[0:13] We're going to go ahead

[0:13] and get started here this

[0:14] morning.

[0:15] Just the kind of recap a

[0:19] little bit of what today

[0:19] and where we left off

[0:23] yesterday and what today

[0:23] will look like.

[0:24] So it's 8:00 now.

[0:25] I'm going to try to stay

[0:27] consistent with a break

[0:28] every two hours more or

[0:32] less depending on kind of

[0:33] where there is a good

[0:33] break in the questioning.

[0:35] 12:00 we will break for

[0:36] lunch.

[0:41] We MAY go late today.

[0:41] I was kind of alluding

[0:42] that yesterday.

[0:42] So I want to plan for

[0:45] maybe a 9:00 finish if we

[0:46] need that much time this

[0:47] evening and then we will

[0:50] have a break at some point

[0:52] maybe as kind of a dinner

[0:54] break at some point maybe

[0:57] chat a little bit at the

[0:58] lunch hour figure out when

[1:01] the right time for that

[1:02] would be.

[1:02] So if we're good with

[1:05] that, let's go ahead and

[1:17] pick up where we left off.

[1:19] MR. Stryker is here in the

[1:22] witness box.

[1:25] Sierra club, I will kick

[1:26] it back to you.

[1:28] >> if you are member

[1:29] yesterday we were

[1:31] discussing limitation

[1:31] guidelines and your and

[1:33] teco's contention at big

[1:39] bend four and polk one

[1:40] discharging waste waters

[1:40] into underground injection

[1:46] wells, is that correct?

[1:46] >> MS. Sparkman: that is

[1:46] correct.

[1:47] >> can you please refer to

[1:54] cl exhibit cl exhibit 799

[1:54] purges f-6 207 and f6 208,

[2:06] please?

[2:10] So just staying on 206 --

[2:16] or sorry, 207, teco spent

[2:17] about $33.3 million to

[2:18] build underground

[2:20] injection wells at big

[2:21] bend, correct?

[2:22] >> MR. Stryker: that's

[2:23] correct.

[2:24] >> and then moving on to

[2:28] the next page, teco spent

[2:29] over $30 million to build

[2:31] underground injection

[2:39] wells at polk, correct?

[2:39] >> MR. Stryker: that is

[2:39] not correct.

[2:40] The total cost of the

[2:40] wells was about 30

[2:41] million, but 50% was

[2:43] funded by swift mud.

[2:43] >> okay.

[2:49] To map that out, that

[2:49] would be about 15 million

[2:50] and half --

[2:50] >> MR. Stryker: about 7.5

[2:51] million was funded by

[2:53] water management district.

[2:54] >> sorry, you said 22.5

[2:57] million?

[2:58] >> MR. Stryker: 7.5

[2:58] million.

[3:07] >> in total somewhere

[3:08] around 55 million total

[3:10] spent on underground

[3:11] injection wells in total?

[3:14] >> MR. Stryker: sounds

[3:14] about right.

[3:17] >> and were these wells

[3:17] built to comply with the

[3:19] eog rule, which was

[3:21] imposed last year and

[3:23] adopted earlier this year?

[3:25] >> the primary purpose of

[3:27] the polk wells to was to

[3:29] reclaim to reduce its

[3:34] groundwater withdrawal and

[3:34] consume reclaimed water

[3:35] from the city of lakeland

[3:37] and the injection was part

[3:44] of the treatment process.

[3:44] -- one of which was

[3:45] compliance with eog rule.

[3:45] The other reason was an

[3:47] additional way to manage

[3:56] stormwater on the side.

[3:57] >> can you please refer to

[4:03] cel exhibit c4 starting on

[4:11] f-6 06?

[4:13] So this is big bend's

[4:15] revised national pollutant

[4:16] distribution system permit

[4:18] application.

[4:19] Are you familiar with it?

[4:23] >> I am somewhat familiar

[4:29] with it, yes.

[4:29] >> this revised

[4:31] application was submitted

[4:35] in FEBRUARY 2024, is that

[4:35] correct?

[4:37] >> MR. Stryker: it was

[4:37] originally submitted in

[4:40] 2015, but the renewal

[4:40] process has been delayed

[4:42] and my understanding

[4:43] updated app application

[4:44] because so much has

[4:44] changed since the time the

[4:49] application was originally

[4:49] submitted.

[4:51] >> right, so that update

[4:51] was submitted in FEBRUARY

[4:53] of this year.

[4:54] >> MR. Stryker: I believe

[4:54] that's correct.

[4:57] >> and this application

[4:59] generally covers teco's

[5:02] application at big bend in

[5:03] their compliance with the

[5:03] clean water act, is that

[5:06] right?

[5:06] >> MR. Stryker: that's

[5:07] correct.

[5:09] >> can you please refer to

[5:09] page 10 of this document,

[5:22] which is f-6 515?

[5:23] This permit generally

[5:25] refers to eog rules permit

[5:26] requirements, is that

[5:29] right?

[5:29] >> MR. Stryker: that's

[5:31] correct, this document is

[5:33] a fact sheet by the

[5:36] environmental --

[5:37] department of environment

[5:37] protection.

[5:41] >> no untreatable water

[5:41] can be discharged into the

[5:42] united states, is that

[5:42] right?

[5:44] >> MR. Stryker: I believe

[5:46] that's correct, yeah.

[5:48] >> so there's a revision

[5:49] in this fact sheet that is

[5:51] attached to the permit

[5:55] application on this page

[5:57] that states "the facility

[6:01] does generate fgd

[6:05] wastewater and therefore

[6:11] the limitations of cfr --

[6:13] for fgd wastewater are not

[6:14] applicable in this case.

[6:15] Do you see that?

[6:20] >> MR. Stryker: I do.

[6:20] >> and fgd is bluegrass

[6:21] diesel fertilization,

[6:24] which is a result of polk

[6:29] combustion?

[6:29] >> MR. Stryker: it's a

[6:30] product of coal combustion

[6:31] afterwards treated to

[6:34] remove emissions.

[6:37] >> and uic stands for

[6:38] underground injection

[6:39] control is?

[6:40] >> MR. Stryker: that is

[6:41] correct.

[6:43] >> based on the

[6:44] highlighting of this

[6:46] provision, it looks like

[6:47] the revision was published

[6:50] in MARCH 29, 2023.

[6:50] Teco went from stating

[6:51] that it's fgd wastewater's

[6:53] are subject to the fgd

[6:56] rule to subject that it's

[6:57] fgd wastewater's are not

[6:57] subject because it will

[6:59] now inject wastewater into

[7:01] these uic wells, is that

[7:03] correct?

[7:03] >> MR. Stryker: I don't

[7:04] know if we ever said the

[7:06] waters are subject to the

[7:08] elg.

[7:09] This is in our document.

[7:15] This is the florida dep's

[7:17] document.

[7:17] >> it looks like the

[7:23] florida dep said added the

[7:23] word "not".

[7:24] So.

[7:25] >> MR. Stryker: I don't

[7:26] know that the highlight

[7:29] means this wasn't an

[7:29] addition.

[7:29] I don't know who

[7:30] highlighted this or why it

[7:32] was highlighted.

[7:38] >> okay.

[7:40] Presumably, the florida

[7:42] dep works with teco in

[7:43] order to produce this

[7:44] document, correct?

[7:47] >> MR. Stryker: it is a

[7:47] collaborative process, but

[7:49] once again I don't know

[7:51] who wrote what.

[7:51] >> okay.

[7:53] Understand.

[7:55] But you nevertheless agree

[7:59] with this statement?

[8:00] >> MR. Stryker: I agree

[8:02] with the statement as it

[8:08] is currently written.

[8:09] >> has epa confirmed this

[8:12] language or, you know,

[8:14] confirmed this permit

[8:17] revision that fgd

[8:17] revisions are not

[8:19] applicable because fgd

[8:22] blowdown can be discharged

[8:24] to uic wells?

[8:25] >> MR. Stryker: I don't

[8:27] know whether epa has

[8:28] agreed with it or not in

[8:29] florida.

[8:29] Florida MS. Wessling has

[8:31] jurisdiction over the

[8:32] program.

[8:35] It is not require epa's

[8:37] approval.

[8:38] Epa would have opportunity

[8:39] to review and comment on

[8:41] the draft permit, which I

[8:44] believe --

[8:45] >> this permit has not

[8:47] been granted yet?

[8:48] >> MR. Stryker: that's

[8:48] correct.

[8:49] However, the epa has

[8:51] reviewed and uic permit

[8:55] has been issued.

[8:57] Uic permit doesn't

[8:59] specifically state that

[9:00] fgd blowdown water can

[9:02] beat injection -- injected

[9:06] into the groundwater at

[9:09] big bend.

[9:12] >> has teco confirmed the

[9:13] accuracy of this

[9:19] contention within the

[9:23] permit with epa --

[9:27] >> MR. Stryker: dep has

[9:30] primacy over this program.

[9:33] >> is possible teco will

[9:34] not be able to get around

[9:35] fgd by injecting

[9:37] wastewater into uic wells,

[9:37] right?

[9:40] >> MR. Stryker: no, as I

[9:40] mission before, the

[9:43] permitting agency that has

[9:50] permitting of this is dep

[9:51] of florida.

[9:54] Elg are not applicable to

[9:55] big bend because injection

[9:59] controls are not --

[10:00] >> objection.

[10:03] Asked and answered.

[10:04] >> CHAIRMAN La Rosa: it

[10:10] has been.

[10:15] >> could you please turn

[10:16] to cl exhibit to cl

[10:20] exhibit 121 in page c3 to

[10:32] 3580?

[10:35] Epa estimated the cost of

[10:38] elg compliance due to

[10:39] dealing with fgd

[10:43] wastewater at big bend is

[10:43] about 129 million in

[10:45] capital cost and 9 million

[10:45] in operating and

[10:46] maintenance cost, is that

[10:48] right?

[10:49] >> MR. Stryker: I'm going

[10:50] to take your word for it

[10:50] because there's no way I'm

[10:51] reading that.

[10:55] >> have you seen this

[10:55] document before?

[10:56] >> MR. Stryker: if it's

[10:56] the same as the

[10:58] spreadsheet during the

[10:59] deposition, I saw it then.

[11:03] >> are you aware of -- at

[11:04] big bend?

[11:08] >> MR. Stryker: I am.

[11:12] >> and, MR. Stryker, when

[11:16] do elg wastewater rules go

[11:17] into effect?

[11:21] >> MR. Stryker: I believe

[11:22] this year.

[11:25] >> can you please refer to

[11:26] cl exhibit refer to cl

[11:43] exhibit 798 page f-6 192?

[11:43] Have you seen the cpa

[11:46] document before, MR.

[11:47] Stryker?

[11:48] >> MR. Stryker: I saw it

[11:49] recently when you guys

[11:51] submitted it as a hearing

[11:52] exhibit.

[11:53] I have not seen it before

[11:57] that.

[11:57] >> would you accept it was

[12:03] published along with 2024

[12:05] elg guidelines in APRIL of

[12:05] this year?

[12:06] >> MR. Stryker: if you

[12:06] say so.

[12:07] I have no way to know its

[12:10] source and authenticity.

[12:15] >> okay.

[12:15] could you turn to page 4

[12:15] --

[12:16] >> MR. CHAIRMAN?

[12:16] Object on the bigness that

[12:18] the witness just said he

[12:18] doesn't know what this is

[12:19] and there's no foundation

[12:20] to what it is or accuracy.

[12:22] >> CHAIRMAN La Rosa: can

[12:24] you give more explanation

[12:24] of what the exhibit is?

[12:26] >> MR. CHAIRMAN, this

[12:29] exhibit is a document

[12:30] summons submitted to the

[12:31] federal register.

[12:33] Is a compliance cost

[12:34] document associated with

[12:39] the elg rule of which MR.

[12:40] Stryker is apparently the

[12:41] expert witness.

[12:42] >> CHAIRMAN La Rosa: can

[12:43] the witness clarify

[12:45] whether they are familiar

[12:45] with this document?

[12:46] >> MR. Stryker: excuse

[12:46] me?

[12:47] >> CHAIRMAN La Rosa: can

[12:49] you clarify whether you

[12:50] are familiar with this

[12:51] document?

[12:51] >> MR. Stryker: I am not

[12:53] familiar.

[12:53] >> CHAIRMAN La Rosa: then

[13:32] sustained.

[13:33] >> could you please turn

[13:36] to exhibit to exhibit 795

[13:40] in the cl page f-6 120?

[13:42] Which is the big bend uic

[13:56] permit.

[13:57] Are you familiar with this

[14:00] document, -- one?

[14:01] >> MR. Stryker: yes, I

[14:01] am.

[14:02] >> this is permit for the

[14:03] two water injection wells

[14:05] that teco built at big

[14:08] bend four, correct?

[14:09] >> MR. Stryker: that's

[14:09] correct.

[14:11] >> and I believe that

[14:12] these were built in 2023,

[14:13] is that correct?

[14:16] >> MR. Stryker: they went

[14:17] into service in 2023.

[14:17] They were constructed over

[14:19] a period of making it a

[14:22] year or so.

[14:23] >> this permit was granted

[14:25] by the florida department

[14:26] of environmental

[14:28] protection, correct?

[14:28] >> MR. Stryker: that's

[14:28] correct.

[14:32] >> if you turn to page 3

[14:40] of this permit, f-6 122.

[14:42] States the injection wells

[14:46] will also be permitted to

[14:47] receive bluegrass diesel

[14:50] authorization or fgd

[14:50] wastewater from tampa

[14:52] electric big bend station

[14:53] after department approval

[14:55] of the analysis of the fgd

[14:58] waste treaty.

[14:59] Do you see that?

[15:00] It's the middle of the

[15:01] bottom paragraph on this

[15:04] page?

[15:04] >> MR. Stryker: I do.

[15:07] >> has teco received this

[15:07] department approval?

[15:09] >> MR. Stryker: yes, we

[15:13] have.

[15:14] >> and winded teco receive

[15:15] that?

[15:18] >> MR. Stryker: was

[15:18] recently.

[15:19] However, that recent

[15:21] approval was only to allow

[15:24] direct ingestion of fgd

[15:24] wastewater since the

[15:26] initial we were permitted

[15:29] to discharge the fgd

[15:32] wastewater into the well

[15:34] as part of -- recycled

[15:41] water system.

[15:41] The approval we recently

[15:46] received from the eep

[15:50] since day one of our

[15:50] operation of the wells we

[15:51] have been able to

[15:52] discharge that same water

[15:56] into the wells because it

[15:57] was mixed into other waste

[16:01] streams.

[16:05] >> can you turn to page 6

[16:28] of this document, f-6 125?

[16:28] Here the permit states

[16:29] injection of fgd

[16:29] wastewater is authorized

[16:37] after department approval.

[16:38] The perimeter table MAY be

[16:38] amended based on the

[16:41] constituents detected in

[16:41] the fgd or other waste

[16:42] stream analysis.

[16:42] Do you see where it says

[16:42] that?

[16:47] >> MR. Stryker: I do.

[16:48] >> was the perimeter table

[16:50] amended?

[16:51] >> MR. Stryker: no, it

[16:51] was not.

[17:06] >> department approval?

[17:07] When does teco anticipate

[17:10] getting epa approval with

[17:15] regards to the elg?

[17:16] >> MR. Stryker: epa

[17:16] approval?

[17:17] Never.

[17:19] >> why do you say that?

[17:20] >> MR. Stryker: because

[17:20] it's not a requirement to

[17:22] do it in the state of

[17:23] florida.

[17:25] >> it's not a requirement

[17:27] in the state of florida to

[17:30] get an ea -- eap approval?

[17:34] >> environmental

[17:38] protection agency has --

[17:40] in the state of florida.

[17:42] >> MR. Stryker, I have a

[17:43] few questions about teco

[17:45] is summer and winter

[17:50] reserve margins.

[17:50] Should I ask these

[17:51] questions or should they

[17:52] be reserved for witness

[17:52] aponte?

[17:54] >> MR. Stryker: those are

[17:57] questions better for

[17:58] witness aponte.

[18:00] >> could you please refer

[18:04] to your testimony page 7?

[18:04] Your I think direct

[18:15] testimony.

[18:19] And the master page number

[18:22] is d is d255.

[18:23] I'm so sorry, that might

[18:23] be.

[18:31] [Indiscernible]

[18:33] >> MR. Stryker: okay.

[18:34] You state that in addition

[18:37] with the passage of the

[18:37] inflation act, federal

[18:38] government is providing

[18:39] tax incentives that

[18:41] benefit customers

[18:41] , the

[18:42] solar projects the

[18:43] customers would not

[18:47] receive the benefits of

[18:47] the additional tax

[18:48] incentives until a later

[18:48] time.

[18:53] Do you see that?

[18:54] >> MR. Stryker: yes, I

[18:54] do.

[18:56] It's actually on page 8.

[18:56] >> you go on.

[18:57] These cost increases and

[19:00] additional tax credits

[19:01] were included in the solar

[19:03] projects, cost-effective

[19:05] still provide net savings

[19:07] to our customers.

[19:08] I understand that teco

[19:10] incorporated tax credits

[19:12] into the cost analyses

[19:14] while electing to pursue

[19:15] solar projects, is that

[19:18] right?

[19:18] >> MR. Stryker: that's

[19:20] correct.

[19:21] >> can you please refer to

[19:27] teco response for fl psc

[19:28] exhibit 114, which is

[19:32] teco's response to sierra

[19:32] club's 50th interrogatory

[19:53] master page c32 c323261?

[19:53] the company has board

[19:54] approved plans to install

[19:54] an additional 350 mw of

[19:57] solar from 27-2028 and an

[19:57] additional 755 mw of solar

[20:02] from 2029-2033, right?

[20:04] Tend to clarify, belong

[20:08] document beyond 2028 the

[20:08] plans are preliminary

[20:09] based on current your site

[20:10] plan.

[20:15] >> great.

[20:16] And then could you please

[20:21] turn on the same exhibit

[20:36] page c 32 page c 30 23266.

[20:40] The company has board

[20:40] approved plans through the

[20:41] tenure site plan to

[20:42] install an additional 70

[20:45] mw storage project in

[20:48] 2028, correct?

[20:49] >> MR. Stryker: that is

[20:50] correct.

[20:51] >> why is teco not

[20:53] bringing on more than one

[20:57] storage project in a six

[20:57] year period from

[20:58] 2027-2023?

[21:01] >> MR. Stryker: our basic

[21:01] storage plan is based on

[21:02] when we have a need as

[21:04] based on winter reserve

[21:07] margin falling below 20%.

[21:08] We will likely as we move

[21:13] on evaluate whether it

[21:14] benefits customers further

[21:14] to have a criminal storage

[21:17] above and beyond that.

[21:19] The only need we have as

[21:20] far as additional capacity

[21:22] is not until the winter of

[21:24] 2028.

[21:28] >> could teco add

[21:29] additional projects to

[21:29] ensure mega wattages

[21:32] impaired with stored while

[21:34] retiring other assets like

[21:38] we went for polk one?

[21:39] >> MR. Stryker: that

[21:40] would be a lot of storage

[21:41] and I doubt we can get it

[21:45] added in that timeframe.

[21:50] >> but does teco need all

[21:50] of big bend four in its

[21:53] capacity?

[21:55] >> MR. Stryker: yes, we

[21:55] do.

[22:00] >> 100% of the capacity of

[22:01] big bend four to meet its

[22:01] winter margin?

[22:04] >> objection.

[22:04] Asked and answered.

[22:05] >> CHAIRMAN La Rosa: I'm

[22:06] going to allow the

[22:06] question to continue

[22:13] because I think you're

[22:14] trying to get something

[22:14] specific.

[22:14] >> MR. Stryker: as I

[22:15] mentioned, this is being

[22:15] built or proposed because

[22:16] we will have a shortage in

[22:17] the reserve margin in that

[22:23] timeframe.

[22:23] So by default that means

[22:25] we need the capacity we

[22:25] already have because we

[22:27] are going to need more

[22:28] than what we currently

[22:28] have.

[22:32] Further details of that

[22:33] analysis would be deferred

[22:36] to witness aponte, though.

[22:37] >> because you said that,

[22:37] could we please look at

[22:39] exhibit

[22:39] >> because you said that,

[22:40] could we please look at

[22:45] exhibit 120 c 32 3577?

[22:46] And could you please zoom

[23:03] in on the last row?

[23:05] MR. Stryker, as you can

[23:06] see here, this document

[23:10] shows this is teco's

[23:11] response to sierra club

[23:17] interrogatory

[23:17] .

[23:18] It shows that teco's, it

[23:19] shows teco's winter and

[23:20] summer reserve margins,

[23:21] the first column for each

[23:24] year shows the winter

[23:25] reserve margin.

[23:26] Second shows the summer

[23:31] margin.

[23:32] Going out to 2033, at no

[23:35] point does teco is reserve

[23:39] margin dip below 21%.

[23:41] So my question is how

[23:42] could you possibly need

[23:46] 100% of polk one and big

[23:47] bend four to meet reserve

[23:51] margin when there's a

[23:52] surplus of reserve margin?

[23:52] >> MR. Stryker: there's a

[23:55] serve -- surplus because

[23:55] when you look at the

[23:58] bottom two roles we --

[24:01] maintain and keep from

[24:03] falling below.

[24:09] The second row is the

[24:09] battery we were just

[24:10] talking about and below

[24:10] that is future of

[24:10] combustion turbine.

[24:11] Without those future

[24:14] projects it would fall

[24:17] below 28% requirement.

[24:22] >> okay.

[24:25] That 20%, 21% reserve

[24:26] margin assumes polk one

[24:28] and big bend four are

[24:37] online, right?

[24:37] >> MR. Stryker: that is

[24:37] correct.

[24:38] >> in order to get back up

[24:39] to 21%, you would need

[24:39] 100% of capacity of big

[24:43] bend four and polk one,

[24:44] no?

[24:44] >> MR. Stryker: I can't

[24:46] do the math on the fly,

[24:49] but pretty close to it.

[24:50] >> that's all my

[24:50] questions.

[24:55] Thank you.

[24:56] >> CHAIRMAN La Rosa:

[24:57] thank you.

[24:59] Florida retail federation.

[25:02] >> good morning, -- one.

[25:06] how are you?

[25:07] >> MR. Stryker: great,

[25:07] how are you?

[25:12] >> I have a very brief

[25:14] cross for you regarding

[25:18] your company's plans and

[25:18] consideration of what you

[25:20] are calling carbon capture

[25:22] and storage.

[25:23] I've gotten used to

[25:25] calling it carbon capture

[25:29] and sql station, but

[25:29] that's the same thing,

[25:29] right?

[25:30] >> MR. Stryker: it is the

[25:34] same thing.

[25:37] >> my basic question I

[25:38] think is pretty simple.

[25:42] What guarantees from

[25:43] , what

[25:43] guarantees does the

[25:48] company expect to have

[25:49] that co2 is going to stay

[25:50] where you put?

[25:51] >> the main, I wouldn't

[25:55] call it a guarantee, but

[25:56] the main assurance is the

[25:59] class vi usc program,

[26:00] which is administered by

[26:03] the epa.

[26:04] It's a very rigorous

[26:04] permitting program to both

[26:05] monitor the design,

[26:08] construction, and

[26:12] operation of the wells.

[26:12] 's apartment we are

[26:14] working with the epa on.

[26:17] These plans are pretty far

[26:17] out in the future, but

[26:20] that is the main method of

[26:21] compliance.

[26:23] There's also a 20-30 year

[26:24] period even after you

[26:28] would cease injection of

[26:29] the ground.

[26:30] The company would have the

[26:31] obligation to monitor the

[26:32] status of those wells and

[26:35] make sure there's no new

[26:37] effects.

[26:37] >> MR. Scheffel Wright:

[26:40] what would happen if a

[26:43] well or start to leak co2

[26:44] back into the ambient

[26:51] atmosphere?

[26:51] >> MR. Stryker: really

[26:55] nothing other than he

[26:56] would've lost what you

[26:56] were trying to accomplish

[26:57] in the first place.

[26:59] Is not hazardous to health

[26:59] unless in higher

[27:01] concentrations it would

[27:07] disperse pretty rapidly.

[27:09] Currently, as we spoke

[27:10] about before there is not

[27:12] a mandate to do any sort

[27:16] of -- project.

[27:17] Mainly we're looking at

[27:20] css because we believe it

[27:21] prudent not to because the

[27:23] potential economic

[27:26] benefits to customers via

[27:27] tax credits, but also the

[27:27] significant federal

[27:28] funding we have been

[27:31] awarded.

[27:32] >> MR. Scheffel Wright:

[27:33] wouldn't you expect that

[27:34] the potential for epa

[27:36] enforcement would be

[27:40] equivalent to a mandate?

[27:41] >> MR. Stryker: I would,

[27:42] but I just don't know

[27:46] which rule they would be

[27:47] enforcing under because if

[27:47] there's not a rule saying

[27:51] you have to do this.

[27:52] >> MR. Scheffel Wright: I

[27:53] understand that, and I

[27:53] think we all understand

[27:55] this is a future scenario.

[27:56] My question is what

[27:56] happens with that work.

[27:59] >> MR. Stryker: I think

[27:59] the biggest exposure in

[28:00] all honesty is the call

[28:01] back revision of the tax

[28:02] credit if you do not keep

[28:04] it sequestered.

[28:08] the tax credit, you have

[28:10] to give it back.

[28:11] I think it's less of an

[28:12] environmental issue than

[28:15] in my mind.

[28:15] >> MR. Scheffel Wright:

[28:16] thanks very much.

[28:19] That's all I have.

[28:20] >> MR. Stryker: thank

[28:20] you.

[28:28] Walmart?

[28:28] >> MS. Eaton: thank you.

[28:29] I do have a couple of

[28:29] follow-up questions.

[28:30] We do appreciate your

[28:33] commitment to adding clean

[28:34] energy to your grade and

[28:34] generation fleet and have

[28:35] a cook of questions

[28:38] related to collaboration

[28:40] with customers in that

[28:41] regard.

[28:42] Were you here yesterday

[28:44] when MRS. Sparkman was

[28:45] testifying?

[28:50] >> MS. Eaton: I was not

[28:51] present in the hearing

[28:51] room.

[28:52] >> MS. Eaton: are you

[28:52] familiar with the optional

[28:56] customer programs she was

[28:56] developing and talking

[28:56] about?

[28:57] >> MR. Stryker: at a very

[28:57] high level.

[28:58] >> MS. Eaton: I'm just

[28:59] wondering if your team

[29:01] collaborated with her team

[29:04] ingathering information

[29:07] from your commercial and

[29:07] industrial customers about

[29:12] their sustainability and

[29:13] renewable energy goals and

[29:14] how programs could

[29:14] ultimately be developed

[29:17] that help tampa electric

[29:21] and all -- excuse me, and

[29:21] all the customers.

[29:23] >> MR. Stryker: there are

[29:24] a few members for my team

[29:25] involved.

[29:30] Her team as the lead face

[29:31] on customers.

[29:31] My team has technological

[29:32] input to the equipment and

[29:32] design of potential

[29:33] projects.

[29:34] >> MS. Eaton: sure.

[29:39] At some point your team

[29:39] would get involved in

[29:42] order to provide the

[29:42] technical insight into how

[29:44] to develop those programs.

[29:45] The other thing that I

[29:49] didn't hear you mention,

[29:49] and perhaps this is

[29:52] another witness, what is

[29:53] tempos plans to do with

[29:58] the renewable energy

[29:59] credits with these new

[29:59] solar energy and battery

[30:03] storage units?

[30:04] >> MR. Stryker: I don't

[30:05] believe it's anybody's

[30:09] testimony.

[30:11] I know we are currently

[30:11] selling the renewable

[30:12] energy credits and hundred

[30:12] percent flow back to

[30:15] customers and fuel because

[30:21] , witness heisey can

[30:23] elaborate more.

[30:23] >> CHAIRMAN La Rosa:

[30:24] thank you.

[30:24] Staff?

[30:25] >> Staff: staff has just

[30:34] a couple of questions.

[30:35] Good morning, -- one.

[30:35] I would like to ask you a

[30:36] couple of brief questions

[30:36] about the 98.4 million

[30:37] from the department of

[30:37] energy that you discussed

[30:39] in your direct testimony.

[30:39] Are you familiar with

[30:40] that?

[30:42] >> I am.

[30:42] >> Staff: what was that

[30:46] funding for?

[30:46] >> MR. Stryker: it was

[30:47] for three different

[30:47] funding orders.

[30:47] One of them was a front

[30:49] end engineering and design

[30:52] study to evaluate carbon

[30:52] capture storage or

[30:54] sequestration technology

[30:58] in our polk unit two

[30:59] combined cycle.

[31:03] That was approximately $5

[31:04] million award.

[31:06] The second award was to

[31:13] build upon on that study

[31:14] and take the feed study to

[31:14] the next level, which

[31:15] would include evaluating

[31:15] the storage and

[31:17] transportation component

[31:20] of the project.

[31:23] Including developing

[31:23] permit application.

[31:23] It's really taking the

[31:30] engineering to the next

[31:30] level.

[31:30] There was another $5

[31:31] million.

[31:31] The biggest award in the

[31:32] $88 million as part of

[31:35] what's called the carbon

[31:36] safe program and that is

[31:38] to do with detailed

[31:38] geological

[31:40] characterization including

[31:42] drilling up to two wells

[31:49] and 3d seismic survey.

[31:50] >> Staff: could that

[31:50] funding has been used for

[31:51] something besides carbon

[31:53] capture and storage

[31:53] evaluation?

[31:55] >> MR. Stryker: no, it

[31:58] cannot.

[31:59] >> Staff: is teco using

[31:59] 1/3 party -- who is that

[32:00] contractor?

[32:00] >> MR. Stryker: there's a

[32:01] couple of them.

[32:05] Sergeant lending is our

[32:05] engineering consultant

[32:06] doing the engineering.

[32:07] what we call the balance

[32:13] of planned engineering.

[32:17] -- seven clean energy and

[32:19] ari or advanced resources

[32:19] internationalism are

[32:23] geological consultant.

[32:24] >> Staff: thank you very

[32:24] much.

[32:30] Those are all the

[32:30] questions I have.

[32:31] >> CHAIRMAN La Rosa:

[32:31] thank you.

[32:32] Commissioners, any

[32:32] questions?

[32:40] Commissioner graham?

[32:40] >> Commissioner Graham: I

[32:41] am a very serious question

[32:42] for you.

[32:43] Who is responsible for

[32:46] naming these solar plants?

[32:47] Bullfrog creek,

[32:50] cottonmouth, I mean.

[32:50] >> MR. Stryker: I wish it

[32:52] wasn't me.

[32:52] It's kind of a

[32:53] collaborative effort.

[32:58] It's funny, a lot of those

[32:58] names have changed

[32:59] multiple times, but we

[33:00] tend to find a water body

[33:04] or geological feature and

[33:05] try to name them.

[33:07] There actually is a

[33:07] bullfrog creek and

[33:08] cottonmouth branch.

[33:09] >> Commissioner Graham:

[33:09] thank you.

[33:10] >> CHAIRMAN La Rosa:

[33:11] commissioners, any other

[33:16] questions?

[33:16] Seeing none, we're back to

[33:16] teco for redirect.

[33:18] >> MR. Stryker, you recall

[33:24] questions about the ccs

[33:24] project yesterday and

[33:24] today.

[33:25] >> MR. Stryker: I do.

[33:27] >> is teco requesting --

[33:27] in this case?

[33:33] >> MR. Stryker: no, as i

[33:33] mentioned before, the only

[33:34] request in this case is

[33:39] our cost year of the doe

[33:39] awards.

