, 38:2, 93:14 action [6] - 10:9, 61:2, 76:14, 85:10 alignment [1] - 75:19 69:23, 81:17, 82:6, arguably [1] - 106:18 77:2, 77:14, 84:6, Administrative [1] - allocate [1] - 72:16 97:10, 97:13, 97:18, argue [1] - 19:10 101:20 4:7 allocated [5] - 61:18, 109:23 argued [5] - 66:2, actions [3] - 67:15, administrative [1] - 62:17, 66:1, 73:14, analyzing [2] - 68:6, 67:2, 67:6, 85:18, 82:15, 82:23 73:1 73:23 71:1 86:3 activities [3] - 51:6, admission [1] - 64:5 allocating [4] - 72:15, annual [6] - 15:23, argues [3] - 66:11, 51:12, 53:10 adopt [2] - 76:24, 72:19, 75:24, 78:16 16:15, 16:19, 16:20, 66:13, 77:18 activity [8] - 17:12, 100:9 allocation [5] - 9:17, 20:18, 99:24 arguing [1] - 60:5 [4] 19:18, 21:23, 22:14, adopted [5] - 43:14, 43:10, 62:18, 83:4, annually - 16:17, argument [2] - 2:18, 28:4, 53:22, 54:3, 58:1, 58:16, 74:14, 86:16 20:23, 22:17, 50:17 107:21 103:16 76:7 Allocation [1] - 75:22 anomalies [1] - 71:6 arguments [1] - 77:23 [5] actual [7] - 20:13, adopts [5] - 66:4, allocations [3] - 9:14, answer - 27:1, arrangements [1] - 21:4, 32:9, 60:21, 67:22, 76:5, 85:19, 33:9, 62:11 36:13, 56:13, 57:1, 105:2 66:2, 66:4, 97:6 85:20 allow [5] - 45:19, 75:4, 79:13 arrears [3] - 48:1, add [2] - 40:19, 53:20 advantageous [1] - 75:8, 81:8, 92:24 answered [1] - 54:22 48:5, 48:10 [2] added [7] - 27:22, 98:9 allowance [6] - 20:18, answers - 83:2, ascertain [1] - 94:7 67:5, 77:15, 83:11, advised [1] - 3:5 22:2, 22:13, 103:21, 96:21 assess [1] - 97:21 ante [1] - 38:24 108:24, 109:23, advisors [1] - 4:23 108:23 assessment [2] - 71:4, 110:13 advisory [4] - 68:5, allowed [19] - 10:23, anticipate [2] - 62:11, 96:3 ADDEPALLI [7] - 68:9, 69:11, 71:16 12:24, 13:4, 13:7, 111:22 asset [4] - 13:11, 32:14, 32:20, 35:1, advocacy [1] - 69:9 13:8, 15:14, 15:19, anticipated [2] - 21:8, 13:22, 14:13, 86:21 27:6 36:17, 36:21, 54:15, advocate [1] - 48:17 15:21, 20:19, 20:23, assets [4] - 13:2, 79:20 advocated [1] - 100:8 29:5, 31:18, 32:2, anticipation [2] - 3:21, 23:14, 28:1, 54:1 Addepalli [1] - 9:16 advocates [1] - 48:18 37:7, 38:10, 77:24, 4:18 assignments [1] - adding [2] - 110:7, affect [1] - 96:17 81:14, 92:24, 99:14 apart [1] - 39:12 9:14 [1] 110:9 affected [1] - 30:5 allowing [1] - 81:3 apiece - 39:20 assist [1] - 48:24 addition [8] - 15:11, affecting [1] - 96:24 alluded [1] - 49:21 appear [2] - 107:14 Assistance [1] - 46:24 [1] 21:1, 27:15, 34:13, affiliate [1] - 91:8 almost [2] - 15:3, 51:8 applicability - 99:6 assistance [1] - 49:1 35:24, 38:12, 44:4, affiliates [2] - 61:20, alone [1] - 7:4 applicants [1] - 39:19 assisted [1] - 70:24 [3] 88:23 73:19 Alternative [1] - 4:9 application - 3:19, assisting [1] - 48:22 additional [8] - 8:19, affordability [2] - alternatives [3] - 11:3, 103:2 associated [5] - 15:10, 20:5, 31:4, 47:17, 56:6 11:17, 77:5, 77:7 applications [1] - 79:3 14:17, 52:5, 68:19, 48:17, 92:19, 99:14, agencies [2] - 3:13, ameliorate [1] - 45:14 applied [2] - 86:22, 77:22, 87:22 107:7 86:13 amortization [1] - 27:4 99:13 assumed [2] - 16:4, address [4] - 34:16, Agency [1] - 1:8 amortize [1] - 45:12 applies [1] - 69:16 17:13 50:5, 92:9, 105:14 aggressive [2] - amortized [3] - 23:23, apply [7] - 44:12, assumes [1] - 44:19 [4] addressed - 2:17, 78:24, 101:18 44:21, 78:5 86:19, 88:8, 88:10, assumption [2] - 33:19, 80:22, 81:23 aging [1] - 37:12 amortizing [1] - 83:12 102:17, 103:20, 62:24, 68:18 addressing [2] - ago [3] - 6:23, 21:6, amount [37] - 6:11, 103:23 assuring [1] - 38:4 82:21, 96:16 applying [1] - 87:12 81:3 13:15, 13:21, 16:11, ate [1] - 23:22
3
attained [1] - 92:18 balancing [1] - 64:11 56:23, 68:14, 68:19, 98:19 111:2, 112:1, 112:10 attention [2] - 55:7, bank [4] - 78:17, 79:24, 81:16, 81:23 bottom [1] - 25:8 Brown [2] - 3:9, 46:11 59:23 79:22, 80:5, 81:1 best [5] - 51:22, 73:18, Bouteiller [2] - 4:8, bucket [2] - 44:16, attract [1] - 41:7 bar [2] - 42:15, 42:20 87:9, 106:2, 107:16 91:5 65:20 attracting [1] - 54:18 bars [3] - 43:2, 43:6, better [3] - 53:11, BOUTEILLER [30] - budget [1] - 18:6 audit [28] - 24:21, 44:1 56:19, 71:5 4:13, 4:19, 5:5, budgets [1] - 38:12 25:1, 33:15, 33:16, base [10] - 15:6, between [26] - 4:20, 21:24, 23:10, 26:24, Buffalo [1] - 17:21 33:19, 34:13, 34:17, 15:16, 30:22, 31:17, 8:18, 11:13, 17:3, 27:20, 62:2, 68:4, build [1] - 111:13 35:1, 35:3, 39:9, 51:7, 54:7, 76:8, 22:5, 26:23, 29:19, 70:11, 72:1, 72:11, building [1] - 51:6 59:24, 60:2, 60:20, 90:4, 103:14, 103:16 36:15, 38:21, 55:5, 75:14, 75:20, 77:21, Building [1] - 1:8 61:3, 61:14, 61:17, based [14] - 21:21, 64:6, 65:5, 70:14, 82:14, 84:17, 90:15, built [5] - 8:2, 19:1, 61:24, 62:12, 63:1, 22:22, 31:10, 34:14, 74:17, 76:1, 79:15, 94:22, 95:3, 101:17, 37:3, 37:6, 103:18 63:4, 65:7, 67:8, 36:10, 39:4, 43:10, 86:7, 90:21, 91:14, 103:7, 103:18, bullet [4] - 25:8, 73:21, 74:4, 77:17, 46:22, 62:24, 89:23, 91:19, 91:21, 104:8, 104:13, 27:13, 34:21, 50:18 77:23, 91:7 95:13, 97:11, 110:2, 103:21, 106:17, 104:21, 105:10, bundles [1] - 107:1 audited [1] - 81:22 111:17 106:21, 106:24 109:10, 109:16, burdensome [1] - audits [1] - 63:19 Based [1] - 39:15 beyond [5] - 6:5, 111:6 50:3 austerity [6] - 6:17, basic [1] - 28:8 37:17, 39:7, 44:13, Boy [1] - 94:12 business [9] - 3:20, 65:21, 67:14, 67:22, basis [28] - 16:15, 83:22 break [3] - 59:3, 79:5, 51:8, 65:21, 66:10, 67:23, 109:4 16:20, 31:14, 36:12, big [5] - 17:14, 31:21, 101:12 67:3, 67:6, 67:12, authority [1] - 49:20 48:23, 57:2, 57:20, 43:3, 79:21 breaking [2] - 65:6, 67:20, 109:12 authorize [1] - 2:19 69:10, 87:23, 88:3, bigger [4] - 21:8, 70:2 bypassing [1] - 41:23 authorized [1] - 84:13 88:4, 89:1, 90:7, 42:23, 51:7, 65:10 brief [1] - 33:11 automatic [1] - 18:18 91:18, 91:20, 91:22, Bill [8] - 4:7, 4:11, briefing [2] - 20:8, C automatically [3] - 100:4, 103:20, 23:8, 68:3, 72:3, 22:7 26:13, 29:17, 41:14 105:3, 105:12, 79:4, 101:7, 103:4 briefly [2] - 46:19, [2] available [6] - 24:13, 105:24, 106:2, 107:3 bill [10] - 9:4, 9:18, 85:13 C&I - 42:21, 43:4 24:15, 25:5, 25:13, batteries [1] - 52:2 14:22, 42:24, 45:6, briefs [7] - 33:11, CAIDI [1] - 38:17 49:1, 87:9 BBB [2] - 98:16, 98:17 47:13, 47:24, 48:5, 43:12, 43:13, 69:9, calculated [1] - 66:4 avails [1] - 69:16 beans [1] - 77:22 58:12, 64:16 82:13, 88:14, 95:24 calculation [1] - 23:4 average [1] - 91:14 bearable [1] - 5:1 billing [1] - 100:3 BRILLING [1] - 112:5 calendar [4] - 34:9, avoid [2] - 9:8, 16:1 became [1] - 16:13 billion [19] - 11:23, bring [4] - 10:8, 54:3, 36:19, 37:9, 53:2 avoidable [2] - 19:10, because.. [1] - 99:15 13:16, 13:17, 14:5, 88:5, 110:19 California [1] - 80:17 19:16 become [4] - 41:17, 14:7, 14:13, 15:3, bringing [1] - 46:5 candidate [2] - 68:22, avoided [1] - 18:21 41:18, 42:3, 53:11 15:9, 15:11, 15:13, brings [1] - 75:18 69:3 award [1] - 80:14 becomes [3] - 46:10, 23:21, 23:22, 23:23, Britain [1] - 62:7 cap [1] - 80:24 awarded [1] - 80:10 68:22, 107:9 30:23, 31:4, 31:5, broad [4] - 33:10, capacitor [3] - 78:17, 33:23, 36:23, 37:2 aware [5] - 3:13, began [2] - 8:17, 12:1 35:2, 42:8, 46:22 79:22, 80:5 37:23, 58:14, 58:16, Begin [1] - 59:3 bills [3] - 24:6, 45:4, broader [2] - 105:15, capex [1] - 33:13 82:15 begin [3] - 9:5, 47:14, 100:3 106:3 Capital [2] - 17:21, binding [1] - 37:16 awareness [1] - 58:21 50:5 broken [1] - 47:23 85:16 [9] awhile [1] - 106:7 Beginning [2] - 46:16, bit - 11:5, 51:16, brought [1] - 93:5 capital [24] - 6:3, 18:6, 59:22 51:17, 55:6, 57:3, BROWN [50] - 1:14, 33:3, 33:14, 33:16, 73:8, 85:6, 92:6, B beginning [10] - 3:2, 54:9, 55:2, 55:24, 33:23, 34:2, 34:5, 11:4, 11:16, 14:20, 102:23 56:11, 59:2, 59:6, 34:10, 35:8, 35:14, 16:18, 23:23, 50:6, blank [1] - 96:19 61:4, 70:4, 71:17, 35:19, 38:12, 51:22, Baa1 [1] - 98:16 55:14, 105:7, 112:8 blip [1] - 44:2 74:20, 75:18, 75:21, 64:9, 67:8, 70:10, backed [2] - 80:15, begun [1] - 5:17 blue [2] - 111:18, 78:13, 79:14, 80:2, 71:2, 71:10, 76:10, 80:18 behind [2] - 39:13, 112:1 81:24, 82:24, 83:15, 76:12, 83:14, 85:13, background [3] - 82:17 board [1] - 107:17 83:17, 83:21, 83:24, 86:21 10:18, 57:6, 82:3 beliefs [1] - 2:14 Board [1] - 2:5 84:7, 84:11, 85:3, capitalization [4] - bad [2] - 3:14, 93:9 believes [1] - 28:3 body [2] - 53:15, 85:8, 85:23, 89:8, 31:10, 70:6, 108:20, 108:21 baked [1] - 51:17 below [2] - 75:6, 98:5 111:13 90:10, 90:19, 90:24, CAPM [3] - 86:21, balance [11] - 13:14, beneficial [1] - 93:15 bolded [1] - 111:9 92:1, 92:5, 94:3, 87:1, 89:24 14:12, 15:14, 17:9, benefit [11] - 38:11, bolstered [1] - 69:4 95:1, 96:12, 98:23, 17:20, 24:18, 28:4, 41:8, 47:7, 49:16, bond [8] - 87:8, 89:6, 100:12, 105:18, capped [1] - 97:19 31:5, 64:6, 67:12, 53:9, 69:18, 69:20, 92:14, 93:19, 97:5, 106:12, 107:20, capture [2] - 63:21, 111:17 70:6, 99:8, 108:21 97:8, 97:23, 98:13 108:16, 109:21, 95:11 balances [2] - 24:20, care [1] - 84:21 benefits [10] - 17:16, bonus [1] - 90:20 110:11, 110:17, 24:23 18:4, 53:14, 54:4, borrow [2] - 98:9, 110:19, 110:23, carrying [2] - 37:7,
4
38:11 85:8, 85:23, 89:8, 45:1, 45:20, 60:16, 2:19, 4:3, 6:1, 6:8, committed [3] - 33:22, case [71] - 3:22, 3:23, 90:10, 90:19, 90:24, 65:18 6:16, 8:24, 12:19, 36:22, 65:23 4:2, 5:1, 5:7, 5:16, 92:1, 92:5, 94:3, classifications [1] - 12:20, 14:16, 26:17, commodity [1] - 89:16 5:24, 8:17, 9:22, 95:1, 96:12, 98:23, 9:15 28:10, 38:24, 39:15, communicating [1] - 16:2, 21:7, 21:21, 100:12, 105:18, clause [3] - 5:21, 40:14, 46:7, 46:8, 58:19 22:1, 22:10, 22:13, 106:12, 107:20, 60:10, 61:9 57:24, 58:5, 61:2, communications [2] - 24:22, 26:9, 28:16, 108:16, 109:21, clauses [1] - 70:20 62:1, 68:6, 68:11, 58:22, 58:24 28:17, 30:10, 33:23, 110:11, 110:17, clean [2] - 17:24, 78:7, 78:10, 79:13, companies [18] - 21:7, 34:8, 34:16, 35:23, 110:19, 110:23, 20:13 84:6, 87:13, 87:15, 51:12, 52:19, 52:21, 36:23, 37:15, 44:21, 111:2, 112:1, 112:10 clear [4] - 27:24, 87:20, 100:16, 52:22, 53:11, 58:19, 45:15, 48:10, 55:14, Chairman [11] - 1:14, 79:13, 103:13, 101:23, 106:8 59:22, 62:18, 72:14, 59:24, 62:3, 67:1, 3:9, 46:11, 79:11, 108:10 Commission's [6] - 73:5, 75:16, 78:8, 68:7, 68:11, 68:14, 79:20, 80:22, 90:15, clearly [2] - 45:9, 56:8 2:14, 61:11, 67:15, 78:15, 86:23, 87:8, 70:19, 72:17, 76:4, 101:11, 106:16, clock [1] - 95:18 86:17, 86:18, 102:24 89:3, 106:19 76:16, 76:18, 78:2, 107:7, 108:3 close [4] - 4:16, 12:14, COMMISSIONER [77] company [149] - 5:16, 82:12, 84:8, 85:9, change [9] - 16:4, 56:14, 111:21 - 3:1, 4:17, 5:4, 5:18, 5:22, 6:12, 86:10, 88:12, 88:16, 56:20, 70:9, 84:5, closely [3] - 35:9, 13:24, 14:10, 15:8, 6:13, 6:21, 7:4, 7:16, 90:11, 92:13, 92:16, 99:4, 99:10, 99:12, 59:20, 103:11 18:3, 19:5, 19:19, 7:19, 7:21, 13:7, 92:18, 94:10, 95:5, 99:14, 100:9 closer [1] - 92:24 20:3, 20:7, 21:2, 13:20, 14:8, 15:21, 95:6, 95:18, 95:20, changed [1] - 23:3 coal [1] - 76:21 21:12, 21:15, 22:6, 16:2, 16:7, 16:9, 95:23, 96:4, 96:7, changes [4] - 15:21, coincidentally [1] - 22:19, 23:2, 23:8, 22:22, 23:22, 24:17, 96:8, 99:10, 104:3, 71:1, 71:2, 