[33:40] >> de recall a line of

[33:41] questioning yesterday when

[33:42] there is a current limit

[33:46] of omissions for polk unit

[33:46] two?

[33:47] >> MR. Stryker: I do.

[33:50] >> if there is not an

[33:51] emissions limit, why are

[33:53] you proceeding with this

[33:53] now?

[33:57] >> MR. Stryker: one is

[33:57] the credibility of funding

[33:58] that MAY not be available

[33:59] in the future if and when

[34:02] there becomes a mandate.

[34:04] The other reason is, as I

[34:06] mentioned, you heard in

[34:09] witness collins testimony

[34:10] we are constantly looking

[34:15] for ways it can benefit

[34:15] the customer and the

[34:16] affordability concern and

[34:16] the magnitude of the

[34:18] taxpayers associated,

[34:19] we're talking $3 billion

[34:21] in tax credits over the

[34:23] life of the project.

[34:23] We feel it would be

[34:24] imprudent for us to not

[34:30] evaluate the potential of

[34:30] such a project.

[34:31] >> no further questions.

[34:31] >> CHAIRMAN La Rosa:

[34:32] great.

[34:33] Thank you.

[34:36] Let's start with moving

[34:36] some exhibits into the

[34:41] record.

[34:41] Teco, do you have any

[34:41] exhibits?

[34:42] >> yes, we move exhibits

[34:47] 19 and 143 into the

[34:47] record.

[34:48] >> CHAIRMAN La Rosa: 19

[34:48] and 143.

[34:48] Any objections to those?

[34:52] see no objections, see

[34:53] them entered into the

[34:57] record.

[34:57] Do any parties have any

[34:57] exhibits?

[34:57] Start with opc.

[34:59] >> things, MR. Chair.

[34:59] Opc would move into the

[35:01] record hearing exhibits

[35:05] 408, 300, and 457, please.

[35:05] >> CHAIRMAN La Rosa: any

[35:06] objections to those

[35:08] exhibits?

[35:09] Seeing none, show them

[35:17] entered into the record.

[35:17] Lulac?

[35:18] >> thank you, MR. Chair.

[35:19] Lulac would move hearing

[35:19] exhibits 616, 646, 677,

[35:22] 678, and 711 into the

[35:23] record.

[35:25] >> CHAIRMAN La Rosa: any

[35:28] thoughts or concerns?

[35:29] >> no objections.

[35:30] >> CHAIRMAN La Rosa: no

[35:33] objections.

[35:33] Show them entered into the

[35:33] record.

[35:38] >> sierra club would like

[35:39] to introduce exhibits 799,

[35:42] 714, 121, 795, and 120

[35:46] into the record.

[35:46] >> no objections.

[35:47] >> CHAIRMAN La Rosa: no

[35:50] objections.

[35:51] Show them entered into the

[35:51] record.

[35:51] Any other intervening

[35:53] parties have exhibits to

[35:55] enter into the record?

[35:55] Seeing none, I think we

[35:58] can go ahead and move on.

[36:02] MR. Stryker, you are

[36:08] excused.

[36:09] Thank you for your witness

[36:09] testimonies today.

[36:09] All right.

[36:10] I will throw it back over

[36:10] to teco.

[36:11] You can introduce your

[36:11] next witness.

[36:11] Okay.

[36:12] MR. CHAIRMAN, before we do

[36:14] that if you don't mind I

[36:16] did a little lawyer map

[36:23] and it looks like we've

[36:24] got about 14 tampa

[36:24] electric witnesses left

[36:25] and 13 intervener

[36:26] witnesses.

[36:30] We talked about it on the

[36:30] table electric side.

[36:37] I talked to MR.

[36:38] Trierweiler and MR.

[36:39] Rehwinkel.

[36:44] Tampa talk about we

[36:45] probably would not

[36:45] cross-examine intervener

[36:46] witnesses.

[36:49] We are part -- prepared to

[36:49] say we would not

[36:52] cross-examine any

[36:53] intervener witnesses

[36:54] and/or staff witnesses and

[36:55] we are perfectly happy to

[36:57] have them insert their

[36:58] testimony into the record

[37:00] as though red and the

[37:03] excused without appearing.

[37:05] I think public counsel

[37:07] historically has liked to

[37:07] have their witnesses make

[37:09] a summary and they can

[37:11] speak for themselves, but

[37:12] we are perfectly happy for

[37:16] them all to just be

[37:16] entered into the record

[37:17] without any summary or

[37:18] anything.

[37:20] We also talked a little

[37:22] bit, there's been

[37:24] discussion about outside

[37:26] witnesses experts, trying

[37:27] to get them all done

[37:31] tomorrow.

[37:31] We are fine with that.

[37:32] I have also understood

[37:33] from MR. Rehwinkel that

[37:35] maybe they are going to do

[37:37] a little bit of work and

[37:38] see if they can figure out

[37:42] how to trim

[37:42] cross-examination, too,

[37:43] but we are working on the

[37:45] schedule and for planning

[37:45] purposes wanted everyone

[37:46] to know that tampa

[37:50] electric is fine with all

[37:51] the outside experts,

[37:52] out-of-town witnesses

[37:55] appearing tomorrow, we

[37:56] would like hours to do

[37:57] that, too, if we can and

[37:58] will not be

[38:00] cross-examining the

[38:00] intervener or staff

[38:01] witnesses.

[38:02] >> CHAIRMAN La Rosa:

[38:03] thank you, and I

[38:04] appreciate the discussion

[38:05] back and forth to help us

[38:07] move along.

[38:08] I'm going to consult with

[38:10] my staff just really

[38:12] quickly to see if there's

[38:13] anything that we can maybe

[38:15] move to expedite things.

[38:17] So if you MAY be just give

[38:18] me 2 and a half minutes

[38:19] and I will come right

[39:07] back.

[42:38] >> CHAIRMAN La Rosa: all

[42:38] right.

[42:43] I think we can jump back

[42:43] and.

[42:43] Got what I needed from

[42:43] that.

[42:44] Certainly appreciate the

[42:44] parties working through

[42:47] things and to continue

[42:48] working on things.

[42:50] Thank you guys.

[42:53] Let's move back to teco to

[42:57] introduce their next

[42:57] witness.

[42:59] >> tampa electric calls

[43:19] jose aponte, please.

[43:20] >> CHAIRMAN La Rosa: MR.

[43:20] Aponte, before you sit

[43:21] down, I don't believe you

[43:26] have been administered the

[43:26] oath yet.

[43:27] Do you mind stay standing

[43:28] and raise your right hand.

[43:28] Do you swear and affirm

[43:31] the testimony you are

[43:31] about to give will be the

[43:32] truth, the whole truth,

[43:35] and nothing but the truth?

[43:35] Thank you.

[43:37] Have a seat, settle in,

[43:37] and will give you a few

[43:51] seconds to get situated.

[43:55] It's yours when you're

[44:00] ready.

[44:03] >> MR. Wahlen: would you

[44:03] please state your name for

[44:04] the record?

[44:05] >> MR. Aponte: jose

[44:06] aponte.

[44:08] >> MR. Wahlen: and who is

[44:09] your current employer and

[44:14] business address?

[44:14] >> MR. Aponte: table

[44:15] electric company business

[44:16] is 702 north franklin st.

[44:17] >> MR. Aponte: table

[44:17] electric company business

[44:18] is 702 north franklin st.,

[44:19] tampa, fl.

[44:19] The limb did you prepare

[44:20] cause to be filed in this

[44:23] docket APRIL 22, 2024,

[44:24] prepared direct testimony

[44:30] consisting of 38 pages?

[44:30] >> MR. Aponte: yes.

[44:31] >> MR. Wahlen: did you

[44:35] also prepare cause to be

[44:35] filed prepare a rebuttal

[44:36] testimony consisting of 15

[44:39] pages?

[44:40] >> MR. Aponte: yes.

[44:40] >> MR. Wahlen: do you

[44:41] have any additions or

[44:46] corrections to your direct

[44:46] rebuttal testimony?

[44:47] >> MR. Aponte: I do not.

[44:47] >> MR. Wahlen: if I would

[44:49] ask you questions prepared

[44:50] in your direct and

[44:50] rebuttal testimony, with

[44:54] those answers be the same?

[44:55] >> MR. Aponte: yes, they

[44:55] would.

[44:56] >> MR. Wahlen: tampa

[44:59] electric request it be

[45:01] inserted into the record

[45:05] as though red.

[45:06] MR. Aponte, did you also

[45:07] prepare cause to be filed

[45:10] with your direct testimony

[45:11] exhibit marked j a-one

[45:11] consisting of 22

[45:15] documents?

[45:16] >> MR. Aponte: yes.

[45:19] >> MR. Wahlen: did you

[45:21] prepare cause to be filed

[45:22] exhibit marked j a to

[45:22] consisting of three

[45:22] documents?

[45:23] >> MR. Aponte: yes.

[45:27] >> MR. Wahlen: MR.

[45:27] CHAIRMAN, for the record

[45:28] we will note exhibits ja

[45:28] one and two have been

[45:29] identified in the

[45:31] comprehensive exhibit list

[45:33] as exhibits 20 and 144.

[45:34] >> CHAIRMAN La Rosa:

[45:34] okay.

[45:36] >> MR. Wahlen: MR.

[45:36] Aponte, we please

[45:39] summarize your direct and

[45:42] rebuttal testimony.

[45:43] >> MR. Aponte: good

[45:43] morning, commissioners.

[45:49] My name is MR. Aponte.

[45:50] As you are aware, the

[45:50] company is proposing

[45:53] several resource additions

[45:54] to its general portfolio

[45:56] in order to satisfy our

[45:59] reserve margin needs and

[45:59] affordability for

[46:00] customers.

[46:01] My direct testimony

[46:02] demonstrates that the

[46:04] projects in the proposed

[46:06] portfolio consisting of

[46:16] this tampa resilience polk

[46:16] one flexibility, future

[46:17] energy storage and future

[46:17] energy projects are

[46:22] cost-effective, they are

[46:23] prudent, promote

[46:23] efficiency and fuel

[46:24] diversity, and enhance the

[46:29] reliability and resilience

[46:29] of the company's system.

[46:31] Together, these projects

[46:31] are expected to save

[46:33] customers about $1.2

[46:36] billion in fuel costs.

[46:40] And over $490 million in

[46:41] cumulative present value

[46:44] revenue requirements.

[46:47] My rebuttal testimony

[46:50] serves several purposes.

[46:51] It refused criticism

[47:03] raised by fipa and lulac.

[47:03] It addresses comments from

[47:04] sierra club about the

[47:07] economics of converting

[47:07] polk unit one to a single

[47:19] cycle unit and responds to

[47:20] fipug's -- this concludes

[47:22] my summary.

[47:22] Thank you.

[47:25] >> MR. Wahlen: MR. Aponte

[47:28] is available for

[47:28] cross-examination.

[47:29] >> CHAIRMAN La Rosa:

[47:29] thank you.

[47:31] Opc, you are recognized.

[47:34] >> good morning.

[47:34] Can I ask you to turn to

[47:38] page 6 of your direct

[47:38] testimony?

[47:51] 25302.

[47:51] >> MR. Aponte: yes.

[47:55] >> on page 6 starting on

[47:57] line 13, then you say the

[47:57] purpose of your testimony

[48:00] is to do the

[48:01] cost-effectiveness test to

[48:02] support teco's request to

[48:04] include the multiple

[48:07] generic projects, correct?

[48:07] >> MR. Aponte: yes.

[48:09] >> okay.

[48:09] and then if you move on to

[48:13] page 7 of your testimony,

[48:16] starting at line 1 you

[48:21] start to say that your

[48:26] testimony shows from a cpv

[48:27] rr basis the company's

[48:31] resource plan is

[48:31] favorable, is that

[48:31] correct?

[48:32] >> MR. Aponte: yes.

[48:35] >> okay.

[48:37] What does cpvrr mean?

[48:40] >> MR. Aponte:

[48:41] communicative present

[48:41] value revenue

[48:42] requirements.

[48:45] >> okay.

[48:45] Would you agree that the

[48:50] -- five is intended to

[48:51] compare the alternative of

[48:52] the proposed unit and its

[48:53] revenue requirement to the

[48:55] next alternative unit?

[48:56] >> MR. Aponte: yes,

[48:58] that's correct.

[48:59] >> okay.

[48:59] And you're the person who

[49:02] developed the economic

[49:02] evaluations and support

[49:05] for the companies solar

[49:06] projects, correct?

[49:11] >> MR. Aponte: correct.

[49:11] >> would you agree that in

[49:12] your economic evaluations

[49:12] for the new solar

[49:13] resources, you used a 35

[49:15] year service life for the

[49:21] solar?

[49:21] >> MR. Aponte: yes.

[49:22] >> would you also agree if

[49:27] you use ash longer or

[49:27] shorter service life the

[49:28] economic evaluation and

[49:29] present value benefit or

[49:29] harm of adding the

[49:32] resource compared to the

[49:35] base rate?

[49:35] >> MR. Aponte: it would

[49:37] change it.

[49:39] >> and isn't it true if

[49:40] you used a shorter service

[49:41] life, it would reduce the

[49:42] economic benefit of the

[49:48] solar resources?

[49:50] >> MR. Aponte: subject to

[49:51] check, I believe the

[49:56] change will be

[49:56] insignificant.

[49:57] >> but you would agree

[49:59] that it would lessen the

[50:01] economic benefit?

[50:06] However slightly.

[50:07] >> MR. Aponte: not having

[50:08] done it, I would have to

[50:09] say it's just a small

[50:11] change.

[50:12] I don't know which way it

[50:14] would go.

[50:15] >> okay.

[50:18] If the solar project is

[50:19] delayed or never billed,

[50:19] that would reduce the

[50:22] economic benefit of the

[50:22] solar resource itself,

[50:26] correct?

[50:29] >> MR. Aponte: yes.

[50:33] >> I would ask to look at

[50:38] opc five.

[50:42] And as soon as that is up,

[50:43] there we go.

[50:49] Do you see that workpaper?

[50:53] >> MR. Aponte: yes.

[50:54] >> okay.

[50:57] Is this your analysis for

[50:59] the solar farm project?

[51:01] >> MR. Aponte: yes.

[51:07] >> looking at the bottom

[51:07] there's a note there, I

[51:08] know it's difficult to

[51:08] read and would be easier

[51:09] from your laptop.

[51:11] It says 2053 contains and

[51:12] affects.

[51:15] Does this mean the -- five

[51:16] analysis was done for 30

[51:21] years or three 2053?

[51:22] >> MR. Aponte: what that

[51:22] means is in order to

[51:23] capture the full revenue

[51:27] requirements for assets

[51:29] that go in service later

[51:30] in the time horizon, we

[51:34] have to extend the

[51:35] calculations past 2053 to

[51:36] capture their full revenue

[51:38] requirement components of

[51:42] future assets.

[51:43] >> okay.

[51:43] Is a correct that the

[51:44] company does not have any

[51:49] specific plans to retire

[51:50] its solar resources prior

[51:50] to the 35 year service

[51:52] life reflected in the

[51:56] economic evaluations?

[51:57] >> MR. Aponte: yes.

[52:01] >> and would you agree

[52:01] that in the near term, and

[52:06] this is a slightly

[52:06] different take.

[52:07] Artificial intelligence

[52:09] holds the possibility of

[52:11] lowering operating costs

[52:13] of and extending the lives

[52:14] of your solar generation

[52:17] facilities, if you know.

[52:18] >> MR. Aponte: sorry, you

[52:19] said artificial

[52:22] intelligence?

[52:26] >> mm-hmm.

[52:28] >> MR. Aponte: I hope it

[52:31] will.

[52:32] I'm not sure it is.

[52:35] >> I would ask you look at

[52:37] opc 1, and this should be

[52:39] a copy of the 10 year site

[52:39] plan.

[52:44] Are you familiar with this

[52:44] document?

[52:45] The company's 10 year site

[52:46] plan?

[52:48] >> MR. Aponte: yes, I am.

[52:50] >> I think that's just the

[52:52] coversheet, but if you

[52:53] move down to page -- I'm

[52:55] sorry, there it is.

[52:56] Two pages you can see the

[52:58] cover page for the 10 year

[53:00] site plan.

[53:02] >> MR. Aponte: yes.

[53:04] >> then I would ask to go

[53:07] to page 80 f21-80, which

[53:10] is page 78 of this 10 year

[53:13] site plan.

[53:14] And once we get there, I

[53:16] was going to ask you to

[53:18] take a look at this, which

[53:24] is the

[53:27] , I believe it is

[53:29] the english creek 10 year

[53:31] site plan.

[53:32] And if you can look down

[53:35] at the bottom of this

[53:36] portion of the document

[53:41] and under line 13, I

[53:44] believe it says that the

[53:45] service life or the book

[53:49] life here is 35 years, is

[53:50] that correct?

[53:51] >> MR. Aponte: yes.

[53:52] >> okay.

[53:53] And then if we go to the

[53:57] next page, which is

[53:58] another project, this is

[53:59] the bullfrog creek

[54:03] project, right?

[54:03] >> MR. Aponte: yes, it

[54:04] is.

[54:08] >> okay.

[54:09] And if you go down to that

[54:10] same line, 13, and go to

[54:11] book life years, it also

[54:12] says 35 years, correct?

[54:14] >> MR. Aponte: yes.

[54:16] >> okay.

[54:20] Let me take you back to

[54:21] your testimony at page 13

[54:22] ,

[54:24] and if you can let me know

[54:28] when you get there.

[54:29] >> MR. Aponte: I'm there.

[54:32] >> okay.

[54:33] I'm going to give it a

[54:34] second for these guys to

[54:35] also get there.

[54:42] Starting at line 7 of your

[54:43] testimony, you start

[54:44] talking about the south

[54:46] tampa resiliency project,

[54:48] correct?

[54:53] >> MR. Aponte: yes.

[54:53] >> and you are adding four

[54:58] reciprocating engines with

[54:59] capacity of 71 mw on

[55:03] macdill air force base, is

[55:03] that correct?

[55:04] >> MR. Aponte: that is

[55:04] correct.

[55:04] >> and if you go down

[55:06] further on the line to

[55:09] page 23 here, you through

[55:11] the top of the next page,

[55:17] you say in exchange for

[55:17] access to the base side,

[55:19] teco is getting an added

[55:20] added level of resiliency,

[55:24] is that correct?

[55:25] >> MR. Aponte: yes.

[55:26] >> am I correct that by

[55:29] adding the resilience you

[55:31] MAY not south tampa

[55:31] resiliency project

[55:32] generation is located in

[55:34] the middle of a dense load

[55:36] center?

[55:36] >> MR. Aponte: yes, it

[55:37] is.

[55:40] >> okay.

[55:40] And would you agree that

[55:42] adding -- or would you

[55:45] agree that this would

[55:46] provide essential backup

[55:49] power for the base in case

[55:50] of emergency?

[55:50] >> MR. Aponte: yes.

[55:52] >> would you also agree

[55:53] that you did not include

[55:56] any government funding in

[55:59] your -- five analysis?

[56:00] >> MR. Aponte: I did not.

[56:04] >> going to page 17 of

[56:13] your testimony, starting

[56:23] at line 14, you say the --

[56:23] five differential was

[56:24] favorable for customers by

[56:25] only 10 million without

[56:29] the omissions, is that

[56:30] correct?

[56:31] >> MR. Aponte: yes.

[56:33] >> you would agree that

[56:35] the cpvrr would've been

[56:36] more favorable for

[56:38] customers if governmental

[56:40] monetary funding had been

[56:42] sought?

[56:44] >> MR. Aponte: not

[56:46] knowing what type of

[56:49] funding is good.

[56:51] I don't know any type of

[56:55] funding.

[56:56] >> okay.

[57:01] If we go on to page 18 of

[57:02] your testimony, looking at

[57:03] line 5, you start talking

[57:08] about the future energy

[57:10] storage projects, which is

[57:11] the same thing as utility

[57:15] scale battery storage,

[57:15] correct?

[57:16] >> MR. Aponte: yes.

[57:19] >> at this time, is teco

[57:25] planning four battery

[57:25] storage projects in 2025?

[57:35] Those would be over mabel,

[57:35] wamama, and south tampa,

[57:35] correct?

[57:36] >> MR. Aponte: yes.

[57:37] >> and south tampa has

[57:39] been delayed to DECEMBER,

[57:43] 2025.

[57:44] Is that still the case?

[57:44] >> MR. Aponte: yes,

[57:45] that's my understanding.

[57:47] >> okay.

[57:49] Going to the top of page

[57:53] 25 of this document, or

[57:59] I'm sorry, 24, you discuss

[58:03] the future solar projects,

[58:03] correct?

[58:07] >> MR. Aponte: yes.

[58:08] >> and if you go over to

[58:11] the next page on page 25

[58:17] starting at line 22 if

[58:17] you're there,

[58:19] >> MR. Aponte: yes, I am.

[58:21] >> you can see that you

[58:22] are also starting to talk

[58:25] about the company's plans

[58:28] to build future solar.

[58:33] Do you see that?

[58:35] >> MR. Aponte: I do.

[58:41] >> and on that line, you

[58:42] say the company plans to

[58:43] build 448.7 million mw of

[58:43] additional solar scale pv

[58:44] projects across its

[58:46] service territory by the

[58:49] end of 2026, is that

[58:49] correct?

[58:52] >> MR. Aponte: yes.

[58:56] >> and mi correct these

[58:57] projects are cottonmouth,

[59:03] big for booster and

[59:03] wamama?

[59:05] >> MR. Aponte: yes.

[59:07] >> okay.

[59:08] Would you agree that you

[59:11] have a total of 97.5 mw of

[59:14] solar put in place by the

[59:16] end of 2024?

[59:17] >> MR. Aponte: yes.

[59:18] >> okay.

[59:22] And those would consist of

[59:23] the english creek and

[59:23] bullfrog creek project

[59:26] ,

[59:26] correct?

[59:26] >> MR. Aponte: yes, that

[59:27] is correct.

[59:28] >> if you can go to page

[59:33] 26 of your testimony, you

[59:34] say that 140 mw of future

[59:37] solar will be put in place

[59:39] by the end of 2025, is

[59:42] that correct?

[59:42] >> MR. Aponte: yes.

[59:48] >> those projects are --

[59:49] and cottonmouth projects,

[59:50] yes?

[59:51] >> MR. Aponte: yes.

[59:54] >> moving on further into

[59:56] your testimony, you say

[59:58] you have 240 mw of future

[59:59] solar that will be put

[1:00:02] into the place by the end

[1:00:04] of 2026, correct?

[1:00:06] >> MR. Aponte: yes.

[1:00:07] >> those projects are the

[1:00:10] remaining ones, big four,

[1:00:15] booster, and wamama?

[1:00:15] >> MR. Aponte: that's

[1:00:18] correct.

[1:00:19] >> if we can look at page

[1:00:23] 58 for bait stamp 70 of

[1:00:26] the 10 year site plan that

[1:00:29] is f272.

[1:00:32] Soon as we get there we'll

[1:00:41] take a look at that.

[1:00:43] And yeah, I think 72 I

[1:00:45] think master sheet

[1:00:47] .

[1:00:49] Okay.

[1:00:51] And I know it's not right

[1:00:56] side out.

[1:00:58] You can see that this

[1:00:59] shows the current summer

[1:01:03] margin reserve for tampa

[1:01:09] electric, correct?

[1:01:14] >> MR. Aponte: yes.

[1:01:16] >> it MAY be easier to

[1:01:16] look up on the screen

[1:01:18] because it has the correct

[1:01:19] orientation.

[1:01:21] Can you see that?

[1:01:30] And can you see -- do you

[1:01:31] have a better view?

[1:01:32] Let me know when you got

[1:01:35] it in a good orientation

[1:01:35] for you to take a look at

[1:01:56] it.

[1:01:59] >> MR. Aponte: okay.

[1:02:02] >> this shows the southern

[1:02:08] reserve in 2026 and 29% in

[1:02:15] 2027, is that correct?

[1:02:15] >> MR. Aponte: yes.

[1:02:17] >> I'm going to ask you to

[1:02:19] scroll to the next page of

[1:02:24] this exhibit I believe

[1:02:24] should be -- I'm sorry, f

[1:02:26] 73, which should be the

[1:02:30] next page.

[1:02:30] We MAY still have similar

[1:02:32] orientation issues.

[1:02:32] When you get that

[1:02:37] oriented, let me know.

[1:02:39] And this page should show

[1:02:42] the winter reserve margin

[1:02:42] for teco.

[1:02:44] >> MR. Aponte: yes.

[1:02:45] >> okay.

[1:02:47] can you see over into the

[1:02:50] last column where it says

[1:02:54] there's a 23% reserve

[1:02:57] margin in 2025, 23% in

[1:03:00] 2026, and 22% in 2027?

[1:03:02] >> MR. Aponte: yes.

[1:03:07] >> okay, and that's

[1:03:08] correct as far as you

[1:03:08] know?

[1:03:09] >> MR. Aponte: yes.

[1:03:09] >> would you agree that

[1:03:10] solar does not contribute

[1:03:15] to winter reserve margin?

[1:03:15] >> MR. Aponte: that's

[1:03:16] correct.

[1:03:17] >> and would you agree

[1:03:18] that right now there is no

[1:03:18] carbon emission cost

[1:03:21] imposed the federal

[1:03:23] government or state of

[1:03:24] florida?

[1:03:24] Has that changed as of

[1:03:26] today?

[1:03:27] >> MR. Aponte: it has

[1:03:30] not.

[1:03:31] >> and would you agree

[1:03:32] that the companies reserve

[1:03:34] margin is above 20% for

[1:03:41] both winter and summer

[1:03:41] reserve margins from 2025

[1:03:49] through 2027?

[1:03:50] >> MR. Aponte: they are.

[1:03:50] >> and is not correct that

[1:03:51] the solar generation

[1:03:51] projects are not needed to

[1:04:02] meet the companies solar

[1:04:02] peak needs in 2025 through

[1:04:02] 2027?

[1:04:03] >> MR. Aponte: did you

[1:04:03] say summer?

[1:04:04] >> summer.

[1:04:04] >> MR. Aponte: they

[1:04:05] contribute to the summer

[1:04:07] reserve margin, but a

[1:04:08] small percent.

[1:04:10] >> okay.

[1:04:14] Would also be correct it

[1:04:15] is not needed to meet the

[1:04:15] company's winter peak

[1:04:17] demand needs in 2025

[1:04:18] through 2027?

[1:04:20] >> MR. Aponte: yes.

[1:04:22] >> okay.

[1:04:25] I would like to call your

[1:04:25] attention to your rebuttal

[1:04:29] testimony page 7, and then

[1:04:30] when you get there we will

[1:04:33] be looking at lines 10

[1:04:45] through 12.

[1:04:49] Let me know

[1:04:49] .

[1:04:51] >> MR. Aponte: I'm there.

[1:04:52] >> okay.

[1:04:55] And looking at that

[1:04:55] portion of your testimony,

[1:04:57] you say the company

[1:04:57] performed a sensitivity

[1:05:01] analysis incorporating a

[1:05:02] 0.4% degradation per year

[1:05:06] until the end of the

[1:05:07] project's useful life for

[1:05:11] the future solar projects,

[1:05:12] is that correct?

[1:05:12] >> MR. Aponte: yes, that

[1:05:13] is correct.

[1:05:15] >> and you used a 35 year

[1:05:15] life for the solar in this

[1:05:17] analysis, is that correct?

[1:05:20] >> MR. Aponte: yes, I

[1:05:20] did.

[1:05:21] >> okay.

[1:05:24] Thank you very much.

[1:05:25] >> CHAIRMAN La Rosa:

[1:05:25] thank you.

[1:05:27] Florida rising and lulac.

[1:05:28] >> thank you.

[1:05:34] Good morning, MR. Aponte.

[1:05:37] If we can go to f3.3-5838,

[1:05:47] fll 177.

[1:05:50] As MR. Christiansen just

[1:05:51] ended out, I believe you

[1:05:53] just said that solar

[1:05:56] contributes zero points

[1:06:00] the winter reserve margin

[1:06:01] and that's because solar

[1:06:03] has a zero assumed

[1:06:04] capacity value during the

[1:06:08] time of the winter peak.

[1:06:09] >> MR. Aponte: that's

[1:06:09] correct.

[1:06:11] >> this chart here in

[1:06:15] exhibit fll-177 is the

[1:06:18] summer capacity value for

[1:06:22] the solar plant that are

[1:06:23] issued at this case?

[1:06:26] >> MR. Aponte: yes.

[1:06:28] >> so way four includes

[1:06:31] the booster and wamama

[1:06:32] solar booster project?

[1:06:34] >> MR. Aponte: yes.

[1:06:36] >> those are planned to

[1:06:42] come into start generating

[1:06:42] in 2027?

[1:06:43] >> MR. Aponte: that's

[1:06:43] correct.

[1:06:43] >> so that will be part of

[1:06:44] the subsequent year

[1:06:49] adjustment?

[1:06:50] >> MR. Aponte: yes.

[1:06:51] >> they are assumed to

[1:06:51] have a summer capacity

[1:06:52] volume of one point

[1:06:53] >> MR. Aponte: yes.

[1:06:53] >> they are assumed to

[1:06:54] have a summer capacity

[1:06:54] volume of 1.5%?

[1:06:55] >> MR. Aponte: they do.

[1:06:55] >> why is that?

[1:06:56] >> MR. Aponte: the reason

[1:06:57] for that is the more solar

[1:07:00] you add the effect on the

[1:07:03] system peak is that it

[1:07:06] moves the system peak to a

[1:07:07] later time in the day.

[1:07:13] The net between the load

[1:07:14] minus the output of solar

[1:07:15] is what we call net peak.

[1:07:16] The more solar you add,

[1:07:19] the later that net peak is

[1:07:21] going to occur during the

[1:07:23] day when the solar is

[1:07:29] producing less output.

[1:07:30] >> and if I can now direct

[1:07:31] your attention to what has

[1:07:39] been admitted on the cel,

[1:07:39] this is master number c

[1:07:57] 32-1577.

[1:07:57] Do you recognize this

[1:07:59] document?

[1:08:03] >> MR. Aponte: I do.

[1:08:03] >> and what is it?

[1:08:04] >> MR. Aponte: it is a

[1:08:05] spreadsheet that we used

[1:08:06] to calculate reserve

[1:08:08] margins.

[1:08:09] >> those diminished solar

[1:08:14] reserve firm capacity --

[1:08:15] >> MR. Aponte: if you

[1:08:23] mean capacity values, yes.

[1:08:24] >> for example, wamama

[1:08:25] three has a capacity of --

[1:08:26] but has a summer firm

[1:08:27] capacity on this chart of

[1:08:27] 1.1 mw?

[1:08:28] >> MR. Aponte: that's

[1:08:39] correct.

[1:08:39] >> would be fair to say

[1:08:40] for the period of

[1:08:40] 2025-2027, in order to

[1:08:41] maintain 20% would be the

[1:08:41] winter reserve margin we

[1:08:42] should be looking at the

[1:08:44] could be driving plant

[1:08:47] additions into the system?

[1:08:47] >> MR. Aponte: can you

[1:08:50] please repeat that

[1:08:53] question?

[1:08:53] >> sure.

[1:08:54] In other words, the summer

[1:08:54] reserve margin as

[1:08:55] reflected in this chart

[1:08:57] for 2025-2027 is higher

[1:08:59] than the winter reserve

[1:09:01] margin?

[1:09:02] >> MR. Aponte: yes.

[1:09:05] >> so any plant additions,

[1:09:07] for reserve margin

[1:09:09] purposes to meet that 20%

[1:09:12] we should be looking at

[1:09:13] that winter reserve

[1:09:13] margin?

[1:09:14] >> MR. Aponte: we are.

[1:09:18] >> and solar plants are

[1:09:18] assumed to not contribute

[1:09:20] to that?

[1:09:26] >> MR. Aponte: correct.

[1:09:27] >> so the solar plants

[1:09:27] that are being added to

[1:09:28] the system or for the

[1:09:28] energy value that

[1:09:29] translates into economic

[1:09:30] benefits for teco and its

[1:09:31] customers?

[1:09:35] >> MR. Aponte: yes, a big

[1:09:36] portion of the benefit is

[1:09:37] reduction of fuel costs.

[1:09:41] >> so the solar is not

[1:09:41] being added for its

[1:09:43] capacity value?

[1:09:48] >> MR. Aponte: correct.

[1:09:50] >> you're not aware of any

[1:09:52] recent analysis by teco

[1:09:52] showing that if you went

[1:09:55] below 20% reserve margin

[1:09:59] that rolling blackouts

[1:10:02] would be more likely to

[1:10:02] occur?

[1:10:03] >> MR. Aponte: I'm not

[1:10:04] aware of any analysis like

[1:10:04] that.

[1:10:09] >> if I connect direct

[1:10:10] your attention to master

[1:10:21] page f 3.1-2651.

[1:10:23] You are the sponsor of

[1:10:30] this interrogatory?

[1:10:30] >> MR. Aponte: yes.

[1:10:31] >> and so teco does not

[1:10:34] conduct loss of load

[1:10:37] probability studies?

[1:10:38] >> MR. Aponte: not at the

[1:10:38] time.

[1:10:43] >> what is a loss of load

[1:10:43] probability study?

[1:10:44] >> MR. Aponte: a loss of

[1:10:46] load would indicate if the

[1:10:46] portfolio, it's a measure

[1:10:47] of the reliability of the

[1:10:50] portfolio and it's trying

[1:10:51] to determine the chances

[1:10:54] of not meeting load.

[1:10:57] The industry standard

[1:10:57] seems to be one day in 10

[1:11:01] years.

[1:11:03] >> switching topics now,

[1:11:04] you did a series of

[1:11:12] cost-effective analyses in

[1:11:13] connection with this case?

[1:11:13] >> MR. Aponte: yes.

[1:11:14] >> and if we can go to

[1:11:14] what has been admitted as

[1:11:15] staff exhibit 159 master e

[1:11:31] master e1965.

[1:11:32] This is a copy of the

[1:11:35] financial inputs that you

[1:11:35] used in your

[1:11:36] cost-effective analyses

[1:11:38] that were included in your

[1:11:42] study?

[1:11:43] >> MR. Aponte: yes.

[1:11:49] >> you assumed a 10.2 %

[1:11:49] return on equity?

[1:11:50] >> MR. Aponte: I did.

[1:11:50] >> if the return on equity

[1:11:53] was approved it would

[1:11:58] impact your analyses?

[1:11:59] >> MR. Aponte: it would.

[1:11:59] >> that would create a

[1:12:01] different than the revenue

[1:12:01] requirement?

[1:12:02] >> MR. Aponte: it would

[1:12:07] create a different revenue

[1:12:08] requirement.

[1:12:08] The only thing I would add

[1:12:09] to that is when we are

[1:12:09] doing cost-effective

[1:12:11] analysis we are looking at

[1:12:12] doing reference case as

[1:12:15] well as a change case and

[1:12:15] when the financial

[1:12:19] assumptions change, they

[1:12:22] have to be changed on both

[1:12:22] and I'm saying that

[1:12:24] because we expect the

[1:12:32] changes to the results to

[1:12:34] be not that material.

[1:12:36] >> if I can direct your

[1:12:38] attention to e your

[1:12:53] attention to e2088.

[1:12:55] This shows a copy of the

[1:13:02] fuel price that was used

[1:13:02] in the right case?

[1:13:03] >> MR. Aponte: yes.

[1:13:07] >> included in your

[1:13:08] cost-effective analysis?

[1:13:08] >> MR. Aponte: correct.

[1:13:09] >> it does show escalating

[1:13:11] gas prices?

[1:13:18] >> MR. Aponte: it does.

[1:13:26] >> the south tampa

[1:13:27] resiliency project is a

[1:13:27] series of reciprocating --

[1:13:28] on the macdill air force

[1:13:28] base?

[1:13:29] >> MR. Aponte: yes.

[1:13:29] >> it will provide backup

[1:13:33] -- in case of an

[1:13:33] emergency?

[1:13:34] >> MR. Aponte: in the

[1:13:34] case of an emergency, yes.

[1:13:38] >> besides the land, the

[1:13:39] us government is not

[1:13:39] providing any contribution

[1:13:44] to the us --

[1:13:44] >> MR. Aponte: not that

[1:13:45] I'm aware of.

[1:13:46] >> if I can direct your

[1:13:51] attention to f ll master

[1:14:13] page f 3.3-5305.

[1:14:13] This is one of your

[1:14:14] documents?

[1:14:16] >> MR. Aponte: yes.

[1:14:19] >> and it includes the

[1:14:20] reserve margin

[1:14:21] calculations for the

[1:14:22] winter with and without

[1:14:25] the south tampa resiliency

[1:14:26] project?

[1:14:40] >> MR. Aponte: yes.

[1:14:40] >> then if I connect

[1:14:41] direct your attention to

[1:14:45] exhibit fll 127 master

[1:15:10] page f 3.2-3894.

[1:15:11] >> MR. Aponte: I'm sorry,

[1:15:13] MAY I have a clarification

[1:15:14] on the previous exhibit?

[1:15:19] >> we can go back to that

[1:15:31] was master page f 3.3-505.

[1:15:31] 3.3 b

[1:15:36] 5305.

[1:15:38] >> MR. Aponte: thank you.

[1:15:39] When this exhibit was

[1:15:47] developed and reflect with

[1:15:48] and without the specific

[1:15:51] project, I just wanted to

[1:15:53] clarify the remaining

[1:15:57] expansion plan has been

[1:16:02] tailored to meet reserve

[1:16:02] margin of 20%.

[1:16:05] So this does not reflect

[1:16:06] pulling the project out

[1:16:08] and leaving a reserve

[1:16:12] margin gap.

[1:16:14] >> I'm sorry, could you

[1:16:15] say that again?

[1:16:17] >> MR. Aponte: yes.

[1:16:18] For example, if I take

[1:16:20] away all the proposed

[1:16:23] projects that we have, we

[1:16:25] would fall under 20%

[1:16:29] reserve margin ready

[1:16:30] quickly.

[1:16:31] And to satisfy that

[1:16:32] reserve margin, if we were

[1:16:35] to not do the projects, we

[1:16:39] would have to add capacity

[1:16:40] in a different way.

[1:16:42] Perhaps it's the next best

[1:16:43] condition, which could be

[1:16:45] a ct.

[1:16:47] What I'm trying to say is

[1:16:49] when we took away the

[1:16:51] south tampa project, for

[1:16:56] example, in this chart and

[1:16:56] it created a reserve

[1:16:58] margin need, we filled it

[1:17:00] with another resource.

[1:17:03] >> and I think we're going

[1:17:04] to get there.

[1:17:04] We have a lot of

[1:17:07] documents, MR. Aponte.

[1:17:07] I think what you're

[1:17:08] referring to is the

[1:17:09] documents that show the

[1:17:11] base case and the change

[1:17:13] case with each individual

[1:17:19] projects and those base

[1:17:19] cases has placeholder ct

[1:17:24] for teco to meet its

[1:17:24] reserve margin, is that

[1:17:24] right?

[1:17:25] >> MR. Aponte: that is

[1:17:29] correct.

[1:17:30] >> this would be in

[1:17:30] reference to those base

[1:17:32] cases?

[1:17:40] >> MR. Aponte: yes.

[1:17:41] >> if we can go back now

[1:17:42] to master page f 3.2 b

[1:17:43] 3894, this is going to be

[1:18:04] fll 127.

[1:18:07] and this document provides

[1:18:08] the detail of that base

[1:18:10] case without the south

[1:18:19] tampa resiliency project?

[1:18:22] >> MR. Aponte: I believe

[1:18:25] so.

[1:18:27] >> and you would agree

[1:18:29] there's no summer reserve

[1:18:32] margin issue?

[1:18:33] >> MR. Aponte: that's

[1:18:35] correct.

[1:18:37] >> and it does show on the

[1:18:39] next page for the winter

[1:18:43] it does show a 20% reserve

[1:18:49] margin for the winter of

[1:18:53] 2026?

[1:18:55] >> MR. Aponte: yes, I see

[1:18:57] that.

[1:18:58] >> and it does not show a

[1:19:00] winter reserve margin

[1:19:02] before then?

[1:19:03] >> MR. Aponte: not before

[1:19:04] then.

[1:19:07] >> would you agree it

[1:19:07] would be for economic

[1:19:10] reasons, not capacity

[1:19:10] reasons?

[1:19:16] >> MR. Aponte: yes.

[1:19:19] >> if I can now go to

[1:19:20] fll-128, this is going to

[1:19:41] be master page f.2-3897.

[1:19:42] And so this document would

[1:19:43] provide additional detail

[1:19:44] regarding the reserve

[1:19:46] margins with the south

[1:19:51] tampa resiliency project.

[1:19:54] >> MR. Aponte: I'm going

[1:19:55] to go with that because I

[1:19:57] don't see a title on the

[1:19:59] page.

[1:20:00] >> we can go through the

[1:20:02] bait stamped number and

[1:20:04] establish the trail.

[1:20:04] >> MR. Aponte: that's

[1:20:05] okay.

[1:20:07] We can move on.

[1:20:10] >> and this document,

[1:20:11] again, if I represent to

[1:20:13] you is would be the south

[1:20:17] tampa resiliency change

[1:20:17] case, it would only

[1:20:18] include the reserve

[1:20:22] margins over the next

[1:20:26] document that we're going

[1:20:27] to get to, which would be

[1:20:27] the south tampa resiliency

[1:20:30] project case that you use

[1:20:30] in your cost-effective

[1:20:33] analysis.

[1:20:33] >> MR. Aponte: okay.

[1:20:36] >> so it does not include

[1:20:37] all of the storage

[1:20:42] projects after the --

[1:20:42] project?

[1:20:44] >> MR. Aponte: that's

[1:20:46] correct.

[1:20:49] >> this shows it would be

[1:20:51] down to a 20% reserve

[1:20:53] margin for the winter of

[1:20:56] 2027?

[1:20:57] >> MR. Aponte: yes, that

[1:20:58] is correct.

[1:20:58] >> maybe I should've done

[1:21:00] this in a different order,

[1:21:02] but what let's now go to

[1:21:20] master page f 3.2-3900.

[1:21:21] And so this document shows

[1:21:23] the base case and south

[1:21:25] tampa resiliency project

[1:21:28] change case used for your

[1:21:33] cost-effective analysis?

[1:21:37] >> MR. Aponte: yes.

[1:21:38] >> so it does not include

[1:21:41] any of the solar

[1:21:41] subsequent to the dover

[1:21:44] battery project in either

[1:21:44] case, although teco is

[1:21:45] moot landing to move

[1:21:46] forward with those

[1:21:49] projects?

[1:21:50] >> MR. Aponte: that is

[1:21:54] correct.

[1:21:54] >> even for the change

[1:21:56] case, it still shows a

[1:21:59] need for the ct

[1:22:02] ?

[1:22:02] >> MR. Aponte: yes.

[1:22:08] >> and it does include the

[1:22:10] polk one simple cycle

[1:22:13] conversion project, is

[1:22:16] that right?

[1:22:16] >> MR. Aponte: it does.

[1:22:18] >> we will discuss the

[1:22:20] project more in-depth

[1:22:23] later, but that actually

[1:22:28] increases the depth of

[1:22:28] that?

[1:22:29] >> MR. Aponte: slightly,

[1:22:29] yes.

[1:22:34] >> if I can next direct

[1:22:35] your attention to fll-233

[1:22:36] master page f 3.2-388

[1:22:36] direct your attention to

[1:22:37] fll-233 master page f

[1:22:53] 3.2-3883.

[1:22:58] And this shows your

[1:22:59] cost-effectiveness results

[1:23:01] for the south tampa

[1:23:01] resiliency project?

[1:23:06] >> MR. Aponte: yes.

[1:23:12] >> and some basic

[1:23:12] questions here.

[1:23:13] If it's in parentheses,

[1:23:13] that's savings.

[1:23:14] If it's not in

[1:23:14] parentheses, that's base

[1:23:22] cost.

[1:23:26] The biggest savings come

[1:23:26] from system fuel, right?

[1:23:30] And it is directed with

[1:23:32] energy fuel, not -- this

[1:23:33] project would not have

[1:23:35] been found to be

[1:23:39] cost-effective.

[1:23:40] >> MR. Aponte: that's

[1:23:41] correct.

[1:23:44] >> if I can next direct

[1:23:49] your attention to master

[1:23:50] page if 3.2-3901.

[1:24:07] This is fll-29.

[1:24:11] And just want to direct

[1:24:12] your attention to the

[1:24:14] bottom of the page there's

[1:24:17] a note.

[1:24:23] It says the south tampa

[1:24:23] resiliency project is

[1:24:26] constrained to 37.6 mw

[1:24:27] until summer of 2026.

[1:24:31] Is that right?

[1:24:32] >> MR. Aponte: yes, I see

[1:24:32] that.

[1:24:32] >> is that your

[1:24:34] understanding that that's

[1:24:34] true?

[1:24:35] >> MR. Aponte: that is

[1:24:40] true that analysis was --

[1:24:44] we MAY have some

[1:24:50] accelerating on that date.

[1:24:51] >> one of the benefits of

[1:24:51] the project for teco's

[1:24:52] customers was to avoid

[1:24:59] transmissions upgrades, is

[1:24:59] that right?

[1:25:00] >> MR. Aponte: yes.

[1:25:00] >> if I can direct your

[1:25:01] attention to fll-247

[1:25:05] master page f 3.4 -- I'm

[1:25:06] sorry, yes.

[1:25:25] F 3.4-19921.

[1:25:27] This is an earlier draft

[1:25:28] of the cost-effectiveness

[1:25:31] analysis for the south

[1:25:37] tampa resiliency project.

[1:25:39] >> MR. Aponte: yes.

[1:25:42] >> and it shows an

[1:25:44] estimate of approximately

[1:25:46] $5.5 million in savings

[1:25:52] and avoided transmission

[1:25:53] is a benefit.

[1:25:53] >> MR. Aponte: that's

[1:25:54] correct, yes.

[1:25:54] >> it also shows the cost

[1:25:55] for the facility are

[1:25:56] estimated to be 8.2

[1:26:02] million.

[1:26:02] >> MR. Aponte: yes.

[1:26:04] >> sold those interdiction

[1:26:07] costs are higher than the

[1:26:07] avoided transmission

[1:26:09] costs?

[1:26:09] >> MR. Aponte: yes, they

[1:26:22] are.

[1:26:23] >> all right.

[1:26:33] If I could go back to

[1:26:34] master page c32-3577.

[1:26:36] This is admitted exhibit

[1:26:46] 320.

[1:26:50] This document contains all

[1:26:51] of the generation and

[1:26:54] storage projects that teco

[1:26:56] has proposed through this

[1:27:23] rate case?

[1:27:26] >> MR. Aponte: I'm there.

[1:27:32] >> this document contains

[1:27:32] all of the stroller,

[1:27:33] battery storage, and

[1:27:33] generation projects that

[1:27:36] teco has in this case?

[1:27:38] >> MR. Aponte: it does.

[1:27:40] >> if you go to winter of

[1:27:42] 2027, south tampa

[1:27:48] resiliency has 75 mw of

[1:27:49] capacity that's

[1:27:51] contributing to that

[1:27:53] winter reserve margin?

[1:28:00] >> MR. Aponte: yes.

[1:28:01] >> if you deduct that 75

[1:28:02] mw, you would still have

[1:28:04] that margin in 2027, would

[1:28:07] you?

[1:28:14] >> MR. Aponte: we MAY in

[1:28:14] that year, we MAY fall

[1:28:15] shorter than that.

[1:28:15] >> you would agree that

[1:28:16] through 2027 you would be

[1:28:20] okay?

[1:28:20] >> MR. Aponte: yes.

[1:28:21] >> if I can next direct

[1:28:31] your attention to fll-131.

[1:28:31] This is going to be master

[1:28:52] page f 3.2-3908.

[1:28:56] This document would

[1:28:57] include the big four solar

[1:29:00] base case and change case?

[1:29:02] >> MR. Aponte: okay.

[1:29:06] >> and you would agree

[1:29:07] that the reserve margins

[1:29:11] on here are -- well, even

[1:29:19] through 2027 are both 20%?

[1:29:19] >> MR. Aponte: winter,

[1:29:19] yes.

[1:29:20] >> as comparison to the

[1:29:21] base case and change case

[1:29:26] we were looking at with

[1:29:27] the south tampa resiliency

[1:29:27] projects, the shows other

[1:29:28] projects lingered on,

[1:29:29] which is the energy

[1:29:31] storage subsequent to the

[1:29:32] dover energy project and

[1:29:34] other solar projects that

[1:29:38] come before this.

[1:29:39] >> MR. Aponte: that's

[1:29:48] correct.

[1:29:49] >> and just for comparison

[1:29:50] purposes, keep in mind the

[1:29:54] summer reserve margin here

[1:29:54] for 2027, and if we could

[1:30:03] next go to fll-145, this

[1:30:03] is going to be master page

[1:30:09] f 3.2-3964.

[1:30:09] Before we -- sorry, real

[1:30:09] quick.

[1:30:11] This does not show the

[1:30:19] wamama three project?

[1:30:19] >> MR. Aponte: it is not.

[1:30:20] >> now let's go to that

[1:30:44] master f 3.2-3964.

[1:30:46] This document includes the

[1:30:48] wamama change case and

[1:30:50] base case?

[1:30:53] >> MR. Aponte: yes.

[1:30:55] >> and the reserve margin

[1:30:56] is not all that different

[1:30:58] from what we were looking

[1:30:59] at before?

[1:31:06] >> MR. Aponte: yes.

[1:31:12] >> if we can next go to

[1:31:13] fll-122.

[1:31:13] This is going to be master

[1:31:33] page f 3.2-3875.

[1:31:34] This is your

[1:31:35] cost-effective analysis

[1:31:38] for the polk unit one

[1:31:39] flexibility project, which

[1:31:41] is the simple cycle

[1:31:43] conversion project?

[1:31:49] >> MR. Aponte: yes.

[1:31:51] >> and this project found

[1:31:57] savings or has savings

[1:32:00] from the polk one project

[1:32:00] upgrade and polk one

[1:32:05] sustaining capital and

[1:32:05] feeling?

[1:32:06] >> MR. Aponte: yes.

[1:32:06] >> so you would agree that

[1:32:08] those savings are coming

[1:32:09] from some kind of capital

[1:32:10] investment teco is

[1:32:11] assuming would need to be

[1:32:20] made at polk unit one to

[1:32:21] keep polk unit one as it

[1:32:21] is without the flexibility

[1:32:22] project?

[1:32:22] >> MR. Aponte: yes, that

[1:32:23] is correct.

[1:32:24] >> and this is not a

[1:32:25] project to add capacity to

[1:32:31] the system?

[1:32:31] >> MR. Aponte: it is not.

[1:32:32] >> in fact, the expected

[1:32:33] output of the converted

[1:32:33] unit is about 20 mw less

[1:32:35] than the converted cycle?

[1:32:36] >> MR. Aponte: that's

[1:32:39] correct.

[1:32:40] >> if I can next direct

[1:32:45] your attention to fll-92

[1:33:10] master page f 3.1-2895.

[1:33:11] Do you see that

[1:33:11] interrogatory answer in

[1:33:11] front of you?

[1:33:12] >> MR. Aponte: I do.

[1:33:13] >> this actually shows the

[1:33:14] cost of that polk one

[1:33:14] upgrade without the polk

[1:33:18] one flexibility project.

[1:33:18] >> MR. Aponte: I believe

[1:33:20] so, yes.

[1:33:20] >> so this will be the

[1:33:24] cost necessary to maintain

[1:33:25] polk one as is?

[1:33:27] >> that's correct.

[1:33:28] >> would you agree the

[1:33:30] biggest cost is capital

[1:33:35] for the steam turbine?

[1:33:36] >> MR. Aponte: yes, I see

[1:33:44] that.

[1:33:48] >> and the next biggest

[1:33:49] cost would be for the heat

[1:33:49] recovery steam generator?

[1:33:54] >> MR. Aponte: yes.

[1:33:57] >> if I can next direct

[1:34:01] your attention to fll 124.

[1:34:02] This is going to be master

[1:34:16] page f 3.2-3885.

[1:34:19] And so this document shows

[1:34:22] the reserve margins in the

[1:34:24] fgd one flexibility base

[1:34:31] case.

[1:34:32] >> MR. Aponte: yes.

[1:34:33] >> the base case for that

[1:34:34] is flexibility project

[1:34:38] does not move forward and

[1:34:44] polk one stays as is?

[1:34:45] >> MR. Aponte: that's

[1:34:45] correct.

[1:34:46] >> if I can next direct

[1:34:47] your attention to fll --

[1:35:03] master page 3888.

[1:35:04] And this document shows

[1:35:06] the reserve margins in the

[1:35:08] fgd one flexibility case

[1:35:08] as the project moves

[1:35:11] forward.

[1:35:12] >> MR. Aponte: yes.

[1:35:14] >> and as alluded to

[1:35:15] earlier, you would agree

[1:35:18] the total installed form

[1:35:18] capacity as compared to

[1:35:20] the document we were just

[1:35:25] looking at those down

[1:35:25] slightly?

[1:35:25] >> MR. Aponte: yes.

[1:35:26] >> you would agree that

[1:35:27] the summer reserve margins

[1:35:29] are still well below 20%?

[1:35:32] >> MR. Aponte: they are.

[1:35:38] >> if we can next go to

[1:35:38] fll-126 master page f

[1:35:50] 3.2-3891.

[1:35:53] And this document shows

[1:35:54] the polk one flexibility

[1:35:57] base case and the polk one

[1:36:04] flexibility change case.

[1:36:08] >> MR. Aponte: yes.

[1:36:11] >> and the fgd one

[1:36:14] flexibility base case does

[1:36:15] not include any of the

[1:36:19] other projects at issue in

[1:36:19] this case, correct?

[1:36:21] Other than the dover

[1:36:22] energy storage capacity

[1:36:27] project going in 2024?

[1:36:31] >> MR. Aponte: yes, in

[1:36:31] this particular

[1:36:32] illustration it does not.

[1:36:33] >> it is not include the

[1:36:35] -- it does not show any

[1:36:36] need for additional

[1:36:40] generation until 2027?

[1:36:40] >> MR. Aponte: yes.

[1:36:41] >> and that's going to be

[1:36:42] based on the 20% reserve

[1:36:46] margin for winter?

[1:36:46] >> MR. Aponte: yes.

[1:36:54] >> if I can next direct

[1:36:54] your attention to f ll-97

[1:37:09] master page f 3.1-3000.

[1:37:12] You conducted a

[1:37:13] cost-effective analysis

[1:37:13] looking at the potential

[1:37:18] to retire polk unit one?

[1:37:18] >> MR. Aponte: yes, we

[1:37:21] did.

[1:37:21] >> and found such

[1:37:22] retirement to be

[1:37:23] cost-effective

[1:37:23] ?

[1:37:29] >> MR. Aponte: did.

[1:37:30] >> thank you.

[1:37:30] That's all my questions,

[1:37:31] MR. CHAIRMAN.

[1:37:31] >> CHAIRMAN La Rosa:

[1:37:31] thank you.

[1:37:37] Next up is fipug.

[1:37:37] >> thank you, MR.

[1:37:38] CHAIRMAN.

[1:37:41] Good morning.

[1:37:42] >> MR. Aponte: good

[1:37:45] morning.

[1:37:45] >> I had a question

[1:37:46] yesterday for your vice

[1:37:48] PRESIDENT Of operations

[1:37:48] with respect to how you

[1:37:51] determine the need for

[1:37:52] future facilities.

[1:37:52] I believe he asked me to

[1:37:57] ask you that question and

[1:37:58] you are responsible for

[1:37:59] future facilities, is that

[1:38:03] right?

[1:38:04] >> MR. Aponte: yes.

[1:38:04] >> MR. Moyle: how do you

[1:38:05] determine the need for the

[1:38:09] solar plants that you are

[1:38:10] putting in now?

[1:38:10] You were asked a question

[1:38:18] about an economic need

[1:38:19] versus a physical reserve

[1:38:19] margin need.

[1:38:20] Explain how you would

[1:38:20] determine the need for the

[1:38:22] solar plants that you are

[1:38:23] seeking recovery for,

[1:38:24] please.

[1:38:25] >> MR. Aponte: yes, of

[1:38:25] course.

[1:38:28] There are two basic

[1:38:29] components of need or a

[1:38:35] criteria for adding new

[1:38:36] resources.

[1:38:36] In the example of solar,

[1:38:37] that is affordability.

[1:38:40] It is an economic need,

[1:38:43] adding the solar lowers

[1:38:48] the cpvrr for customers

[1:38:48] compared to not doing

[1:38:49] those projects.

[1:38:50] The second criteria is the

[1:38:58] 20% reserve margin.

[1:38:58] We are required to

[1:38:59] maintain 20%.

[1:38:59] In the case of tampa

[1:39:00] electric, it's a winter

[1:39:06] reserve margin.

[1:39:07] >> MR. Moyle: is part of

[1:39:07] your analysis, if you're

[1:39:10] looking and you have a 20%

[1:39:11] reserve margin and there's

[1:39:11] an economic benefit with

[1:39:17] silver, when you keep

[1:39:18] adding solar to take you

[1:39:18] above 25 to go to 30?

[1:39:19] Is there a hard line

[1:39:19] anywhere stop on the

[1:39:22] reserve margin?

[1:39:24] >> MR. Aponte: well, with

[1:39:27] solar, as I described very

[1:39:29] briefly earlier, there's a

[1:39:34] point where solar loses in

[1:39:35] a capacity value, which in

[1:39:37] this case will be in the

[1:39:38] summer.

[1:39:39] At some point, solar

[1:39:41] doesn't really move the

[1:39:45] needle in any way in terms

[1:39:45] of reserve margin for

[1:39:49] either winter or summer.

[1:39:52] And we believe that is a

[1:39:52] proper way to look at it

[1:39:54] because if we don't do

[1:39:56] that adjustment, solar

[1:39:59] would artificially inflate

[1:40:03] reserve margins and that's

[1:40:06] just not a good

[1:40:07] reliability metric to have

[1:40:11] high reserve for solar.

[1:40:11] That's why that adjustment

[1:40:12] is necessary for the

[1:40:16] summer.

[1:40:17] >> MR. Moyle: I think you

[1:40:17] answered a question where

[1:40:18] you said there's no value

[1:40:22] added to the winter.

[1:40:24] There's a very small

[1:40:26] benefit added to the

[1:40:27] summer.

[1:40:28] It was 1.5%, is that

[1:40:32] right?

[1:40:32] >> MR. Aponte: that's

[1:40:32] correct.

[1:40:33] That would be the last

[1:40:34] couple of projects we are

[1:40:37] presenting would have 1.5%

[1:40:39] capacity value to the

[1:40:41] summer.

[1:40:46] >> MR. Moyle: and when

[1:40:46] you say that 1.5% capacity

[1:40:47] value to the summer,

[1:40:49] explain exactly what that

[1:40:49] means.

[1:40:50] That doesn't mean you're

[1:40:59] at 18.5 and it gets you

[1:40:59] 1.5, so you're at 20%, so

[1:41:00] you're good on reserve

[1:41:00] margin, does it?

[1:41:05] >> MR. Aponte: no, it

[1:41:07] does not mean that.

[1:41:07] What that means is out of

[1:41:08] the name plate capacity

[1:41:08] out of solar going on

[1:41:09] doing calculation for the

[1:41:13] reserve margin on any

[1:41:13] given year, I'm only

[1:41:14] counting 1.5% of its

[1:41:17] nameplate to contribute

[1:41:18] towards reserve margin in

[1:41:23] the summer in that year.

[1:41:24] >> MR. Moyle: so what's

[1:41:26] the math on that assuming

[1:41:28] 75 mw?

[1:41:31] >> MR. Aponte: like one,

[1:41:37] 2 mw.

[1:41:37] >> MR. Moyle: do you have

[1:41:38] operational familiarity

[1:41:41] with how your solar

[1:41:42] utility skills solar

[1:41:45] works?

[1:41:47] >> MR. Aponte: yes.

[1:41:51] Somewhat, yes.

[1:41:51] >> MR. Moyle: there was a

[1:41:52] discussion about if the

[1:41:59] sun is not shining it can

[1:41:59] degrade the solar unit

[1:42:00] output.

[1:42:00] Obviously, that makes

[1:42:02] sense at night.

[1:42:03] But in a discussion

[1:42:03] yesterday with MR. Stryker

[1:42:07] you said there's

[1:42:07] variability on that.

[1:42:07] Can the variability go

[1:42:09] higher as well?

[1:42:10] He was talking about it

[1:42:12] going lower, but can I go

[1:42:13] higher as well

[1:42:16] operationally?

[1:42:18] >> MR. Aponte: yes.

[1:42:23] The variability of solar

[1:42:23] can go both ways.

[1:42:24] At any given hour, solar

[1:42:25] could move a little bit up

[1:42:29] or down.

[1:42:30] >> MR. Moyle: and if

[1:42:32] you're designing your

[1:42:32] solar fields, utility

[1:42:36] skills solar fields at

[1:42:39] 71.5, is that right?

[1:42:39] >> MR. Aponte: that is

[1:42:39] correct.

[1:42:40] >> MR. Moyle: can go over

[1:42:41] that on an ideal day for

[1:42:42] solar?

[1:42:43] >> MR. Aponte: no, it

[1:42:45] cannot.

[1:42:46] That is governed by the

[1:42:52] converters.

[1:42:53] >> MR. Moyle: inverter,

[1:42:54] is that like a governor

[1:42:54] that won't let it go about

[1:42:55] that?

[1:42:59] Have you heard of a

[1:42:59] governor on a car?

[1:43:01] >> MR. Aponte: yeah,

[1:43:07] something like that.

[1:43:12] >> MR. Moyle: on page 27

[1:43:13] of your testimony, line

[1:43:18] 12, I mean, you run

[1:43:20] cost-effective analysis on

[1:43:23] all of these solar

[1:43:24] projects, correct?

[1:43:26] >> MR. Aponte: yes.

[1:43:27] >> MR. Moyle: you said

[1:43:28] one was not

[1:43:32] cost-effective, yes?

[1:43:32] Which one is that?

[1:43:33] >> MR. Aponte: it's

[1:43:43] english creek.

[1:43:43] >> but you're asking it to

[1:43:45] be approved even though

[1:43:46] it's not cost-effective,

[1:43:47] right?

[1:43:47] >> MR. Aponte: that is

[1:43:49] correct.

[1:43:51] Although, there has been a

[1:43:52] couple of changes to

[1:43:55] inputs that have recently

[1:43:55] happen.

[1:43:57] For example, the increase

[1:44:00] of the ptc from 27.5-$30

[1:44:04] per megawatt hour.

[1:44:04] We also filed a midcourse

[1:44:06] correction forecast

[1:44:08] several months ago as

[1:44:11] another input change and I

[1:44:12] believe that both of those

[1:44:14] combined make english

[1:44:20] creek the small benefit.