84:9 92:2 23:11, 25:7, 25:16, 24:20, 24:24, 25:9, 106:2, 107:3, 107:4, 26:4, 26:14, 27:12, changing [1] - 34:21 collaborative [1] - 25:21, 26:3, 26:9, 111:24 characterization [1] - 50:4 27:19, 28:13, 29:21, 27:24, 28:3, 28:7, cases [6] - 8:23, 38:7, 30:18, 32:16, 34:19, 20:12 Collaborative [1] - 28:12, 29:6, 29:9, 47:11, 54:3, 79:17, charge [14] - 6:13, 7:9, 50:5 36:14, 36:20, 50:24, 30:13, 31:2, 31:6, 101:24 52:7, 52:12, 53:5, 7:10, 7:13, 8:14, collect [5] - 6:14, 31:16, 31:23, 32:5, cash [3] - 12:13, 10:20, 13:2, 14:12, 25:13, 63:11, 84:13 54:21, 55:9, 58:8, 32:11, 33:17, 34:1, 86:21, 99:5 58:18, 59:17, 60:18, 15:14, 23:15, 24:12, collected [4] - 5:20, 34:3, 34:5, 34:7, 61:13, 62:23, 63:16, catch [1] - 23:9 76:11, 99:17, 100:2 42:18, 43:7, 61:5 34:11, 35:6, 35:11, categories [4] - 19:11, 63:23, 64:20, 65:4, chargeable [1] - 53:7 collecting [1] - 6:22 35:18, 36:1, 36:4, 62:2, 95:11, 111:20 71:20, 71:23, 72:2, 36:5, 36:22, 37:6, charges [11] - 4:3, collective [1] - 36:10 category [3] - 19:21, 72:18, 73:3, 74:6, 37:14, 37:19, 37:21, 6:22, 9:20, 13:12, collectively [2] - 80:3, 81:2, 83:3, 62:8, 78:6 37:7, 38:11, 41:13, 35:15, 39:21 38:1, 38:13, 38:22, caused [2] - 11:12, 86:6, 86:12, 94:19, 39:3, 39:10, 39:18, 64:13, 72:16, 73:14, combination [1] - 94:24, 95:2, 96:11, 45:9, 46:5, 46:8, 30:22 73:20 106:19 caution [2] - 87:18, check [1] - 20:21 96:15, 98:7, 98:22, 48:18, 49:6, 49:9, combined [1] - 108:21 87:24 [1] 101:11, 103:4, 49:15, 49:18, 51:19, Chinese - 96:22 comfortable [2] - CDCs [2] - 41:17, 103:13, 104:2, 52:3, 52:9, 52:21, choice [1] - 100:4 45:17, 79:9 43:23 [4] 104:11, 104:14, 53:21, 54:2, 54:5, Choice - 12:21, coming [15] - 6:7, 104:23, 105:16, 54:17, 56:5, 56:7, cent [1] - 11:10 14:4, 14:5, 15:12 34:13, 35:16, 39:14, 106:16, 107:6, 108:3 57:1, 60:4, 61:1, center [1] - 48:21 chooses [1] - 5:13 39:19, 41:21, 49:24, Commissioner [12] - 62:12, 63:8, 64:13, Central [1] - 67:16 choosing [1] - 105:16 61:13, 63:1, 82:2, 3:7, 21:24, 22:13, 64:21, 65:2, 65:22, certain [5] - 16:2, circumstances [2] - 82:12, 82:15, 83:8, 26:24, 32:15, 35:21, 66:11, 66:13, 66:17, 16:6, 21:10, 58:22, 58:22, 84:20 83:24, 94:8 53:21, 54:11, 55:5, 66:19, 66:24, 69:1, 72:6 cited [1] - 67:7 commence [1] - 3:2 80:13, 82:24, 96:14 Certainly [1] - 71:22 72:6, 72:15, 72:19, City [3] - 1:15, 1:16, commend [1] - 32:22 commissioners [3] - certainly [2] - 92:11, 72:20, 72:21, 72:22, 3:7 comment [2] - 79:10, 33:15, 94:5, 100:24 72:23, 73:2, 73:10, 107:20 claim [1] - 71:8 94:6 COMMISSIONERS [1] certify [1] - 61:2 73:15, 73:21, 73:24, clarify [2] - 66:17, Comments [1] - 111:5 - 1:13 chair [1] - 3:12 74:4, 74:13, 75:5, 82:20 comments [5] - 44:11, Commissioners [4] - 76:22, 77:11, 77:15, CHAIRMAN [49] - clarifying [1] - 104:11 59:13, 59:21, 96:12, 3:6, 10:16, 32:14, 81:13, 82:11, 82:15, 54:9, 55:2, 55:24, class [11] - 40:5, 98:23 56:11, 59:2, 59:6, 46:12 83:9, 84:17, 85:16, 42:12, 42:13, 42:19, commercial [4] - Commissions's [1] - 90:17, 91:2, 91:4, 61:4, 70:4, 71:17, 43:16, 43:20, 43:23, 42:14, 55:22, 57:10, 2:4 91:22, 92:15, 92:17, 74:20, 75:18, 75:21, 44:2, 44:8, 45:19, 98:20 78:13, 79:14, 80:2, commit [1] - 91:23 92:20, 92:24, 93:3, 65:17 COMMISSION [1] - commitment [4] - 93:16, 94:2, 94:14, 81:24, 82:24, 83:15, classes [12] - 42:12, 1:1 83:17, 83:21, 83:24, 34:2, 37:2, 47:23, 94:20, 94:23, 95:9, 42:14, 43:15, 43:17, Commission [37] - 84:7, 84:11, 85:3, 91:9 96:2, 96:5, 96:10, 44:6, 44:9, 44:22, 1:3, 2:3, 2:11, 2:16,
5
96:20, 97:15, 99:12, 94:3 construction [2] - 55:19, 56:11 20:10, 24:11, 26:2, 99:19, 99:23, 100:6, concerns [4] - 35:10, 34:23, 35:5 Corporation [1] - 3:21 26:22, 27:21, 29:11, 103:22, 104:4, 39:16, 49:22, 72:7 consulting [1] - 77:11 Corporation's [1] - 4:4 30:10, 54:5, 55:7, 107:1, 108:7 conclude [1] - 82:16 consumer [2] - 48:17, Correct [9] - 61:7, 62:3, 73:20, 85:23 Company [3] - 67:2, concluded [2] - 72:9, 55:22 63:22, 85:12, 89:21, cover [4] - 5:15, 5:18, 71:24, 103:7 87:12 Consumer [1] - 48:17 92:4, 92:8, 99:9, 26:21, 62:13 company's [20] - 9:9, concludes [2] - 32:13, consummate [1] - 110:4, 110:18 coverage [2] - 93:23, 24:23, 27:8, 37:1, 45:21 4:24 correct [6] - 36:17, 93:24 38:4, 41:23, 46:20, condition [1] - 73:4 contact [2] - 32:18, 52:14, 75:20, 78:9, covered [1] - 99:18 50:13, 53:13, 57:7, conditions [4] - 18:9, 58:12 81:17, 90:15 Covered [1] - 109:14 64:9, 66:2, 66:8, 19:2, 88:9, 88:11 contain [3] - 2:7, correctly [1] - 5:23 covers [1] - 50:21 71:8, 76:24, 86:2, conducted [1] - 2:8 76:11, 107:19 Corso [3] - 51:15, CPB [2] - 49:6, 86:3 90:12, 94:7, 99:5, Coney [1] - 106:9 contained [1] - 2:18 79:1, 82:21 create [2] - 50:15, 102:11 configuration [1] - contemplated [2] - CORSO [5] - 52:14, 52:17 comparable [1] - 73:18 19:20, 51:18 53:20, 55:4, 79:10, creating [2] - 64:9, 71:10 confirm [1] - 84:18 contemplating [1] - 80:13 74:13 compare [1] - 89:14 confirmed [1] - 80:22 50:17 cost [35] - 9:14, 10:5, credit [12] - 48:4, compared [2] - 21:5, conform [2] - 75:15, contentious [1] - 83:5 12:15, 13:22, 17:9, 48:11, 63:6, 87:5, 61:19 84:20 contents [1] - 71:24 17:23, 20:5, 22:11, 89:24, 96:16, 97:11, comparison [1] - confused [1] - 73:9 contested [5] - 40:8, 31:13, 32:3, 32:7, 97:19, 97:24, 98:2, 64:15 confusion [1] - 82:17 42:4, 90:10, 100:17, 32:9, 32:11, 34:15, 98:4 compensation [1] - conjecture [1] - 91:2 100:19 35:12, 39:8, 64:9, creditable [1] - 71:7 70:2 connected [1] - 60:19 context [2] - 33:20, 68:18, 69:4, 90:6, credited [1] - 99:8 competitive [14] - consensus [5] - 36:15 93:20, 96:17, creditworthy [1] - 7:20 6:22, 7:9, 7:10, 7:13, 33:10, 42:8, 50:20, contexts [1] - 69:17 102:14, 103:8, criteria [3] - 35:21, 8:14, 9:20, 10:20, 77:20, 112:2 continue [9] - 6:17, 103:15, 103:16, 48:3, 68:24 13:1, 13:11, 14:12, consequences [3] - 9:5, 10:7, 30:19, 104:15, 105:2, CTC [4] - 25:11, 25:13, 15:13, 23:15, 24:12, 57:16, 57:17, 57:24 38:14, 46:12, 59:2, 105:5, 105:17, 42:10, 43:3 41:13 conservative [1] - 99:1, 101:9 107:11, 110:8 CTCs [22] - 15:3, 15:5, complaint [2] - 55:20, 102:3 continued [4] - 25:13, Cost [2] - 83:14, 85:13 23:18, 23:20, 41:13, 56:17 [58] consider [3] - 95:19, 41:12, 86:16, 93:14 costs - 12:20, 41:17, 42:2, 42:16, complete [2] - 48:7, 100:15, 107:16 continues [1] - 16:20 12:24, 13:2, 13:4, 42:17, 42:22, 42:23, 101:9 considerable [1] - continuing [2] - 78:10, 13:15, 13:21, 14:2, 43:5, 43:18, 44:5, completed [2] - 8:19, 34:5 104:24 14:8, 15:12, 15:22, 44:9, 44:17, 45:19, 23:19 16:3, 16:6, 16:7, consideration [5] - contract [1] - 12:12 83:10, 83:18, 84:3, 16:8, 16:16, 17:1, completely [3] - 3:22, 95:14, 96:8, contracts [11] - 11:8, 84:23 24:21, 26:10, 79:24 100:22, 111:15 11:9, 11:12, 12:7, 17:2, 17:13, 17:19, curiosity [1] - 82:1 [1] 18:17, 18:19, 18:22, completes - considerations [1] - 12:9, 12:11, 12:14, curious [2] - 51:9, 100:10 6:7 12:15, 41:4, 41:5, 19:10, 19:17, 20:17, 55:24 20:23, 21:20, 22:22, compliance [1] - considered [2] - 41:10 current [14] - 9:2, 30:1, 30:5, 35:11, 27:10 67:17, 77:8 contractual [1] - 13:3 21:20, 21:21, 22:1, [1] 52:4, 53:13, 54:7, complicated - considering [2] - contrary [1] - 105:11 22:13, 22:22, 24:6, 61:22, 62:3, 62:8, 32:24 31:16, 35:9 contribute [1] - 78:20 47:24, 50:15, 84:20, 63:14, 64:19, 71:3, comply [1] - 47:22 considers [1] - 55:19 contribution [1] - 88:9, 88:11, 91:19, [2] 73:24, 74:3, 75:8, component - consistency [2] - 53:22 110:9 75:11, 78:5, 78:17, 68:17, 76:12 79:6, 83:1 control [3] - 16:3, CURRY [27] - 1:15, 80:16, 92:22, 92:23, components [5] - consistent [10] - 35:2, 68:15, 102:11 5:4, 18:3, 19:5, 94:2, 102:7, 102:9, 46:18, 46:21, 48:14, 40:6, 47:10, 58:5, controlling [1] - 69:15 19:19, 20:3, 23:2, 102:16, 103:9, 51:20, 70:3 75:1, 79:15, 79:19, convenience [1] - 23:8, 23:11, 27:12, 107:19, 110:7 composed [1] - 20:5 81:8, 86:16, 101:23 90:18 27:19, 28:13, 29:21, coughing [1] - 32:18 composing [1] - 12:7 consolidated [5] - conventional [1] - 30:18, 34:19, 36:14, count [2] - 66:12, 67:3 comprise [1] - 42:23 97:11, 97:16, 98:1, 51:11 36:20, 71:20, 71:23, counted [1] - 66:14 72:2, 72:18, 73:3, computers [1] - 58:11 98:4, 100:3 conversation [1] - counting [1] - 71:8 Con [7] - 35:3, 67:15, Consolidated [2] - 111:18 74:6, 96:15, 98:7, countries [1] - 11:19 98:22, 107:6 81:3, 87:13, 89:19, 68:13, 74:24 conversations [1] - couple [8] - 5:11, Curry [2] - 3:6, 96:14 90:22, 90:23 constituencies [1] - 108:7 39:7, 40:8, 40:10, customer [18] - 28:11, concept [1] - 51:1 106:19 conversely [1] - 63:20 79:16, 89:8, 94:13, 29:3, 29:13, 43:7, concern [4] - 50:1, constraint [2] - 76:20, cooperative [1] - 109:10 79:22, 104:24, 105:8 76:23 102:13 45:2, 47:13, 52:10, course [13] - 12:18, 55:12, 55:19, 55:21, concerned [2] - 47:15, constraints [1] - 47:2 core [3] - 55:18,
6
56:17, 56:21, 57:9, 85:21, 87:13, 91:3, 43:16, 43:19, 77:6 diplomatic [1] - 96:22 56:22, 58:5, 58:9, 57:21, 58:7, 60:16, 94:21, 109:8, 111:23 demonstrated [1] - direction [4] - 58:13, 80:17, 106:8, 100:4 decisional [1] - 56:8 106:7, 108:17, 106:11, 106:12, customer's [2] - 111:16 departing [1] - 108:9 110:24 109:22 14:24, 57:4 Decisions [1] - 2:15 department [3] - 5:3, directly [3] - 54:5, Doris [5] - 4:24, 89:8, customers [49] - 6:14, declare [1] - 60:24 5:8, 55:19 69:2, 98:12 96:15, 101:7, 108:5 9:4, 11:17, 17:12, decline [1] - 88:18 depleted [1] - 7:21 disagree [1] - 101:20 double [2] - 66:12, 23:24, 24:14, 38:10, decoupling [7] - 33:4, Depreciation [1] - disagreement [5] - 71:8 40:15, 40:19, 40:22, 40:1, 54:10, 54:13, 76:13 41:14, 46:14, 55:15, doubled [1] - 38:24 41:7, 41:8, 41:23, 54:15, 60:12, 65:13 depreciation [1] - 58:3 Doug [7] - 4:24, 9:21, 42:21, 43:4, 45:5, decrease [1] - 43:15 95:13 disagreements [1] - 33:5, 45:21, 50:24, 46:4, 47:6, 47:9, decreased [2] - 7:1, derived [1] - 67:15 24:22 55:24, 58:8 47:19, 47:20, 48:2, 28:18 describe [1] - 34:20 disappointed [1] - down [8] - 5:7, 7:10, 48:4, 48:12, 48:13, decreases [1] - 44:23 described [4] - 58:4, 92:12 30:2, 47:24, 69:12, 48:16, 48:23, 48:24, dedication [1] - 8:7 88:4, 92:23, 100:14 disciplining [1] - 78:3, 85:1, 108:8 49:16, 49:17, 51:7, deductible [4] - 18:18, describing [1] - 107:13 downside [4] - 94:20, 52:6, 52:16, 53:11, 19:2, 74:9, 74:12 109:24 disconnect [1] - 54:13 94:21, 94:22, 95:9 53:17, 54:8, 54:18, deduction [3] - 99:11, design [3] - 9:17, disconnected [1] - downward [1] - 38:8 54:19, 56:5, 58:19, 99:15 33:5, 40:13 48:16 draft [10] - 59:20, 60:15, 61:5, 61:15, default [1] - 40:20 designed [2] - 41:22, discount [5] - 46:22, 59:21, 85:19, 85:24, 63:5, 65:15, 65:17 defer [4] - 15:21, 75:5, 48:7 47:5, 47:8, 99:20, 86:4, 100:14, 108:9, customers' [1] - 24:6 75:9, 75:11 detail [2] - 59:14, 100:1 110:5, 111:8, 111:12 [2] cut - 69:12, 69:14 deferrable [2] - 18:14, 60:10 discounted [1] - 86:21 dramatic [1] - 20:9 19:3 detailed [1] - 86:19 discretion [1] - 70:19 driver [1] - 30:20 D deferral [32] - 