[1:44:21] >> MR. Moyle: but you

[1:44:23] haven't done an analysis

[1:44:26] or have a document or

[1:44:30] anything that suggests

[1:44:30] that's the case, is that

[1:44:31] correct?

[1:44:31] >> MR. Aponte: that's

[1:44:31] correct.

[1:44:32] We believe it's going to

[1:44:33] become a cost-effective

[1:44:44] project.

[1:44:45] >> MR. Moyle: MR. Collins

[1:44:47] indicated that you did not

[1:44:50] use a carbon ater with

[1:44:53] respect to your analysis

[1:44:56] of a cost-effectiveness of

[1:44:57] solar projects.

[1:44:59] Wasn't he half right when

[1:45:03] he said that?

[1:45:05] >> MR. Aponte: MR.

[1:45:06] Collins was absolutely

[1:45:06] correct.

[1:45:07] I did not.

[1:45:12] >> MR. Moyle: duly noted.

[1:45:13] Let me come at it this

[1:45:13] way.

[1:45:14] Didn't you do an analysis

[1:45:15] of your cost-effectiveness

[1:45:20] assuming a carbon cost in

[1:45:22] one way and then also not

[1:45:27] assuming a carbon cost?

[1:45:28] >> MR. Aponte: yes,

[1:45:28] that's correct.

[1:45:29] We did it both ways,

[1:45:33] although the company's

[1:45:34] criteria for determining

[1:45:36] to move forward with

[1:45:39] cost-effective projects

[1:45:43] excludes all benefits from

[1:45:45] the reduction of co2.

[1:45:49] Exhibits show it to show

[1:45:49] how much more benefit we

[1:45:51] could potentially get in

[1:45:53] the event that a carbon

[1:45:56] tax becomes a mandate, but

[1:45:58] the criteria for the

[1:45:59] company to move forward

[1:46:00] with cost-effective

[1:46:02] projects excludes the

[1:46:05] benefit of co2.

[1:46:06] >> MR. Moyle: let's just

[1:46:06] reference one.

[1:46:08] The last exhibit in your

[1:46:16] direct testimony.

[1:46:22] It's on page 63.

[1:46:23] Document number 22 page

[1:46:25] 101 of your direct

[1:46:42] testimony.

[1:46:44] >> MR. Aponte: I am

[1:47:10] there.

[1:47:13] >> MR. Moyle: I believe

[1:47:14] -- okay, it's up there.

[1:47:16] The name of this project

[1:47:19] is, what?

[1:47:20] >> MR. Aponte: wamama

[1:47:22] three.

[1:47:23] >> MR. Moyle: if you go

[1:47:25] down so we can scroll down

[1:47:29] to the co2 emissions cost.

[1:47:35] >> MR. Aponte: yes.

[1:47:36] >> CHAIRMAN La Rosa: that

[1:47:36] figure, how did you come

[1:47:36] up with that figure?

[1:47:37] >> MR. Aponte: some time

[1:47:38] ago we went out and

[1:47:42] purchased a report from an

[1:47:44] outside consultant that

[1:47:46] based on their research

[1:47:48] and their analysis

[1:47:52] assigned a specific value

[1:47:56] to a cost per ton of co2.

[1:47:58] For our region.

[1:48:00] So basically using that

[1:48:04] value multiplied by the

[1:48:05] amount of tons that the

[1:48:14] solar project would reduce

[1:48:15] on our system, that turns

[1:48:15] into a benefit.

[1:48:18] The amount of tons reduced

[1:48:19] by the cost of each ton

[1:48:19] that would've cost us if

[1:48:22] there was a carbon tax,

[1:48:29] that is what that cost

[1:48:29] benefit.

[1:48:31] The consultant's name was

[1:48:34] called icf.

[1:48:38] >> MR. Moyle: what did

[1:48:38] the report conclude?

[1:48:39] When you read it, what was

[1:48:39] the rationale and

[1:48:41] reasoning as to why a

[1:48:43] carbon cost was projected

[1:48:45] to be in place

[1:48:48] particularly at a point in

[1:48:49] time that it would affect

[1:48:52] the solar units that you

[1:48:56] are moving forward with.

[1:48:57] >> MR. Aponte: like I

[1:49:01] said, the report is a year

[1:49:02] or two old and the report

[1:49:02] looked at the macro

[1:49:04] economics everything going

[1:49:10] on with any type of

[1:49:15] proposals for regulations,

[1:49:16] emission regulations.

[1:49:19] It looks at the region.

[1:49:22] It looked at many factors

[1:49:25] to come up with that.

[1:49:26] >> MR. Moyle: and did his

[1:49:29] report assume it would be

[1:49:30] government action that

[1:49:35] would impose a fee or tax

[1:49:37] on carbon?

[1:49:39] >> MR. Aponte: at the

[1:49:39] time of that report, I

[1:49:42] believe that it did assume

[1:49:44] government action at a

[1:49:46] certain year in the

[1:49:49] future.

[1:49:52] Like I said, the report is

[1:49:55] a couple of years old.

[1:49:58] >> MR. Moyle: did you, in

[1:49:59] preparing your testimony,

[1:49:59] did you check the

[1:50:02] conclusion there might be

[1:50:05] a tax on carbon imposed by

[1:50:05] the government?

[1:50:09] Did you check it with any

[1:50:09] legislative people at the

[1:50:10] state people and say I

[1:50:13] think florida is going to

[1:50:14] be putting a carbon tax in

[1:50:17] place anytime soon?

[1:50:18] >> MR. Aponte: not

[1:50:19] outside the company, but

[1:50:19] we recognize that the

[1:50:22] moment there is no plan to

[1:50:24] assign a carbon tax.

[1:50:26] >> MR. Moyle: what about

[1:50:28] within the company?

[1:50:28] >> MR. Aponte: yes, we

[1:50:30] recognize our immediate

[1:50:32] plan to assign a carbon

[1:50:35] tax.

[1:50:35] >> MR. Moyle: same

[1:50:36] question with regard to

[1:50:39] federal legislative

[1:50:42] actions you have.

[1:50:43] >> MR. Wahlen: MR.

[1:50:44] CHAIRMAN, this is

[1:50:46] fascinating to me, of

[1:50:47] course, but the testimony

[1:50:53] is the company is not

[1:50:54] relying on carbon ater to

[1:50:54] prove cost-effectiveness.

[1:50:55] I really don't know that

[1:50:57] this is adding a lot.

[1:51:02] If MR. Moyle wants to

[1:51:04] continue, he can, but --

[1:51:07] >> CHAIRMAN La Rosa: I

[1:51:07] think the question has

[1:51:11] been answered.

[1:51:12] >> MR. Moyle: I was

[1:51:12] trying to understand.

[1:51:15] He said he did report.

[1:51:15] I was trying to understand

[1:51:17] the rationale for the

[1:51:17] report.

[1:51:20] They got exhibits that are

[1:51:20] showing this.

[1:51:24] They are saying they are

[1:51:24] not relying on it, but

[1:51:24] they done it and are

[1:51:25] putting it in front of

[1:51:28] you, but I think I've

[1:51:29] exhausted that line of

[1:51:30] questioning.

[1:51:31] >> CHAIRMAN La Rosa:

[1:51:31] okay.

[1:51:44] Thank you.

[1:51:45] >> MR. Moyle: you also

[1:51:51] are projected savings

[1:51:52] unprotected fuel savings

[1:51:52] and you had to use a

[1:51:53] forecast of what natural

[1:51:54] gas prices would be going

[1:51:57] forward, is that right?

[1:52:00] >> MR. Aponte: yes.

[1:52:01] >> MR. Moyle: the prices

[1:52:02] that you used are higher

[1:52:04] than the henry hub natural

[1:52:07] gas price futures that

[1:52:16] come from imex, is that

[1:52:16] correct?

[1:52:17] >> MR. Aponte: yes,

[1:52:19] because we have databases

[1:52:20] to get the fuel delivered

[1:52:31] to our region.

[1:52:32] >> MR. Moyle: I have no

[1:52:33] further questions.

[1:52:33] >> CHAIRMAN La Rosa:

[1:52:37] thank you.

[1:52:37] All right.

[1:52:37] Fea?

[1:52:41] >> fea has no questions.

[1:52:42] Thank you, commissioner.

[1:52:43] >> CHAIRMAN La Rosa:

[1:52:45] thank you.

[1:52:45] Sierra club?

[1:52:47] >> yes, we have some

[1:52:47] questions.

[1:52:50] Good morning, MR. Aponte.

[1:52:51] >> MR. Aponte: good

[1:52:51] morning.

[1:52:52] >> you state in your

[1:52:58] testimony that the polk

[1:52:58] one project will cost $85

[1:52:59] million, correct?

[1:53:02] >> MR. Aponte: yes.

[1:53:03] >> can you please pull up

[1:53:03] sierra club exhibit 17,

[1:53:04] which is psc exhibit

[1:53:04] >> can you please pull up

[1:53:05] sierra club exhibit 17,

[1:53:05] which is psc exhibit 84

[1:53:09] page f-6 360?

[1:53:11] And let me know when you

[1:53:25] have that in front of you.

[1:53:25] >> MR. Aponte: I see it.

[1:53:29] >>

[1:53:29] >> thanks.

[1:53:29] When looking at the cost

[1:53:35] with polk one cost

[1:53:35] flexibly, we can see and

[1:53:40] $90.1 million cost for the

[1:53:40] conversion of polk one.

[1:53:41] Do you see that?

[1:53:41] >> MR. Aponte: I see it.

[1:53:44] >> possible total cost of

[1:53:45] the polk one flexibility

[1:53:47] project is higher than

[1:53:49] 81.5 million?

[1:53:52] >> MR. Aponte: what the

[1:53:56] 90.1 million represents is

[1:53:57] the cost after we have

[1:53:57] gone through the

[1:53:58] calculation of adding the

[1:53:59] revenue requirement for

[1:54:01] that capital.

[1:54:03] So the mpv of the revenue

[1:54:04] requirement of that

[1:54:09] capital becomes 90.1.

[1:54:10] Seem

[1:54:10] >> so which cost is passed

[1:54:11] on to ratepayers, the 80.5

[1:54:15] or this higher 90.1?

[1:54:17] >> MR. Aponte: the 90.1.

[1:54:18] >> all right.

[1:54:20] Thank you.

[1:54:25] Looking again at sierra

[1:54:26] club the same exhibit on

[1:54:30] page f-6 353, the tab,

[1:54:30] this is a tab that

[1:54:32] considers a scenario

[1:54:33] without the polk one

[1:54:34] flexibility project.

[1:54:37] Thank you.

[1:54:38] This also projects high

[1:54:39] cost for maintaining the

[1:54:44] unit as is, right?

[1:54:45] >> MR. Aponte: yes.

[1:54:45] >> including a $130.9

[1:54:47] million project upgrade

[1:54:49] cost, right?

[1:54:50] >> MR. Aponte: yes.

[1:54:53] >> when without upgrade

[1:54:53] need to occur?

[1:54:59] >> MR. Aponte: in 2025.

[1:55:00] >> okay.

[1:55:00] If polk one were to retire

[1:55:05] in 2021, teco would avoid

[1:55:05] incurring this roughly 1

[1:55:06] $31 million cost, right?

[1:55:06] >> MR. Aponte: if that

[1:55:08] unit retires in 2025, it

[1:55:14] will be replaced with the

[1:55:15] same -- it would need to

[1:55:15] be replaced with the same

[1:55:16] amount of capacity to

[1:55:20] retain reserve margin, so

[1:55:21] I believe that the amount

[1:55:22] of money would be higher

[1:55:25] than that.

[1:55:28] >> okay.

[1:55:30] That feeds right into my

[1:55:32] next question, so thank

[1:55:32] you.

[1:55:34] Teco is not performed a

[1:55:37] retirement analysis for

[1:55:37] polk one since 2022,

[1:55:42] correct?

[1:55:43] >> MR. Aponte: retirement

[1:55:45] analysis for polk one

[1:55:48] since 2022?

[1:55:49] I know we have looked at

[1:55:50] it several times.

[1:55:50] Our most recent one might

[1:55:53] be 2023.

[1:55:57] >> 2023.

[1:55:58] Is that in the record?

[1:55:58] >> MR. Aponte: yes, it

[1:56:00] is.

[1:56:02] >> so was that the same

[1:56:04] retirement analysis I had

[1:56:10] asked witness -- about?

[1:56:11] >> MR. Aponte: that's

[1:56:12] correct.

[1:56:16] >> but this study did not

[1:56:16] consider any retirement

[1:56:17] years apart from 2028,

[1:56:24] right?

[1:56:24] >> MR. Aponte: it did

[1:56:24] not.

[1:56:25] >> so when assessing the

[1:56:26] cost of retiring polk one

[1:56:26] versus keeping the unit

[1:56:29] operational, teco did not

[1:56:29] consider a scenario that

[1:56:30] replaces polk one with

[1:56:31] renewable energy or energy

[1:56:38] storage, right?

[1:56:38] >> MR. Aponte: we did

[1:56:38] not.

[1:56:39] >> in performing this

[1:56:39] retirement study, teco did

[1:56:42] not consider the cost of

[1:56:42] acquiring renewable energy

[1:56:43] such as storage through an

[1:56:44] open source rfp process,

[1:56:47] did it?

[1:56:48] >> MR. Aponte: for

[1:56:49] purposes of the analysis,

[1:56:52] no.

[1:56:52] >> but teco is not

[1:56:57] planning on offering -- is

[1:56:57] it?

[1:57:00] >> MR. Aponte: I am not

[1:57:02] the project expert, but we

[1:57:07] have a competitive buying

[1:57:11] methodology.

[1:57:11] >> okay.

[1:57:12] does that methodology

[1:57:15] include an open source rfp

[1:57:16] where participants can

[1:57:20] bid?

[1:57:20] >> MR. Aponte: I believe

[1:57:23] it does.

[1:57:23] I'm not the right person

[1:57:26] to answer that.

[1:57:27] >> okay.

[1:57:28] I guess put differently

[1:57:29] maybe this is more

[1:57:31] helpful.

[1:57:34] Teco is planning on

[1:57:39] building its storage

[1:57:39] itself, correct?

[1:57:40] >> MR. Aponte: yes.

[1:57:41] >> would you agree the

[1:57:42] economics of building

[1:57:42] storage are changing

[1:57:45] rapidly?

[1:57:45] >> MR. Aponte: yes, they

[1:57:47] are changing.

[1:57:48] >> for example, do you

[1:57:50] anticipate the inflation

[1:57:52] reduction act credits are

[1:57:56] driving down the cost of

[1:57:56] battery storage further?

[1:58:00] >> MR. Aponte: yes, I do.

[1:58:01] >> can you guarantee

[1:58:01] holding an open source rfp

[1:58:05] would not result in energy

[1:58:06] storage then if teco build

[1:58:09] its own energy storage?

[1:58:10] >> MR. Aponte: I'm not

[1:58:11] the right person to answer

[1:58:16] that.

[1:58:16] >> okay.

[1:58:19] And who would be the right

[1:58:23] witness in this case to

[1:58:23] answer that?

[1:58:26] >> that would be witness

[1:58:26] stryker.

[1:58:28] >> witness stryker

[1:58:31] directed much of his

[1:58:32] questions to you.

[1:58:36] Did teco consider the cost

[1:58:37] of the polk -- I

[1:58:39] apologize, from 2023.

[1:58:41] Did teco consider the cost

[1:58:43] of the polk one project in

[1:58:46] that study?

[1:58:47] >> MR. Aponte: I'm sorry,

[1:58:47] can you repeat the

[1:58:50] question?

[1:58:50] >> yes, I have the wrong

[1:58:51] year.

[1:58:52] Turning back to the 2023

[1:58:54] polk one retirement study,

[1:58:57] did teco consider the cost

[1:58:59] of the diversity project

[1:59:02] in conducting this study?

[1:59:02] >> MR. Aponte: my

[1:59:03] understanding is those two

[1:59:05] projects are not

[1:59:06] connected.

[1:59:08] >> okay.

[1:59:13] So did teco consider

[1:59:13] , I

[1:59:13] guess I will ask

[1:59:15] differently.

[1:59:16] Did teco consider the

[1:59:22] costs of the teco --

[1:59:29] >> MR. Aponte: no.

[1:59:30] >> did teco consider the

[1:59:32] cost of the polk one

[1:59:34] flexibility process

[1:59:39] ?

[1:59:40] >> MR. Aponte: ask me

[1:59:40] that one more time,

[1:59:42] please.

[1:59:42] >> no problem.

[1:59:42] >> MR. Aponte: in

[1:59:45] conducting that retirement

[1:59:48] study, did teco consider

[1:59:52] the cost of the polk one

[2:00:04] flexibility project?

[2:00:05] >> MR. Aponte: in order

[2:00:05] to do a complete analysis

[2:00:06] for the polk one

[2:00:06] flexibility, we looked at

[2:00:08] a retirement analysis in

[2:00:08] 2028, yes.

[2:00:11] That was one sensitivity

[2:00:13] we did.

[2:00:16] >> in performing the 2023

[2:00:19] study, did teco factor in

[2:00:21] compliance costs?

[2:00:24] >> MR. Aponte: no, we did

[2:00:25] not.

[2:00:26] >> okay.

[2:00:29] teco did not consider cost

[2:00:29] of rules that were not

[2:00:30] finalized after 2023 such

[2:00:34] as the 2024 greenhouse gas

[2:00:35] standards, right?

[2:00:36] >> MR. Aponte: no, not on

[2:00:37] that analysis.

[2:00:43] >> so in your rebuttal

[2:00:43] testimony on page 13, you

[2:00:44] stated that if polk unit

[2:00:56] one were to return to ijcc

[2:00:57] -- would you still agree

[2:00:57] with that statement?

[2:00:58] >> MR. Aponte: can you

[2:00:59] please point to me?

[2:01:04] >> absolutely.

[2:01:04] This is your rebuttal

[2:01:05] testimony -- apologies,

[2:01:07] that is actually witness

[2:01:10] aldazabal's rebuttal, so

[2:01:11] that is a mistake.

[2:01:17] This is about polk unit

[2:01:18] one and retirement.

[2:01:18] I'm going to ask you this

[2:01:19] question and if you are

[2:01:20] unfamiliar, let me know.

[2:01:24] But it's on witness

[2:01:25] aldazabal's rebuttal on

[2:01:29] page 13 line 20 --

[2:01:30] >> MR. Wahlen: excuse me,

[2:01:30] it sounds like she's about

[2:01:32] to cross examine MR.

[2:01:35] Aponte on MR. Aldazabal's

[2:01:35] testimony.

[2:01:36] >> CHAIRMAN La Rosa: can

[2:01:40] we get clarification on

[2:01:40] where you're going?

[2:01:41] >> absolutely and that was

[2:01:43] my mistake.

[2:01:43] I'm just going to ask the

[2:01:47] witness a question that

[2:01:48] relates to this retirement

[2:01:48] analysis.

[2:01:49] It's just one statement

[2:01:52] that was in witness

[2:01:53] aldazabal's rebuttal, but

[2:01:56] it relates to -- if this

[2:02:01] witness is unfamiliar, MR.

[2:02:02] Aponte can just let me

[2:02:02] know.

[2:02:04] >> CHAIRMAN La Rosa: go

[2:02:04] ahead.

[2:02:07] >> thank you.

[2:02:07] So this is on witness

[2:02:08] aldazabal's testimony on

[2:02:13] page 13 lines 20-22.

[2:02:13] And I can read it aloud

[2:02:17] and you can let me know if

[2:02:18] you're unfamiliar with

[2:02:19] this topic.

[2:02:19] Is that okay?

[2:02:20] >> MR. Aponte: that's

[2:02:21] okay.

[2:02:21] >> thank you.

[2:02:23] So MR. Aldazabal stated if

[2:02:24] polk unit one were to

[2:02:32] return to ijcc operation

[2:02:32] but retire before 2032, it

[2:02:33] would not be subject to

[2:02:33] any greenhouse gas

[2:02:36] emission standards.

[2:02:36] Does that sound right to

[2:02:37] you?

[2:02:37] >> MR. Aponte: I am very

[2:02:43] unfamiliar with that.

[2:02:43] Any greenhouse gas

[2:02:43] standards.

[2:02:44] >> okay.

[2:02:44] That's fine.

[2:02:46] So then I will move on.

[2:02:49] Okay.

[2:03:03] So okay.

[2:03:04] You are familiar with the

[2:03:04] term reserve margin,

[2:03:05] correct?

[2:03:05] >> MR. Aponte: yes, I am.

[2:03:06] >> can you briefly explain

[2:03:06] how reserve margin impacts

[2:03:07] and electric utilities

[2:03:10] generation mix?

[2:03:11] >> MR. Aponte: can you

[2:03:16] repeat that question?

[2:03:16] >> yes, of course.

[2:03:20] Can you please briefly

[2:03:20] explain how utilities

[2:03:20] reserve margin impacts its

[2:03:23] generation mix?

[2:03:24] >> MR. Aponte: well,

[2:03:29] planning reserve margin

[2:03:30] and generation mix are two

[2:03:30] different things.

[2:03:31] We can satisfy reserve

[2:03:33] margin in many different

[2:03:36] ways very different

[2:03:38] generation mixes.

[2:03:41] I'm not sure I'm following

[2:03:41] your question.

[2:03:46] >> okay.

[2:03:47] I think that answer is

[2:03:47] helpful.

[2:03:48] The higher reserve margin

[2:03:52] makes it more difficult to

[2:03:52] retire a generation asset,

[2:03:55] all else equal, right?

[2:03:55] >> MR. Aponte: higher

[2:03:56] reserve margins make it

[2:03:59] more difficult to retire

[2:03:59] margins?

[2:04:02] No, I don't agree with

[2:04:07] that.

[2:04:07] >> generally compared to

[2:04:08] having a lower reserve

[2:04:16] margin, is that right?

[2:04:17] >> MR. Aponte: they don't

[2:04:17] have to be online.

[2:04:24] Every margin is based on

[2:04:24] reserve store capacity.

[2:04:25] >> okay.

[2:04:25] It generally requires a

[2:04:28] higher degree as opposed

[2:04:29] to lower reserve margin,

[2:04:32] right?

[2:04:33] >> MR. Aponte: yes,

[2:04:41] that's right.

[2:04:42] >> when resources can be

[2:04:42] retired without

[2:04:42] replacement?

[2:04:43] >> MR. Aponte: at this

[2:04:43] moment, yes, we are a

[2:04:47] winter need to.

[2:04:47] >> okay.

[2:04:54] Can you please turn to

[2:04:55] florida psc exhibit 120

[2:05:06] page c3 2-1577?

[2:05:07] And we MAY need to zoom in

[2:05:09] if possible.

[2:05:10] I'm just looking at the

[2:05:12] last row.

[2:05:16] In the last row, can you

[2:05:16] see that teco is winter

[2:05:16] reserve margins for

[2:05:23] 2024-2027 are 30%, 23%,

[2:05:26] 23%, and 22%?

[2:05:27] >> MR. Wahlen: MR.

[2:05:30] CHAIRMAN, I think we have

[2:05:31] been through this ground a

[2:05:34] few times now.

[2:05:34] >> it was asked.

[2:05:37] I was trying to lay down a

[2:05:37] foundation, but if

[2:05:38] everyone is familiar with

[2:05:39] it, I can ask my next

[2:05:43] question.

[2:05:43] Okay.

[2:05:48] Focusing on this 30%

[2:05:50] number for a second, would

[2:05:51] you agree it's unusual to

[2:05:51] have a reserve margin the

[2:05:51] high.

[2:05:53] >> MR. Aponte: no.

[2:05:56] It's not unusual.

[2:05:56] The reason that number is

[2:06:00] that hi, I believe we, for

[2:06:00] reliability purposes,

[2:06:04] purchased some short-term

[2:06:06] dpa's.

[2:06:07] For like I said,

[2:06:15] reliability on the energy

[2:06:15] and fuel supply.

[2:06:16] That's just temporary.

[2:06:16] That's why you see that

[2:06:17] bump up and you stated get

[2:06:19] back down to 23% the next

[2:06:22] year.

[2:06:23] >> okay.

[2:06:28] Teco is operating on an

[2:06:29] assumption of 23% margin,

[2:06:29] correct?

[2:06:31] >> MR. Aponte: 20%.

[2:06:32] >> it has far more

[2:06:35] capacity than that for,

[2:06:38] right?

[2:06:39] >> MR. Wahlen: that has

[2:06:39] been covered two or three

[2:06:40] times, MR. CHAIRMAN.

[2:06:40] >> CHAIRMAN La Rosa: I

[2:06:41] would agree.

[2:06:43] >> okay.

[2:06:44] I will just ask one more

[2:06:46] reserve margin question

[2:06:47] and then I can move on if

[2:06:48] that's fine.

[2:06:50] That I believe hasn't been

[2:06:51] asked.

[2:06:55] So a 30% reserve margin

[2:06:59] compared to say a 50% --

[2:07:01] >> MR. Wahlen: asked and

[2:07:02] answered.

[2:07:03] >> okay.

[2:07:05] I will move on to another

[2:07:07] topic and we are close to

[2:07:08] the end of these

[2:07:10] questions.

[2:07:12] Teco is planning to add

[2:07:20] nearly 500 mw of new solar

[2:07:20] across its service

[2:07:21] territory by the end of

[2:07:21] 2026, correct?

[2:07:21] >> MR. Aponte:

[2:07:22] >> you would agree that

[2:07:25] solar has no fuel cost,

[2:07:25] correct?

[2:07:25] >> correct.

[2:07:29] >> you added that this

[2:07:30] would save customers

[2:07:30] nearly $800 million in

[2:07:34] fuel costs over the

[2:07:35] lifetime of the projects,

[2:07:35] correct?

[2:07:36] >> MR. Aponte: correct.

[2:07:37] >> solar plants tend to

[2:07:37] have lower operation

[2:07:39] admittance costs than

[2:07:40] fossil plants, yes?

[2:07:43] >> MR. Aponte: they do.

[2:07:45] >> teco is solar will

[2:07:46] reduce costs and price

[2:07:49] volatility for ratepayers,

[2:07:49] right?

[2:07:50] >> MR. Aponte: yes,

[2:07:53] absolute.

[2:07:53] >> you would agree that

[2:07:57] solar generators conserve

[2:07:59] more water than fossil

[2:07:59] generators, right?

[2:08:00] >> MR. Aponte: yes, I

[2:08:00] would agree.

[2:08:05] >> solar will supply 18%

[2:08:05] of the energy on its

[2:08:05] system, right?

[2:08:06] >> MR. Aponte: subject to

[2:08:09] checks, the year, yes.

[2:08:10] >> okay.

[2:08:12] And this will increase

[2:08:13] teco fuel diversity,

[2:08:15] right?

[2:08:15] >> MR. Aponte: correct.

[2:08:18] >> results will fuel

[2:08:19] diversity from energy

[2:08:19] storage, right?

[2:08:21] >> MR. Aponte: some.

[2:08:21] >> as well as energy

[2:08:23] efficiency and demand

[2:08:26] measures?

[2:08:27] >> MR. Aponte: I'm not

[2:08:30] sure about that when.

[2:08:31] >> okay.

[2:08:31] But a number of the

[2:08:32] sources of energy can

[2:08:32] hedge against high gas

[2:08:36] prices, correct?

[2:08:37] >> absolutely.

[2:08:39] >> teco is planning on

[2:08:41] bringing four new storage

[2:08:41] units, right?

[2:08:45] >> MR. Aponte: yes.

[2:08:46] >> but teco is planning on

[2:08:46] bringing only one new

[2:08:49] storage project, a 70 mw

[2:08:51] project, coming online in

[2:08:51] 2028 in the six year

[2:08:54] period from 2027-2033,

[2:08:56] right?

[2:08:57] >> MR. Aponte: that's

[2:09:00] what we are reflecting

[2:09:01] now.

[2:09:05] We have an degraded

[2:09:06] resource plan process that

[2:09:08] we execute every year as

[2:09:09] part of the development of

[2:09:10] the 10 year site plan.

[2:09:11] We are always looking for

[2:09:16] ways to optimize the

[2:09:17] portfolio in ways that

[2:09:17] creates value to

[2:09:19] customers, affordability,

[2:09:24] we look for reliability of

[2:09:25] the system, we look for

[2:09:25] many criteria, many

[2:09:26] objectives, and to the

[2:09:28] extent that we find more

[2:09:34] battery storage is

[2:09:34] cost-effective, it creates

[2:09:35] value for customers.

[2:09:37] It adds reliability and

[2:09:38] resiliency to the system

[2:09:39] we would consider doing

[2:09:40] that.

[2:09:45] It could change.

[2:09:45] >> okay.

[2:09:46] There's no technical

[2:09:47] barrier from teco -- and

[2:09:51] as teco brings on energy

[2:09:52] storage, that storage can

[2:09:52] be paired with teco's

[2:09:57] existing solar units,

[2:09:57] correct?

[2:09:58] >> MR. Aponte: I'm sorry,

[2:09:59] repeat that question.

[2:10:03] >> as -- that storage can

[2:10:07] be compared with solar

[2:10:17] generation, right?

[2:10:17] >> MR. Aponte: it could,

[2:10:18] but we are finding it is

[2:10:18] most cost-effective to

[2:10:21] connect it to the grid and

[2:10:22] optimize charging so it is

[2:10:22] the most economic way of

[2:10:25] charging might not be from

[2:10:27] solar at this point.

[2:10:31] >> do you know how many of

[2:10:31] the storage projects

[2:10:31] coming online or paired

[2:10:36] with existing storage

[2:10:36] projects?

[2:10:36] >> MR. Aponte: the ones

[2:10:37] coming online are all

[2:10:44] connected with the grid.

[2:10:44] >> thanks.

[2:10:44] When storage is paired

[2:10:45] with solar or optimized to

[2:10:47] connect to the grid,

[2:10:53] energy storage can saul's

[2:10:54] power that is -- return it

[2:10:54] to the grid at times of

[2:10:55] peak demand, right?

[2:10:56] >> MR. Aponte: a code if

[2:11:05] that is the lowest-cost

[2:11:05] way to dispatch it.

[2:11:05] >> okay.

[2:11:06] thanks.

[2:11:06] The capacity of new energy

[2:11:07] storage units is 100%,

[2:11:09] right?

[2:11:10] >> MR. Aponte: yes.

[2:11:12] For the proposed projects,

[2:11:15] it is.

[2:11:16] >> this means they are

[2:11:16] assumed to provide 100% of

[2:11:21] capacity at times of peak

[2:11:22] demand on teco the system,

[2:11:22] right?

[2:11:25] >> MR. Aponte: yes.

[2:11:26] >> okay.

[2:11:31] So if teco brings say more

[2:11:32] than one storage unit in

[2:11:36] the period from 2027-2023,

[2:11:37] would you predict that

[2:11:37] storage unit would also

[2:11:37] have a 100% storage

[2:11:41] capacity credit?

[2:11:44] >> MR. Aponte: we need to

[2:11:44] be studied, but I can tell

[2:11:47] you the capacity of

[2:11:47] storage at some point

[2:11:47] , we

[2:11:54] are not there yet.

[2:11:54] It will start to decline

[2:11:55] also, not as drastic as

[2:11:55] earlier, but it will

[2:11:56] decline.

[2:11:58] Effective load carrying

[2:12:01] incapability.

[2:12:01] >> okay.

[2:12:03] Teco measures credits for

[2:12:09] solar at tons of peak load

[2:12:10] as ranging from about 56%

[2:12:10] in the summer to lower

[2:12:12] around maybe one or lower

[2:12:14] percent in the winter, is

[2:12:21] that right?

[2:12:22] >> MR. Aponte: that's

[2:12:23] right.

[2:12:24] >> but the energy storage

[2:12:25] would be higher than this,

[2:12:27] right?