8:15, deterioration [1] - discuss [5] - 32:20, drivers [6] - 28:16, 10:22, 13:14, 15:19, 98:1 33:5, 33:12, 42:9, 28:17, 31:13, 31:21, 16:16, 17:2, 17:9, determination [2] - 45:22 37:11 data [3] - 75:24, 76:3 17:12, 17:20, 17:24, 2:13, 68:15 discussed [3] - 2:12, driving [1] - 28:20 date [1] - 6:2 18:8, 18:11, 19:13, determinations [2] - 33:8, 74:10 drop [3] - 43:5, 44:18, days [2] - 50:6, 100:18 23:16, 24:20, 24:23, 68:6, 97:8 discusses [1] - 28:15 83:10 DCF [3] - 86:20, 86:24, 28:4, 46:9, 74:16, determine [5] - 19:16, discussing [2] - 3:19, dual [1] - 100:3 89:24 74:18, 75:3, 78:1, 26:18, 27:5, 28:9, 24:4 due [2] - 8:7, 41:22 deal [6] - 41:16, 50:22, 81:6, 81:9, 81:14, 28:10 discussion [11] - 2:8, duplicate [1] - 96:23 83:13, 90:24, 91:12, 81:19, 83:10, 83:12, determined [2] - 13:7, 7:8, 10:21, 46:12, duration [2] - 38:18, 91:13 84:24, 85:2, 103:20 73:18 60:22, 66:23, 68:5, 84:5 dealing [4] - 69:9, Deferral [1] - 99:4 develop [1] - 77:11 85:15, 101:3, 101:8, during [25] - 3:13, 7:3, 72:19, 104:17, deferrals [17] - 15:20, 111:14 8:16, 13:9, 15:12, 105:13 developer [1] - 52:8 16:6, 16:10, 16:11, development [12] - discussions [1] - 15:23, 17:16, 19:12, deals [7] - 35:15, 16:13, 16:23, 24:7, 110:2 19:24, 20:6, 20:24, 40:13, 41:3, 50:9, 8:13, 33:6, 41:6, 24:10, 24:17, 25:5, dislocation [1] - 6:16 21:1, 27:3, 27:21, 50:13, 55:11, 90:2 49:9, 49:13, 50:13, 26:1, 26:19, 27:14, 51:2, 51:4, 51:10, disposition [1] - 73:6 29:7, 30:16, 30:24, dealt [1] - 82:4 44:20, 45:11, 74:1 51:21, 53:10, 58:7 dispute [2] - 56:15, 31:8, 31:19, 31:24, debating [1] - 7:23 deferred [2] - 47:22, differ [1] - 98:13 74:8 32:8, 46:7, 62:3, debt [15] - 7:20, 7:22, 77:19 difference [6] - 25:24, Dispute [1] - 4:9 75:8, 96:4 32:3, 32:7, 32:10, deferring [1] - 82:5 26:23, 61:10, 70:14, distinguish [2] - During [1] - 16:5 32:11, 85:20, 93:20, defining [1] - 51:9 74:17, 90:3 50:10, 51:11 DVORSKY [2] - 106:8, 93:21, 96:18, 97:2, definitely [1] - 111:14 106:15 97:3, 98:12, 98:18 differences [2] - distress [1] - 6:16 degree [5] - 29:24, 102:15, 103:21 distributed [1] - 77:6 DEC [2] - 102:12, 54:14, 79:19, 95:5, 107:14 different [6] - 45:10, distribution [4] - 35:8, E 102:9 62:18, 74:21, 74:22, 53:18, 72:23, 108:14 decade [1] - 8:14 deliberation [1] - 6:8 86:9, 106:6 District [1] - 17:21 December [2] - 14:16, e-mail [3] - 58:12, delivery [18] - 6:24, differential [4] - 30:1, divestiture [2] - 13:9, 79:23 58:19, 58:21 9:3, 9:8, 14:21, 86:7, 87:7, 90:20 15:1 decide [4] - 26:21, earliest [2] - 20:11, 14:23, 16:14, 20:24, difficult [4] - 11:14, dollar [3] - 15:11, 90:14, 106:6, 111:24 90:18 24:5, 31:17, 40:1, 32:24, 68:2, 102:17 30:3, 45:3 decided [3] - 4:14, early [1] - 77:2 41:23, 42:11, 42:16, difficultly [1] - 95:23 dollars [8] - 11:23, 87:15, 87:20 earn [2] - 29:6, 92:24 42:22, 42:24, 44:15, difficulty [2] - 57:8, 14:8, 15:3, 49:15, Decision [1] - 105:10 earned [1] - 93:3 45:4, 45:6 57:10 79:12, 79:21, 80:4, decision [10] - 2:11, earnings [6] - 8:3, Delivery [1] - 9:10 dime [1] - 28:2 95:11 6:8, 11:2, 43:10, 31:9, 69:6, 93:4, demand [5] - 42:13, dimensions [1] - 65:8 done [9] - 47:11,
7
93:7, 93:16 12:8, 44:9 52:8 74:4 expire [2] - 41:10, easily [1] - 93:23 elsewhere [1] - 82:4 enure [2] - 68:20, 69:5 examining [2] - 5:9, 41:17 echo [1] - 48:21 embedded [1] - 93:20 enures [1] - 69:1 87:4 expiring [1] - 49:24 economic [12] - 6:15, embrace [1] - 105:17 environmental [1] - example [9] - 30:9, explain [3] - 74:19, 33:6, 41:6, 49:8, embraced [1] - 51:10 17:24 45:2, 47:3, 51:23, 74:20, 101:15 49:13, 50:13, 51:2, embracing [1] - 58:23 EPA [1] - 102:12 52:6, 52:15, 61:18, explanation [1] - 28:8 51:3, 51:10, 51:21, emergencies [1] - equal [2] - 45:7, 46:3 73:16, 74:22 explicit [1] - 49:19 53:10, 58:6 3:13 equation [2] - 97:4, except [3] - 2:19, explicitly [1] - 55:12 economists [1] - 8:9 Empire [1] - 2:5 97:17 60:13, 99:18 exposed [1] - 95:4 economy [2] - 53:16, employed [1] - 70:13 equipment [1] - 18:5 excepted [2] - 40:9, expressed [2] - 25:11, 93:9 employee [1] - 17:16 equity [12] - 7:20, 8:2, 40:11 39:16 Ed [6] - 35:3, 67:16, employees [5] - 48:19, 31:23, 32:2, 57:20, exception [1] - 33:11 Expressions [1] - 2:12 87:13, 89:19, 90:22, 48:22, 62:6, 69:14, 85:17, 85:19, 86:2, exceptions [4] - extend [1] - 43:19 90:23 69:17 88:24, 93:18, 33:11, 43:12, 43:13, extent [6] - 29:23, Edison [2] - 68:14, employing [1] - 75:16 108:24, 109:2 82:13 37:5, 38:9, 54:16, 74:24 encompass [1] - escalation [1] - 76:6 excepts [1] - 66:7 96:16, 108:6 Edison's [1] - 81:4 27:14 ESCOs [3] - 99:20, excess [3] - 20:21, extreme [1] - 42:21 EDOT [2] - 108:19, encourage [2] - 48:7, 99:22, 100:3 104:5, 104:17 extremely [1] - 48:22 109:15 78:22 essence [1] - 88:12 exchange [1] - 96:22 eye [2] - 56:14, 111:19 effect [2] - 25:23, 84:8 end [34] - 4:14, 4:16, essentially [4] - 50:10, excludable [1] - 69:21 eyes [1] - 107:22 effective [1] - 53:13 9:19, 9:20, 10:12, 59:15, 61:9, 90:11 exclude [1] - 68:17 effectively [1] - 53:19 14:11, 14:19, 16:21, establish [3] - 75:4, excluded [2] - 62:3, F efficiencies [3] - 17:4, 17:8, 23:19, 84:3, 91:15 62:9 65:23, 67:9, 69:4 24:1, 24:11, 24:18, established [6] - excluding [1] - 41:13 efficiency [3] - 14:24, 25:3, 25:18, 25:23, 86:17, 89:22, exclusion [1] - 69:3 face [1] - 70:21 [1] 77:6, 93:8 26:8, 26:11, 26:13, 103:14, 104:5, exempt [2] - 60:15, faced - 93:10 effort [3] - 19:9, 95:10, 26:16, 28:1, 28:6, 104:6, 104:18 60:17 facilities [3] - 52:1, 107:10 29:15, 41:11, 43:6, estimate [7] - 14:4, existing [2] - 54:19, 52:17, 106:18 eight [3] - 75:17, 44:5, 44:9, 45:20, 14:7, 28:18, 37:16, 62:21 facility [1] - 51:23 91:18, 100:18 50:7, 50:18, 55:15, 37:20, 64:7, 103:10 exists [1] - 53:14 facing [1] - 40:23 either [9] - 5:15, 5:20, 83:9, 83:18 estimated [12] - 17:2, exit [2] - 41:20, 42:5 fact [12] - 18:7, 25:20, 25:5, 41:7, 48:24, ends [2] - 6:21, 33:24 17:8, 24:16, 24:21, Exit [1] - 42:1 27:1, 30:22, 55:13, 60:9, 68:21, 102:19, energy [3] - 52:5, 24:24, 27:24, 29:3, expand [2] - 52:16, 73:23, 74:10, 82:14, 108:17 77:5, 93:8 29:12, 30:4, 30:9, 53:16 89:4, 92:13, 107:10 factor [5] - 22:11, elected [1] - 99:12 Energy [1] - 46:24 32:6, 32:7 expanded [1] - 47:12 76:6, 82:20, 89:11, electric [14] - 4:5, engage [1] - 51:12 estimates [6] - 20:11, expatriates [1] - 62:4 93:6 5:10, 11:15, 38:7, engaged [1] - 90:6 21:6, 29:22, 35:11, expect [2] - 21:22, 45:4, 48:13, 52:2, engineering [2] - 9:13, 102:15, 103:12 34:1 factors [3] - 36:6, 62:18, 105:4 52:17, 72:16, 72:20, 23:6 estimating [1] - 24:18 expectation [1] - 8:18 failed [1] - 47:22 72:24, 76:1, 106:17, engineers [1] - 8:8 estimation [3] - 34:15, expected [4] - 22:23, 108:14 England [1] - 7:6 35:12, 39:8 30:24, 50:12, 57:12 failure [1] - 38:19 Faint [1] - 5:4 electrical [1] - 72:5 enhance [1] - 52:22 etc [1] - 89:12 expecting [1] - 43:5 fairly [2] - 73:6, 101:22 electricity [2] - 11:7, enjoy [1] - 96:18 event [2] - 18:14, 19:3 expects [1] - 22:23 faith [2] - 21:5, 107:10 11:18 enroll [1] - 56:5 events [2] - 10:21, expenditure [2] - 13:3, element [7] - 9:9, ensemble [1] - 4:22 27:11 34:6 fall [6] - 26:8, 27:1, 27:7, 27:9, 78:6, 15:17, 32:12, 40:11, ensure [2] - 39:17, evolution [1] - 101:16 expenditures [6] - 6:4, 42:4, 55:16, 63:3 93:15 exact [3] - 106:9, 33:14, 33:24, 34:2, 84:4 elements [2] - 35:20, Enter [1] - 14:14 106:10, 109:20 35:5, 107:10 falls [2] - 26:14, 26:15 [2] 44:7 entered [3] - 11:8, exacting [1] - 29:24 expense [7] - 10:4, familiar - 33:15, ELFNER [11] - 46:11, 12:3, 12:8 exactly [2] - 73:21, 71:19, 74:8, 77:16, 40:2 51:14, 52:10, 52:13, entering [1] - 6:10 88:2 77:18, 79:18, 108:23 family [2] - 47:1, 47:2 52:15, 53:12, 55:11, Entering [1] - 11:11 Exactly [2] - 60:20, expenses [3] - 54:7, Family [2] - 47:1, 47:4 56:2, 56:12, 58:15, entire [2] - 14:6, 66:15 84:10 61:18, 93:13 far [2] - 10:13, 71:5 58:20 entirely [2] - 54:24, exaggerated [1] - experience [2] - fashioned [1] - 51:5 Elfner [2] - 9:21, 45:21 102:11 61:22 21:17, 36:10 fault [1] - 82:7 eligibility [1] - 48:3 entitled [2] - 6:12, examination [3] - experiencing [2] - faulting [1] - 82:11 eliminated [3] - 42:5, 63:5 35:22, 105:1, 105:11 3:14, 32:5 fearing [1] - 103:3 56:1, 62:20 entity [2] - 80:17, examine [3] - 27:8, expert [1] - 23:6 feature [1] - 7:7 eliminating [1] - 44:5 107:18 64:18, 77:17 experts [1] - 8:8 February [1] - 9:5 elimination [3] - 7:12, entrepreneur [1] - examined [2] - 73:21, expiration [1] - 45:19 Federal [1] - 11:10
8
federal [5] - 78:17, 54:7 fully [4] - 44:21, 77:8, grid [4] - 77:14, 80:5, headquarters [1] - 80:7, 99:4, 99:10, flat [1] - 46:7 81:23, 88:8 81:4, 109:7 3:11 99:12 flex [5] - 41:3, 41:4, function [4] - 39:9, Grid [30] - 3:20, 5:13, heads [1] - 3:12 feds [1] - 78:19 41:5, 41:10, 49:23 76:11, 99:17, 100:2 5:24, 6:24, 7:6, 7:19, health [1] - 47:14 fee [1] - 48:15 flexibility [2] - 49:14, fund [4] - 31:3, 63:8, 8:17, 9:7, 14:14, healthy [2] - 73:6, 94:1 feeble [1] - 65:10 102:8 63:11, 74:14 14:15, 28:23, 33:22, HEAP [2] - 46:23, 47:7 fees [3] - 41:20, 42:1, Floor [2] - 1:8, 2:5 funded [2] - 14:23, 52:18, 72:14, 73:1, hear [3] - 4:15, 32:19, 42:5 flow [2] - 86:21, 99:5 55:7 73:17, 80:4, 80:6, 100:23 few [9] - 4:19, 19:23, flu [1] - 32:17 funding [9] - 46:17, 80:10, 81:5, 97:3, heard [2] - 60:13, 42:7, 48:3, 48:9, flyover [1] - 59:12 47:8, 47:12, 49:11, 97:8, 97:16, 97:20, 100:21 76:9, 81:2, 99:3, focus [5] - 97:15, 49:12, 50:10, 50:21, 97:24, 98:2, 98:13, Hearings [1] - 4:9 101:4 97:23, 101:1, 52:3, 54:1 98:16 heating [5] - 47:8, figure [7] - 9:1, 13:24, 111:10, 111:19 future [5] - 34:11, Grid's [6] - 5:10, 7:14, 47:12, 47:13, 47:15, 14:1, 15:9, 18:4, focused [2] - 6:2, 45:14, 75:10, 75:12, 14:17, 49:13, 78:21, 48:13 85:9, 94:16 70:14 105:22 96:17 heavily [1] - 97:7 file [10] - 16:2, 26:3, focusing [1] - 55:17 grounds [1] - 99:21 hedges [1] - 41:1 26:9, 46:5, 83:9, follow [8] - 27:12, G group [13] - 40:20, held [3] - 2:3, 49:16, 91:5, 91:6, 91:10, 28:23, 29:12, 59:20, 40:23, 41:2, 42:19, 60:6 91:23 79:11, 80:20, 89:9, 43:7, 65:15, 86:22, help [4] - 19:4, 37:12, gain [1] - 60:7 filed [8] - 2:16, 33:10, 89:18 87:2, 89:3, 97:20, 37:13, 50:11 gained [2] - 69:8, 34:7, 37:19, 43:12, followed [1] - 5:14 97:24, 98:2, 98:14 helped [2] - 29:9, 70:17 82:13, 92:18, 94:20 following [7] - 34:12, groups [2] - 40:7, 54:12 gains [1] - 14:24 filing [10] - 27:6, 37:17, 50:19, 53:4, 65:17 helpful [1] - 23:9 game [1] - 107:8 27:10, 37:15, 45:8, 88:12, 94:4, 94:17 grown [3] - 20:10, helping [1] - 49:2 GARRY [1] - 1:14 79:23, 83:8, 84:2, font [1] - 111:19 21:13, 22:11 helps [1] - 34:22 gas [10] - 48:10, 90:18, 95:18, 95:19 footnote [1] - 46:2 growth [2] - 22:8, Herculean [1] - 19:17 48:11, 72:19, 73:5, 105:5 final [8] - 2:13, 6:10, forecast [5] - 30:24, high [5] - 8:13, 59:12, 76:1, 76:4, 87:14, 10:2, 22:12, 25:1, 54:16, 89:11, 89:16, guess [3] - 34:22, 71:12, 92:7, 101:5 89:5, 106:18 