[2:12:29] >> MR. Aponte: I think it

[2:12:32] will still be the same.

[2:12:35] You just have batteries.

[2:12:37] Also on the grid as

[2:12:44] another asset.

[2:12:44] >> okay.

[2:12:45] But if, for example, there

[2:12:47] were a storage unit that

[2:12:50] repaired with a solar

[2:12:51] unit, the capacity would

[2:12:53] be higher, right?

[2:12:54] >> MR. Aponte: again, it

[2:12:55] depends.

[2:12:57] If the portfolio was

[2:12:58] asking for a solar plus

[2:13:01] storage asset as one,

[2:13:05] together it would create a

[2:13:06] higher capacity value, but

[2:13:07] those are not the type of

[2:13:09] projects we are looking

[2:13:12] for at this time.

[2:13:12] >> okay.

[2:13:13] Thanks.

[2:13:17] Can you please look at

[2:13:18] your direct testimony on

[2:13:28] page 31?

[2:13:32] And just let me know when

[2:13:43] you're ready.

[2:13:44] >> MR. Aponte: I'm there.

[2:13:44] >> thank you.

[2:13:45] Can you please read lines

[2:13:45] 1 through I believe it's

[2:13:46] 12 starting at public

[2:13:47] policy considerations and

[2:13:57] ending at possibility?

[2:13:58] >> MR. Aponte: can you

[2:13:58] point to me the row

[2:13:58] number?

[2:13:59] >> yes.

[2:13:59] It begins on line 1

[2:14:03] actually on that page.

[2:14:04] >> MR. Aponte: okay.

[2:14:04] >> I believe it is on page

[2:14:07] 31 and it begins with

[2:14:07] public policy

[2:14:09] considerations.

[2:14:14] Actually, looks like it

[2:14:14] does start on page 3 -- I

[2:14:15] mean line 3. And then

[2:14:23] extending to rule out that

[2:14:24] possibility.

[2:14:24] Spirit yes, public-policy

[2:14:29] consideration expectations

[2:14:29] in the united states and

[2:14:30] around the world are

[2:14:30] trending against carbon

[2:14:32] emissions and in favor of

[2:14:33] renewable energy like

[2:14:35] solar innovation.

[2:14:36] It is difficult to predict

[2:14:43] when a carbon tax or fuel

[2:14:44] will be imposed.

[2:14:45] >> thanks.

[2:14:45] You would agree that it's

[2:14:46] possible new environment

[2:14:46] or regulation could impose

[2:14:50] limits on carbon

[2:14:58] emissions, right?

[2:14:59] >> MR. Aponte: is

[2:14:59] possible.

[2:15:00] >> emissions from carbon

[2:15:00] are more intense than gas,

[2:15:01] right?

[2:15:01] >> MR. Aponte: yes.

[2:15:02] >> gas is more carbon

[2:15:02] intensive them solar,

[2:15:02] right?

[2:15:04] >> MR. Aponte: yes.

[2:15:07] >> if -- deciding on its

[2:15:08] generation mix, this would

[2:15:12] make fossil fuel plants

[2:15:13] more extensive than they

[2:15:15] otherwise would be, right?

[2:15:15] >> MR. Wahlen: MR.

[2:15:18] CHAIRMAN, I think we have

[2:15:22] been very clear that we

[2:15:23] don't consider the cost of

[2:15:23] carbon in our

[2:15:24] cost-effectiveness and we

[2:15:34] or maybe on the second lap

[2:15:34] of this topic.

[2:15:35] >> CHAIRMAN La Rosa: it

[2:15:36] is certainly a similar

[2:15:36] topic.

[2:15:36] Let's do this.

[2:15:36] It is 10:20 almost.

[2:15:37] Let's take a quick break

[2:15:38] for 10 minutes and then we

[2:15:38] will jump back into

[2:15:38] questioning.

[2:15:40] >> actually, I have two

[2:15:42] more questions.

[2:15:43] >> CHAIRMAN La Rosa:

[2:15:43] let's go with those.

[2:15:46] >> is it fine if I just

[2:15:48] re-ask that question?

[2:15:49] >> CHAIRMAN La Rosa: is

[2:15:54] it a question you just

[2:15:54] asked before?

[2:15:55] >> it is.

[2:15:55] >> CHAIRMAN La Rosa: we

[2:15:59] have talked about that

[2:16:00] subject.

[2:16:00] I think the question was

[2:16:00] more related to policy.

[2:16:00] If there's a direct

[2:16:09] question in there, yes, I

[2:16:09] will allow it.

[2:16:10] I don't want to keep on

[2:16:10] skirting around the same

[2:16:10] subject.

[2:16:11] >> okay.

[2:16:11] That makes sense.

[2:16:11] I will ask this last

[2:16:12] question and just make it

[2:16:13] one question, if that's

[2:16:15] okay.

[2:16:15] If teco were to consider

[2:16:16] avoiding carbon cost and

[2:16:23] deciding on its generation

[2:16:24] mix, this would make

[2:16:24] fossil fuel plants

[2:16:25] relatively more expensive

[2:16:25] and renewables relatively

[2:16:26] more cost-effective,

[2:16:26] right?

[2:16:27] >> MR. Aponte: sorry, you

[2:16:27] said that very fast.

[2:16:28] >> I know.

[2:16:32] Apologies.

[2:16:32] I will say that more

[2:16:33] slowly.

[2:16:33] If teco were to consider

[2:16:42] avoiding carbon cost and

[2:16:42] deciding on its generation

[2:16:43] mix, that would make

[2:16:43] fossil fuel plants

[2:16:44] relatively more expensive

[2:16:44] and renewables relatively

[2:16:45] more cost-effective,

[2:16:48] right?

[2:16:51] >> MR. Aponte: will make

[2:16:52] renewables more

[2:16:56] cost-effective, yes?

[2:16:56] >> thank you.

[2:16:57] No further questions.

[2:16:57] >> CHAIRMAN La Rosa:

[2:16:58] thank you.

[2:16:59] Let's go ahead and jump

[2:17:03] into a 10 minute break.

[2:17:03] We will reconvene here at

[2:17:04] 10:30.

[2:17:21] Thank you.

[2:18:43] [Break]

[2:30:10] >> CHAIRMAN La Rosa: all

[2:30:10] right.

[2:30:11] I think we can go ahead

[2:30:12] and jump back in our seats

[2:30:20] and get rolling.

[2:30:23] So where we left off was

[2:30:24] sierra club just finished

[2:30:27] up with questions for

[2:30:30] witness aponte.

[2:30:31] I will go to florida

[2:30:37] retail federation.

[2:30:37] >> thank you, MR.

[2:30:38] CHAIRMAN.

[2:30:40] I don't have any cross for

[2:30:45] MR. Aponte.

[2:30:45] >> CHAIRMAN La Rosa:

[2:30:45] thank you.

[2:30:46] Walmart?

[2:30:47] >> I don't have any cross.

[2:30:53] Thank you.

[2:30:54] >> CHAIRMAN La Rosa:

[2:30:54] thank you.

[2:30:54] Staff?

[2:30:55] >> Staff: staff does not

[2:30:55] have any questions for MR.

[2:30:56] Aponte.

[2:30:56] Thank you.

[2:30:56] >> CHAIRMAN La Rosa:

[2:31:00] seeing no questions, teco,

[2:31:00] I threw it back to you for

[2:31:01] redirect.

[2:31:05] >> MR. Wahlen: thank you.

[2:31:06] MR. Aponte, you are asked

[2:31:10] about the solar project

[2:31:11] and you indicated with the

[2:31:11] increase in the tax

[2:31:12] credit, the

[2:31:14] cost-effectiveness was

[2:31:15] better.

[2:31:20] Do you are member that?

[2:31:20] >> MR. Aponte: yes.

[2:31:23] >> I was going to object

[2:31:24] on asked and answered for

[2:31:30] my friend, MR. Wahlen.

[2:31:32] >> CHAIRMAN La Rosa: I'm

[2:31:33] sure he appreciates that.

[2:31:39] Go ahead, continue.

[2:31:40] >> MR. Wahlen: if you

[2:31:40] apply the higher tax

[2:31:44] credits all the projects

[2:31:44] you are imposing, with the

[2:31:45] cost-effectiveness

[2:31:52] improve?

[2:31:52] >> MR. Aponte: yes,

[2:31:53] absolutely.

[2:31:53] >> MR. Wahlen: thank you.

[2:31:54] You are asked some

[2:31:54] questions about the south

[2:31:55] tampa resiliency project

[2:31:55] by the office of public

[2:31:57] counsel and they asked you

[2:32:01] the question, well, if the

[2:32:01] government had paid money

[2:32:02] toward the project, would

[2:32:08] have improved?

[2:32:08] Do your member that?

[2:32:09] >> MR. Aponte: I remember

[2:32:11] that.

[2:32:12] >> MR. Wahlen: company is

[2:32:13] getting the land from that

[2:32:13] project for no cost,

[2:32:15] correct?

[2:32:18] >> MR. Aponte: that's

[2:32:19] correct.

[2:32:19] >> MR. Wahlen: if the

[2:32:20] company had to buy land or

[2:32:20] lease land from that

[2:32:22] project, it would hurt the

[2:32:24] cost-effectiveness,

[2:32:25] wouldn't it?

[2:32:29] >> MR. Aponte: yes, it

[2:32:29] would be very expensive

[2:32:34] almost impossible to get.

[2:32:34] >> MR. Wahlen: the fact

[2:32:35] that there's free land

[2:32:35] helps the

[2:32:36] cost-effectiveness of the

[2:32:38] project, correct?

[2:32:39] >> MR. Aponte: it helps a

[2:32:44] lot.

[2:32:45] >> MR. Wahlen: okay.

[2:32:45] Thank you.

[2:32:45] You are asked a question

[2:32:47] about the winter reserve

[2:32:47] margin.

[2:32:47] When the company

[2:32:49] calculates its winter

[2:32:50] reserve margin, does the

[2:32:59] company assume a

[2:33:00] particular temperature?

[2:33:00] >> MR. Aponte: yes.

[2:33:01] That's correct.

[2:33:01] We do.

[2:33:01] >> MR. Wahlen: and what

[2:33:04] is that temperature?

[2:33:04] >> MR. Aponte: it is

[2:33:10] 30b0f.

[2:33:10] >> MR. Wahlen: does the

[2:33:11] company do temperature

[2:33:11] analysis?

[2:33:12] >> MR. Aponte: yes.

[2:33:12] >> MR. Wahlen: could we

[2:33:15] call up master document f

[2:33:20] 2.1-74, please?

[2:33:34] Part of cel 226.

[2:33:35] Is that the reserve margin

[2:33:45] that you were sensitivity

[2:33:45] that you were referring

[2:33:45] to?

[2:33:46] >> MR. Aponte: yes, it

[2:33:46] is.

[2:33:47] >> MR. Wahlen: what

[2:33:47] temperature does this

[2:33:54] assume?

[2:33:55] The

[2:33:55] >> MR. Aponte: 29b0.

[2:33:56] >> MR. Wahlen: if the

[2:33:56] temperature is 29b0 as

[2:33:57] opposed to 31, what does

[2:33:57] the winter reserve margin

[2:34:02] look like in 2025?

[2:34:02] >> MR. Aponte: well, it

[2:34:03] drops significantly to

[2:34:04] 17%.

[2:34:04] >> MR. Aponte: and that

[2:34:11] is below the 20%, right?

[2:34:11] >> MR. Aponte: it is

[2:34:12] below.

[2:34:12] >> MR. Wahlen: do you

[2:34:14] recall whether replacing

[2:34:15] the company solid fuel

[2:34:18] assets -- you were asked

[2:34:19] about whether the company

[2:34:20] did an analysis about

[2:34:21] replacing the company's

[2:34:24] solid fuel assets with

[2:34:25] solar and battery storage?

[2:34:27] >> MR. Aponte: yes, I

[2:34:27] recall.

[2:34:28] >> MR. Wahlen: would it

[2:34:35] be possible to

[2:34:36] cost-effectively replace

[2:34:36] the company's solid fuel

[2:34:39] capacity generating

[2:34:39] capacity with solar and

[2:34:40] energy storage?

[2:34:41] >> MR. Aponte: possible.

[2:34:52] I mean, it would be

[2:34:52] extremely expensive.

[2:34:53] >> MR. Wahlen: would it

[2:34:53] be cost-effective?

[2:34:55] >> MR. Wahlen: solid fuel

[2:34:58] units have the capability

[2:35:02] of running 24/7

[2:35:03] around-the-clock for

[2:35:03] weeks.

[2:35:07] In the event that fuel is

[2:35:09] economic fuel or in the

[2:35:14] event we have a disruption

[2:35:14] with natural gas, those

[2:35:17] units can run for extended

[2:35:18] amounts of time.

[2:35:19] To replace them with solar

[2:35:22] and battery storage would

[2:35:27] require a lot of solar and

[2:35:28] battery storage.

[2:35:28] Doing some mental math

[2:35:32] here, it's going to not be

[2:35:33] cost-effective.

[2:35:33] It's going to be very

[2:35:36] expensive.

[2:35:37] >> MR. Wahlen: okay.

[2:35:41] Thank you.

[2:35:41] MR. Bradley marshall asked

[2:35:42] you about your retirement

[2:35:51] analysis for polk one.

[2:35:51] Do you remember that?

[2:35:52] >> MR. Aponte: I do.

[2:35:53] >> MR. Wahlen: did you do

[2:35:53] an analysis that showed

[2:35:54] the compared retirement of

[2:35:54] polk one to the simple

[2:35:59] cycle conversion of polk

[2:35:59] one?

[2:36:01] >> MR. Aponte: yes.

[2:36:04] >> MR. Wahlen: and which

[2:36:04] was the most

[2:36:06] cost-effective?

[2:36:07] >> MR. Aponte: the status

[2:36:11] quo option was the most

[2:36:12] expensive option.

[2:36:14] Retiring it in 2028 was a

[2:36:14] slight benefit to

[2:36:16] customers, but converting

[2:36:21] the unit to simple cycle

[2:36:21] was the most

[2:36:28] cost-effective option.

[2:36:28] >> MR. Wahlen: okay.

[2:36:29] One last series of

[2:36:29] questions.

[2:36:31] There was talk about

[2:36:32] reserve margin and its

[2:36:37] role in the company's

[2:36:37] planning.

[2:36:38] Any generation additions

[2:36:40] you are talking about

[2:36:40] being proposed solely to

[2:36:43] meet reserve margin

[2:36:48] requirements?

[2:36:51] >> MR. Aponte: well, as I

[2:36:51] said earlier, the reserve

[2:36:56] minimum is a minimum 20%

[2:36:56] criteria.

[2:36:57] To the extent we can add

[2:37:00] assets that enhance value

[2:37:01] to the customer or

[2:37:02] affordability

[2:37:03] , fuel

[2:37:06] savings to the customer,

[2:37:10] fuel price mitigation, we

[2:37:12] would be comfortable with

[2:37:13] being slightly above the

[2:37:16] 20% because of the added

[2:37:18] benefit that it brings to

[2:37:19] the customer.

[2:37:23] So not all the proposed

[2:37:23] additions are strictly due

[2:37:27] to reserve margin

[2:37:27] requirement contribution.

[2:37:34] Many of them are just

[2:37:35] additional value to

[2:37:35] customer.

[2:37:35] I mentioned the $1.2

[2:37:36] billion of fuel cost

[2:37:37] benefit over the

[2:37:38] portfolio.

[2:37:39] Part of that benefit comes

[2:37:45] from an asset that MAY not

[2:37:46] contribute to reserve

[2:37:46] margin, but it's of

[2:37:47] economic benefit to the

[2:37:52] customer to do so.

[2:37:53] >> MR. Wahlen: thank you

[2:37:54] very much.

[2:37:54] Those are my questions.

[2:37:55] >> CHAIRMAN La Rosa:

[2:37:55] thank you.

[2:37:56] Now, let's --

[2:37:57] >> commissioner?

[2:38:01] This is patty christensen.

[2:38:02] -- one has to question in

[2:38:02] redirect regarding a

[2:38:06] comment I made during my

[2:38:06] cross, but he went further

[2:38:09] afield, I think, of the

[2:38:09] topic that I covered.

[2:38:11] He asked about the use of

[2:38:13] the land for the south

[2:38:17] tampa resiliency project,

[2:38:17] but I think there needs to

[2:38:19] be some additional

[2:38:19] information that needs to

[2:38:23] be good out in cross and I

[2:38:24] have just a few follow-up

[2:38:25] questions.

[2:38:29] >> CHAIRMAN La Rosa: let

[2:38:30] me go to my advisors on

[2:38:30] this.

[2:38:30] It's not typically

[2:38:40] something I prefer to do.

[2:38:41] >> maybe we should hear

[2:38:43] from -- one first, MR.

[2:38:44] CHAIRMAN?

[2:38:44] >> CHAIRMAN La Rosa:

[2:38:46] let's do that.

[2:38:47] >> MR. Wahlen: I didn't

[2:38:47] think I was going beyond

[2:38:49] the scope of her

[2:38:50] cross-examination.

[2:38:52] If I did, it was

[2:38:55] inadvertent.

[2:38:57] >> MR. CHAIRMAN,

[2:39:02] unfortunately, I wasn't

[2:39:02] here at the time.

[2:39:03] It's within your

[2:39:04] prerogative.

[2:39:05] MR. Wahlen is supposed to

[2:39:11] stay within the scope of

[2:39:11] the cross-examination that

[2:39:12] is conducted by the

[2:39:12] parties and I wasn't here

[2:39:16] and I don't have an

[2:39:17] opinion on that, so it's

[2:39:17] really within your

[2:39:18] prerogative whether you

[2:39:19] think it's appropriate or

[2:39:21] not, but I can say it is

[2:39:24] highly irregular in our

[2:39:24] practice to have further

[2:39:28] cross-examination after a

[2:39:28] party has taken their

[2:39:31] turn.

[2:39:31] >> commissioner, I can

[2:39:33] pose the question to ask.

[2:39:33] >> CHAIRMAN La Rosa: go

[2:39:37] ahead and propose it.

[2:39:37] >> MS. Christensen: my

[2:39:38] question would be how long

[2:39:41] does teco have use of the

[2:39:43] federal land for the south

[2:39:44] florida tampa resiliency

[2:39:44] project?

[2:39:48] 30 or 35 years?

[2:39:49] >> CHAIRMAN La Rosa:

[2:39:49] before you answer the

[2:39:50] question --

[2:39:51] >> MR. Wahlen: that's

[2:39:51] fine.

[2:39:54] She can ask that.

[2:39:55] I don't mind.

[2:39:55] >> CHAIRMAN La Rosa: go

[2:39:56] ahead.

[2:39:56] You MAY answer.

[2:39:58] >> MR. Aponte: yes, I

[2:39:59] believe it's 30 or 35

[2:40:02] years.

[2:40:03] >> MS. Christensen: thank

[2:40:03] you.

[2:40:04] >> CHAIRMAN La Rosa:

[2:40:04] thank you.

[2:40:10] let's now move exhibits

[2:40:10] into the record.

[2:40:10] Let's start with teco.

[2:40:11] >> MR. Wahlen: thank you.

[2:40:11] Tampa electric moves

[2:40:16] exhibits 20 and 144 into

[2:40:16] the record.

[2:40:17] >> CHAIRMAN La Rosa: are

[2:40:17] there any objections to

[2:40:17] that?

[2:40:25] Seeing none, show them

[2:40:25] entered into the record.

[2:40:26] Opc?

[2:40:27] >> I would move to 30 and

[2:40:28] I believe 226, but it MAY

[2:40:36] have already been moved

[2:40:36] in.

[2:40:37] >> CHAIRMAN La Rosa: any

[2:40:38] objections to those

[2:40:38] exhibits?

[2:40:39] >> MR. Wahlen: no

[2:40:39] objection.

[2:40:39] >> CHAIRMAN La Rosa:

[2:40:40] okay.

[2:40:40] Show them entered into the

[2:40:40] record.

[2:40:41] Lulac?

[2:40:41] >> we have a list here.

[2:40:42] >> CHAIRMAN La Rosa: just

[2:40:44] read them slowly so

[2:40:45] everyone else can digest.

[2:40:49] >> exhibits 545, 552, 557,

[2:41:00] 582, through 589, 591,

[2:41:10] 605, 633, 637, and 707.

[2:41:11] >> MR. Wahlen: no

[2:41:11] objection.

[2:41:12] >> CHAIRMAN La Rosa: no

[2:41:12] objections.

[2:41:12] Thank you.

[2:41:15] Show them entered into the

[2:41:16] record.

[2:41:16] Sierra club.

[2:41:18] >> sierra club moves

[2:41:18] exhibit 804 into the

[2:41:22] record.

[2:41:23] >> MR. Wahlen: no

[2:41:23] objection.

[2:41:23] >> CHAIRMAN La Rosa:

[2:41:24] seeing none, show them

[2:41:24] entered into the record.

[2:41:26] any other exhibits?

[2:41:32] Seeing none, MR. Aponte,

[2:41:32] you are excused.

[2:41:33] >> MR. Aponte: thank you,

[2:41:39] commissioners.

[2:41:39] Appreciate it.

[2:41:40] >> CHAIRMAN La Rosa:

[2:41:42] thank you.

[2:41:42] I will throw it back over

[2:41:43] to teco.

[2:41:43] In fact, before I do that,

[2:41:44] let me do some

[2:41:44] housekeeping here.

[2:41:45] Still planning to break at

[2:41:45] 12:00.

[2:41:46] I know there's still some

[2:41:51] questions on some of the

[2:41:51] witnesses.

[2:41:51] I have course encourage

[2:41:54] that.

[2:41:54] What I would like to do

[2:41:55] this afternoon, later this

[2:41:57] afternoon is at 6:00 until

[2:41:59] 6:30 is have kind of a

[2:42:07] brief dinner break and

[2:42:07] then we will continue

[2:42:08] after that.

[2:42:08] So after the 6:30 hour

[2:42:11] until 9:00 or so.

[2:42:15] Just to make sure we all

[2:42:16] have an understanding of

[2:42:16] the schedule.

[2:42:17] Is somewhat early now, but

[2:42:18] just want to give you guys

[2:42:19] a heads up anyone who's

[2:42:21] got to make plans or

[2:42:28] thoughts.

[2:42:28] Hopefully give you enough

[2:42:29] time to do anything

[2:42:29] additional.

[2:42:38] Again, still planning to

[2:42:39] break at 12:00.

[2:42:39] Teco, let's go ahead and

[2:42:40] introduce your next

[2:42:40] witness.

[2:42:40] >> thank you, MR.

[2:42:41] CHAIRMAN.

[2:42:41] Tampa electric calls chip

[2:42:45] whitworth.

[2:42:49] >> CHAIRMAN La Rosa: mr.

[2:42:50] whitworth, I do not

[2:42:50] believe you have been

[2:42:55] administered the oath.

[2:42:55] Do you mind standing?

[2:42:56] Do you swear and affirm

[2:42:56] the testimony you are

[2:42:57] about to give will be the

[2:43:02] truth, the whole truth,

[2:43:03] and nothing but the truth?

[2:43:03] >> MR. Whitworth: I do.

[2:43:04] >> CHAIRMAN La Rosa:

[2:43:04] thank you.

[2:43:05] Have a seat, get settled

[2:43:05] in, we'll give you a

[2:43:20] second to get organized.

[2:43:22] Teco, we are ready when

[2:43:22] you are.

[2:43:24] >> thank you, MR.

[2:43:26] CHAIRMAN.

[2:43:28] Good morning, transacting.

[2:43:29] >> MR. Whitworth: good

[2:43:29] morning.

[2:43:33] >> can you please state

[2:43:34] your full name for the

[2:43:34] record?

[2:43:34] >> MR. Whitworth: --

[2:43:35] seven.

[2:43:38] >> were just sworn,

[2:43:38] correct?

[2:43:39] >> MR. Whitworth: I was.

[2:43:40] Tampa electric company

[2:43:41] business address is 702

[2:43:53] north franklin st. Is 702

[2:43:53] north franklin st., tampa,

[2:43:54] fl.

[2:43:54] >> did you prepare plan

[2:43:55] cause to be filed APRIL

[2:43:55] 22, 2024 prepare direct

[2:43:56] testimony consisting of --

[2:43:56] pages?

[2:43:57] >> MR. Whitworth: I did.

[2:43:57] >> and did you prepare in

[2:44:02] cause prepare rebuttal

[2:44:03] testimony consisting of 15

[2:44:03] pages?

[2:44:04] >> MR. Whitworth: I did.

[2:44:04] >> do you have any

[2:44:05] additional questions to

[2:44:09] your prepared rebuttal

[2:44:09] testimony?

[2:44:10] >> MR. Whitworth: I do

[2:44:10] not.

[2:44:11] >> if I would ask you

[2:44:11] questions compared in your

[2:44:17] direct and -- would your

[2:44:17] interest the same?

[2:44:18] >> MR. Whitworth: they

[2:44:18] would.

[2:44:18] >> tampa electric request

[2:44:19] the prepared and rebuttal

[2:44:45] testimony of transacting

[2:44:45] the insert into the record

[2:44:46] as the red.

[2:44:46] Did you also prepare in

[2:44:47] cause to be filed with

[2:44:47] your direct testimony

[2:44:48] exhibit marked cw-one

[2:44:48] consisting of eight

[2:44:48] documents?

[2:44:49] >> MR. Whitworth: I did.

[2:44:50] >> did you also prepare

[2:44:50] cause to be filed exhibit

[2:44:51] marked cw-two consisting

[2:44:51] of three documents?

[2:44:52] >> MR. Whitworth: I did.

[2:44:52] >> MR. CHAIRMAN, tampa

[2:44:53] electric would note for

[2:44:53] the record that exhibit

[2:44:54] cw-one and cw-two have

[2:44:54] been identified on the

[2:44:55] comprehensive exhibit list

[2:44:55] as exhibits 21 and 145.

[2:44:56] >> CHAIRMAN La Rosa:

[2:44:56] okay.

[2:44:57] >> MR. Whitworth, and to

[2:44:57] prepare a summary of your

[2:44:58] direct and rebuttal

[2:44:58] testimony?

[2:44:59] >> MR. Whitworth: I did.

[2:45:01] >> would you please give

[2:45:01] that testimony?

[2:45:02] >> MR. Whitworth: good

[2:45:02] morning, commissioners.

[2:45:03] My direct testimony

[2:45:06] describes my companies

[2:45:07] just vision system,

[2:45:07] however system has grown

[2:45:08] and changed since the

[2:45:11] company's last base rate

[2:45:12] case, our customers have

[2:45:12] benefited from improved

[2:45:16] blue sky and extreme

[2:45:16] weather reliability and

[2:45:17] white capital investments

[2:45:17] in the tnd system since

[2:45:20] the last rate cases were

[2:45:21] necessary and prudent.

[2:45:22] Are direct testimony

[2:45:27] explains -- in our

[2:45:28] transmission distribution

[2:45:31] substation expansion and

[2:45:32] upgrades that are needed

[2:45:32] to support customer

[2:45:37] growth, maintain and

[2:45:38] improve system

[2:45:38] reliability, improve grid

[2:45:39] resiliency, replace aging

[2:45:40] infrastructure, improve

[2:45:41] our customers experience,

[2:45:44] and meet our governmental

[2:45:45] and regulatory

[2:45:45] commitments.

[2:45:50] Lastly, my direct

[2:45:50] testimony describes how

[2:45:51] tampa electric proposed

[2:46:09] t&d and capital budgets

[2:46:10] represent a strategic

[2:46:10] approach that will provide

[2:46:11] a modern grade to meet our

[2:46:11] customers increasing

[2:46:12] expectations, and after

[2:46:12] growing demand, and ensure

[2:46:13] a grid that will be safe,

[2:46:13] resilient, secure, and

[2:46:14] reliable for many years to

[2:46:14] come.

[2:46:15] My rebuttal testimony

[2:46:15] addresses two main issues

[2:46:16] raised by the office of

[2:46:16] public counsel' is

[2:46:17] testimony related to the

[2:46:17] companies spare medium

[2:46:20] power transformer

[2:46:20] inventory and accounting

[2:46:21] for spp work.

[2:46:25] First, our rebuttal

[2:46:25] testimony explained the

[2:46:26] company's reasonable and

[2:46:26] prudent process for

[2:46:29] maintaining inventory.

[2:46:29] tampa electric it

[2:46:35] currently has four

[2:46:35] transformers in stock and

[2:46:36] the office of public

[2:46:36] counsel has requested the

[2:46:37] company reduce medium

[2:46:42] power transformer

[2:46:42] inventory by four.

[2:46:43] I recommend the company

[2:46:50] make no adjustment since

[2:46:50] lead times for medium

[2:46:50] power transformers are

[2:46:51] approximately 1.5-2 years,

[2:46:55] they are an essential

[2:46:55] piece of equipment to

[2:46:56] serve our customers and

[2:46:56] needed to keep up with

[2:46:57] energy demand and customer

[2:46:57] growth.

[2:47:07] Second.

[2:47:07] My rebuttal testimony!

[2:47:08] How opc's reclassification

[2:47:08] of certain feeder

[2:47:09] hardening costs from base

[2:47:09] rates to the spp recovery

[2:47:20] clause is inconsistent

[2:47:20] with the commission's

[2:47:20] order when tampa

[2:47:21] electric's 2020 spp

[2:47:21] settlement agreement was

[2:47:22] approved.

[2:47:22] That agreement, which opc

[2:47:23] signed, requires tampa

[2:47:23] electric to charge the

[2:47:25] cost of removal for assets

[2:47:25] that are being retired as

[2:47:29] part of an spp project to

[2:47:30] the accumulated

[2:47:31] depreciation and rate

[2:47:33] based used to set base

[2:47:33] rates.

[2:47:33] I recommend that the

[2:47:34] commission make no

[2:47:40] adjustments to the

[2:47:40] hardening cost removal of

[2:47:41] expenses since those were

[2:47:41] charged properly under the

[2:47:42] 2022 spp agreement.

[2:47:46] This concludes my summary.

[2:47:47] Thank you.

[2:47:47] >> we tender the witness

[2:47:49] for cross-examination.

[2:47:49] >> CHAIRMAN La Rosa:

[2:47:50] thank you.

[2:47:53] Opc, you are recognized

[2:47:53] when ready.

[2:47:54] >> good morning,

[2:48:00] commissioners.

[2:48:00] Good morning, MR.

[2:48:01] Whitworth.

[2:48:01] MR. Whitworth, can I have

[2:48:02] you take a look at page 2

[2:48:05] of the testimony that's up

[2:48:05] there?

[2:48:06] In your direct, you say

[2:48:06] that your duties include

[2:48:07] advanced metering and for

[2:48:14] structure, advanced this

[2:48:15] tradition management

[2:48:15] systems, line clearing

[2:48:15] activities, and fleet

[2:48:16] equipment, is that

[2:48:16] correct?

[2:48:17] >> MR. Whitworth: that's

[2:48:21] correct.

[2:48:22] >> and are you aware of

[2:48:22] the filing your company

[2:48:26] made on AUGUST 22, 2024

[2:48:28] where teco revised

[2:48:31] portions of the gr r

[2:48:32] program that is now

[2:48:39] included in this request?

[2:48:40] >> MR. Whitworth: could

[2:48:40] you repeat the question,

[2:48:40] please?

[2:48:41] >> sure to go are you

[2:48:41] aware of the AUGUST 22

[2:48:43] filing that was made to

[2:48:45] revise the request?

[2:48:47] >> MR. Whitworth: yes, I

[2:48:47] am.