28:14, 41:20, 50:18 110:6 81:7, 107:6 higher [5] - 9:6, 30:21, gateway [1] - 46:23 finally [1] - 64:1 forgiveness [1] - guesstimate [1] - 37:3, 92:22, 95:14 gathering [1] - 58:10 Finally [3] - 17:23, 48:10 107:11 highest [1] - 97:21 general [11] - 2:9, 6:6, [1] 31:12, 100:7 form [8] - 41:9, 52:7, guide - 18:23 highly [1] - 83:5 8:5, 47:21, 53:15, gut [1] - 101:19 financial [5] - 8:8, 56:21, 56:22, 57:2, hill [1] - 77:21 58:24, 66:14, 75:15, 8:20, 57:16, 57:23 61:15, 69:10, 74:15 hire [1] - 48:17 [1] 102:18, 103:23, financials - 69:1 formal [1] - 2:10 H historic [5] - 51:12, 104:15 financing [1] - 13:22 formerly [1] - 6:21 61:21, 66:9, 70:14, generally [1] - 94:9 findings [5] - 33:18, forms [1] - 106:21 89:16 generate [1] - 54:2 half [16] - 14:7, 29:4, 34:14, 34:16, 35:2, formula [2] - 92:7, historical [2] - 36:4, generation [7] - 13:9, 30:11, 33:23, 36:23, 62:1 104:7 71:5 13:18, 15:1, 39:14, 37:2, 78:21, 79:4, fine [1] - 32:19 forth [2] - 2:14, 20:13 Historically [1] - 56:18 72:24, 73:4, 77:6 80:3, 81:15, 81:18, finest [1] - 4:23 forward [14] - 5:14, history [10] - 10:19, generic [3] - 105:12, 88:24, 90:21, 91:16, finger [1] - 65:1 16:9, 21:2, 21:17, 20:9, 21:5, 41:22, 105:24, 106:14 91:18, 92:1 finish [2] - 5:16, 108:5 35:18, 37:17, 37:24, 51:1, 51:16, 78:14, genuinely [1] - 99:2 hand [2] - 68:24, 78:7 finished [1] - 7:11 38:7, 39:11, 41:1, 104:9, 104:16, 107:4 Given [1] - 104:8 handle [1] - 36:8 firm [1] - 64:5 43:8, 88:10, 90:14, hold [2] - 46:7, 64:17 given [4] - 77:24, 78:2, handled [1] - 8:24 First [4] - 6:9, 32:22, 105:19 holders [1] - 92:14 89:3, 107:11 handout [1] - 59:18 60:14, 99:18 fought [1] - 95:23 holding [1] - 78:3 goal [1] - 44:4 hang [1] - 3:15 first [15] - 4:15, 8:12, four [8] - 6:7, 14:6, holds [1] - 63:8 goals [1] - 45:18 hangs [1] - 111:17 12:22, 18:13, 25:10, 14:22, 15:12, 47:4, home [1] - 99:3 Governor [2] - 3:10, happy [1] - 3:16 33:13, 42:9, 42:15, 55:18, 65:16, 72:13 Home [1] - 46:23 3:12 hard [4] - 4:23, 5:6, 46:21, 55:16, 76:19, fourth [1] - 6:19 hope [1] - 86:13 grant [6] - 51:21, 52:8, 32:23, 70:13 97:12, 102:1, 106:23 freeze [1] - 94:10 hourly [3] - 40:14, 52:12, 52:21, 52:24, harder [1] - 107:9 fiscal [3] - 7:15, 70:16, friends [1] - 86:12 HARRIS [5] - 1:15, 40:21, 40:23 70:18 79:2 fringe [3] - 70:6, household [1] - 47:2 grants [1] - 78:24 32:16, 80:3, 81:2, five [14] - 12:21, 14:4, 70:16, 108:21 housekeeping [1] - graph [1] - 42:11 83:3 14:6, 17:1, 27:8, fuel [2] - 110:6, 110:8 84:21 Great [1] - 62:7 Harris [4] - 3:7, 32:15, 33:24, 36:24, 37:2, full [12] - 13:13, 13:18, 80:13, 82:24 Hudson [1] - 67:16 59:3, 83:8, 90:7, great [1] - 29:23 15:15, 16:3, 20:20, huge [2] - 38:2, 59:23 greater [4] - 15:22, head [2] - 79:2, 111:3 91:14, 93:3, 93:24 24:1, 26:15, 26:21, headed [1] - 9:19 human [1] - 73:17 fixed [3] - 53:13, 54:1, 29:2, 29:13, 48:6 22:3, 31:7, 75:7
9
hundred [2] - 53:6, 13:8, 13:10, 62:10, industrial [5] - 11:16, introduced [1] - 7:3 itself [3] - 42:6, 43:1, 104:16 68:16, 69:19, 81:11, 42:14, 52:10, 55:23, introducing [3] - 4:12, 98:18 hurdles [1] - 95:17 81:15, 81:17 57:10 9:4, 71:6 included [12] - 15:15, inflation [4] - 109:16, Investigation [1] - J I 17:19, 17:20, 31:5, 109:19, 110:8, 18:1 35:20, 39:17, 62:16, 110:10 investigation [7] - JAMES [1] - 1:16 66:21, 66:24, 69:24, influences [1] - 97:7 20:17, 22:14, 38:2, idea [3] - 16:22, 64:12, Jamestown [2] - 90:4, 103:10 inform [1] - 72:8 63:13, 100:7, 64:15 76:19, 76:20 includes [4] - 27:17, informal [1] - 2:11 101:21, 102:10 identified [3] - 33:16, JANUARY [1] - 1:6 38:15, 65:20, 77:10 information [9] - 2:10, investment [3] - 33:3, 35:10, 39:9 January [10] - 2:4, 3:2, including [2] - 69:6, 3:24, 22:5, 39:5, 51:22, 92:20 identify [1] - 10:3 3:23, 9:7, 10:9, 93:6 58:10, 70:15, 81:21, investors [4] - 92:14, identifying [1] - 49:1 84:11, 91:10, 91:23, inclusion [1] - 68:23 87:10, 102:4 93:4, 93:15, 93:18 ill [1] - 62:5 112:8, 112:9 income [15] - 33:6, infrastructure [4] - invited [1] - 66:16 illustrates [1] - 43:2 job [1] - 39:18 46:16, 46:20, 47:1, 37:12, 52:5, 53:14, involve [1] - 102:24 illustration [2] - 44:14, Joe [12] - 4:23, 8:12, 47:2, 47:3, 47:6, 53:19 involved [2] - 34:24, 44:19 10:10, 20:7, 33:21, 47:19, 47:21, 48:14, initiative [2] - 67:6, 78:8 immediate [1] - 60:5 36:22, 44:20, 70:24, 48:15, 49:5, 56:6, 67:12 involves [3] - 76:14, 71:12, 72:12, 72:18, immediately [4] - 58:6, 99:12 initiatives [5] - 65:21, 77:5, 100:3 29:4, 30:11, 91:7, 92:23 incomplete [1] - 5:11 66:10, 67:4, 67:21, IOU [4] - 24:14, 25:21, join [1] - 3:9 94:20 inconsistency [2] - 109:13 28:6, 28:11 impact [6] - 9:18, joining [2] - 3:6, 3:8 106:17, 107:5 input [1] - 34:7 IOUs [1] - 28:2 57:19, 64:9, 73:10, joint [16] - 6:9, 6:21, increase [30] - 5:19, inputs [1] - 111:8 IPPs [1] - 12:14 73:11, 79:13 7:7, 8:6, 9:19, 10:21, 8:21, 9:2, 9:8, 9:11, inquiries [1] - 10:12 irrelevant [1] - 82:23 impacts [4] - 9:4, 14:18, 15:17, 15:24, 11:12, 16:15, 22:16, insolvency [1] - 7:14 IRS [2] - 99:11, 99:13 45:10, 45:14, 105:7 16:23, 17:14, 22:17, 24:4, 24:5, 26:12, instance [3] - 70:22, Island [1] - 106:9 implement [1] - 6:17 23:1, 31:1, 31:8, 28:5, 28:20, 29:10, 102:1 ISO [1] - 40:23 implementation [2] - 99:7 30:20, 30:23, 31:9, instances [1] - 79:16 issue [34] - 7:20, 12:3, 89:1, 102:20 jointly [1] - 80:17 43:18, 43:24, 44:3, Instead [1] - 74:15 12:16, 13:4, 41:3, implemented [2] - JR [1] - 1:15 44:8, 44:15, 44:17, instructed [1] - 81:5 41:15, 41:17, 41:19, 5:22, 89:5 judge [2] - 71:15, 46:3, 46:17, 47:8, instructing [1] - 46:8 42:3, 43:3, 57:3, important [4] - 28:19, 67:23, 78:3, 99:21, 100:14 instructs [1] - 46:5 60:1, 66:7, 68:1, 49:4, 56:4, 99:15 109:4 JUDGE [63] - 4:13, integrate [1] - 35:7 68:2, 69:8, 69:12, impose [1] - 105:20 increased [11] - 16:16, 4:19, 5:5, 21:24, integrated [1] - 7:5 75:23, 77:20, 77:22, impossible [1] - 30:2 24:5, 28:21, 39:12, 23:10, 26:24, 27:20, intended [1] - 2:9 80:2, 82:21, 83:5, impressed [2] - 68:9, 48:10, 54:6, 58:21, 30:6, 45:23, 59:7, intends [2] - 46:7, 83:13, 88:6, 96:13, 68:10 64:10, 67:8, 99:5, 59:19, 60:21, 61:7, 46:9 96:16, 99:6, 100:2, improve [2] - 35:12, 110:8 61:16, 62:2, 63:7, intent [2] - 62:22, 101:1, 101:15, 57:5 increases [4] - 16:6, 64:3, 64:24, 65:12, 75:14 106:1, 106:6 improved [1] - 69:1 31:13, 45:15, 58:6 68:4, 70:5, 70:11, intention [1] - 94:7 issued [1] - 81:3 71:19, 71:22, 72:1, improves [1] - 69:5 increasing [3] - 11:22, issues [28] - 10:3, intentions [1] - 94:18 72:11, 74:7, 75:14, improving [1] - 52:4 45:18, 58:1 11:2, 32:24, 33:5, Interest [1] - 88:19 75:20, 75:22, 77:21, impute [1] - 66:22 incremental [1] - 33:17, 34:23, 36:16, interest [10] - 10:15, 82:10, 82:14, 83:4, imputed [5] - 65:19, 19:17 40:8, 40:10, 40:13, 54:18, 54:23, 54:24, 83:16, 83:20, 83:23, 66:16, 67:13, 67:18, incur [4] - 21:22, 41:20, 47:15, 50:5, 63:23, 88:18, 93:24, 84:2, 84:10, 84:17, 67:21 22:23, 75:7, 75:10 59:8, 59:9, 59:12, 94:2, 97:4, 109:17 84:23, 85:5, 85:12, imputing [1] - 66:21 incurred [3] - 30:1, 60:14, 61:23, 65:8, interim [1] - 26:3 86:1, 90:15, 94:22, inaccuracies [1] - 2:7 57:12, 62:19 76:8, 76:18, 82:4, interject [1] - 10:14 95:3, 99:2, 99:16, incentive [14] - 30:16, incurs [1] - 103:22 99:18, 100:11, internal [1] - 66:3 101:17, 103:7, 52:18, 54:10, 56:5, indefinite [1] - 84:5 100:17, 100:19, internally [1] - 99:12 103:18, 104:8, 56:10, 57:21, 70:1, independent [6] - 101:18, 107:24 interpretation [1] - 104:13, 104:21, 90:4, 90:5, 103:1, 11:9, 11:23, 12:2, issuing [1] - 7:22 99:6 105:10, 108:2, 103:11, 104:1, 12:5, 12:6, 12:16 item [9] - 4:2, 17:19, interrupt [1] - 10:14 108:5, 108:18, 106:10, 107:18 indicate [1] - 71:4 17:23, 25:8, 50:11, interruption [1] - 109:10, 109:14, incentives [5] - 52:20, indicated [1] - 91:5 73:23, 74:8, 76:13, 38:17 109:16, 111:6 68:15, 68:20, 69:18, indication [2] - 64:13, 101:13 intervening [2] - Judge [5] - 4:7, 4:8, 69:19 91:1 items [8] - 15:20, 70:15, 70:18 40:10, 91:5, 99:1 incessant [1] - 32:18 indices [1] - 68:21 17:15, 46:13, 71:2, Intervenors [4] - judges [5] - 4:7, 8:20, inclined [1] - 102:23 indirectly [1] - 53:9 71:4, 71:10, 99:3, 49:10, 49:23, 60:5, 87:18, 88:7, 96:1 include [10] - 2:8, 9:2, individual [1] - 22:9 111:8 67:16
10
jump [2] - 59:12, 20:7, 21:2, 21:12, lighted [2] - 71:12, low [18] - 33:5, 46:16, math [2] - 110:11, 63:20 21:15, 22:6, 22:19, 101:5 46:20, 47:6, 47:19, 111:2 justification [4] - 36:3, 25:7, 25:16, 26:4, likelihood [1] - 64:7 47:21, 48:14, 48:15, matter [3] - 2:11, 65:1, 53:6, 63:4, 63:18 26:14, 50:24, 52:7, likely [1] - 98:5 49:5, 56:5, 58:6, 100:22 justified [1] - 63:2 52:12, 53:5, 54:21, limitation [1] - 47:3 91:17, 93:20, 93:21, matters [12] - 5:16, justify [1] - 61:14 55:9, 59:17, 60:18, limited [1] - 42:2 94:2, 96:17, 97:21, 5:18, 9:22, 9:24, 61:13, 62:23, 63:16, line [3] - 32:15, 37:1, 98:20 10:7, 27:19, 65:9, K 63:23, 64:20, 65:4, 49:14 lower [6] - 31:14, 84:21, 95:6, 95:8, 101:11, 103:4, lines [3] - 18:24, 31:22, 32:1, 32:4, 96:8, 102:10 103:13, 104:2, 44:16, 81:7 38:1, 98:18 MAUREEN [1] - 1:15 keep [3] - 24:3, 30:14, 104:11, 104:14, link [1] - 22:7 lowering [1] - 40:18 maximum [1] - 58:2 56:14 104:23, 105:16, list [2] - 107:24, 108:9 lowest [2] - 11:6, MCGOWAN [3] - keeping [1] - 54:19 106:16, 108:3 listening [1] - 86:13 40:17 63:22, 109:12, 110:5 kept [1] - 29:6 [1] Larocca - 3:6 litigated [5] - 10:3, mean [8] - 30:1, 45:3, key [3] - 44:7, 50:3, Larocca's [1] - 54:11 59:10, 76:9, 90:11, M 60:21, 61:4, 91:5, 93:6 Last [2] - 9:7, 49:12 100:11 92:10, 94:9, 110:12 KeySpan [19] - 28:24, last [20] - 7:11, 8:2, litigation [7] - 10:1, meaning [1] - 57:11 29:19, 31:3, 33:22, macro [2] - 31:14, 8:10, 27:13, 29:16, 55:14, 56:16, 95:6, meaningful [3] - 38:23, 65:22, 66:12, 64:4 34:4, 34:21, 36:23, 95:20, 95:22, 96:10 44:24, 45:5, 82:23 66:18, 66:22, 71:24, Madam [1] - 112:3 40:3, 40:12, 42:7, lives [1] - 76:15 means [5] - 36:15, 72:4, 72:6, 72:10, magnitude [1] - 42:10 42:20, 43:2, 45:24, load [1] - 54:6 38:9, 40:22, 52:23, 72:15, 72:22, 72:23, mail [4] - 56:22, 58:12, 47:11, 48:9, 51:23, loads [1] - 37:11 69:24 73:15, 73:24 67:13, 76:4, 101:13 58:19, 58:21 locate [1] - 11:18 measure [1] - 29:24 kind [11] - 21:5, 50:5, late [7] - 77:14, 77:17, main [3] - 28:17, Lochner [3] - 8:12, measured [1] - 104:15 54:10, 57:20, 78:6, 46:21, 51:20 79:23, 81:22, 82:2, 70:24, 92:23 measurement [2] - 79:18, 90:5, 90:19, 82:8 maintain [1] - 37:13 LOCHNER [40] - 79:22, 80:23 91:12, 91:15, 94:15 maintenance [1] - Law [1] - 4:7 10:16, 14:3, 14:11, measures [6] - 38:17, kinds [4] - 78:5, 78:8, 74:11 law [4] - 11:10, 99:5, 15:10, 18:7, 19:7, 38:18, 55:17, 55:18, 95:7, 104:9 major [17] - 6:7, 17:18, 99:10, 99:14 19:22, 20:4, 20:16, 55:19, 57:15 known [1] - 5:22 17:23, 18:10, 18:11, lay [1] - 9:16 21:9, 21:14, 21:19, mechanical [1] - 84:3 kw [2] - 40:16, 40:19 18:17, 18:19, 19:3, lead [3] - 53:17, 76:12, 22:12, 