[2:48:51] >> are you aware in that

[2:48:51] filing one of the things

[2:48:54] they revised were a number

[2:48:55] of things that were

[2:48:56] included in the gr r?

[2:48:58] >> MR. Whitworth: yes,

[2:49:03] I'm aware of that.

[2:49:04] >> can you tell me how

[2:49:04] many programs from the

[2:49:05] original 40 programs that

[2:49:10] you discuss in your

[2:49:10] testimony on page 22 have

[2:49:15] been removed?

[2:49:16] >> MR. Whitworth: that

[2:49:16] question is better suited

[2:49:20] for witness david lukcic.

[2:49:22] >> david?

[2:49:24] >> yes.

[2:49:27] >> me ask you this

[2:49:27] question.

[2:49:28] Would I be correct that

[2:49:31] removing this program from

[2:49:31] this request does not mean

[2:49:34] these projects will not be

[2:49:34] done?

[2:49:34] >> MR. Whitworth: that's

[2:49:38] correct.

[2:49:41] >> and looking at page 22

[2:49:42] of your testimony, and let

[2:49:43] me know when you get

[2:49:46] there.

[2:49:51] Lines 15 through 17, I

[2:49:51] believe.

[2:49:57] Referring to

[2:49:57] .

[2:49:59] In that portion of your

[2:50:05] testimony, you say it is

[2:50:06] teco's goal to complete

[2:50:11] all the projects by 2030.

[2:50:12] But you would agree that

[2:50:16] completion date is not a

[2:50:16] firm date?

[2:50:17] >> MR. Whitworth: our

[2:50:18] intent is to complete the

[2:50:23] entire set of our gr

[2:50:24] projects by 2030.

[2:50:26] I would also like to note

[2:50:27] we are not asking the

[2:50:27] commission to approve the

[2:50:32] entire set of the gr

[2:50:33] projects for this rate

[2:50:33] case.

[2:50:34] We are only asking you to

[2:50:34] approve a subset of those

[2:50:38] in 2025 stubbs had asked.

[2:50:40] >> mi fair to assume that

[2:50:43] you agree with my question

[2:50:45] that it's not a firm date?

[2:50:53] >> MR. Whitworth: we

[2:50:53] intend to complete it by

[2:50:54] 2030 and I would refer to

[2:50:54] david lukcic about the

[2:50:56] specific dates.

[2:50:56] >> okay.

[2:51:04] On the bottom of 2022 on

[2:51:05] the page, this page of

[2:51:05] your testimony, your claim

[2:51:06] is that aggregating these

[2:51:06] projects result in more

[2:51:08] efficient capital spend

[2:51:14] and enhancement

[2:51:14] functionality.

[2:51:15] Not that all these 40

[2:51:15] projects cannot be done

[2:51:18] individually, is that

[2:51:18] correct?

[2:51:19] >> MR. Whitworth: that's

[2:51:19] correct.

[2:51:24] >> living on the page 24

[2:51:24] of this portion of your

[2:51:26] testimony.

[2:51:29] You say that the gr are

[2:51:38] projects are necessary to

[2:51:39] replace obsolete systems

[2:51:39] and equipment that have

[2:51:40] reached the end of their

[2:51:40] life, correct?

[2:51:41] >> MR. Whitworth:

[2:51:41] correct.

[2:51:43] That is one component of

[2:51:46] the gr auto projects.

[2:51:47] >> you would agree that

[2:51:48] replacing old obsolete

[2:51:48] equipment is normal

[2:51:48] activities

[2:51:48] , correct?

[2:51:51] >> MR. Whitworth: in

[2:51:51] certain circumstances it

[2:51:52] is.

[2:51:54] In other circumstances

[2:51:55] when you can replace these

[2:51:58] assets in a coordinated

[2:52:00] fashion, there is a way a

[2:52:01] company can execute these

[2:52:03] projects and save the

[2:52:07] customers further capital

[2:52:08] by the efficiency these

[2:52:11] are executed

[2:52:13] .

[2:52:14] david lukcic has a great

[2:52:18] deal of --

[2:52:18] >> you would agree it's

[2:52:20] normal activities, right?

[2:52:24] >> CHAIRMAN La Rosa: it

[2:52:24] has been asked.

[2:52:27] >> I know I asked it, but

[2:52:31] I did not get a yes or no

[2:52:31] answer.

[2:52:32] If I can ask that the

[2:52:37] witness give me a yes or

[2:52:38] no answer.

[2:52:38] >> CHAIRMAN La Rosa: I'm

[2:52:39] going to allow the

[2:52:41] question to be asked.

[2:52:50] >> I think you agree it is

[2:52:50] --

[2:52:51] >> MR. Whitworth: I said

[2:52:51] in certain circumstances

[2:52:51] it is.

[2:52:52] >> okay.

[2:52:52] You then say in your

[2:52:53] testimony that investments

[2:52:56] are to improve

[2:52:57] reliability, access to

[2:52:58] data

[2:52:58] , correct?

[2:53:02] >> MR. Whitworth: what

[2:53:02] page are you on, please?

[2:53:06] >> I'm on page 22 -- or

[2:53:10] I'm sorry, 24.

[2:53:15] And I believe we are

[2:53:16] looking at your answer

[2:53:20] which starts at line 4.

[2:53:20] >> MR. Whitworth: excuse

[2:53:20] me?

[2:53:22] Which line?

[2:53:26] >> line 4 if you need to

[2:53:27] read through that answer,

[2:53:31] that's fine.

[2:53:32] >> MR. Whitworth: okay.

[2:53:40] Thank you.

[2:53:40] >> so would you agree in

[2:53:41] your testimony you say

[2:53:41] investments are to improve

[2:53:42] reliability, access to

[2:53:50] data, and improve -- would

[2:53:50] you agree that teco

[2:53:51] routinely looks for ways

[2:53:51] to improve its systems

[2:53:54] functions?

[2:53:55] >> MR. Whitworth: we do.

[2:53:56] >> okay.

[2:53:58] Let's go to page 29 of

[2:54:07] your testimony.

[2:54:11] Looking at lines 1 and two

[2:54:18] on that page, it says the

[2:54:22] company plans to begin the

[2:54:23] grid reliability and

[2:54:25] resiliency projects in

[2:54:30] 2024 and conclude in 2023.

[2:54:36] Did you mean to say 2030

[2:54:36] and that portion of your

[2:54:37] testimony?

[2:54:37] >> MR. Whitworth: yes,

[2:54:39] that should say 2030.

[2:54:39] >> would you agree that

[2:54:41] existing field devices

[2:54:42] communicate through your

[2:54:49] radio network currently?

[2:54:50] >> MR. Whitworth: they

[2:54:50] do.

[2:54:50] >> and would you agree

[2:54:52] that the current radio

[2:54:55] scata system was installed

[2:54:59] in -- and that the scata

[2:55:00] system needs replacing?

[2:55:04] >> MR. Whitworth: that is

[2:55:04] correct.

[2:55:08] >> looking at your exhibit

[2:55:09] for your testimony,

[2:55:09] document seven, given a

[2:55:28] minute here.

[2:55:28] Okay.

[2:55:31] This is an exhibit that

[2:55:39] shows the gr project as

[2:55:39] proposed, correct?

[2:55:40] >> MR. Whitworth: no, it

[2:55:40] does not.

[2:55:41] This is a general graph

[2:55:43] that shows large buckets

[2:55:43] and timeline, but does not

[2:55:45] depict any in-service

[2:55:51] dates.

[2:55:51] >> okay.

[2:55:52] It's a general indication

[2:56:01] of the projects and

[2:56:02] timelines, but not

[2:56:02] specific in-service date,

[2:56:03] correct?

[2:56:03] >> MR. Whitworth:

[2:56:03] correct.

[2:56:04] >> part of this talks

[2:56:04] about the new

[2:56:05] communication platform

[2:56:08] that is the plt spectrum,

[2:56:10] is that correct?

[2:56:11] >> MR. Whitworth: it does

[2:56:11] mention that, correct.

[2:56:14] >> and that is the purple

[2:56:22] line, correct?

[2:56:23] >> MR. Whitworth: yes,

[2:56:23] correct.

[2:56:23] >> and the plte spectrum

[2:56:24] project, that is projected

[2:56:25] to go into service in

[2:56:25] 2026, is that still

[2:56:30] correct?

[2:56:30] >> MR. Whitworth: that's

[2:56:31] my understanding, but

[2:56:31] witness lukcic has the

[2:56:32] specifics on the plte

[2:56:42] project and all the

[2:56:43] projects.

[2:56:43] >> let me ask the

[2:56:44] questions and to the

[2:56:44] extent that you know you

[2:56:45] can answer.

[2:56:45] Looking at the blue field

[2:56:46] devices, did your items

[2:56:47] that will communicate the

[2:56:51] plte system, correct?

[2:56:52] >> MR. Whitworth: that's

[2:56:56] correct.

[2:56:56] >> your plan is to modify,

[2:57:02] your plan is to modify

[2:57:03] existing capacitors

[2:57:03] already out in the field

[2:57:07] to communicate through the

[2:57:14] plte system, correct?

[2:57:14] >> MR. Whitworth: yes, we

[2:57:15] have to modify existing

[2:57:15] equipment and if there's

[2:57:17] other equipment we might

[2:57:17] have to modify and what we

[2:57:21] install new we will have

[2:57:21] the ability to communicate

[2:57:22] through the solar network.

[2:57:26] Again, witness lukcic can

[2:57:26] provide all the details

[2:57:32] around how that

[2:57:33] communications network

[2:57:33] will interact with these

[2:57:34] field devices.

[2:57:38] >> you will also replace

[2:57:39] older automated lateral

[2:57:39] switches and modify the

[2:57:40] newer als switches to

[2:57:44] enact the plte spectrum

[2:57:46] system, correct?

[2:57:48] That's the plan?

[2:57:49] >> MR. Whitworth: if

[2:57:52] necessary, yes.

[2:57:52] >> okay.

[2:57:55] Starting on page 36 of

[2:58:03] your testimony.

[2:58:03] When we get there I'm

[2:58:04] going to be looking at

[2:58:08] starting at line 19 and

[2:58:16] through the top.

[2:58:17] Okay.

[2:58:21] You mention the projects

[2:58:22] included in the subsequent

[2:58:26] year adjustment in your

[2:58:27] testimony, correct?

[2:58:27] >> MR. Whitworth: I'm

[2:58:32] sorry, which page and

[2:58:33] which line?

[2:58:33] >> looking at page 36

[2:58:34] starting online 19 you

[2:58:42] have a question protecting

[2:58:43] capital investments in 26

[2:58:44] and 27 that were going to

[2:58:44] be proposed to be put into

[2:58:45] the subsequent year

[2:58:45] adjustments.

[2:58:47] Do you see that?

[2:58:48] >> MR. Whitworth: I do.

[2:58:51] >> that was my question.

[2:58:52] This is the portion of

[2:58:52] your testimony starting

[2:59:07] here and going to the next

[2:59:08] page where you discuss the

[2:59:09] projects that will be

[2:59:09] included in the 26 and 27

[2:59:09] subsequent year

[2:59:10] adjustments, correct?

[2:59:10] >> MR. Whitworth: no,

[2:59:11] that's not correct.

[2:59:11] My answer says the

[2:59:12] subsequent year

[2:59:12] adjustments will be

[2:59:13] explained by witness

[2:59:22] lukcic.

[2:59:23] >> to a certain extent you

[2:59:25] do include gr projects?

[2:59:27] >> MR. Whitworth: yes, I

[2:59:29] discussed the gr projects

[2:59:29] in a strategic overall

[2:59:35] level of what we plan to

[2:59:36] achieve in them.

[2:59:36] Specific details how we

[2:59:38] plan to execute that and

[2:59:39] in-service dates of those

[2:59:45] are with witness lukcic.

[2:59:45] >> okay.

[2:59:46] Let's go back to document

[2:59:54] seven.

[2:59:54] Okay.

[2:59:55] And you have green boxes

[2:59:59] with a line for breaker

[2:59:59] replacements.

[3:00:00] You would agree that

[3:00:02] replacement breakers, that

[3:00:06] you replace breakers when

[3:00:06] they are old and obsolete,

[3:00:06] correct?

[3:00:12] >> MR. Whitworth: not

[3:00:12] necessarily when they are

[3:00:13] old and obsolete, but

[3:00:14] certainly when they become

[3:00:15] nonfunctional and

[3:00:18] nonserviceable we make an

[3:00:19] attempt to do that.

[3:00:21] This is referencing relays

[3:00:22] that are not compatible

[3:00:30] with the cellular

[3:00:31] communication technology

[3:00:31] and plans for our

[3:00:32] modernized grade.

[3:00:32] >> let me ask you this.

[3:00:33] When you replace older

[3:00:36] breakers for whatever the

[3:00:36] reason and put them into

[3:00:37] service in between rate

[3:00:37] cases, that would become

[3:00:40] part of rate base that's

[3:00:41] covered in the next rate

[3:00:43] case.

[3:00:49] Without me correct to your

[3:00:50] knowledge?

[3:00:50] >> MR. Whitworth: yes.

[3:00:51] >> looking at the green

[3:00:56] line for power transformer

[3:00:57] replacement, you would

[3:00:57] agree that you upgrade or

[3:00:58] build out transformers

[3:00:58] relative to teco's

[3:00:59] customer planning and

[3:01:06] growth in demand, right?

[3:01:06] >> MR. Whitworth: I

[3:01:06] would.

[3:01:07] We do overhead

[3:01:07] distillation planning

[3:01:12] according to a city state

[3:01:13] criteria.

[3:01:13] >> you would also in the

[3:01:19] agree -- put it into

[3:01:20] service sween rate cases

[3:01:21] it becomes part of rate

[3:01:21] base that is then

[3:01:25] recovered in the next base

[3:01:30] rate, correct?

[3:01:33] >> MR. Whitworth: that is

[3:01:40] correct.

[3:01:44] >> let me take you to opc

[3:01:46] exhibit to opc exhibit

[3:01:51] 145, I believe is

[3:01:59] f2.27210.

[3:02:05] Are you familiar with this

[3:02:06] document?

[3:02:07] >> MR. Whitworth: I am.

[3:02:07] >> and can we have you

[3:02:09] look at page 3 of this

[3:02:24] document?

[3:02:27] And let me know when you

[3:02:27] get there.

[3:02:28] >> MR. Whitworth: I'm

[3:02:30] there.

[3:02:31] >> wonderful.

[3:02:31] And if you look at the

[3:02:33] bottom of that document

[3:02:34] you see project risk

[3:02:37] assessment header.

[3:02:42] >> MR. Whitworth: I do.

[3:02:42] >> okay.

[3:02:43] You would agree that the

[3:02:46] third bullet down talks

[3:02:48] about the risk of material

[3:02:52] shortages, correct?

[3:02:53] >> MR. Whitworth: it

[3:02:53] does.

[3:02:54] >> if you look further

[3:02:56] down about the for the

[3:02:57] bullet is as program

[3:02:59] benefits are not achieved

[3:03:00] on specific timelines.

[3:03:01] Is there another risk you

[3:03:02] identified?

[3:03:07] >> MR. Whitworth: that is

[3:03:07] correct.

[3:03:08] >> and an additional risk

[3:03:08] that you identified is the

[3:03:11] pace of change exceeds the

[3:03:12] organizations ability to

[3:03:15] adapt and you called that

[3:03:21] change fatigue, correct?

[3:03:21] >> MR. Whitworth:

[3:03:22] correct.

[3:03:22] >> another risk you

[3:03:23] identified related to the

[3:03:24] gr are programs is the

[3:03:27] cost changing on

[3:03:27] ecstatically over time,

[3:03:29] correct?

[3:03:30] >> MR. Whitworth:

[3:03:30] correct.

[3:03:31] What I really like about

[3:03:40] this list shows the

[3:03:40] company's forethought in

[3:03:41] understanding the risk

[3:03:41] before we enter a capital

[3:03:42] project like this.

[3:03:42] Before we even started, we

[3:03:42] mapped it out.

[3:03:43] We communicate it to our

[3:03:45] leaders, staff, and we are

[3:03:45] mapping out in

[3:03:46] understanding what

[3:03:55] mitigation plans do we put

[3:03:56] in place to avoid this

[3:03:56] risk?

[3:03:56] We are thinking about it

[3:03:57] ahead of time.

[3:03:57] This is a testament to us

[3:03:58] how we achieve success.

[3:03:58] >> finally, one of the

[3:04:00] other risks that you

[3:04:00] identified is technology

[3:04:07] and standards changeover

[3:04:07] program life among other

[3:04:08] risks, correct?

[3:04:08] >> MR. Whitworth:

[3:04:08] correct.

[3:04:09] >> if I can have you look

[3:04:11] back on page 24 of your

[3:04:24] direct testimony.

[3:04:26] And specifically I'm

[3:04:38] looking at line 10-14.

[3:04:43] You mention in always on

[3:04:48] experience.

[3:04:48] Do you see that?

[3:04:49] >> MR. Whitworth: I do.

[3:04:49] >> are you warranting that

[3:04:50] customers will never lose

[3:04:58] serious -- service if the

[3:04:58] chief rre is never

[3:04:59] implemented?

[3:04:59] >> MR. Whitworth: I am

[3:04:59] not.

[3:05:00] >> am I correctly believe

[3:05:01] the gr projects are giving

[3:05:01] the distribution system

[3:05:03] the brain whereas the spp

[3:05:05] or the physical aspects

[3:05:10] that are being replaced?

[3:05:11] >> MR. Whitworth: that is

[3:05:11] correct.

[3:05:12] >> and you would agree

[3:05:14] that there is a --

[3:05:14] component, mechanical

[3:05:17] devices that are going out

[3:05:20] into the field, correct?

[3:05:20] >> MR. Whitworth: that is

[3:05:23] correct.

[3:05:23] The mechanical devices are

[3:05:26] installed since the crews

[3:05:27] are there, they are

[3:05:30] mobilized, they are

[3:05:30] already performing the

[3:05:31] work.

[3:05:31] It's just a matter of

[3:05:32] efficiency to have them

[3:05:34] installed hardware and the

[3:05:41] gr are welcome and --

[3:05:51] >> can you tell me what

[3:05:55] frf --

[3:05:55] >> MR. Whitworth: yes, I

[3:05:57] would.

[3:05:58] >> you mainly rely on

[3:06:00] alabama power as an

[3:06:03] example of utility

[3:06:05] development of a private

[3:06:10] lte communication network

[3:06:11] and flssr technology, is

[3:06:11] that correct?

[3:06:17] >> MR. Whitworth: no,

[3:06:18] that is not correct.

[3:06:18] We have a team of people

[3:06:19] and staff of people who

[3:06:19] evaluate this technology.

[3:06:21] It's a proven technology

[3:06:21] that's been installed

[3:06:22] throughout the us and

[3:06:30] alabama is one example of

[3:06:32] an iou nearby, but there

[3:06:32] are many examples across

[3:06:38] the country of this.

[3:06:46] >> this is the one you

[3:06:47] have the most familiarity

[3:06:47] with?

[3:06:48] >> MR. Whitworth: that

[3:06:48] would be the company I

[3:06:48] visit with.

[3:06:49] >> is it true the

[3:06:51] affiliate company in

[3:06:51] canada nova scotia power

[3:06:55] does not have a gr program

[3:06:55] or private network, to

[3:06:58] your knowledge?

[3:07:00] >> MR. Whitworth: not to

[3:07:00] my knowledge.

[3:07:06] >> the gr rp is prudent,

[3:07:09] correct?

[3:07:12] >> MR. Whitworth: we are

[3:07:13] only seeking a portion of

[3:07:14] the gr are project in its

[3:07:16] entirety.

[3:07:19] David lukcic can speak to

[3:07:20] that.

[3:07:27] >> it will not go into

[3:07:29] service until after 2027,

[3:07:32] teco will come back in the

[3:07:34] future and ask for psc

[3:07:35] authorization to recover

[3:07:38] those costs later?

[3:07:39] >> MR. Whitworth:

[3:07:39] correct.

[3:07:41] Whatever is not allowed in

[3:07:41] 2025, that will be for

[3:07:48] another rate case.

[3:07:48] >> you are not seeking

[3:07:49] continual progress beyond

[3:07:49] what you are asking for in

[3:07:53] 2027, correct?

[3:07:54] >> MR. Whitworth:

[3:07:54] correct.

[3:07:55] >> I have no further

[3:07:58] questions.

[3:07:58] Thank you.

[3:07:59] >> CHAIRMAN La Rosa:

[3:07:59] thank you.

[3:08:06] Florida rising, lulac.

[3:08:07] >> good after -- I think

[3:08:07] it's afternoon now.

[3:08:08] Good afternoon, MR.

[3:08:08] Whitworth.

[3:08:09] >> MR. Whitworth: good

[3:08:13] morning, or afternoon.

[3:08:13] Whatever you want.

[3:08:19] >> I think we met during

[3:08:19] the depositions.

[3:08:20] I have just a few

[3:08:20] questions.

[3:08:20] I'm going to try not to be

[3:08:25] repetitive with the

[3:08:26] questions MS. Christiansen

[3:08:26] just asked.

[3:08:34] I will direct you to your

[3:08:35] -- actually, speaking

[3:08:39] generally about your

[3:08:40] testimony, you did look at

[3:08:41] sort of long-term trends

[3:08:44] of the grid reliability

[3:08:47] project.

[3:08:48] >> we did, yes.

[3:08:51] >> thank you.

[3:08:52] I will direct you to this

[3:08:59] is staff exhibit 181 staff

[3:09:02] exhibit 181e4022.

[3:09:04] And if we can rotate it

[3:09:06] .

[3:09:11] Perfect.

[3:09:12] Just scrolling down to

[3:09:14] where there are the key

[3:09:16] bullet points or key

[3:09:19] observations, the first

[3:09:22] bullet point does state

[3:09:31] that teco has maintained

[3:09:31] second place in the state

[3:09:32] in the last few years with

[3:09:32] minimal reliability and

[3:09:35] proactive preventability

[3:09:39] maidens programs, correct?

[3:09:40] >> MR. Whitworth: that is

[3:09:40] correct.

[3:09:48] >> now I would like to

[3:09:48] direct you to your

[3:09:49] testimony particularly

[3:09:49] this is master page

[3:10:02] c6-938.

[3:10:02] If we can scroll down to

[3:10:06] lines 13 and -- yeah.

[3:10:18] Lines 13.

[3:10:18] Sorry.

[3:10:27] C6-938.

[3:10:32] Okay.

[3:10:33] Sorry.

[3:11:10] Oh, 398.

[3:11:13] My own device is

[3:11:13] .

[3:11:17] [Indiscernible] Generally

[3:11:21] speaking, the reliability

[3:11:25] project is reported to

[3:11:30] benefit customers,

[3:11:30] correct?

[3:11:31] >> MR. Whitworth: that's

[3:11:34] correct.

[3:11:34] >> thank you.

[3:11:41] If we can pull up fll 265,

[3:11:45] which is master number

[3:12:00] f3.5-4488.

[3:12:04] And these are I feel like

[3:12:07] I'm going to say this

[3:12:12] incorrectly, the mife

[3:12:15] numbers regarding the --

[3:12:26] project.

[3:12:27] >> MR. Whitworth: it

[3:12:27] looks like based on the

[3:12:28] title this is the data

[3:12:32] that was used for the ice

[3:12:40] calculator.

[3:12:40] >> thank you so much.

[3:12:41] If you look under column b

[3:12:41] it shows that residential

[3:12:42] customers have a total

[3:12:46] benefit of 6%.

[3:12:46] >> MR. Whitworth: that's

[3:12:46] correct.

[3:12:49] >> and 94% would be going

[3:12:54] towards other customers?

[3:12:59] >> small cni, medium, and

[3:13:00] large cni.

[3:13:03] >> would you agree that

[3:13:03] residential customers are

[3:13:08] the vast majority of teco'

[3:13:08] is customers?

[3:13:09] >> MR. Whitworth: I would

[3:13:09] say we have a higher

[3:13:11] number of residential

[3:13:12] customers, yes, then

[3:13:15] commercial customers.

[3:13:16] >> okay.

[3:13:16] Thank you.

[3:13:19] I'm not going to pull up

[3:13:20] fll 266, which is master

[3:13:24] number f fll 266, which is

[3:13:43] master number f3.5-24492.

[3:13:45] And once again might not

[3:13:46] say this correctly, but

[3:13:58] this shows the sadie

[3:14:13] benefits?

[3:14:19] >> MR. Whitworth: the

[3:14:19] improvements look more

[3:14:20] like customer minutes

[3:14:24] improvements more so than

[3:14:25] sadie improvements.

[3:14:27] >> with the title of the

[3:14:30] document jog your memory

[3:14:33] on the top where it has

[3:14:34] the bate stamp numbers?

[3:14:38] >> MR. Whitworth: it

[3:14:38] does.

[3:14:42] Is is adi sadie ice

[3:14:42] benefits.

[3:14:42] Just not how I'm used to

[3:14:49] seeing that data.

[3:14:49] >> got it.

[3:14:50] But if I can direct you to

[3:14:51] column b third line this

[3:14:52] shows that residential

[3:14:52] customers have a total

[3:15:03] benefit of 5%, correct?

[3:15:04] >> MR. Whitworth: I do

[3:15:06] not see 5% on this page.

[3:15:11] >> are you on -- if you

[3:15:18] scroll up,

[3:15:22] >> MR. Whitworth: okay.

[3:15:22] Yes, 5%.

[3:15:23] >> thank you so much.

[3:15:27] i believe those are all my

[3:15:31] questions, MR. Whitworth.

[3:15:32] Thank you.

[3:15:32] >> CHAIRMAN La Rosa:

[3:15:35] thank you.

[3:15:35] Fipug.

[3:15:36] >> thank you, MR.

[3:15:37] CHAIRMAN.

[3:15:38] Just a couple of quick

[3:15:40] questions.

[3:15:40] Good morning.

[3:15:41] >> MR. Whitworth:

[3:15:41] morning.

[3:15:44] >> MR. Moyle: I had asked

[3:15:46] a question about the smart

[3:15:49] grid.

[3:15:50] I'm interested in learning

[3:15:50] a little bit more about

[3:15:56] that and in particular

[3:15:57] when do you believe you'll

[3:15:59] have the ability for the

[3:16:03] grid to notify the company

[3:16:05] of an outage as compared

[3:16:07] to customers having to

[3:16:11] call and say hey, I have

[3:16:12] an outage, can you come

[3:16:14] fix it?

[3:16:14] It seems like there's

[3:16:15] evidence that suggests

[3:16:16] that's a pretty

[3:16:19] significant timepiece to

[3:16:20] have a customer call and

[3:16:26] then that message get

[3:16:26] translated down?

[3:16:26] I'm just looking for maybe

[3:16:27] a narrative answer with

[3:16:29] respect to the timing of

[3:16:29] that and generally

[3:16:32] speaking how it would

[3:16:33] work.

[3:16:35] >> MR. Whitworth: I did

[3:16:36] hear witness sparkman's

[3:16:43] testimony yesterday.

[3:16:43] I'm familiar with the

[3:16:44] question.

[3:16:44] We do currently today have

[3:16:45] the ability to know when

[3:16:48] an entire circuit is out,

[3:16:51] which translates to

[3:16:52] customer outage as well.

[3:16:53] we also have ami data that

[3:16:54] comes through a system

[3:16:55] that aggregates that shows

[3:16:59] hey, these meters are out.

[3:17:00] There MAY be a problem

[3:17:00] here.

[3:17:02] That coupled with a call

[3:17:04] from a customer allows us

[3:17:05] to troubleshoot from the

[3:17:08] appropriate

[3:17:09] .

[3:17:09] We are not totally blind,

[3:17:14] but not as specific as we

[3:17:15] would like to get.

[3:17:22] Something that witness

[3:17:22] david lukcic can get at,

[3:17:23] we expect to have that

[3:17:23] technology to pinpoint

[3:17:24] precisely where an outage

[3:17:26] is and have the ability to

[3:17:28] dispatch troubleshooters

[3:17:28] and repair workers to

[3:17:36] expedite those repairs.

[3:17:37] >> MR. Moyle: just a

[3:17:38] follow-up on the dispatch

[3:17:38] piece.

[3:17:38] Is that also projected to

[3:17:39] be taking place at some

[3:17:41] future point in time?

[3:17:44] You referenced 2030, but

[3:17:47] that would be done without

[3:17:48] human beings being

[3:17:50] involved?

[3:17:50] You would just send a

[3:17:55] message and go to a

[3:17:56] message and no passing

[3:17:56] along messages through

[3:17:59] humans?

[3:18:00] >> MR. Whitworth: as we

[3:18:11] begin flssr, the

[3:18:12] technology will be able to

[3:18:13] detect an anomaly on the

[3:18:17] grid or outage,

[3:18:18] automatically restore as

[3:18:21] many customers as possible

[3:18:21] prior to human

[3:18:22] intervention, and also

[3:18:23] pinpoint where the fault

[3:18:29] location is where we can

[3:18:29] roll resources directly to

[3:18:32] that location for repair.

[3:18:33] >> MR. Moyle: and with

[3:18:34] respect to where you are

[3:18:37] rolling this system out,

[3:18:37] are you prioritizing

[3:18:40] circuits that say have

[3:18:41] Mcdill air force base or

[3:18:42] tampa general hospital

[3:18:45] airport in a way so that

[3:18:45] your more critical

[3:18:49] infrastructure is going to

[3:18:53] be plugged in first?

[3:18:54] >> MR. Whitworth: we

[3:18:54] currently do have customer

[3:18:55] reliability programs for

[3:18:58] folks like the airport or

[3:19:02] tgh hospital and those

[3:19:02] types of things.

[3:19:02] Even walmart distribution

[3:19:04] center where we track

[3:19:06] those assets very closely

[3:19:09] in the performance of

[3:19:10] those already and we have

[3:19:15] alarms and substation

[3:19:15] alarms that come to the

[3:19:16] control room on that

[3:19:17] particular infrastructure.

[3:19:18] As we roll out flisr

[3:19:19] through gr are it's going

[3:19:26] to -- as lims towers go in

[3:19:27] we will then deploy field

[3:19:27] devices and such that

[3:19:28] follow that tower

[3:19:32] construction and start to

[3:19:33] bring that technology into

[3:19:33] control.

[3:19:34] >> MR. Moyle: just

[3:19:34] briefly on the cell

[3:19:41] network, is that going to

[3:19:41] be a cell network that is

[3:19:42] exclusive to teco's use or

[3:19:42] a cell network that third

[3:19:43] parties will be able to

[3:19:45] use or something else?

[3:19:46] >> MR. Whitworth: it is a

[3:19:50] private cellular network

[3:19:50] and was evaluated for

[3:19:51] several reasons.

[3:19:51] How we limit on that and

[3:19:55] one of the biggest drivers

[3:19:56] is that is more secure.

[3:19:59] A much more secure way of

[3:19:59] communication between

[3:20:04] devices and data

[3:20:05] transfers.

[3:20:05] >> MR. Moyle: that's all

[3:20:06] the questions I have.

[3:20:10] >> CHAIRMAN La Rosa: fea.

[3:20:13] >> no questions from fea.

[3:20:15] >> CHAIRMAN La Rosa:

[3:20:15] sierra club?

[3:20:17] >> thank you, MR.

[3:20:19] CHAIRMAN.

[3:20:20] I have just a few

[3:20:23] follow-up questions in

[3:20:23] response to MS.

[3:20:25] Christiansen.

[3:20:32] My name is schef wright.

[3:20:34] She asked you whether it

[3:20:37] was normal to replace old

[3:20:43] and obsolete equipment and

[3:20:43] you said under certain

[3:20:44] circumstances.

[3:20:44] My question is when is it

[3:20:45] not normal to replace old

[3:20:47] and obsolete equipment?

[3:20:49] >> MR. Whitworth: what I

[3:20:52] meant by that is we have

[3:20:55] to do that obsolete

[3:20:59] equipment replacement in

[3:21:04] an organized and timely

[3:21:04] fashion.

[3:21:04] And something that has to

[3:21:05] be coordinated.

[3:21:07] Typically that agreement

[3:21:07] is integrated with other

[3:21:08] pieces of equipment in and

[3:21:10] around the system and as

[3:21:10] soon as it becomes

[3:21:13] obsolete we would have to

[3:21:13] coordinate that.

[3:21:15] The other thing is that

[3:21:18] often times through proper

[3:21:19] asset management programs

[3:21:22] and health analysis we can

[3:21:23] also work with that piece

[3:21:25] of equipment for a

[3:21:25] duration of time,

[3:21:32] maximizing our capital

[3:21:33] investment, which also

[3:21:33] maximizes the customer's

[3:21:34] investment as well so we

[3:21:34] get the full use out of

[3:21:36] that piece of equipment.

[3:21:41] >> MR. Wright: so I think

[3:21:42] I understood part of your

[3:21:42] follow-on discussion to

[3:21:45] indicate you might replace

[3:21:46] the function of a piece of

[3:21:52] equipment with better

[3:21:53] equipment or equipment

[3:21:54] that would do more than

[3:21:55] the old obsolete equipment

[3:21:55] did.

[3:21:58] Is that kind of what you

[3:21:59] were getting at?

[3:22:06] >> MR. Whitworth: with

[3:22:07] respect to gr and those

[3:22:07] programs, I did.

[3:22:08] >> MR. Wright: thank you.

[3:22:08] That's all I had.

[3:22:09] >> CHAIRMAN La Rosa:

[3:22:09] walmart.

[3:22:13] >> we have no cross, thank

[3:22:13] you.

[3:22:14] >> CHAIRMAN La Rosa:

[3:22:14] staff.

[3:22:15] >> Staff: staff has no

[3:22:15] questions.

[3:22:15] Thank you.

[3:22:18] >> CHAIRMAN La Rosa:

[3:22:20] staff has no questions.

[3:22:22] I will send it back to

[3:22:22] teco.

[3:22:25] >> I would ask about this

[3:22:31] document fll -- do you see

[3:22:31] were at the top where it

[3:22:34] says reliability

[3:22:35] improvement?

[3:22:36] >> MR. Whitworth: I do.

[3:22:39] >> is the only benefit of

[3:22:40] the grr project going to

[3:22:46] be reliability benefit?

[3:22:47] >> there are many

[3:22:47] benefits.

[3:22:47] In addition to

[3:22:48] reliability.

[3:22:48] Reliability is one of the

[3:22:51] things we balance when we

[3:22:51] consider what's happening

[3:22:53] with the grid and how the

[3:22:55] grid is changing.

[3:22:57] I would add one of the

[3:22:58] largest benefits to gr r

[3:23:01] would be to weigh -- a way

[3:23:07] to detect -- in 2030 we

[3:23:08] expect to have around

[3:23:12] 27,000 customers with

[3:23:12] rooftop power.

[3:23:12] That's around 770 mw of

[3:23:15] connected nameplate

[3:23:15] capacity.

[3:23:16] This will result in two

[3:23:20] way power flows on our

[3:23:21] system.

[3:23:21] This is important for

[3:23:22] three main reasons.

[3:23:24] Number one, safety.

[3:23:25] Safety of our workers.

[3:23:25] Our workers need to

[3:23:26] understand the direction

[3:23:27] of power flow so they can

[3:23:28] properly isolate the

[3:23:35] system and remove the

[3:23:36] hazardous energy and go to

[3:23:36] work.

[3:23:36] Number two, the implement

[3:23:37] we install needs to be

[3:23:37] technically capable to

[3:23:42] handle two way power

[3:23:42] flows.

[3:23:43] Number three, to the

[3:23:43] extent we can understand

[3:23:44] the contribution of

[3:23:44] renewable energy that's

[3:23:48] being injected on our

[3:23:48] grid, we can back down

[3:23:57] traditional fossil fuels

[3:23:58] and reduce line losses,

[3:23:58] which saves the company --

[3:23:59] customer money for fuel

[3:23:59] savings.

[3:24:00] There's many other reasons

[3:24:00] from a security

[3:24:00] perspective and

[3:24:01] obsolescence perspective,

[3:24:03] which we talked a lot

[3:24:05] about and also improving

[3:24:07] our customer experiences

[3:24:08] and different data

[3:24:13] offerings we will be able

[3:24:13] to have access to.

[3:24:14] >> will any of these

[3:24:16] benefits accrue to

[3:24:17] residential customers?

[3:24:17] >> MR. Whitworth: yes,

[3:24:20] they will.

[3:24:20] >> no further questions.

[3:24:21] >> CHAIRMAN La Rosa:

[3:24:21] thank you.

[3:24:24] It's now move exhibits

[3:24:25] into the record.

[3:24:28] >> table electric moves

[3:24:28] exhibits 21 and 145 into

[3:24:30] the record.

[3:24:30] >> CHAIRMAN La Rosa: are

[3:24:32] there objections?

[3:24:33] Seeing none, show them

[3:24:36] entered into the record.

[3:24:36] Opc?

[3:24:38] >> opc would move 370 into

[3:24:46] the record if it has not

[3:24:47] already been admitted.

[3:24:47] >> CHAIRMAN La Rosa: is

[3:24:48] there objections?

[3:24:48] >> no objection.

[3:24:49] >> CHAIRMAN La Rosa:

[3:24:49] seeing none, so that

[3:24:55] entered into the record.

[3:24:56] Anybody else?

[3:24:56] >> florida rising and

[3:24:57] lulac would like to move

[3:24:58] exhibits 725 and 726 into

[3:24:58] the record.

[3:25:01] >> CHAIRMAN La Rosa: any

[3:25:01] objection?

[3:25:05] >> no objection.

[3:25:05] >> CHAIRMAN La Rosa: no

[3:25:06] objection.

[3:25:06] Show that entered into the

[3:25:09] record.

[3:25:09] Any other?

[3:25:11] Seeing none, MR.

[3:25:15] Whitworth, I almost said

[3:25:17] you are recognized.

[3:25:19] You are excused.

[3:25:23] Thank you very much.

[3:25:24] >> MR. Whitworth: thank

[3:25:24] you.

[3:25:27] Thank you so much.

[3:25:28] >> CHAIRMAN La Rosa: all

[3:25:30] right, teco.

[3:25:31] I will throw it back to

[3:25:31] you to introduce your next

[3:25:32] witness and we will see

[3:25:39] how far we get with him

[3:25:39] before lunch.

[3:25:40] >> thank you, MR.

[3:25:40] CHAIRMAN.

[3:25:41] Tampa electric calls david

[3:25:43] lukcic.

[3:25:44] >> MR. Wahlen: MR. Chair,

[3:25:53] while we are on a break

[3:25:53] would be all right if I

[3:25:54] said congratulations for

[3:25:54] making this document

[3:25:54] system work and the

[3:25:55] lawyers working at and

[3:25:56] people working at?

[3:25:56] It's actually turning out

[3:25:59] to be fairly cool.

[3:25:59] I don't want to jinx it or

[3:26:04] anything.

[3:26:05] >> CHAIRMAN La Rosa: I

[3:26:05] had similar thoughts.

[3:26:06] >> MR. Wahlen: so if it

[3:26:07] fails this afternoon, you

[3:26:09] can blame me, but I just

[3:26:09] wanted to acknowledge all

[3:26:15] of the hard work and

[3:26:15] effort.

[3:26:15] It looks like it's on its

[3:26:16] way, and I appreciate

[3:26:19] that.

[3:26:20] >> CHAIRMAN La Rosa: from

[3:26:20] my perspective up here

[3:26:23] makes following along much

[3:26:24] easier, especially doing

[3:26:25] multiple things.

[3:26:28] If you do jinx us, but

[3:26:31] hopefully you don't.

[3:26:32] MR. Lukcic, sorry I didn't

[3:26:37] get you before you sat

[3:26:37] down.

[3:26:38] If you don't mind standing

[3:26:38] up really quickly, I don't

[3:26:42] believe you have been

[3:26:42] administered the oath.

[3:26:43] Please raise your right

[3:26:43] hand.

[3:26:44] do you swear and affirm

[3:26:46] the testimony you are

[3:26:47] about to give will be the

[3:26:47] truth, the whole truth,

[3:26:48] and nothing but the truth?

[3:26:52] >> MR. Lukcic: I do.

[3:26:52] >> CHAIRMAN La Rosa:

[3:26:53] thank you.

[3:26:53] >> good morning, MR.

[3:26:56] Lukcic.

[3:26:56] Can you please state your

[3:26:57] full name for the record?

[3:26:58] >> MR. Lukcic: yes, david

[3:27:00] lukcic.

[3:27:01] >> you were just sworn?

[3:27:01] >> MR. Lukcic: yes, I

[3:27:01] was.

[3:27:05] >> who is your current

[3:27:06] employer and business

[3:27:06] address?

[3:27:07] >> MR. Lukcic: tampa

[3:27:07] electric company.

[3:27:14] Business address is 702

[3:27:14] north franklin st., tampa,

[3:27:15] fl.

[3:27:15] >> did you prepare cause

[3:27:16] to be filed on this docket

[3:27:21] APRIL 22, 2024 preparing

[3:27:21] direct testimony

[3:27:21] consisting of 61 pages?

[3:27:22] >> MR. Lukcic: yes, I

[3:27:22] did.

[3:27:23] >> did you prepare cause

[3:27:28] and file prepare rebuttal

[3:27:29] testimony consisting of 20

[3:27:29] pages?

[3:27:30] >> yes, I did.

[3:27:30] >> do you have any

[3:27:31] additions or corrections

[3:27:33] to your prepared or

[3:27:33] rebuttal testimony?

[3:27:36] >> MR. Lukcic: I do not.

[3:27:43] >> MR. Lukcic, are you

[3:27:44] familiar with the AUGUST

[3:27:44] 22 filing tampa electric

[3:27:45] made to change the

[3:27:45] company's revenue

[3:27:54] requirement?

[3:27:54] >> MR. Lukcic: yes, I am.

[3:27:55] >> do you have any changes

[3:27:56] associated with that

[3:27:56] filing?

[3:27:56] >> MR. Lukcic: I do.

[3:27:57] On AUGUST 22, tampa

[3:27:57] electric filed a change to

[3:27:58] the revenue requirements

[3:27:58] to remove the cost of the

[3:28:02] project refined to as line

[3:28:03] sensor software and the

[3:28:03] distinguishing planning

[3:28:04] software from the

[3:28:07] company's sya.

[3:28:07] This would change mike

[3:28:08] direct and rebuttal

[3:28:12] testimony in several

[3:28:12] places.

[3:28:13] Instead of going through

[3:28:13] this page by page I want

[3:28:15] to note on the record that

[3:28:15] my testimony no longer

[3:28:20] applies.

[3:28:20] >> thank you.

[3:28:21] Other than those changes,

[3:28:21] if I would ask you

[3:28:23] questions in your prepared

[3:28:23] and rebuttal testimony

[3:28:28] today, would your answers

[3:28:28] be the same?

[3:28:28] >> they would.

[3:28:32] >> tampa electric requests

[3:28:32] that -- be inserted into

[3:28:36] the record as read.

[3:28:37] MR. Lukcic, did you also

[3:28:37] prepare cause to be filed

[3:28:39] in your testimony

[3:28:40] consisting of two

[3:28:40] documents?

[3:28:48] >> MR. Lukcic: I did.

[3:28:48] >> MR. CHAIRMAN, tampa

[3:28:49] electric would note for

[3:28:49] the record that exhibit

[3:28:50] dl-one has been identified

[3:28:50] in the comprehensive

[3:28:51] exhibit list as exhibit

[3:28:53] 22.

[3:28:54] MR. Lukcic, did you

[3:28:54] prepare a summary of your

[3:28:57] direct and rebuttal

[3:28:57] testimony?

[3:29:11] >> MR. Lukcic: I did.

[3:29:12] good morning,

[3:29:12] commissioners.

[3:29:12] My direct testimony

[3:29:13] describes the company's

[3:29:13] operation technology and

[3:29:14] strategy department.

[3:29:14] The ot resources and

[3:29:15] applications tampa

[3:29:15] electric uses to operate

[3:29:16] its electric system

[3:29:16] explains the progress made

[3:29:17] to date in operation

[3:29:21] technology and strategy

[3:29:22] since the company's last

[3:29:22] bait rate case.

[3:29:23] The testimony summarizes

[3:29:23] the ots plans and

[3:29:25] explained the company's ot

[3:29:25] and ask capital

[3:29:29] investments and also

[3:29:41] describes the grade

[3:29:41] reliability and visit with

[3:29:42] the project has been

[3:29:43] created to increase

[3:29:43] customer expectations, two

[3:29:44] way power flows, obsolete

[3:29:44] systems and equipment in

[3:29:45] addition to safety and

[3:29:45] reliability, concerns with

[3:29:47] the evolving grid.

[3:29:48] Grr is a collection of a

[3:29:49] series of upgrades that

[3:29:53] will deliver maximum value

[3:29:54] in the most cost-effective

[3:29:54] manner.

[3:29:55] In addition to addressing

[3:30:03] the issues above, grr will

[3:30:04] also address cyber

[3:30:04] security, operational

[3:30:05] efficiencies, which will

[3:30:05] reduce expenses, provide

[3:30:06] fuel savings due to

[3:30:06] reducing line losses, as

[3:30:07] well as setting the

[3:30:11] foundation for additional

[3:30:12] customer programs.

[3:30:12] The program will go into

[3:30:17] service as subsequent year

[3:30:18] adjustments in 26 and 27.

[3:30:20] My rebuttal testimony

[3:30:21] addresses why the

[3:30:21] commission should address

[3:30:25] inclusion of projects in

[3:30:29] the company's sya.

[3:30:29] My rebuttal testimony --

[3:30:31] does allow recovery for

[3:30:32] the grr project.

[3:30:36] This concludes my summary.

[3:30:36] Thank you.

[3:30:37] >> tender the witness for

[3:30:44] cross-examination.

[3:30:44] >> CHAIRMAN La Rosa:

[3:30:45] thank you.

[3:30:45] Opc.

[3:30:45] >> thank you, MR. Chair.

[3:30:50] Good morning, teco team.

[3:30:50] >> MR. Lukcic: good

[3:30:51] morning.

[3:30:51] >> I'm going to jump right

[3:30:52] into questions.

[3:30:52] Is a true the company has

[3:30:53] already been implemented

[3:30:53] individual components of

[3:31:00] what you named the grr

[3:31:01] project since 2022?

[3:31:02] >> MR. Lukcic: that is

[3:31:02] correct.

[3:31:02] >> and the official name

[3:31:05] is the advanced

[3:31:06] distribution infra

[3:31:06] structure, correct?

[3:31:07] >> MR. Lukcic: I don't

[3:31:12] know if I would call that

[3:31:12] the official name.

[3:31:13] Although it has been:

[3:31:14] both advanced distribution

[3:31:23] infrastructure and grid

[3:31:23] reliability.

[3:31:24] The names has been used

[3:31:24] interchangeably.

[3:31:25] >> would you agree it has

[3:31:25] modernized its dispersion

[3:31:27] network?

[3:31:30] >> MR. Lukcic: I would

[3:31:31] say that's fair.

[3:31:33] >> and this is what the

[3:31:34] individual components of

[3:31:34] the adi were intended to

[3:31:39] do when they were forecast

[3:31:39] in the ordinary course of

[3:31:40] business, right?

[3:31:40] >> MR. Lukcic: I don't

[3:31:42] know that I'd say it that

[3:31:42] way.

[3:31:43] I think what might be

[3:31:46] helpful is understanding

[3:31:47] what grr is.

[3:31:49] Grr evolved out of a

[3:31:50] series of grid

[3:31:50] modernization projects and

[3:32:00] as such as we gain through

[3:32:01] time, I think archie

[3:32:01] talked about it starting

[3:32:02] in 2018.

[3:32:02] Through time what we did

[3:32:03] is we found a more

[3:32:03] cost-effective way to

[3:32:04] execute these projects by

[3:32:04] looking at them in a

[3:32:04] holistic way.

[3:32:05] It really allowed us to

[3:32:09] find the most

[3:32:09] cost-effective way to

[3:32:10] deploy them along with

[3:32:14] providing the maximum

[3:32:14] value to the customers.

[3:32:15] It's more than a one plus

[3:32:16] one equals two.

[3:32:18] That's how these things

[3:32:21] kind of evolved.

[3:32:22] >> hasn't the company

[3:32:27] already invested roughly

[3:32:27] 21 million in these

[3:32:28] component projects from

[3:32:34] 2021-2024?

[3:32:34] >> MR. Lukcic: that's

[3:32:35] correct.

[3:32:35] >> doesn't the 2025 test

[3:32:39] year include for an

[3:32:40] additional 65,871,743 for

[3:32:42] these component grr

[3:32:46] projects?

[3:32:47] >> MR. Lukcic: that

[3:32:47] numbers of accurate.

[3:32:48] >> in other words, the

[3:32:48] company has already been

[3:32:52] accounted for adi projects

[3:32:52] consistent with the

[3:32:53] expectations underlying

[3:32:55] the rate setting for the

[3:32:58] 2021 right settlement?

[3:32:59] >> MR. Lukcic: can you

[3:33:06] rephrase the question?

[3:33:07] >> so these adi projects

[3:33:07] are consistent with the

[3:33:08] 2021 settlement agreement,

[3:33:12] correct?

[3:33:13] >> MR. Lukcic: are

[3:33:13] consistent with the 21

[3:33:16] settlement agreement.

[3:33:17] I'm not exact sure what

[3:33:20] you are referring to.

[3:33:23] >> these component capital

[3:33:27] projects were planned for

[3:33:27] and expected to be

[3:33:28] deployed between the 2021

[3:33:32] and 2024 rate case.

[3:33:35] >> MR. Lukcic: so grr

[3:33:37] hasn't evolved that way.

[3:33:41] It is not a rate case

[3:33:42] determined activity.

[3:33:48] It's a continuation that

[3:33:48] results from the increased

[3:33:49] expectations from our

[3:33:49] customers.

[3:33:50] When we continue to see

[3:33:50] the grid evolving out

[3:33:51] underneath us as customers

[3:33:59] make choices around

[3:33:59] electric vehicle

[3:34:00] selections, changes the

[3:34:00] complexity of the grid.

[3:34:01] We look at safety, which

[3:34:04] chip mentioned pv are

[3:34:05] becoming more prevalent.

[3:34:10] We are seeing two way

[3:34:11] power flow and safety

[3:34:11] concerns.

[3:34:12] In addition to customers

[3:34:12] desires for better

[3:34:17] expectations around

[3:34:17] reliability and storm

[3:34:17] restoration.

[3:34:18] It's continuing to

[3:34:18] methodically address those

[3:34:20] issues that allow the grid

[3:34:20] modernization first to

[3:34:24] develop within devolve

[3:34:24] into the most

[3:34:24] cost-effective way to

[3:34:27] deploy it and maximize

[3:34:27] those benefits and that's

[3:34:28] what evolved grr.

[3:34:40] It's not a rate case

[3:34:40] determination.

[3:34:42] It's just next have been

[3:34:43] in a relation continuing

[3:34:43] to find better ways to

[3:34:44] manage our grid.

[3:34:44] >> yes or no these capital

[3:34:45] plans are expected to be

[3:34:46] deployed in the 2021 and

[3:34:46] 2024 rate cases.

[3:34:46] >> MR. Lukcic: yes.

[3:34:47] >> and these component

[3:34:50] capital projects are

[3:34:51] expected to be deployed

[3:34:54] during the --

[3:34:55] >> MR. Lukcic: yes.

[3:34:59] >> the cost incurred in

[3:34:59] 2022 through 2024 are

[3:35:00] being reviewed for

[3:35:00] prudence in the next rate

[3:35:05] case or the current one?

[3:35:05] >> MR. Lukcic: the

[3:35:11] current one.

[3:35:12] >> is it fair to say the

[3:35:12] main dispute between

[3:35:14] yourself and opc witness

[3:35:22] amera is at the prudence

[3:35:23] included in the subsequent

[3:35:23] year adjustments but

[3:35:24] rather the company's

[3:35:24] decision to seek separate

[3:35:25] recovery of them over the

[3:35:25] subsequent year

[3:35:28] adjustments?

[3:35:30] >> MR. Lukcic: I don't

[3:35:34] want to necessarily speak

[3:35:43] for -- there's four

[3:35:43] components that are

[3:35:46] critical we are asking for

[3:35:47] in a subsequent year.

[3:35:55] The first one is the plte

[3:35:55] spectrum, which is the

[3:35:56] background of the

[3:35:56] communications network.

[3:35:57] The second is another

[3:35:57] significant but beneficial

[3:35:58] investment of the

[3:36:05] customers as it opens the

[3:36:05] door to a tremendous

[3:36:06] amount of customer

[3:36:06] programs, more accurate

[3:36:07] billing, those kind of

[3:36:07] issues.

[3:36:08] Then you also have the

[3:36:08] work management system

[3:36:10] that has been in for

[3:36:10] decades and out of

[3:36:10] support.

[3:36:11] That will continue to

[3:36:13] drive operating

[3:36:24] efficiencies and -- back

[3:36:25] office hardware portion of

[3:36:26] it and those final pieces

[3:36:26] go in in DECEMBER 2026.

[3:36:29] Yes, there are substantial

[3:36:29] investments.

[3:36:30] Much of them are multiyear

[3:36:31] projects and we felt the

[3:36:35] sya was inappropriate

[3:36:38] mechanism for recovery to

[3:36:38] relieve pressure in some

[3:36:41] of the out years.

[3:36:46] >> and isn't spending on

[3:36:50] the grr projects going to

[3:36:54] continue beyond 2024?

[3:36:54] >> MR. Lukcic: that is

[3:36:55] correct.

[3:36:55] >> in fact, the company

[3:36:56] forecast these grr

[3:36:59] spending to continue at

[3:37:04] least until 2030, correct?

[3:37:04] >> MR. Lukcic: that is

[3:37:05] correct.

[3:37:05] >> the company can choose

[3:37:07] to re-profile the capital,

[3:37:10] right?

[3:37:11] >> MR. Lukcic: so it's

[3:37:13] not a capital spend

[3:37:14] project.

[3:37:18] >> teco ting, can you

[3:37:18] please answer the question

[3:37:23] yes or no and then?

[3:37:23] >> MR. Lukcic: I would

[3:37:24] say no because these

[3:37:25] projects are codependent.

[3:37:32] You tried to drive towards

[3:37:32] -- maximize the benefit to

[3:37:33] the customers, they have

[3:37:34] to go in a certain order.

[3:37:36] A simple reorganizing

[3:37:36] projects or delaying key

[3:37:40] components is not an

[3:37:40] effective way to maximize

[3:37:41] the value to the

[3:37:47] customers.

[3:37:47] >> the company could

[3:37:48] choose to cancel some of

[3:37:48] the components that have

[3:37:49] yet to be entered,

[3:37:51] correct?

[3:37:53] >> MR. Lukcic: it's a

[3:37:54] possibility, but the

[3:37:54] company would not.

[3:37:56] >> wasn't the plte

[3:37:58] component the only

[3:37:58] component specifically

[3:38:01] approved by the board

[3:38:02] before this case was

[3:38:10] filed?

[3:38:16] >> MR. Lukcic: plte was

[3:38:17] definitely approved by a

[3:38:18] board before this case was

[3:38:18] filed.

[3:38:18] There have been several

[3:38:29] grid modernization

[3:38:29] projects that have been

[3:38:30] approved.

[3:38:30] I don't know of anything

[3:38:31] else in grr that is been

[3:38:31] approved by the board, but

[3:38:32] the board did subsequent

[3:38:32] league approve this

[3:38:33] project in JUNE of this

[3:38:33] year.

[3:38:36] >> and is the plte

[3:38:36] component still expected

[3:38:38] to be in service by 2026?

[3:38:40] >> MR. Lukcic: the plte

[3:38:42] spectrum should be

[3:38:45] deployed and functional in

[3:38:49] AUGUST in AUGUST 2025.

[3:38:49] Then the back office

[3:38:55] hardware in DECEMBER 2026.

[3:38:55] Those are the two

[3:39:00] components.

[3:39:01] >> isn't it true that one

[3:39:04] of the criteria used by

[3:39:05] teco are seeking to

[3:39:05] contain what they name the

[3:39:10] grr and subsequent year

[3:39:11] adjustments was of the

[3:39:11] project was large enough

[3:39:17] to be eligible for afudc?

[3:39:18] >> MR. Lukcic: no.

[3:39:19] Afudc collection was not a

[3:39:19] function for determining

[3:39:20] what actually was asked

[3:39:25] for recovery.

[3:39:26] We picked the most

[3:39:26] substantial investments.

[3:39:31] Some of those qualify for

[3:39:33] afudc, some did not.

[3:39:40] >> do you have a copy of

[3:39:40] that deposition?

[3:39:41] >> MR. Lukcic: I do.

[3:39:41] >> can you please go to

[3:39:42] page 47 of that

[3:39:45] deposition?

[3:39:47] >> CHAIRMAN La Rosa: do

[3:39:54] we know --

[3:39:57] >> no.

[3:39:58] One second.

[3:40:00] Commissioners, can you

[3:40:02] give us a moment to pass

[3:40:07] out the depositions?

[3:40:07] >> CHAIRMAN La Rosa:

[3:41:52] sure.

[3:41:57] I think we're ready when

[3:41:58] you are, but just to

[3:41:58] clarify the witness does

[3:41:59] have a copy.

[3:42:03] >> I do.

[3:42:04] >> my apology,

[3:42:07] commissioners, for the

[3:42:11] delay.

[3:42:11] Can you please take turn

[3:42:13] to page 47?

[3:42:13] >> MR. Lukcic: got it.

[3:42:16] >> it sounds like you are

[3:42:17] planning a standard here

[3:42:18] that if something improves

[3:42:22] efficiency it is -- can

[3:42:23] you please read your

[3:42:28] answer line 6-10?

[3:42:29] >> MR. Lukcic: okay.

[3:42:30] Can you state the first

[3:42:40] part of that question or

[3:42:41] just however you want to

[3:42:41] phrase it.

[3:42:41] >> yes.

[3:42:42] Isn't it true that one of

[3:42:42] the criteria used by teco

[3:42:46] for seeking to recover

[3:42:47] what they named the grr

[3:42:47] project in subsequent year

[3:42:48] adjustments as if the

[3:42:48] project was subject to be

[3:42:56] eligible for afudc?

[3:42:56] And then the question you

[3:42:57] were asked in your

[3:42:58] deposition was it sounds

[3:43:02] like you're planning a

[3:43:02] standard here that if

[3:43:04] something approves --

[3:43:05] improves efficiency that

[3:43:05] it's appropriate to

[3:43:10] include in the sya?

[3:43:10] Am I characterizing that

[3:43:11] correctly?

[3:43:12] Can you please read your

[3:43:16] answer 6-10?

[3:43:16] >> MR. Lukcic: a couple

[3:43:17] of things.

[3:43:20] The assertion that afudc

[3:43:23] was the --

[3:43:26] >> can you please read

[3:43:26] your answer?

[3:43:27] >> MR. Lukcic: my page 47

[3:43:37] 6-10 says lights in a --

[3:43:37] along with potentially ev,

[3:43:38] pv, and other edge type

[3:43:38] devices.

[3:43:42] >> MR. Lukcic, are you

[3:43:45] looking at the -- second

[3:43:51] deposition.

[3:43:58] I apologize.

[3:43:58] >> MR. Lukcic: I'm sorry.

[3:43:59] Can you give me the page

[3:43:59] number again three

[3:44:04] >> 47.

[3:44:04] >> MR. Lukcic: okay.

[3:44:06] Which lines?

[3:44:07] >> question I asked isn't

[3:44:09] it true the criteria

[3:44:12] seeking to recover adi

[3:44:12] projects whether it was

[3:44:31] eligible for afudc and in

[3:44:32] this deposition you were

[3:44:32] asked, I mean it sounds

[3:44:33] like you're planning a

[3:44:33] standard here that if

[3:44:34] something improves

[3:44:34] efficiency that's

[3:44:35] appropriate to include in

[3:44:35] the sya.

[3:44:36] Am I characterizing that

[3:44:36] correctly?

[3:44:36] Can you please read your

[3:44:37] answer from line 6-line

[3:44:37] 10?

[3:44:38] >> MR. Lukcic: yes.

[3:44:40] To be clear, number one

[3:44:41] the project going to be

[3:44:41] completed in that year and

[3:44:42] the second criteria was

[3:44:42] that the project large

[3:44:43] enough to have been

[3:44:51] eligible for afudc.

[3:44:54] Is and that meet --

[3:44:55] >> MR. Lukcic: the only

[3:45:01] other thing I want to do

[3:45:01] is add context.

[3:45:02] You coming off reading

[3:45:03] lines 6-10.

[3:45:05] I want to add along with

[3:45:06] adding benefits to the

[3:45:06] customer.

[3:45:09] >> so my next question is

[3:45:12] with regards to the plte,

[3:45:12] isn't it meant to replace

[3:45:14] the company's current

[3:45:19] obsolete radio system?

[3:45:19] That is not in the

[3:45:20] deposition.

[3:45:24] >> MR. Lukcic: asked the

[3:45:24] question again.

[3:45:24] I'm sorry.

[3:45:28] >> with regards to the

[3:45:29] plte, is not meant to

[3:45:29] replace the company's

[3:45:33] obsolete radio system?

[3:45:40] >> MR. Lukcic: yes.

[3:45:41] If you start deviating

[3:45:41] from the plan, doesn't

[3:45:49] that create problems?

[3:45:49] >> MR. Lukcic: if we

[3:45:50] start deviating from plan,

[3:45:52] that creates problems.

[3:45:53] >> didn't the company just

[3:45:54] file with the commission

[3:45:57] adjustments -- or

[3:46:02] eliminate elements to the

[3:46:02] sya?

[3:46:03] >> MR. Lukcic: the

[3:46:06] company filed to eliminate

[3:46:08] the recovery of elements

[3:46:12] in the sya.

[3:46:16] >> how many were removed

[3:46:29] from your original asked?

[3:46:30] >> MR. Lukcic: was listed

[3:46:31] in my opening statement no

[3:46:31] components.

[3:46:32] >> thank you so much.

[3:46:32] Nothing further.

[3:46:32] >> CHAIRMAN La Rosa:

[3:46:33] thank you.

[3:46:33] Go to florida rising

[3:46:33] lulac.

[3:46:34] >> thank you.

[3:46:37] Good afternoon/morning,

[3:46:38] MR. Lukcic.

[3:46:38] >> MR. Lukcic: good

[3:46:40] afternoon.

[3:46:41] >> I'm going to try to

[3:46:43] keep this short and not

[3:46:44] duplicate efforts.

[3:46:47] So I will ask a few

[3:46:48] questions about the

[3:46:51] private plte network, but

[3:46:52] just making sure that

[3:46:54] nothing that I'm asking

[3:47:01] has already been asked.

[3:47:01] When considering I'm just

[3:47:05] going to call it the plte

[3:47:06] because that might be

[3:47:08] easier.

[3:47:11] Teco also considered the

[3:47:20] cost of doing a

[3:47:21] public/fiber network?

[3:47:22] >> MR. Lukcic: that's

[3:47:22] correct, yes.