22:21, 23:5, mechanism [33] - 30:20, 31:12, 32:3, 102:14 23:12, 25:14, 25:18, 10:22, 15:19, 16:8, 32:12, 37:10, 46:14, L leading [1] - 4:10 26:6, 26:16, 27:16, 18:8, 18:9, 18:11, 77:8, 93:13, 95:16 leads [2] - 66:23, 27:23, 28:14, 29:23, 19:13, 25:17, 40:1, 82:16 Major [1] - 108:23 labor [4] - 70:10, 71:3, 30:8, 30:19, 63:10, 40:5, 60:12, 60:22, leaning [1] - 69:24 manage [2] - 27:9, 71:11, 108:20 64:12, 64:23, 72:13, 65:13, 75:13, 78:1, learn [1] - 57:4 82:12 Labor [1] - 70:6 72:21, 73:11, 74:23, 83:10, 84:3, 93:7, management [12] - learned [1] - 63:3 99:9, 109:18, 110:4, 100:8, 101:14, lack [1] - 95:12 7:15, 33:15, 33:16, least [4] - 7:8, 83:8, 110:6, 110:15, 102:2, 102:17, lag [1] - 76:12 33:19, 34:13, 34:17, 92:7, 108:11 110:21, 111:1 102:19, 102:21, language [5] - 111:9, 35:1, 35:3, 39:9, leave [2] - 34:19, look [12] - 27:10, 103:1, 104:1, 111:13, 111:16, 67:8, 69:13, 72:24 83:15 45:11, 63:20, 70:13, 104:17, 104:19, 111:20 mandate [1] - 77:2 left [1] - 17:9 71:17, 87:13, 91:14, 105:17, 105:20, languages [1] - 84:19 mandated [1] - 11:9 legal [1] - 64:24 91:19, 102:18, 106:11 large [27] - 11:16, [1] Mandatory - 40:13 mechanisms [4] - 17:19, 17:20, 19:23, legislation [1] - 39:15 105:2, 106:1, 111:21 mandatory [1] - 40:21 33:4, 84:19, 93:11, 20:5, 25:4, 26:7, legitimacy [1] - 64:18 looked [1] - 36:4 manner [1] - 43:23 93:15 28:15, 30:20, 40:15, less [10] - 37:13, Looking [1] - 95:5 manufacturing [2] - meet [11] - 34:1, 37:2, 42:14, 42:21, 43:4, 37:14, 37:21, 47:18, looking [14] - 18:3, 52:1, 52:22 38:19, 39:1, 39:5, 43:17, 44:22, 45:1, 56:3, 64:17, 75:10, 20:8, 21:2, 21:19, March [1] - 33:24 56:9, 57:11, 95:16, 45:2, 45:5, 49:23, 84:12, 93:3, 102:22 33:17, 35:15, 35:18, market [6] - 11:15, 111:23, 112:7 60:15, 65:15, 65:17, lesser [1] - 15:22 37:20, 38:3, 61:17, 12:11, 40:24, 88:9, Meeting [2] - 1:3, 73:2, 76:13, 80:23, lessons [1] - 22:7 61:24, 62:19, 102:3, 88:11, 98:12 112:12 95:24 level [11] - 9:6, 21:20, 109:21 [1] [2] marketing - 51:5 meeting [7] - 2:2, 2:8, largely [3] - 7:21, 22:22, 24:6, 29:20, looks - 35:24, Massachusetts [1] - 59:24, 84:3 30:5, 30:9, 34:9, 86:20 34:3, 36:7, 38:22, 62:8 39:18, 112:10 larger [5] - 18:14, 37:13, 38:1, 88:20 lose [1] - 71:15 master [1] - 12:4 megawatt [1] - 76:21 47:13, 54:7, 54:18, levels [4] - 21:22, losses [3] - 13:8, match [1] - 87:3 67:16 36:18, 93:23, 93:24 13:17, 71:18 megawatts [1] - 40:20 matching [3] - 52:21, members [1] - 3:4 LAROCCA [38] - 1:16, liability [1] - 75:11 lost [5] - 14:8, 15:11, 78:18, 78:23 13:24, 14:10, 15:8, light [1] - 8:13 30:15, 41:22, 78:12 memory [1] - 65:11
11
mention [1] - 31:11 16:17, 16:19, 17:4, moderate [2] - 12:15, 21:19, 22:12, 22:21, 46:1, 69:6, 69:12, mentioned [4] - 24:8, 17:6, 17:9, 17:16, 29:10 23:5, 23:12, 25:14, 78:4, 79:14, 84:18, 33:21, 44:20, 89:19 17:19, 18:2, 18:17, moderated [1] - 28:21 25:18, 26:6, 26:16, 84:21, 95:16, 96:6, mentioning [1] - 31:11 18:19, 19:2, 19:5, modified [8] - 43:11, 27:16, 27:23, 28:14, 100:24, 101:10, Merchant [1] - 99:17 19:8, 19:18, 20:1, 43:21, 44:1, 44:3, 29:23, 30:8, 30:19, 111:4 merchant [2] - 76:11, 20:2, 20:14, 20:22, 44:7, 44:12, 44:15, 32:14, 32:20, 35:1, needs [8] - 21:16, 100:2 22:15, 23:18, 24:4, 45:16 36:17, 36:21, 46:11, 25:9, 27:3, 33:17, merger [30] - 6:9, 24:9, 24:12, 24:16, modify [1] - 12:14 51:14, 52:10, 52:13, 35:12, 35:24, 39:18, 6:21, 7:2, 8:6, 9:19, 25:19, 25:20, 25:22, Mohawk [34] - 3:21, 52:14, 52:15, 53:12, 48:24 10:21, 14:18, 15:1, 26:2, 26:19, 27:13, 4:4, 6:24, 7:13, 7:19, 53:20, 54:15, 55:4, negates [1] - 63:4 15:17, 15:24, 16:23, 28:1, 28:7, 28:19, 10:19, 11:6, 11:15, 55:11, 56:2, 56:12, negative [3] - 38:18, 17:14, 22:17, 23:1, 29:8, 29:18, 30:21, 11:20, 12:1, 12:3, 58:15, 58:20, 63:10, 39:1, 57:12 28:22, 28:23, 29:3, 37:10, 37:14, 37:21, 12:12, 12:19, 14:15, 63:22, 64:12, 64:23, negatively [1] - 98:5 31:1, 31:3, 31:8, 38:19, 39:20, 42:16, 14:17, 15:2, 17:7, 72:13, 72:21, 73:11, negotiation [1] - 11:21 33:22, 36:23, 38:23, 42:17, 42:22, 42:23, 24:17, 41:21, 61:19, 74:23, 79:10, 79:20, negotiations [1] - 12:2 65:20, 65:22, 65:24, 44:20, 45:11, 46:18, 61:20, 66:1, 72:16, 80:13, 99:9, 106:8, net [13] - 13:8, 13:17, 66:6, 66:22, 99:7 49:11, 49:12, 51:11, 75:15, 89:5, 89:7, 106:15, 109:12, 16:11, 16:13, 17:2, mergers [3] - 28:24, 53:4, 53:7, 58:2, 93:19, 97:1, 97:10, 109:18, 110:4, 17:8, 18:4, 30:23, 29:1, 29:12 60:3, 60:9, 60:19, 97:19, 98:3, 98:8, 110:5, 110:6, 39:13, 39:19, 76:14, message [1] - 79:6 60:24, 63:18, 64:1, 98:11, 98:17 110:15, 110:21, 110:12 met [4] - 25:12, 39:4, 64:14, 64:16, 65:2, Mohawk's [7] - 5:9, 111:1 never [1] - 29:24 57:14, 106:23 65:6, 65:23, 66:3, 7:4, 7:15, 11:12, MRA [3] - 12:12, Nevertheless [1] - meter [1] - 39:13 66:6, 66:11, 66:12, 12:21, 98:6, 98:15 12:24, 13:15 57:16 metering [2] - 39:13, 66:13, 66:16, 66:18, moment [1] - 101:12 MS [11] - 81:13, 86:11, NEW [1] - 1:1 66:20, 67:2, 67:14, 39:19 money [10] - 37:6, 86:15, 89:21, 90:23, new [11] - 25:9, 25:12, 67:18, 67:21, 67:23, meters [3] - 42:13, 61:15, 63:19, 63:21, 91:4, 92:4, 92:8, 29:18, 34:14, 37:11, 56:2, 80:24 70:7, 73:12, 73:13, 78:18, 80:7, 80:21, 97:1, 98:11, 110:18 37:22, 39:16, 45:9, 74:9, 74:14, 75:23, method [3] - 85:21, 97:3, 98:20 multi [3] - 87:17, 54:18, 82:12, 111:17 76:14, 76:15, 77:15, 88:17, 89:23 monies [1] - 61:5 87:22, 90:2 New [18] - 1:9, 1:15, 79:1, 79:2, 79:4, [3] methodologies [1] - month [5] - 26:10, multi-year - 87:17, 1:16, 2:3, 2:5, 3:7, 80:4, 81:15, 81:18, 70:13 47:9, 47:24, 48:5, 87:22, 90:2 7:6, 11:7, 11:10, 81:19, 84:12, 92:16, [2] methodology [8] - 48:11 Multiple - 49:10, 13:10, 40:23, 51:4, 99:5, 108:14, 76:16, 76:17, 86:20, monthly [1] - 99:24 49:22 62:8, 86:9, 87:4, 108:15, 108:19, 86:21, 87:12, 87:18, months [7] - 9:6, 27:8, myopically [1] - 92:11 89:10, 93:10 108:20, 108:22, 88:7, 88:23 50:7, 53:2, 81:3, newly [2] - 25:12, 108:23, 109:2, metric [1] - 39:10 83:8, 84:1 N 62:16 109:3, 109:5, 109:7, metrics [14] - 34:15, Moody's [3] - 96:19, news [1] - 94:9 109:8, 110:16, 34:22, 35:10, 38:15, 97:6, 97:17 next [32] - 3:22, 16:12, 110:21, 110:22 Narragansett [6] - 38:20, 38:23, 39:2, moot [3] - 41:17, 22:5, 34:18, 36:21, mind [3] - 92:6, 28:24, 29:19, 66:6, 39:4, 39:6, 39:7, 41:18, 42:3 36:24, 40:12, 43:9, 100:24, 105:4 67:20, 108:13, 39:16, 39:20, 39:22, morning [8] - 3:1, 3:5, 44:1, 44:13, 49:8, minimum [1] - 47:22 108:18 97:16 3:10, 4:12, 10:16, 50:12, 53:2, 55:5, ministerial [1] - 85:6 National [31] - 3:20, MHP [1] - 40:16 32:14, 46:11 55:11, 65:5, 68:1, minor [1] - 31:9 5:9, 5:13, 5:24, 6:24, MI [7] - 40:9, 41:14, Most [1] - 76:8 82:2, 90:17, 94:17, minus [5] - 7:21, 97:5, 7:5, 7:14, 7:19, 8:17, 42:4, 44:10, 60:14, most [7] - 3:15, 6:6, 94:21, 100:23, 98:15, 110:2, 110:12 9:7, 14:14, 14:15, 65:14, 67:6 7:7, 10:4, 38:6, 101:8, 106:6, minuses [1] - 110:13 14:16, 28:23, 33:22, Michael [4] - 51:15, 47:19, 48:22 106:20, 107:24, minute [3] - 34:20, 72:14, 73:1, 73:17, 55:2, 79:1, 82:21 mostly [2] - 6:3, 60:13 111:7, 111:11, 59:3, 101:13 80:4, 80:6, 80:10, motion [1] - 4:2 111:23, 112:7 middle [1] - 84:15 81:5, 96:17, 97:3, missing [1] - 25:16 Next [1] - 6:15 Might [1] - 110:11 move [6] - 56:3, 59:14, 97:8, 97:15, 97:20, misunderstand [1] - Niagara [41] - 3:20, might [17] - 10:13, 90:14, 92:2, 96:13, 97:24, 98:2, 98:13 98:10 105:19 4:4, 5:9, 6:24, 7:4, 18:5, 23:8, 44:14, nature [3] - 18:24, mix [1] - 72:10 7:13, 7:15, 7:19, 61:10, 61:11, 64:8, movement [1] - 58:24 79:12, 104:8 mixed [1] - 78:15 Moving [1] - 70:5 10:19, 11:6, 11:12, 69:19, 77:21, 82:16, necessarily [5] - 2:13, MJP [7] - 18:8, 19:2, 11:15, 11:20, 12:1, 82:20, 85:14, 91:22, moving [2] - 58:13, 69:12, 79:24, 87:3, 22:17, 31:19, 31:23, 12:3, 12:12, 12:19, 92:17, 94:18, 102:7 101:21 37:4, 37:5 107:16, 111:19 [68] 12:21, 14:15, 14:17, MR - 10:16, 14:3, necessary [3] - 73:22, mode [2] - 75:1, 15:2, 17:7, 24:17, million [119] - 5:19, 14:11, 15:10, 18:7, 89:2, 95:10 8:19, 8:22, 12:13, 102:13 19:7, 19:22, 20:4, 41:21, 61:19, 61:20, need [16] - 16:2, models [1] - 86:22 65:24, 72:16, 75:15, 12:16, 16:12, 16:15, 20:16, 21:9, 21:14, 24:14, 28:21, 33:8,
12
89:4, 89:6, 93:19, NYPA [1] - 44:10 80:3, 80:6, 80:8, outcome [2] - 104:12, 10:19, 39:14, 43:3, 97:1, 97:10, 97:18, NYSEG [6] - 74:22, 81:9, 81:15, 81:18, 104:14 49:22 98:3, 98:5, 98:8, 74:23, 89:20, 89:21, 86:24, 89:9, 90:11, outcomes [1] - 107:3 particulars [1] - 86:7 98:11, 98:15, 98:17 90:7, 90:21 91:14, 91:19, 102:7, outlined [1] - 83:6 parties [19] - 9:10, NIMO [2] - 36:16, 105:4, 106:3, 106:5, outlook [3] - 97:14, 19:18, 32:22, 33:10, 73:10 O 106:20, 107:3, 97:15, 97:22 33:18, 34:15, 39:16, Nine [2] - 6:23, 7:9 107:6, 112:2 outside [1] - 64:7 40:9, 43:12, 43:22, nine [9] - 8:3, 8:10, One [8] - 5:15, 27:12, outstanding [1] - 96:5 49:7, 49:22, 50:4, O&M [7] - 18:6, 18:22, 14:22, 17:3, 20:17, 28:18, 33:21, 51:22, overage [1] - 104:19 50:19, 68:11, 69:10, 28:18, 28:20, 29:10, 21:1, 48:18, 92:21, 62:2, 105:19, 106:17 overall [10] - 21:13, 70:20, 100:5 33:3, 92:23 93:5 ongoing [2] - 20:24, 21:20, 22:8, 22:10, parties' [2] - 9:23, objectionable [1] - Nine-tenths [1] - 7:9 91:7 29:10, 30:5, 31:16, 100:21 70:21 Nobody [1] - 83:21 OPEBs [2] - 17:15, 57:17, 78:2, 97:19 pass [1] - 12:23 objectives [1] - 6:18 noise [2] - 82:17, 71:24 overcharged [1] - passed [1] - 27:14 observation [1] - 82:20 open [3] - 5:19, 83:12, 61:20 past [8] - 8:14, 10:13, 107:7 non [5] - 42:13, 48:16, 107:22 overlap [1] - 66:18 10:21, 11:5, 68:6, obtain [2] - 8:18, 77:5, 77:7, 96:21 opening [1] - 85:8 overly [1] - 50:2 82:2, 86:19, 92:21 11:21 non-answers [1] - operate [1] - 14:5 overrun [1] - 103:8 path [1] - 37:24 obtains [1] - 29:13 96:21 operated [1] - 31:20 overruns [3] - 107:9, PATRICIA [1] - 1:14 obvious [1] - 47:14 non-demand [1] - operating [2] - 7:16, 107:12, 107:13 Patty [1] - 89:9 obviously [2] - 49:15, 42:13 25:10 overseen [1] - 8:10 pay [18] - 12:13, 15:6, 77:1 non-payment [1] - operation [1] - 8:10 overspend [1] - 49:19 16:24, 20:6, 24:1, Obviously [1] - 22:19 48:16 operations [10] - 5:10, overspends [1] - 47:23, 48:5, 68:1, occupied [1] - 59:23 non-wireless [2] - 7:3, 7:15, 8:4, 11:18, 49:18 68:13, 68:17, 68:19, occur [2] - 18:16, 77:5, 77:7 13:10, 57:5, 62:7, overstated [1] - 63:14 68:22, 69:7, 69:13, 27:11 noon [1] - 59:4 72:4, 87:15 owe [3] - 25:21, 28:2, 79:8, 98:20, 109:6 occurred [1] - 28:22 normalized [1] - 61:23 opinions [1] - 2:12 28:7 paying [3] - 42:24, occurrence [1] - normally [1] - 54:12 opportunity [3] - owed [1] - 75:11 55:7, 103:19 102:15 note [3] - 33:18, 83:7, 62:15, 82:19, 93:2 owes [1] - 28:11 payment [4] - 47:22, occurring [1] - 27:21 97:18 opposed [7] - 53:8, own [5] - 7:22, 13:17, 48:8, 48:11, 48:16 occurs [2] - 18:22, noteworthiness [1] - 60:4, 61:19, 82:5, 53:22, 90:18, 97:1 payments [2] - 11:22 10:4 27:7 85:22, 99:20, 100:5 penalties [1] - 38:24 OF [1] - 1:1 noteworthy [1] - 7:7 opposition [1] - 49:7 P pending [3] - 3:19, offer [1] - 100:6 Nothing [1] - 112:5 optimize [1] - 35:9 60:2, 61:2 [1] nothing [1] - 63:1 Office - 4:8 option [2] - 45:13, penetration [1] - [1] notice [1] - 42:15 office - 3:7 100:6 p.m [1] - 112:12 39:13 [1] notion [1] - 69:4 officers - 62:6 options [3] - 61:11, Pace [4] - 76:18, pension [2] - 71:24, [1] NRDC [4] - 76:18, Offices - 2:4 105:19, 108:1 76:21, 77:4, 77:11 73:24 76:21, 77:4, 77:11 offs [2] - 75:23, 76:1 order [39] - 14:4, 46:4, page [2] - 28:14, 40:12 pensions [2] - 17:15 number [38] - 19:6, offset [5] - 18:20, 47:24, 50:4, 57:23, paid [4] - 23:24, 69:18, people [3] - 4:19, 19:8, 20:8, 20:15, 25:17, 31:12, 52:4, 59:20, 59:21, 60:16, 69:20, 83:18 18:15, 48:20 22:3, 23:7, 37:8, 74:11 65:16, 66:4, 66:7, paper [2] - 2:16, 98:20 per [3] - 24:24, 74:9, 41:5, 44:24, 45:13, offsetting [3] - 79:24, 66:19, 67:10, 67:19, parent [4] - 96:20, 100:4 49:23, 51:6, 59:8, 81:16, 81:22 67:22, 70:8, 74:12, 97:12, 98:9, 98:19 perceived [1] - 87:21 62:12, 63:2, 63:5, old [1] - 51:5 76:2, 76:5, 76:10, parentage [1] - 96:17 Percent [1] - 56:2 63:6, 64:2, 64:5, older [1] - 76:3 76:16, 76:24, 77:1, part [14] - 2:10, 4:22, percent [48] - 8:1, 64:11, 65:9, 67:18, once [3] - 106:7, 77:10, 81:3, 85:1, 7:5, 15:8, 18:7, 11:13, 12:10, 14:22, 67:22, 81:18, 88:14, 106:9, 106:12 85:10, 85:19, 85:20, 19:13, 45:6, 46:21, 29:5, 31:18, 31:24, 89:3, 90:4, 90:8, Once [1] - 41:10 85:24, 86:4, 99:7, 47:16, 49:4, 50:3, 32:8, 32:10, 44:23, 92:3, 103:14, one [54] - 5:15, 8:23, 99:23, 100:5, 100:8, 85:10, 88:23, 90:8 45:1, 53:6, 66:24, 103:16, 104:6, 14:7, 19:10, 19:14, 100:15, 104:19, participants [1] - 67:5, 67:7, 67:11, 104:18, 105:5, 20:10, 25:24, 26:22, 108:9, 110:5 47:18 76:6, 85:17, 85:18, 108:24, 109:24 29:4, 29:11, 30:11, Order [1] - 2:15 participate [2] - 80:15, 85:19, 86:3, 86:4, numbers [12] - 20:10, 31:12, 33:23, 35:17, orders [1] - 19:15 97:2 86:5, 87:16, 87:19, 21:7, 21:13, 21:17, 36:23, 36:24, 37:2, ordinary [1] - 74:11 participation [1] - 87:23, 88:13, 88:15, 21:18, 29:22, 70:9, 38:8, 40:11, 42:4, original [3] - 21:18, 46:23 88:17, 89:20, 92:12, 77:24, 85:14, 45:12, 45:23, 47:2, 23:4, 28:22 particular [5] - 35:23, 93:3, 93:5, 93:20, 108:16, 109:17, 48:23, 51:23, 65:15, originally [1] - 56:15 47:20, 75:9, 77:2, 103:8, 103:9, 109:20 66:24, 67:5, 67:11, otherwise [1] - 92:18 106:13 103:16, 104:3, NYISO [1] - 78:16 67:20, 70:11, 78:21, Otherwise [1] - 101:9 particularly [4] - 104:7, 104:16,
13
109:1, 109:3 93:18 12:21, 14:3, 14:5, 60:1, 65:3 9:20, 10:22, 14:18, percentage [1] - 64:16 planning [7] - 34:6, 15:12 process [13] - 9:1, 9:3, 15:18, 15:24, 16:23, perception [1] - 94:4 34:23, 35:5, 35:8, power [10] - 11:8, 46:5, 50:10, 59:9, 17:14, 22:17, 23:1, perfectly [2] - 27:23, 35:19, 35:21, 91:2 11:9, 11:24, 12:2, 61:12, 62:22, 64:18, 27:8, 31:1, 31:8, 104:21 plans [2] - 34:5, 34:6 12:5, 12:6, 12:15, 76:7, 77:10, 77:13, 38:23, 42:8, 43:11, perform [2] - 6:1, plant [8] - 8:11, 13:18, 12:17, 12:24, 52:18 82:10, 103:15 43:19, 43:21, 44:1, 99:24 15:1, 30:23, 31:4, practice [3] - 75:15, processes [1] - 34:6 44:4, 44:8, 44:12, performance [8] - 31:7, 76:21, 92:20 101:22, 103:23 producers [6] - 11:9, 44:16, 45:16, 47:7, 34:15, 36:4, 38:16, Plaza [1] - 2:5 Practices [1] - 11:11 11:24, 12:2, 12:5, 48:14, 53:3, 76:24, 39:7, 39:10, 39:22, PLC [1] - 98:16 practices [1] - 48:8 12:7, 12:17 77:4, 77:7, 77:12, 55:17, 57:7 pleading [1] - 2:16 praise [2] - 5:4, 5:5 productivity [5] - 86:2, 94:1, 99:7, performed [1] - 18:23 pleasurable [1] - 5:2 precedent [3] - 86:17, 52:22, 65:21, 66:14, 102:4, 102:5, 105:13 performing [1] - 56:18 plug [2] - 19:6, 29:21 105:21, 107:23 66:23, 67:1 Proposal [1] - 104:18 performs [1] - 39:11 Plus [1] - 27:19 Precisely [1] - 86:1 professionals [1] - proposals [3] - 9:10, perhaps [5] - 53:9, plus [7] - 27:20, 44:23, precluding [1] - 90:17 4:24 53:1, 82:12 63:24, 79:14, 107:2, 45:1, 47:24, 67:11, premise [1] - 61:13 profile [2] - 97:11, propose [1] - 41:18 107:16 110:1, 110:12 premium [6] - 87:21, 98:4 proposed [9] - 5:19, period [26] - 6:15, pluses [1] - 110:13 88:2, 90:1, 90:5, profit [1] - 73:6 9:8, 36:2, 36:11, 8:16, 13:1, 14:4, PMUs [2] - 79:21, 91:12, 91:21 program [17] - 20:11, 67:14, 71:13, 74:13, 15:18, 17:17, 18:15, 80:23 preoccupation [1] - 46:16, 46:20, 46:22, 78:16, 85:16 19:13, 19:24, 20:6, point [28] - 8:24, 101:14 46:23, 47:5, 47:16, proposes [2] - 70:23, 20:24, 24:8, 26:10, 10:10, 10:13, 11:1, prepared [2] - 99:11 47:17, 47:21, 48:2, 99:19 26:19, 28:10, 29:7, 17:1, 22:12, 24:19, preparing [1] - 111:7 49:13, 50:16, 52:19, proposing [2] - 102:2, 30:17, 31:1, 33:24, 27:13, 28:9, 30:8, present [3] - 10:11, 52:20, 56:6 103:24 38:21, 70:15, 71:5, 31:4, 31:22, 34:21, 16:9, 50:16 Program [1] - 46:24 protect [1] - 93:13 79:11, 96:4, 100:13, 37:5, 54:11, 68:8, presentation [7] - programs [17] - 35:5, protections [1] - 102:8 71:13, 74:2, 77:19, 4:22, 10:11, 10:17, 35:8, 35:9, 36:1, 92:14 periodically [2] - 34:4, 83:17, 83:21, 94:6, 28:15, 32:13, 45:21, 36:2, 36:18, 37:11, provide [15] - 10:18, 36:8 96:19, 105:6, 105:9, 78:12 37:12, 37:23, 38:4, 23:18, 24:16, 28:11, periods [1] - 102:9 107:2, 108:1, 109:9 presented [1] - 22:24 50:22, 51:21, 51:22, 41:8, 45:17, 52:20, perspective [4] - 41:7, pointed [1] - 71:3 presenter [2] - 8:13, 52:24, 55:3, 55:8, 57:18, 57:20, 57:21, 42:10, 92:5, 105:15 points [13] - 10:15, 10:3 58:4 65:16, 72:24, 74:24, petitioned [1] - 14:15 57:20, 87:23, 88:3, presenters [2] - 4:6, progress [1] - 35:18 103:12 phase [3] - 52:18, 89:1, 90:7, 90:8, 4:12 prohibition [1] - 90:16 provided [9] - 13:14, 56:16 91:18, 91:19, 91:20, pressure [1] - 11:20 project [14] - 21:10, 13:19, 13:23, 36:3, phases [1] - 20:12 91:22, 100:21 presume [2] - 21:3, 52:5, 78:16, 78:17, 48:4, 56:4, 70:19, phasor [2] - 79:21, polarized [1] - 77:23 21:4 80:6, 80:10, 80:11, 71:9, 102:4 80:23 pole [1] - 18:24 pretty [5] - 32:23, 80:16, 80:19, 81:4, Provides [1] - 49:14 phone [1] - 58:9 policies [3] - 39:15, 35:2, 35:22, 40:5, 81:6, 81:9, 81:10 provides [5] - 47:5, phones [1] - 58:11 74:21, 74:22 59:20 projected [4] - 21:22, 52:3, 60:16, 73:15, physically [1] - 41:24 policy [2] - 104:15, prevent [1] - 76:20 37:14, 38:1, 72:15 73:17 pick [1] - 29:17 105:3 previously [4] - 22:4, projecting [2] - 21:16, providing [7] - 31:16, picture [1] - 22:9 pool [2] - 97:3, 98:20 56:4, 104:5, 104:6 37:21 31:23, 34:7, 40:24, 73:18, 92:16, 93:1 piece [3] - 26:7, 42:18, Poor's [3] - 96:20, Previously [1] - 56:21 projection [2] - 34:10, provision [1] - 73:5 43:22 97:7, 97:9 price [1] - 12:11 85:22 provisions [1] - 50:2 pilot [1] - 77:12 portion [4] - 73:12, prices [1] - 40:24 projects [19] - 22:9, provoke [1] - 105:1 place [10] - 6:20, 21:3, 78:20, 78:22, 104:3 pricing [3] - 40:14, 35:11, 36:1, 36:2, 40:4, 41:5, 48:8, position [6] - 7:20, 40:21, 86:22 36:18, 37:11, 37:18, proxy [3] - 86:22, 37:23, 38:4, 77:8, 87:2, 89:3 78:1, 93:12, 104:2, 8:2, 66:5, 66:17, pride [1] - 4:21 78:8, 78:9, 78:11, prudent [2] - 13:3, 106:11, 106:20 105:11, 105:12 primarily [2] - 8:7, placed [1] - 31:6 possibility [1] - 90:16 14:23 79:21, 80:8, 81:11, 13:8 81:16, 104:9, 105:5 PUBLIC [1] - 1:1 places [2] - 22:11, possible [1] - 30:3 principal [1] - 102:18 promise [1] - 10:8 Public [3] - 1:3, 2:3, 101:2 possibly [1] - 94:7 problem [2] - 34:22, promised [1] - 10:2 placing [2] - 65:1 post [1] - 17:16 81:21 11:10 promoting [1] - 40:14 public [3] - 2:2, 3:4, plan [19] - 7:2, 10:22, postponing [1] - procedures [2] - 12:21, 12:23, 14:18, 84:24 35:13, 50:22 properly [3] - 61:18, 47:14 62:17, 73:22 pull [1] - 22:1 14:20, 15:4, 15:16, potential [4] - 25:4, proceed [1] - 50:8 Property [1] - 76:5 purchase [3] - 11:8, 17:3, 29:15, 29:16, 45:14, 88:6, 107:23 proceeding [9] - 2:17, 31:24, 32:9, 43:6, pouring [1] - 5:9 4:2, 13:6, 17:7, proposal [41] - 6:10, 12:15, 99:19 50:13, 50:15, 92:23, Power [6] - 3:21, 4:4, 23:17, 31:15, 50:4, 6:21, 7:8, 8:6, 9:9, purpose [7] - 3:19,
14
10:17, 10:24, 16:1, 9:13, 9:17, 10:18, 29:4, 29:14, 29:18, 23:5, 28:17, 30:9, 63:10, 63:11, 82:17, 21:21, 62:22, 71:15 10:22, 11:2, 12:21, 30:11, 30:24, 31:8, 48:23, 54:12, 57:4, 103:5 purposes [8] - 2:10, 12:22, 14:18, 14:20, 31:17, 37:3, 37:7, 58:4, 62:4, 68:12, recorded [2] - 16:7, 4:1, 5:23, 7:8, 7:24, 15:4, 15:6, 15:16, 41:3, 43:16, 45:9, 76:15, 102:5, 74:1 71:13, 103:12, 111:6 16:2, 16:14, 21:21, 45:18, 46:6, 46:7, 105:14, 108:13 recover [10] - 16:7, pursue [3] - 6:17, 22:1, 22:13, 24:4, 53:23, 60:3, 60:6, reason [6] - 19:8, 16:8, 16:15, 17:10, 57:1, 57:3 24:22, 26:9, 26:12, 60:9, 62:10, 62:16, 54:16, 71:15, 87:24, 24:14, 25:5, 25:24, pushing [1] - 78:4 28:16, 28:17, 29:15, 62:20, 62:21, 63:14, 100:13, 103:10 28:3, 41:22, 75:9 put [3] - 11:20, 93:12, 30:10, 30:20, 30:22, 64:18, 68:16, 68:17, reasonable [3] - 64:7, recoverable [1] - 106:11 31:14, 31:16, 31:17, 68:23, 69:3, 69:7, 73:22, 76:17 62:20 putting [2] - 40:3, 31:22, 31:24, 32:9, 69:19, 70:7, 75:5, reasonableness [1] - recovered [5] - 16:12, 58:11 33:4, 34:8, 34:9, 75:8, 84:4, 84:5, 38:5 23:15, 24:9, 26:20, 35:17, 36:11, 37:15, 84:7, 85:1, 85:21, reasoned [1] - 71:14 27:17 Q 37:17, 38:7, 40:13, 88:18, 88:19, 91:23, reasons [1] - 36:24 recoveries [5] - 23:16, 41:4, 41:5, 41:10, 94:10, 94:12, 97:4, rebounded [1] - 88:20 83:11, 83:12, 84:24, 43:24, 44:3, 44:8, 103:19, 108:19, recalculations [1] - 85:2 qualifications [1] - 44:16, 45:8, 45:9, 109:1, 109:5, 109:7 99:24 recovery [16] - 13:4, 47:1 45:14, 45:15, 47:11, rather [2] - 21:18, receivables [1] - 99:20 15:15, 17:5, 17:12, qualify [2] - 47:21, 48:10, 49:11, 49:23, 101:1 receive [6] - 6:12, 23:18, 24:16, 28:11, 109:11 50:7, 50:15, 53:3, rating [5] - 7:22, 14:9, 47:7, 103:8, 42:2, 46:9, 63:6, quality [12] - 55:12, 54:8, 55:20, 58:6, 86:13, 97:8, 97:19, 103:9, 111:8 71:2, 80:11, 81:3, 55:20, 57:7, 68:21, 60:23, 61:8, 72:17, 97:23 received [1] - 80:7 81:8, 103:8 87:6, 89:24, 95:19, 73:12, 76:8, 78:3, ratings [8] - 87:8, receiving [2] - 11:17, Recovery [1] - 24:6 96:16, 97:20, 97:24, 79:17, 82:12, 84:8, 89:6, 97:5, 97:10, 97:4 recurring [1] - 103:20 98:2, 105:13 84:9, 85:9, 86:10, 98:6, 98:13, 98:15, recent [8] - 51:3, red [1] - 43:6 quantified [1] - 62:9 90:11, 90:17, 92:13, 98:16 51:19, 57:7, 58:6, reduce [8] - 25:6, questioned [1] - 65:14 92:16, 92:23, 95:5, ratio [3] - 85:17, 76:3, 79:17, 88:18, 25:20, 25:24, 26:1, questions [11] - 10:11, 95:18, 96:7, 98:9, 85:19, 109:3 101:14 26:22, 40:16, 84:16, 49:21, 57:2, 59:13, 98:18, 98:20, 99:20, rationale [2] - 69:15, recently [3] - 8:24, 109:5 63:4, 92:10, 98:24, 100:1, 103:21, 104:12 89:20, 95:11 reduced [6] - 12:23, 100:18, 101:6, 105:7, 108:21, rationalize [1] - 107:9 Recess [1] - 59:5 14:21, 16:19, 30:11, 107:1, 111:5 109:17, 110:10 Ravenswood [1] - recognition [1] - 67:18, 88:24 quick [1] - 79:10 ratemaker [1] - 102:16 73:7 49:19 reduces [5] - 67:19, quicker [1] - 56:24 ratemaking [6] - 5:10, RD [26] - 43:14, 43:18, recognize [1] - 8:1 67:21, 93:7, 109:1, quickly [4] - 51:15, 5:23, 7:24, 22:2, 43:21, 66:7, 66:15, recognized [3] - 13:1, 109:3 59:15, 91:3, 111:19 102:6, 103:12 66:16, 66:20, 67:10, 86:15, 87:11 reducing [5] - 15:5, quite [3] - 48:8, 72:5, ratepayer [7] - 16:24, 67:17, 67:24, 69:23, recognizing [2] - 41:1, 55:16, 93:11, 95:20 52:4, 54:1, 54:4, 70:8, 72:9, 76:6, 47:12, 107:22 109:7 quote [1] - 97:9 54:5, 55:1, 55:7 85:17, 86:4, 86:15, recollection [2] - 80:5, reduction [8] - 14:23, ratepayers [22] - 20:6, 87:11, 92:3, 99:22, 80:14 26:12, 32:3, 32:11, 53:7, 53:9, 53:15, 99:23, 105:12, R recommend [3] - 60:3, 45:1, 45:3, 45:6, 54:24, 63:20, 68:20, 108:10, 108:13, 74:3, 88:21 94:11 69:18, 75:9, 75:12, 110:1 recommendation [6] - reductions [3] - 12:22, raise [1] - 98:18 95:1, 95:2, 95:3, RD's [1] - 109:23 48:12, 60:8, 77:20, 69:5, 90:6 raised [3] - 10:15, 99:8, 103:17, RDM [10] - 40:3, 40:4, 83:18, 101:17, refer [1] - 68:3 60:14, 76:18 103:19, 104:4, 40:7, 40:9, 40:11, referencing [1] - 85:21 raises [2] - 97:1, 98:11 109:23 104:7, 104:16, 60:15, 89:1, 89:4, recommendations [4] referring [1] - 89:10 Raj [9] - 4:23, 9:16, 105:8, 106:24 93:7 refined [1] - 102:19 9:18, 9:21, 34:19, - 10:6, 50:8, 100:20, rates [89] - 4:3, 6:20, RDMs [1] - 40:2 49:20, 54:9, 80:22, 110:2 refinement [1] - 69:22 7:1, 9:3, 9:4, 9:18, reaching [1] - 33:1 recommended [4] - reflect [7] - 2:13, 83:6 11:6, 11:12, 12:20, reaction [1] - 101:19 43:10, 64:4, 76:6, 12:19, 29:2, 70:9, ran [1] - 14:7 13:23, 14:9, 14:21, read [2] - 56:2, 111:21 86:4 88:9, 88:11, 97:7 range [8] - 20:22, 16:4, 17:5, 17:13, reading [1] - 69:9 recommending [3] - reflected [9] - 15:22, 32:2, 35:4, 35:7, 20:19, 20:23, 20:24, ready [1] - 10:10 45:17, 88:16, 100:15 19:12, 22:16, 24:5, 44:23, 57:24, 61:23, 22:4, 23:17, 23:24, real [3] - 5:5, 5:6, 64:5 reconciliation [5] - 31:8, 32:4, 53:23, 90:22 24:3, 24:5, 24:7, realities [1] - 20:13 38:8, 40:7, 65:15, 71:10, 88:19 rare [1] - 70:22 24:9, 24:12, 25:6, realize [1] - 25:7 65:17, 93:14 reflecting [2] - 37:1, Rate [1] - 44:14 25:20, 25:24, 26:1, realized [1] - 66:8 reconnection [1] - 92:22 rate [109] - 3:19, 5:14, 26:3, 26:23, 27:2, reallocate [1] - 43:22 48:15 reflective [1] - 97:5 5:16, 6:2, 6:5, 7:2, 27:3, 28:21, 29:3, really [15] - 3:14, 16:1, 8:17, 8:23, 9:8, 9:10, record [5] - 2:11, reflects [4] - 67:12,
15
74:10, 92:19, 103:5 repairing [1] - 18:5 13:20, 34:8, 44:3, RG&E [2] - 74:24, SC-2 [4] - 42:12, refund [4] - 61:6, 61:8, repairs [1] - 74:11 87:2, 91:17 89:21 42:13, 43:16, 43:19 61:9, 63:12 replace [1] - 37:12 resulted [2] - 10:20, RG&E's [1] - 90:8 SC-3 [5] - 42:13, refunded [1] - 61:10 replacing [2] - 18:5, 14:24 rights [1] - 49:2 42:21, 43:3, 43:17, refunding [1] - 61:12 18:23 resulting [1] - 12:24 risk [8] - 30:15, 35:9, 44:22 refurbished [1] - 52:1 reply [2] - 33:11, 43:12 results [10] - 5:21, 64:10, 87:3, 87:7, SC-3A [3] - 42:14, regale [1] - 104:10 report [2] - 50:8, 50:17 57:12, 59:16, 60:2, 89:11, 89:16, 93:11 43:3, 45:2 regard [2] - 106:23 reporting [1] - 38:13 61:2, 62:12, 62:13, risks [1] - 96:9 scenario [1] - 104:3 regarding [2] - 49:23, reports [1] - 97:6 86:20, 86:23, 98:4 ROBERT [1] - 1:15 scenes [1] - 82:18 55:14 representation [1] - retain [3] - 41:7, ROE [6] - 86:8, 86:17, schedule [4] - 27:4, regardless [1] - 81:14 20:20 64:17, 74:9 86:19, 87:16, 89:22, 83:11, 85:7 regards [1] - 5:12 represented [1] - retained [3] - 8:3, 90:5 scheduled [1] - 112:9 region [2] - 54:20, 12:10 42:1, 74:12 Room [1] - 2:5 Second [2] - 6:11, 93:10 represents [1] - retirement [1] - 17:16 roughly [1] - 64:3 100:2 register [1] - 104:24 103:15 retiring [1] - 76:21 round [1] - 5:14 second [9] - 41:3, regularly [1] - 112:9 request [1] - 77:17 retriggering [1] - 96:7 rounds [1] - 5:15 44:16, 46:1, 47:16, regulate [1] - 7:3 requesting [1] - 80:4 retrospective [1] - Rudy [10] - 4:8, 4:13, 56:20, 60:19, 71:21, regulated [1] - 51:4 require [3] - 73:3, 20:15 4:15, 4:24, 10:2, 77:4, 106:22 regulations [2] - 4:4, 75:5, 100:5 Return [2] - 86:2, 40:10, 60:18, 61:4, Secondly [1] - 18:16 18:12 required [4] - 12:13, 108:24 71:20, 108:17 Secretary [1] - 112:3 Regulatory [1] - 11:11 16:6, 31:3, 76:22 return [18] - 13:13, rule [2] - 91:13, SECRETARY [1] - regulatory [8] - 8:6, requirement [7] - 13:19, 13:21, 14:8, 102:18 112:5 13:2, 13:11, 13:22, 18:10, 25:12, 61:1, 15:7, 15:12, 15:15, ruled [2] - 79:16, 81:2 see [27] - 12:13, 13:16, 14:13, 15:14, 23:14, 64:14, 92:17, 92:19, 23:24, 30:21, 31:14, rules [2] - 4:3, 18:12 25:3, 26:7, 31:15, 28:1 93:22 31:17, 31:22, 31:23, run [3] - 47:24, 85:14, 37:1, 42:11, 43:15, reject [1] - 104:19 requirements [4] - 32:2, 61:14, 88:24, 108:8 43:17, 43:23, 44:3, relate [1] - 72:5 15:23, 22:24, 31:19, 93:1, 93:4 running [1] - 95:18 44:23, 45:10, 46:18, related [5] - 6:12, 7:2, 38:13 returned [1] - 49:15 runs [1] - 7:6 53:1, 53:3, 55:9, 51:6, 68:22, 82:4 reserve [10] - 62:23, Revenue [4] - 40:5, 65:5, 65:11, 70:20, relative [1] - 42:10 63:8, 63:10, 74:13, 54:15, 60:12, 83:4 S 71:12, 82:22, 87:8, relatively [1] - 51:2 74:14, 74:15, 74:18, revenue [28] - 5:19, 96:23, 102:22, relevant [1] - 70:9 74:24, 75:2, 93:12 8:21, 9:2, 9:14, 9:17, 106:16, 111:9 safety [1] - 47:15 [2] reliability [7] - 37:13, reserved [3] - 62:13, 15:23, 22:24, 24:15, seeing - 93:4, SAIFI [1] - 38:17 38:16, 38:22, 39:4, 63:2, 64:21 25:12, 25:19, 31:19, 102:1 sale [2] - 13:8, 13:17 39:8, 39:21, 68:21 reset [1] - 29:14 33:4, 33:9, 38:18, seek [1] - 57:18 39:1, 40:1, 43:10, sales [1] - 54:16 relocating [1] - 41:24 residential [4] - 42:12, seeking [1] - 80:11 54:2, 54:3, 54:9, salesmanship [1] - remain [3] - 5:18, 46:4, 55:22, 57:9 seeks [1] - 49:18 51:5 10:5, 107:24 Resolution [1] - 4:9 54:13, 57:12, 60:24, segment [1] - 28:14 64:14, 65:13, 92:17, salient [1] - 68:8 remained [1] - 95:22 resolution [2] - 11:21, segregated [1] - 64:21 92:19, 93:22 salvage [1] - 76:14 remaining [4] - 15:13, 96:6 sell [1] - 73:3 revenues [19] - 6:11, Sandra [1] - 48:20 17:9, 25:5, 26:1 resolve [3] - 10:6, SEMO [1] - 3:11 8:19, 15:22, 24:13, satisfaction [5] - remains [2] - 5:11, 12:3, 13:3 send [1] - 94:13 25:4, 25:9, 25:11, 55:21, 56:21, 57:9, 60:1 resolved [1] - 83:6 sending [2] - 78:9, 25:13, 40:2, 41:22, 57:11, 83:6 remediated [1] - 23:3 resonant [1] - 73:9 78:14 42:11, 42:17, 42:18, sauce [1] - 89:6 remediation [6] - resource [1] - 73:17 sense [8] - 17:11, 42:22, 43:1, 63:11, savings [35] - 10:5, 20:17, 22:14, 100:7, respect [4] - 66:17, 20:4, 29:20, 35:16, 63:13, 77:15 15:2, 28:22, 29:3, 101:22, 102:10, 68:16, 69:17, 111:16 53:16, 62:15, 70:4, reversal [1] - 70:12 29:7, 29:9, 29:13, 107:12 Respectfully [1] - 108:8 reversed [2] - 66:7, 29:14, 29:17, 29:19, Remediation [1] - 54:21 sentence [1] - 97:12 70:12 29:20, 29:24, 30:10, 18:1 response [4] - 56:13, Separate [1] - 39:12 reverses [5] - 66:19, 30:12, 30:16, 65:19, remediations [1] - 56:24, 57:4, 77:6 separate [2] - 39:24, 70:8, 99:23, 108:13, 65:22, 66:3, 66:6, 105:6 responsibility [1] - 70:7 108:19 66:8, 66:10, 66:12, remember [7] - 10:13, 3:11 separately [1] - 50:23 review [12] - 5:10, 66:13, 66:16, 66:20, 19:11, 22:15, 28:19, restoration [3] - September [4] - 87:14, 5:14, 5:17, 5:22, 6:1, 66:21, 67:6, 67:12, 38:21, 72:21, 73:13 17:18, 18:22 87:20, 88:4, 89:22 6:2, 6:4, 8:20, 35:20, 67:13, 67:18, 67:21, remove [1] - 76:22 restored [1] - 7:16 series [2] - 47:11, 58:6 46:19, 81:12, 108:12 68:18, 71:9, 108:15, removed [2] - 23:22, restructure [1] - 11:16 serve [2] - 37:11, 62:7 reviewed [2] - 37:18, 108:20 59:24 restructuring [3] - served [1] - 106:18 95:12 SC-1 [3] - 42:12, renewables [1] - 12:4, 12:8, 13:9 service [39] - 4:5, reviewing [1] - 34:5 42:15, 43:16 39:14 result [7] - 2:17, 9:15, 5:15, 5:18, 5:22,
16
9:15, 31:7, 41:23, 85:20 small [7] - 8:7, 20:1, 71:16, 74:2, 76:2, 75:22, 82:10, 83:4, 42:12, 42:19, 44:5, shortly [1] - 50:6 43:15, 44:2, 46:3, 76:14, 77:12, 77:17, 83:16, 83:20, 83:23, 45:19, 48:16, 52:17, show [3] - 9:18, 36:22, 52:6, 73:12 77:18, 88:12, 88:13, 84:2, 84:10, 84:23, 54:4, 55:12, 55:20, 65:6 smaller [4] - 20:2, 88:14, 88:20, 92:5, 85:5, 85:12, 86:1, 57:7, 57:21, 57:22, showed [1] - 46:2 42:17, 52:15, 52:16 101:18, 102:2, 99:2, 99:16, 108:2, 58:7, 59:22, 62:12, showing [1] - 66:8 Smart [1] - 77:14 102:4, 102:19, 108:5, 108:18, 64:13, 68:21, 72:6, shows [5] - 17:1, 43:9, smart [4] - 58:11, 103:24, 105:14 109:14 72:14, 72:15, 72:22, 44:2, 44:13 80:4, 81:4, 109:7 Staff [7] - 34:3, 66:2, Stegemoeller [1] - 4:8 73:2, 73:5, 73:10, side [6] - 55:1, 71:11, smoke [1] - 82:22 67:5, 67:14, 85:17, stenographer [1] - 4:1 73:15, 73:21, 73:24, 93:18, 93:19, 97:3, SMUD [1] - 80:18 86:3, 100:8 stick [3] - 59:15, 74:4, 76:15, 79:15, 97:17 snow [1] - 3:14 staff's [8] - 64:5, 66:5, 103:11, 105:23 96:5 sided [1] - 75:3 solely [1] - 2:9 67:18, 67:22, 76:17, sticking [1] - 71:5 SERVICE [1] - 1:1 signal [2] - 78:10, solve [1] - 34:22 82:7, 85:20, 88:23 still [12] - 20:2, 25:1, Service [3] - 1:3, 2:3, 94:13 solved [1] - 106:2 Staff's [1] - 35:20 25:21, 45:14, 60:5, 71:24 signals [1] - 78:15 solvency [1] - 7:16 stage [1] - 6:19 60:11, 69:20, 73:8, services [5] - 73:1, signed [1] - 40:9 someone [2] - 98:8, stand [2] - 7:4, 108:10 96:5, 101:2, 101:6, 73:16, 73:17, 73:19 significant [23] - 9:23, 107:8 Standard [3] - 96:20, 111:17 session [13] - 3:3, 13:21, 16:5, 16:13, somewhat [3] - 57:19, 97:7, 97:9 stimulus [2] - 78:18, 3:18, 10:9, 22:5, 17:12, 17:22, 20:2, 87:18, 102:3 standard [5] - 38:16, 80:7 23:9, 50:12, 53:2, 22:8, 22:11, 22:16, somewhere [1] - 57:19, 57:20, 66:24, stipulated [2] - 60:13, 88:4, 89:22, 111:7, 28:16, 31:7, 31:10, 90:21 102:24 76:9 111:10, 112:9 32:10, 37:22, 38:3, sooner [1] - 50:20 standards [2] - 56:9, Stipulation [1] - 36:14 [6] set - 2:14, 6:19, 44:24, 45:5, 46:13, sort [3] - 41:21, 60:10, 57:15 stipulation [26] - 33:6, 29:18, 62:16, 75:24, 71:13, 73:11, 94:11, 84:21 standpoint [1] - 82:11 33:9, 33:13, 33:20, 87:15 105:7 Sort [1] - 85:4 start [9] - 4:11, 4:14, 34:9, 35:14, 36:12, sets [2] - 84:18, 107:1 significantly [3] - sorts [2] - 49:1, 89:15 4:21, 11:4, 14:20, 37:9, 38:8, 38:15, setting [7] - 23:17, 16:4, 32:4, 93:8 sounds [1] - 106:13 15:3, 51:14, 106:4 39:17, 39:23, 39:24, 62:21, 86:17, 93:22, silence [2] - 101:10, source [1] - 52:4 started [3] - 23:20, 40:12, 41:12, 42:1, 105:21, 107:23, 42:8, 49:5, 49:8, 101:12 sources [1] - 67:9 23:21, 59:6 109:2 [1] 50:3, 50:9, 50:18, similar [3] - 35:2, spare [1] - 32:17 Starting - 12:1 settled [3] - 9:24, 55:13, 59:9, 99:18 51:7, 91:11 special [2] - 3:3, 48:24 starts [2] - 11:5, 97:9 95:7, 95:21 [7] stipulations [5] - 9:23, simple [2] - 61:6, 75:3 Special [1] - 1:3 state - 3:15, 21:13, settlement [3] - 87:17, 32:21, 33:1, 33:3, simply [4] - 38:9, specific [4] - 15:20, 22:10, 40:15, 40:18, 87:22, 90:9 33:7 60:24, 75:2, 87:19 35:10, 36:18, 53:1 107:5, 107:17 settlements [1] - 88:1 STATE [1] - 1:1 stop [1] - 71:20 single [2] - 30:3, 52:18 specifically [4] - seven [3] - 28:15, stops [1] - 6:22 SIR [3] - 20:7, 20:23, 50:22, 53:24, 64:21, State [6] - 2:3, 2:5, 32:8, 84:1 Storm [4] - 17:18, 22:14 97:18 11:7, 13:10, 87:5, several [4] - 4:6, 9:23, 93:10 71:19, 74:8, 74:13 Site [1] - 17:24 specify [1] - 46:6 34:4, 40:7 state's [1] - 89:15 storm [24] - 3:14, site [8] - 20:16, 22:14, spend [3] - 33:23, shaking [1] - 79:2 17:18, 17:21, 18:9, 100:7, 101:21, 38:10, 53:4 statement [1] - 2:18 shall [1] - 99:1 [2] 18:10, 18:13, 18:14, 102:10, 106:9, spending [9] - 33:3, states - 11:19, 86:4 share [6] - 14:24, 18:16, 18:17, 18:18, 106:13, 107:11 34:10, 35:8, 35:19, statewide [4] - 20:8, 29:5, 29:13, 78:20, 18:19, 18:22, 19:3, sites [2] - 23:3, 23:7 36:11, 36:18, 37:10, 105:2, 105:11, 78:22 19:11, 19:14, 19:17, situation [3] - 11:14, 38:5, 67:8 106:15 shareholder [2] - 74:9, 74:11, 75:7, 67:11, 107:12 spent [6] - 5:3, 5:8, static [1] - 23:3 53:22, 55:3 75:10, 93:12, 93:14, six [6] - 11:10, 23:13, 34:5, 37:6, 38:3, stating [1] - 4:21 108:23 shareholders [7] - 25:9, 50:7, 53:2, 51:22 status [1] - 80:9 53:8, 53:11, 54:12, storms [8] - 18:3, 55:17 spill [1] - 72:7 stay [3] - 60:8, 102:23, 54:23, 69:2, 69:5, 18:11, 19:12, 19:20, size [3] - 16:22, 47:2, spoken [1] - 4:13 108:8 69:20 19:23, 19:24, 20:2, 47:4 spread [1] - 91:14 stayout [8] - 87:21, shares [1] - 12:16 58:22 skin [1] - 107:8 spreads [1] - 91:19 88:2, 90:1, 90:20, sharing [12] - 54:6, STOUT [11] - 81:13, slap [1] - 95:17 stable [1] - 97:22 91:10, 91:12, 91:21, 100:8, 102:2, 86:11, 86:15, 89:21, slide [11] - 17:1, staff [42] - 3:16, 8:8, 92:6 102:17, 103:1, 90:23, 91:4, 92:4, 23:12, 34:18, 34:20, 24:21, 24:22, 34:10, steam [1] - 87:14 104:18, 105:2, 92:8, 97:1, 98:11, 36:21, 42:9, 43:9, 35:24, 36:11, 36:15, STEGEMOELLER [33] 105:17, 105:20, 110:18 44:13, 45:24, 46:1, 37:18, 38:3, 40:11, - 30:6, 45:23, 59:7, 106:21, 106:24, stranded [3] - 13:15, 55:11 49:6, 49:9, 50:16, 59:19, 60:21, 61:7, 107:21 13:21, 14:1 slides [1] - 42:7 60:4, 64:4, 66:15, 61:16, 63:7, 64:3, shift [1] - 72:11 stream [1] - 24:15 slightly [1] - 98:13 68:5, 68:10, 69:11, 64:24, 65:12, 70:5, short [2] - 26:24, Street [1] - 92:11 Sloane [1] - 48:20 70:17, 70:23, 70:24, 71:19, 71:22, 74:7,
17
street [1] - 86:8 95:5 102:5 touch [1] - 33:2 44:7, 46:21, 56:1, street's [1] - 92:10 survives [1] - 9:9 territory [4] - 54:4, tough [1] - 82:11 60:14, 60:23, 65:16, stretch [1] - 99:3 suspect [1] - 85:14 79:15, 81:9, 81:10 toward [2] - 59:1, 70:3, 70:7, 75:3, stretching [1] - 83:22 suspended [1] - 24:7 test [5] - 61:22, 66:9, 86:24 76:18, 79:21, 80:22, strict [1] - 18:12 suspension [1] - 70:14, 71:5, 83:1 towards [2] - 70:1, 86:24, 90:22, 91:11, strictly [1] - 3:24 26:10 testified [2] - 88:13, 86:24 91:13, 91:15, 91:20, strong [1] - 69:2 sustain [1] - 95:10 88:21 trace [1] - 30:2 95:24, 99:18, stronger [1] - 102:20 sustainable [1] - themselves [2] - tracking [1] - 71:8 100:13, 106:17, strongly [1] - 78:22 94:12 53:17, 96:3 traditional [1] - 89:23 106:21, 106:22, structure [2] - 46:19, symbolism [1] - 77:22 theoretical [1] - 68:12 transactions [2] - 107:1 85:16 synergies [2] - 7:1, theoretically [1] - 53:8 19:15, 91:8 Two [1] - 105:23 studies [1] - 96:5 65:20 theory [1] - 98:17 transcript [5] - 2:2, type [4] - 11:21, 87:24, study [3] - 76:12, 77:1, synergy [2] - 15:2, therefore [2] - 53:14, 2:7, 2:9, 2:12, 2:18 106:10 77:3 71:9 72:6 transformation [1] - typically [1] - 41:8 subject [8] - 9:24, Syracuse [1] - 8:9 thinking [1] - 65:7 108:14 29:22, 61:5, 61:7, system [5] - 7:5, 8:15, third [1] - 86:24 transition [15] - 6:22, U 61:9, 63:12, 64:22, 72:14, 72:23, 80:24 thirds [1] - 86:24 7:4, 7:9, 7:10, 7:13, 81:19 systematic [1] - 7:12 thorough [1] - 35:23 8:14, 9:20, 10:20, ultimate [2] - 97:11, subjects [1] - 63:5 systematically [1] - thousand [1] - 40:19 13:2, 13:11, 14:12, 111:22 submitted [1] - 3:20 6:5 Three [3] - 2:4, 51:20, 15:14, 23:15, 24:12, ultimately [1] - 87:12 substantial [4] - 5:11, 90:24 41:13 unbold [1] - 111:12 9:12, 46:17, 56:17 three [12] - 6:1, 12:23, transmission [3] - T uncertain [1] - 91:4 substitution [1] - 19:24, 33:2, 52:18, 35:7, 76:19, 80:24 uncollectible [1] - 70:15 58:4, 66:10, 67:7, transportation [1] - T&D [1] - 77:8 75:23 subtracted [2] - 87:20, 90:21, 90:23, 110:7 table [2] - 59:21, 71:23 uncontested [1] - 9:22 87:23 105:19, 105:24 treasuries [1] - 91:15 talent [1] - 73:9 Under [3] - 43:14, succeeding [1] - 9:6 threshold [4] - 40:15, treating [1] - 70:1 target [3] - 56:17, 43:18, 50:15 successful [2] - 8:6, 40:17, 40:19, 72:3 treatment [3] - 26:5, 66:3, 66:4 under [16] - 9:10, 96:3 throughout [3] - 3:14, 71:9, 71:11 targeted [1] - 47:17 10:23, 11:9, 12:11, suddenly [1] - 84:12 101:23, 107:5 tree [1] - 18:23 targets [2] - 56:9, 12:12, 12:15, 16:3, sufficient [2] - 67:2, thumb [3] - 65:1, trend [2] - 21:10, 56:14 18:6, 18:11, 18:12, 85:18 91:13, 102:18 21:11 tariff [3] - 40:21, 50:2, 23:1, 27:3, 31:18, suggest [2] - 107:16, Thursday [2] - 3:22, trial [2] - 68:10, 84:19 43:10, 43:18, 60:22 108:1 112:7 105:14 tariffs [3] - 49:24, underlying [1] - suggested [3] - 94:15, ticket [1] - 17:15 tried [1] - 111:10 84:18, 84:19 104:15 107:15, 108:6 tie [2] - 33:14, 76:19 triggered [1] - 96:6 tax [2] - 99:4, 99:13 underpinnings [1] - suggesting [3] - tightening [2] - 56:16, trimming [1] - 18:23 taxes [1] - 76:5 68:12 18:21, 31:15, 83:22 56:18 trouble [1] - 106:4 team [1] - 8:7 underspending [1] - timely [1] - 48:8 true [7] - 30:6, 74:21, summarize [1] - 9:21 38:12 technical [2] - 32:24, summary [1] - 100:10 timetable [1] - 77:3 75:12, 76:6, 99:19, 60:10 underspends [1] - superior [1] - 69:16 timing [3] - 36:2, 90:3, 99:24, 103:21 telephone [4] - 1:15, 49:15 supervising [1] - 102:15 truing [1] - 29:22 3:8, 56:23, 56:24 understood [2] - 107:18 today [11] - 3:16, 3:23, try [9] - 68:3, 78:23, temperament [1] - 5:6 64:22, 104:22 [8] 4:6, 16:20, 101:5, 82:22, 83:1, 102:12, support - 8:21, [1] temporary [7] - 5:20, undertaken - 77:9 76:17, 78:10, 95:12, 101:6, 108:11, 103:11, 111:11, 60:3, 60:9, 60:23, unfortunately [1] - 95:13, 95:14, 102:4, 110:3, 111:18, 111:12, 111:18 61:1, 61:8, 64:18 106:7 102:20 112:4, 112:5 trying [5] - 9:1, 22:7, tend [1] - 74:11 uniform [1] - 101:22 supported [3] - 44:10, today's [2] - 3:18, 7:8 25:14, 105:1, 111:22 [2] tentative [1] - 10:6 union - 69:13, 49:6, 49:9 together [2] - 73:1, turn [3] - 51:15, 65:19, tentatively [1] - 69:17 supports [1] - 78:7 95:17 87:8 unique [2] - 6:15, 108:24 tomorrow [1] - 90:13 turned [1] - 21:8 supposing [1] - 26:2 41:21 tenth [3] - 6:10, 7:11, surcharge [3] - 46:6, took [3] - 70:12, tweak [1] - 46:9 48:19 uniqueness [1] - 83:11, 85:2 87:19, 95:24 twice [2] - 64:3, 66:22 tenths [1] - 7:9 89:10 surrogate [2] - 87:7, top [1] - 103:24 twin [1] - 45:18 units [2] - 79:22, term [7] - 7:2, 62:5, 87:9 total [8] - 14:1, 14:22, two [43] - 4:7, 5:15, 85:20, 97:2, 97:3, 80:23 survey [4] - 56:21, 17:2, 18:17, 42:18, 16:8, 16:12, 19:18, 98:12 universe [1] - 23:2 57:2, 57:9, 57:11 62:9, 64:13, 64:16 23:14, 28:17, 29:11, terms [9] - 6:6, 18:9, Unless [1] - 37:22 surveys [4] - 55:21, totalled [2] - 11:23, 31:13, 34:12, 37:18, 19:1, 45:3, 57:19, unless [1] - 100:23 58:9, 58:10 14:12 38:16, 39:16, 39:20, 61:6, 79:6, 89:11, unofficial [1] - 2:2 survived [2] - 59:9, totalling [1] - 66:11 43:2, 43:6, 43:17,
18
unreasonable [2] - 68:13, 68:17, 68:19, whole [4] - 53:15, 31:24, 34:4, 34:12, 63:14, 74:5 68:22, 69:6, 69:12, 54:17, 70:1, 98:1 36:24, 37:3, 37:8, unrelated [1] - 98:3 69:13 wide [1] - 107:22 37:18, 41:5, 45:13, unresolved [1] - Variable [1] - 109:6 widely [1] - 59:1 48:9, 51:19, 57:8, 107:24 variance [1] - 106:20 willing [1] - 56:8 75:17, 86:19, 88:8, untoward [1] - 63:1 variances [2] - 102:14, win [1] - 71:16 90:21, 90:23, 91:20, unwieldy [1] - 103:2 110:1 wins [1] - 71:18 92:21, 94:13 up [38] - 5:6, 6:9, 8:2, variety [2] - 52:24, wireless [2] - 77:5, yesterday [1] - 25:8 15:20, 17:24, 20:13, 61:17 77:7 YORK [1] - 1:1 23:9, 29:17, 29:22, various [4] - 12:7, wires [1] - 18:24 York [17] - 1:9, 1:15, 30:6, 35:16, 36:11, 36:1, 73:16, 111:20 withholding [2] - 1:16, 2:3, 2:6, 3:7, 37:1, 38:19, 43:22, vary [2] - 54:16, 103:9 63:17, 63:19 7:6, 11:7, 11:10, 47:9, 58:2, 60:19, vehicles [1] - 52:2 won [2] - 78:17, 79:3 13:10, 40:23, 51:4, 65:9, 69:24, 75:13, version [1] - 111:11 wondering [1] - 20:14 62:8, 86:9, 87:4, 76:7, 79:11, 79:23, versus [7] - 22:23, word [1] - 25:1 89:10, 93:10 80:20, 85:8, 89:18, 30:2, 31:18, 43:11, words [4] - 15:15, yourself [1] - 10:14 90:20, 93:5, 94:17, 64:8, 69:13, 89:14 26:6, 27:18, 75:7 99:19, 101:12, via [2] - 3:8, 58:19 works [1] - 55:6 Z 103:21, 109:22, Via [1] - 1:15 world [1] - 72:5 109:24, 110:13, view [7] - 33:7, 35:4, worth [2] - 29:18, zero [7] - 9:18, 44:2, 111:1 37:19, 86:8, 92:10, 31:11 44:16, 46:10, 60:6, update [9] - 56:20, 92:11, 110:15 worthwhile [1] - 94:18 78:3, 85:1 70:23, 88:17, 88:19, viewed [2] - 50:2, 98:4 wrap [1] - 6:9 88:22, 109:16, viewing [1] - 3:5 write [4] - 15:11, 109:17, 109:18, views [1] - 96:23 69:24, 75:23, 76:1 110:9 vigorous [1] - 55:13 write-offs [2] - 75:23, updated [2] - 70:8, vision [1] - 35:6 76:1 88:14 vitality [1] - 54:19 writing [2] - 15:2, 15:5 updates [3] - 70:18, vocabulary [1] - 51:2 written [1] - 97:6 109:11 volatility [3] - 41:1, updating [2] - 22:20, 93:7, 99:21 Y 70:20 volunteered [1] - upped [1] - 38:24 82:22 [2] year [61] - 5:8, 6:1, ups - 89:9, 99:24 vote [1] - 3:23 6:5, 6:10, 8:5, 9:7, upstate [2] - 7:3, vulnerable [2] - 47:19, 93:10 48:23 12:21, 13:1, 14:4, urged [1] - 67:16 14:18, 23:19, 25:10, USA [1] - 98:16 W 25:24, 26:22, 29:17, uses [2] - 35:22, 47:12 33:24, 34:9, 35:7, utilities [13] - 40:4, 35:17, 36:11, 36:19, 40:6, 40:18, 51:4, wait [1] - 10:12 37:9, 37:17, 44:14, 57:19, 58:1, 58:16, waive [1] - 48:15 45:12, 47:4, 49:12, 58:23, 78:19, 78:23, Wall [1] - 92:11 49:24, 50:7, 50:19, 79:17, 87:3, 89:11 wants [1] - 28:11 51:23, 53:2, 53:3, Utilities [1] - 11:11 warrant [1] - 111:14 53:4, 61:22, 66:9, utility [14] - 7:5, 35:4, ways [1] - 106:17 70:16, 70:18, 73:12, 35:22, 38:9, 38:16, weak [1] - 39:9 75:8, 75:9, 75:11, 40:3, 40:24, 86:23, webcast [1] - 3:5 78:4, 83:9, 84:15, 87:4, 93:21, 106:3, WEDNESDAY [1] - 1:6 85:1, 87:17, 87:22, 106:5, 106:6, 107:18 week [10] - 3:22, 55:5, 89:11, 89:16, 89:17, utility's [1] - 53:18 65:5, 79:11, 82:2, 90:2, 90:11, 90:22, utilizes [1] - 54:1 94:17, 94:21, 90:24, 91:11, 91:13, 107:24, 111:24, 91:14, 91:15, 108:8 V 112:7 years [41] - 6:23, 8:3, weighted [1] - 86:23 8:10, 12:23, 13:5, Welcome [1] - 59:7 14:6, 15:12, 15:16, vacant [1] - 51:24 15:18, 15:23, 16:5, wellbeing [1] - 96:21 valuable [1] - 48:22 16:9, 16:12, 17:3, whatsoever [1] - value [1] - 86:16 46:15 17:14, 20:17, 21:1, variable [8] - 68:1, 21:6, 23:16, 31:19, whereas [1] - 42:16