[3:47:22] >> and to these

[3:47:23] considerations teco was

[3:47:25] looking at other utilities

[3:47:29] that currently have a

[3:47:29] plte.

[3:47:29] >> MR. Lukcic: that's

[3:47:31] correct.

[3:47:36] >> in those considerations

[3:47:36] are there any other.

[3:47:42] Utilities for teco that

[3:47:42] use a plte?

[3:47:43] >> MR. Lukcic: I'm sorry,

[3:47:44] say that again?

[3:47:46] >> are there any

[3:47:48] .

[3:47:48] Utilities in florida that

[3:47:52] use a private plte

[3:48:00] network?

[3:48:01] The majority of the pure

[3:48:08] utilities do not use a

[3:48:08] plte network?

[3:48:09] >> MR. Lukcic: that's

[3:48:10] correct.

[3:48:10] >> thank you.

[3:48:11] I would like to bring up

[3:48:18] this is fll 179 or master

[3:48:31] number f3.3-5842.

[3:48:33] Do you recognize this

[3:48:37] document?

[3:48:37] >> MR. Lukcic: I do, yes.

[3:48:39] >> this is a document that

[3:48:41] third parties burns and

[3:48:42] Mcdonald used to look at

[3:48:46] the private lte network?

[3:48:47] >> MR. Lukcic: yes, they

[3:48:48] were responsible for the

[3:48:52] entire evaluation.

[3:48:52] >> I think you scroll down

[3:48:54] two or three pages you'll

[3:48:58] see a pie chart.

[3:48:59] >> MR. Lukcic: sorry,

[3:48:59] there's lag here.

[3:49:01] >> I was dealing with that

[3:49:05] earlier.

[3:49:06] >> MR. Lukcic: I guess

[3:49:09] that lag was forever.

[3:49:11] Yes, I'm there.

[3:49:12] >> this shows the

[3:49:14] breakdown of the estimate

[3:49:16] of cost.

[3:49:19] >> MR. Lukcic: summary of

[3:49:22] 10 year cost, yeah.

[3:49:23] >> a huge chunk of it are

[3:49:27] the lte devices.

[3:49:28] >> MR. Lukcic: that is

[3:49:30] correct.

[3:49:34] >> followed by spectrum.

[3:49:35] >> MR. Lukcic: that is

[3:49:36] correct.

[3:49:46] >> thank you.

[3:49:46] Just making sure some of

[3:49:47] the questions were not

[3:49:49] asked.

[3:49:49] Okay.

[3:49:52] The last document I would

[3:49:54] like to pull up is fll

[3:49:57] 189, which is master

[3:50:30] number f f3.3-6365.

[3:50:30] And if you can click the

[3:50:34] hyperlink, the excel

[3:50:45] there.

[3:50:45] >> MR. Lukcic: okay.

[3:50:48] >> this represents

[3:50:55] different -- one second.

[3:50:57] This represents different

[3:50:59] operations projects and

[3:51:05] the costs associated.

[3:51:05] >> MR. Lukcic: I'm sorry,

[3:51:06] what projects?

[3:51:08] >> operation spending

[3:51:13] cost.

[3:51:14] And you recognize this

[3:51:14] document?

[3:51:15] >> MR. Lukcic: I do.

[3:51:16] >> thank you so much.

[3:51:16] Those are my questions,

[3:51:17] MR. Lukcic.

[3:51:17] Thank you.

[3:51:18] >> CHAIRMAN La Rosa:

[3:51:20] thank you.

[3:51:20] Fipug?

[3:51:22] >> no questions.

[3:51:26] >> CHAIRMAN La Rosa: fea.

[3:51:27] >> no questions.

[3:51:27] >> CHAIRMAN La Rosa:

[3:51:27] sierra club.

[3:51:29] >> no questions.

[3:51:32] >> CHAIRMAN La Rosa:

[3:51:33] walmart?

[3:51:33] >> no questions.

[3:51:34] Thank you.

[3:51:34] >> CHAIRMAN La Rosa:

[3:51:35] staff.

[3:51:37] >> Staff: no questions.

[3:51:38] Thank you.

[3:51:39] >> CHAIRMAN La Rosa:

[3:51:40] commissioners, any

[3:51:42] questions?

[3:51:44] Seeing none, transit, give

[3:51:44] it back to you for

[3:51:46] redirect.

[3:51:47] >> thank you, MR.

[3:51:48] CHAIRMAN.

[3:51:57] Just a few.

[3:51:57] MR. Lukcic, do you recall

[3:52:04] when MR. Waltrus asked you

[3:52:06] and you said two?

[3:52:07] Is the cost recovery in

[3:52:09] this case for 40 trento

[3:52:09] projects?

[3:52:09] >> MR. Lukcic: they are

[3:52:11] not.

[3:52:13] >> how many are originally

[3:52:13] included in this case?

[3:52:14] >> MR. Lukcic: for the

[3:52:14] subsequent year

[3:52:16] adjustments there were six

[3:52:16] and there are currently

[3:52:22] four.

[3:52:23] >> thank you.

[3:52:26] Just one second, MR.

[3:52:32] CHAIRMAN.

[3:52:33] MR. Lukcic, do you

[3:52:36] remember earlier when MR.

[3:52:36] Waltrus asked you about

[3:52:38] your deposition transcript

[3:52:42] and you stated that afudc

[3:52:46] was -- do you recall that?

[3:52:46] >> MR. Lukcic: I do.

[3:52:48] >> did you make a mistake

[3:52:51] when you said that?

[3:52:52] >> MR. Lukcic: in the

[3:52:52] deposition, yes.

[3:52:53] >> thank you.

[3:52:56] No further questions.

[3:52:57] >> CHAIRMAN La Rosa:

[3:52:57] thank you.

[3:52:59] Let's move exhibits into

[3:53:00] the record.

[3:53:07] Teco?

[3:53:07] >> thank you.

[3:53:07] We would move exhibits 22

[3:53:08] into the record.

[3:53:08] >> CHAIRMAN La Rosa: 22

[3:53:09] into the record.

[3:53:10] Any objection?

[3:53:11] seeing none, show that

[3:53:21] entered into the record.

[3:53:21] Opc?

[3:53:21] >> no exhibits from opc.

[3:53:22] Thank you.

[3:53:22] >> CHAIRMAN La Rosa: any

[3:53:22] others?

[3:53:23] Any other parties?

[3:53:24] >> florida rising and

[3:53:25] lulac would like to move

[3:53:30] exhibits 649 and 639 into

[3:53:30] the record.

[3:53:31] >> CHAIRMAN La Rosa: any

[3:53:31] opposition to moving

[3:53:32] those?

[3:53:36] >> no objections.

[3:53:37] >> CHAIRMAN La Rosa: no

[3:53:37] objections.

[3:53:37] Show them entered into the

[3:53:38] record.

[3:53:38] Are there any other

[3:53:39] exhibits entered into the

[3:53:39] record?

[3:53:44] Okay.

[3:53:44] MR. Lukcic, thank you for

[3:53:47] being with us today and

[3:53:47] you are excused.

[3:53:49] >> MR. Lukcic: thank you.

[3:53:50] >> CHAIRMAN La Rosa: so I

[3:53:55] think we are good for a

[3:53:56] lunch break.

[3:53:56] It is a few minutes before

[3:54:01] 12:0, so let's say 1:05.

[3:54:03] Same 1:05 we will

[3:54:04] reconvene here.

[3:54:06] Fair?

[3:54:10] Testing 10 987654321 this is a

[3:54:14] test for the closed captioning

[3:54:18] service for this afternoon.

[3:54:25] Testing 10 987654321 this is a

[3:54:27] test for the closed captioning

[3:54:45] service test. 10 987654321

[3:54:48] thank you.

[4:07:52] A few minutes after 1 pm I

[4:07:56] think we can start to get in

[4:08:00] position to get rolling again.

[4:08:02] We finished the last witness.

[4:08:04] I think we will turn it back

[4:08:08] over to teco to introduce the

[4:08:09] next witness.

[4:08:13] >> thank you MR. CHAIRMAN tampa

[4:08:15] electric calls.

[4:08:15] [Listing names]

[4:08:17] >> Mike La Rosa,CHAIRMAN:

[4:08:18] [Listing names] If you don't

[4:08:24] mind before you sit down

[4:08:25] administering the oath to swear

[4:08:27] and affirm the testimony you

[4:08:29] are about to give will be the

[4:08:31] truth the whole truth and

[4:08:32] nothing but the truth.

[4:08:35] Have a seat and settle in.

[4:08:39] >> teco: good afternoon will

[4:08:40] state your name for

[4:08:41] the record.

[4:08:42] >>.

[4:08:44] [Listing names].

[4:08:45] Who is your current employer

[4:08:48] what is your business address.

[4:08:49] Tampa electric 702 n. Franklin

[4:08:51] st. Tampa electric 702 n.

[4:08:54] Franklin st., tampa, fl.

[4:08:55] >> teco: did you prepare and

[4:08:57] cause to be filed on this

[4:08:59] docket APRIL 24 prepare direct

[4:09:02] testimony insisting of 35 pages

[4:09:02] .

[4:09:02] >> I did.

[4:09:05] >> teco: any corrections or

[4:09:07] durations if I were to answer

[4:09:16] the questions contained in your

[4:09:17] prepared testimony would

[4:09:19] renters be the same as those

[4:09:20] written testimony.

[4:09:21] >> Witnes: they would.

[4:09:23] >> teco: MR. CHAIRMAN temple

[4:09:24] electric prepared testimony to

[4:09:26] be inserted into the record as

[4:09:27] read.

[4:09:29] Did you also prepare and cause

[4:09:31] to be filed with your direct

[4:09:32] testimony and exhibits marked

[4:09:32] ch

[4:09:33] b

[4:09:34] one consisting of 2

[4:09:34] documents.

[4:09:35] >> Witnes: I did.

[4:09:37] >> teco: MR. CHAIRMAN temple

[4:09:39] electric window for the record

[4:09:41] that exhibit seat one is

[4:09:43] identified on the cl as exhibit

[4:09:50] number 23.

[4:09:54] Yes it is 23.

[4:09:56] Would you please summarize your

[4:09:58] testimony.

[4:09:59] >> Witness: I will thank you

[4:10:01] good afternoon commissioners

[4:10:04] might direct testimony has five

[4:10:06] primary objectives. Number one

[4:10:06] ,

[4:10:09] it describes tampa electric

[4:10:11] informational technology

[4:10:13] department and the key services

[4:10:16] it provides the company's

[4:10:18] functional areas. Number two it

[4:10:20] discusses our comprehensive

[4:10:22] cybersecurity program now we

[4:10:23] are addressing the ever

[4:10:24] escalating and more

[4:10:26] sophisticated cyber security

[4:10:29] threats and data privacy

[4:10:33] concerns. Number three,

[4:10:34] explains the cost to operate

[4:10:37] and maintain the idf locations

[4:10:37] ,

[4:10:39] number four, it addresses the

[4:10:41] important changes made since

[4:10:45] our 2021 rate case to our major

[4:10:47] idf locations. Lastly, I direct

[4:10:48] testimony demonstrates the

[4:10:50] information technology rate

[4:10:52] base amount and operation and

[4:10:56] maintenance expenses for 2025

[4:10:58] test year are reasonable and

[4:10:59] prudent.

[4:11:00] That concludes my summary thank

[4:11:00] you.

[4:11:03] >> teco: [Listing names] Is

[4:11:05] available for cross-examination

[4:11:06] .

[4:11:08] > Mike La Rosa,CHAIRMAN:

[4:11:08] thank you.

[4:11:09] >> MR. CHAIRMAN and

[4:11:12] commissioners good afternoon

[4:11:19] MR. Haack nice meeting you.

[4:11:20] >> Witness: nice to meet you.

[4:11:22] >> I think you just stated your

[4:11:24] title is vice PRESIDENT Of

[4:11:25] information technology?

[4:11:29] Chief information officer tampa

[4:11:29] electric.

[4:11:31] >> Witness: that is correct.

[4:11:33] >> at the time you filed your

[4:11:35] testimony you have been a tampa

[4:11:37] electric for exactly one year.

[4:11:37] >> Witness: that's

[4:11:38] correct.

[4:11:41] >> immediately prior to APRIL

[4:11:42] 2023 you were the chief digital

[4:11:43] officer beginning in 2020 is

[4:11:44] that correct.

[4:11:45] >> Witness: that's correct.

[4:11:49] >> teco: [Listing names] Shows

[4:11:51] you in that role on their

[4:11:55] website is there a dual role

[4:11:56] that you have.

[4:11:56] > Witness:

[4:11:58] there is a dual role that I

[4:11:59] have I am doing both.

[4:12:01] >> teco: are you transitioning

[4:12:06] is it something that you do for

[4:12:07] both companies.

[4:12:09] >> Witness: I do it for both

[4:12:11] companies for some period of

[4:12:12] time undefined at this point.

[4:12:13] >> teco: okay.

[4:12:15] >> is all of your time on the

[4:12:16] books of tampa electric that

[4:12:18] you allocate time

[4:12:18] .

[4:12:19] >> Witness: I allocate based on

[4:12:26] calendar entries and reviewing

[4:12:27] that is my longing for our

[4:12:28] spread.

[4:12:29] >> do have an idea of what

[4:12:31] roughly what split

[4:12:31] .

[4:12:33] >> Witness: it is exactly 75

[4:12:35] tampa electric 25.

[4:12:38] [Listing names].

[4:12:40] >> in your role or your roles

[4:12:43] different do perform

[4:12:49] essentially the same functions

[4:12:49] at.

[4:12:51] [Listing names] And tampa

[4:12:51] electric.

[4:12:54] >> Witness: and the technology

[4:12:55] guy if you will and both

[4:12:55] companies there is

[4:12:57] a lot of

[4:12:58] similarities and overlap but my

[4:12:59] role at.

[4:13:01] [Listing names] Is broader and

[4:13:03] done for the parent company

[4:13:04] overall affiliates.

[4:13:04] >> do you

[4:13:06] do work for

[4:13:06] .

[4:13:12] [Listing names]

[4:13:18] >> in your role before at emera

[4:13:20] you are the cio or chief

[4:13:20] information

[4:13:22] officer be 13 I was

[4:13:22] .

[4:13:23] >> arguably one of the largest

[4:13:26] if not one of the largest five

[4:13:28] utilities in the company.

[4:13:29] Was your role there essentially

[4:13:34] the same as what you do at

[4:13:35] emera@tampa electric.

[4:13:36] >> Witness: yes.

[4:13:42] >> with your experience in the

[4:13:45] utility world and your current

[4:13:46] responsibilities you would've

[4:13:49] had oversight knowledge and

[4:13:51] responsibilities integration of

[4:13:52] software application into a

[4:13:54] whole array of business

[4:13:57] operations of all the companies

[4:13:57] ?

[4:13:58] Is that right.

[4:13:59] >> Witness: this is true.

[4:14:03] >> your responsibility as the

[4:14:15] cdo chief digital officer.

[4:14:17] >> Witness: I do.

[4:14:19] >> at emera would include both

[4:14:20] oversight knowledge and

[4:14:22] oversight responsibility of the

[4:14:24] integration of software

[4:14:25] applications into the whole

[4:14:27] array of business operations of

[4:14:29] the emera operating companies

[4:14:31] including tampa.

[4:14:32] >> Witness: it is the knowledge

[4:14:33] of as an employee of the parent

[4:14:35] company it is more about

[4:14:37] governance of what is done at

[4:14:39] the affiliates than intimate

[4:14:40] knowledge within the

[4:14:41] affiliates.

[4:14:43] >> I take it every single

[4:14:45] software application does not

[4:14:47] come across your desk.

[4:14:48] >> Witness:

[4:14:48] exactly.

[4:14:50] >> I think in your testimony

[4:14:52] you talked about cybersecurity

[4:14:52] .

[4:14:53] >> Witness: I do.

[4:14:55] >> I both emera and tampa

[4:14:56] electric.

[4:14:57] >> Witness: yes.

[4:14:59] >> would that role require all

[4:15:00] software that supports

[4:15:02] operations must at some degree

[4:15:03] your organization and under

[4:15:13] your overall supervision be

[4:15:15] screened for compliance with

[4:15:17] company security standards?

[4:15:19] >> Witness: that's correct yes.

[4:15:20] >> also for compliance with any

[4:15:22] relations that you describe in

[4:15:24] your testimony pages 14 and 15.

[4:15:26] >> Witness: that's correct.

[4:15:27] >> this concept would apply to

[4:15:29] the software that you show in

[4:15:31] document number two of your

[4:15:31] exhibit.

[4:15:31] >>.

[4:15:32] >> Witness: gas.

[4:15:34] >> that would be when I say

[4:15:35] this concept I would say the

[4:15:36] screening or governance of

[4:15:38] cybersecurity reasons for the

[4:15:40] software that was resident in

[4:15:46] the capital budget of the other

[4:15:47] operating departments of the

[4:15:49] company presented in this case

[4:15:49] .

[4:15:51] >> Witness: can you repeat that

[4:15:52] for me.

[4:15:57] >> what I'm asking you present

[4:15:58] your capital budget or your

[4:16:02] department

[4:16:02] .

[4:16:03] >> Witness: yes.

[4:16:04] > some of

[4:16:06] the other operations they have

[4:16:08] their own dedicated software

[4:16:08] right.

[4:16:09] >> Witness: yes.

[4:16:12] >> even though you were not

[4:16:14] talking about the prudence of

[4:16:16] the software for software that

[4:16:18] they use still has to come up

[4:16:19] under your cybersecurity

[4:16:21] governance.

[4:16:22] >> Witness: this is correct.

[4:16:24] >> in this sense you have a

[4:16:26] general awareness of at least

[4:16:28] the major software application

[4:16:33] that support all areas of the

[4:16:35] company's operation is that

[4:16:35] there.

[4:16:36] >> Witness: that is fair.

[4:16:41] >> no rebuttal testimony from

[4:16:41] you.

[4:16:43] > Witness: correct.

[4:16:44] >> no one has filed testimony

[4:16:46] in response to your testimony

[4:16:48] describe the historical and

[4:16:50] projected cost of your

[4:16:51] department.

[4:16:52] >> Witness: that is correct.

[4:16:53] >> I note in your that you

[4:16:55] justify your testimony does not

[4:16:57] include operations technology

[4:16:59] applications and their

[4:17:01] supporting staff their

[4:17:03] supporting software supporting

[4:17:05] hardware, which is described in

[4:17:07] the direct testimony of.

[4:17:11] [Listing names]

[4:17:12] >> Witness: that's correct.

[4:17:14] >> one might conclude the lack

[4:17:16] of rebuttal would indicate

[4:17:18] there is no controversy or

[4:17:19] dispute relative to the it

[4:17:21] department is that how you

[4:17:21] look

[4:17:22] at it.

[4:17:23] >> Witness: I made no

[4:17:24] assumptions.

[4:17:24] >> fair enough.

[4:17:27] In your testimony at 481

[4:17:29] ,

[4:17:34] [Unclear audio] It is page 5.

[4:17:45] Line 8-17 you recount tampa

[4:17:47] electric company's major areas

[4:17:49] of strategic focus and pointed

[4:17:52] to MR. Collins testimony to do

[4:17:52] it.

[4:17:53] >> Witness: I do.

[4:17:55] >> can you read aloud items one

[4:17:57] and two please.

[4:18:00] >> Witness: item 1 is carefully

[4:18:01] imprudently manage operating

[4:18:03] expenses and capital spending

[4:18:05] to meet growing and changing

[4:18:07] needs in our service area

[4:18:11] excuse me and 2 to continuously

[4:18:13] improve the safety of the

[4:18:14] liability and resiliency of our

[4:18:15] electric system.

[4:18:17] >> in your testimony in this

[4:18:19] vicinity you testified that the

[4:18:21] company's it department your

[4:18:22] department plays a vital role

[4:18:26] in supporting those areas

[4:18:26] .

[4:18:27] >> Witness: yes.

[4:18:29] >> would you agree that in your

[4:18:31] testimony that you focus on

[4:18:33] presenting the cost of both

[4:18:34] capital and deity in

[4:18:42] cybersecurity projects under

[4:18:43] your purview.

[4:18:44] >> Witness: I do.

[4:18:46] >> would also be fair to

[4:18:48] conclude at least in the area

[4:18:50] of cybersecurity the company is

[4:18:50] somewhat less

[4:18:52] focused on

[4:18:53] efficiencies and more focused

[4:18:56] on striving to minimize if not

[4:18:57] eliminate security threats.

[4:18:59] >> Witness: it is risk

[4:19:00] management that is what

[4:19:01] cybersecurity is focused on.

[4:19:05] >> outside cybersecurity aspect

[4:19:06] of your role item 3 on page 41

[4:19:08] lines 13-14 it would indicate

[4:19:13] that the it department has a

[4:19:15] significant role in developing

[4:19:17] and implement thing software

[4:19:18] solutions to achieve and

[4:19:20] improve on efficiency in all

[4:19:21] areas of temporal separation

[4:19:25] that right

[4:19:25] .

[4:19:27] >> Witness: that's right we

[4:19:29] partner with the other business

[4:19:31] units and functions within

[4:19:32] tampa electric and all

[4:19:34] technology initiatives.

[4:19:36] >> would you agree with me that

[4:19:38] a growing aspect of achieving

[4:19:45] efficiencies in electric

[4:19:46] utilities sphere is the

[4:19:48] application of artificial

[4:19:50] intelligence machine learning

[4:19:52] and advanced data analytics to

[4:19:53] processes that are fundamental

[4:19:55] to the utility operating

[4:19:56] systems?

[4:19:58] >> Witness: artificial

[4:19:59] intelligence really is a broad

[4:20:01] term. Artificial intelligence

[4:20:03] has been around for decades.

[4:20:05] There is artificial

[4:20:07] intelligence and that the

[4:20:08] systems we deploy in use today.

[4:20:10] But it is not the height

[4:20:12] artificial intelligence since

[4:20:14] NOVEMBER artificial

[4:20:14] intelligence since NOVEMBER

[4:20:17] 2022 when chad gpd was

[4:20:18] introduced that's a whole

[4:20:20] another legal artificial

[4:20:22] intelligence and we do not use

[4:20:23] and utilize today much in the

[4:20:26] way of general ai.

[4:20:27] >> when we talk about

[4:20:28] artificial intelligence I'm

[4:20:32] talking about generative ai.

[4:20:39] >> Witness: fair enough I don't

[4:20:40] agree can you ask your

[4:20:40] question.

[4:20:42] >> that is fair I was asking is

[4:20:44] a growing aspect of achieving

[4:20:45] efficiencies in electric

[4:20:48] utility sphere and application

[4:20:51] we can insert generative ai.

[4:20:53] >> Witness: I would say it is a

[4:20:56] potential it is emerging and

[4:20:59] not growing.

[4:21:01] That is not the right way to

[4:21:02] characterize it today.

[4:21:10] >> okay.

[4:21:12] To your understanding of

[4:21:13] generative ai would you agree

[4:21:16] that these are overwhelmingly

[4:21:16] if

[4:21:18] not entirely software driven

[4:21:19] applications to the extent that

[4:21:21] they are being used.

[4:21:23] >> Witness: yes software might

[4:21:25] be embedded in hardware but it

[4:21:26] is absolutely software.

[4:21:28] >> are you familiar with human

[4:21:30] interface human machine

[4:21:35] interface applications?

[4:21:36] >> Witness: sure!

[4:21:36] Hmi yes.

[4:21:38] >> is that a potential area as

[4:21:39] an example where artificial

[4:21:41] intelligence might be used in

[4:21:42] the future.

[4:21:44] >> Witness: into the future

[4:21:46] yes.

[4:21:48] >> do you know what machine

[4:21:53] laurie learning is referred to

[4:21:55] you considered that to be under

[4:21:55] the

[4:21:57] broad umbrella of artificial

[4:21:58] intelligence.

[4:22:00] >> Witness: it is it is not

[4:22:02] generative ai.

[4:22:03] >> teco: what about advanced

[4:22:05] data analytics is that a

[4:22:07] byproduct of machine learning

[4:22:07] and ai.

[4:22:13] >> Witness: again analytics can

[4:22:15] be human based analytics or

[4:22:17] artificial intelligence-based

[4:22:18] analytics will be

[4:22:19] pre-generative ai.

[4:22:20] >> what was the word used

[4:22:20] .

[4:22:23] >> Witness: heuristics self

[4:22:24] learning.

[4:22:35] >> heuristics.

[4:22:37] I have an exhibit MR. CHAIRMAN

[4:22:39] I would like to discuss at this

[4:22:40] time.

[4:22:45] To see if it is in your book

[4:22:47] that redbook over there, opc

[4:22:49] 217.

[4:22:56] Confidential exhibit.

[4:22:57] This has a number assigned to

[4:23:07] it within the case center.

[4:23:08] >> Witness: can you repeat the

[4:23:10] number

[4:23:10] .

[4:23:11] >> it is opc b

[4:23:27] 217.

[4:23:37] >> is it that cl 442?

[4:23:38] >> I've been told yes it is.

[4:23:39] >> okay thank you.

[4:23:41] >> I forgot to bring my cl work

[4:23:44] with me.

[4:23:47] Okay.

[4:23:50] This is a confidential document

[4:23:51] it is labeled highly competent

[4:23:53] by the company. I'm going to

[4:23:59] ask you some preliminary

[4:24:00] questions about it without

[4:24:02] getting into the details of it.

[4:24:04] I would ask you first off are

[4:24:06] you familiar with this document

[4:24:12] or what is in it?

[4:24:18] It appears to be a document

[4:24:21] presented at the NOVEMBER 7,

[4:24:25] 2023 tampa electric peoples gas

[4:24:34] board meeting.

[4:24:35] >> Witness: I have seen it

[4:24:36] before.

[4:24:37] >> okay you are familiar with

[4:24:39] this document.

[4:24:40] Would you agree that this

[4:24:45] document is a document that was

[4:24:48] presented to tampa electric

[4:24:50] sort of as an information about

[4:24:56] what potential generative

[4:24:58] artificial intelligence

[4:24:59] applications might exist for

[4:25:04] the company in the future?

[4:25:06] Or do have a different

[4:25:08] characterization?

[4:25:12] >> Witness: first it's been a

[4:25:14] long time since I thought the

[4:25:18] document NOVEMBER 7, 2023.

[4:25:19] I have not seen it since then

[4:25:24] before now.

[4:25:25] I really cannot tell you what

[4:25:27] the major themes are through

[4:25:27] there.

[4:25:28] >> okay.

[4:25:28] There are

[4:25:30] enough.

[4:25:32] i was looking for his name I

[4:25:33] saw men who presented this

[4:25:36] seemed like his first name

[4:25:40] began with a. Would you have

[4:25:53] been at this presentation?

[4:25:54] >> Witness: I'm sure I was am

[4:25:57] not sure who presented it.

[4:25:58] >> that is fair. In this

[4:26:05] document can you read the title

[4:26:05] on the first page?

[4:26:07] Without revealing confidential

[4:26:10] information?

[4:26:11] I don't know if you worked out

[4:26:13] with your attorney if I ask you

[4:26:15] to do something and ask you if

[4:26:18] it would reveal confidential

[4:26:20] information is only hope you

[4:26:22] look down the row and get a

[4:26:23] thumbs up or something.

[4:26:26] >> Witness: okay thank you for

[4:26:29] that but yes I can remember it

[4:26:30] generative ai use cases and

[4:26:31] next steps.

[4:26:32] >> okay.

[4:26:33] Can you turn to the second page

[4:26:36] which has a base number the big

[4:26:41] large 7826?

[4:26:44] On the left-hand side of the

[4:26:47] landscape.

[4:26:48] >> Witness: yes.

[4:26:53] >> in this document on this

[4:26:58] page would you agree that the

[4:26:59] far right-hand column with the

[4:27:02] darker blue arrow talks about

[4:27:11] potential ai

[4:27:14] .

[4:27:15] Can you tell me what generally

[4:27:19] that talks about?

[4:27:21] It's without revealing

[4:27:22] confidential information.

[4:27:24] >> Witness: underneath the

[4:27:26] fourth arrow is that which were

[4:27:27] looking at.

[4:27:27] >> yes.

[4:27:37] >> Witness: okay you would like

[4:27:38] me to.

[4:27:41] >> above the number what is the

[4:27:42] subheading in that arrow

[4:27:42] .

[4:27:43] >>

[4:27:43] .

[4:27:45] >> Witness: distributed

[4:27:53] intelligence apps 2022 through

[4:27:53] ongoing.

[4:27:55] >> does this area show some

[4:27:56] potential for the use of

[4:28:00] generative ai in the future?

[4:28:05] If you know?

[4:28:07] >> Witness: this has to do with

[4:28:09] applications that can run on

[4:28:12] meters our new ami meters on

[4:28:14] the edge.

[4:28:20] Again, this is potential stuff.

[4:28:25] That is not been deployed yet.

[4:28:27] It would be part of the gr rr.

[4:28:29] Were we helped use of these

[4:28:35] edge applications that is

[4:28:37] distributed on the distribution

[4:28:38] network yes.

[4:28:45] >> on the next 1278-28 and at

[4:28:50] the same area of that page

[4:28:52] there are some

[4:28:53] , there is a

[4:28:57] column it has a subheading that

[4:29:04] starts with p pb.

[4:29:08] On the far right-hand side.

[4:29:09] >> Witness: yes

[4:29:10] .

[4:29:14] >> can you read those four

[4:29:15] words without revealing

[4:29:22] financial information.

[4:29:24] >> Witness: driving value

[4:29:25] across business.

[4:29:27] >> does is talk about potential

[4:29:30] overall areas where artificial

[4:29:32] intelligence applications might

[4:29:33] provide a benefit in the

[4:29:34] future?

[4:29:35] >> Witness: yes sure yes these

[4:29:37] are all areas that would be

[4:29:42] areas in the future would have

[4:29:45] high potential to benefit from

[4:29:46] artificial intelligence.

[4:29:51] >> on the next 78 30

[4:29:51] , if you

[4:29:52] can look at that.

[4:29:53] >> Witness: 7830?

[4:29:55] >> teco: if you can read the

[4:29:56] first

[4:29:56] headline.

[4:30:00] >> there without revealing

[4:30:02] confidential information?

[4:30:04] >> Witness: the main headline

[4:30:05] or the one underneath.

[4:30:05] >> it

[4:30:07] starts with g.

[4:30:11] >> Witness: generative ai at

[4:30:12] tampa electric.

[4:30:15] >> can you read what is below

[4:30:17] that without revealing

[4:30:18] confidential information?

[4:30:19] >> Witness: yes I can.

[4:30:23] Our foray into generative ai

[4:30:25] again this year with a pallet

[4:30:27] to assist team members with

[4:30:29] annual benefits enrollment.

[4:30:33] >> okay now I believe that has

[4:30:35] been discussed in some of the

[4:30:37] testimony at least in the

[4:30:38] deposition in this case.

[4:30:40] >> Witness: I'm not familiar

[4:30:42] but I will trust you will not.

[4:30:44] Box in the lower right-hand

[4:30:48] corner you see the lower

[4:30:50] right-hand quadrant with a

[4:30:50] subheading there?

[4:30:53] Can you read that

[4:30:53] .

[4:30:55] >> Witness: the subheading next

[4:30:56] steps.

[4:30:57] >> yes.

[4:30:58] >> Witness:

[4:31:02] >> is the three bullets under

[4:31:07] that is that confidential if

[4:31:08] they are not trying to push you

[4:31:09] to read that?

[4:31:11] >> Witness: I don't think it is

[4:31:11] confidential.

[4:31:12] >>

[4:31:13] okay can you read each bullet

[4:31:13] .

[4:31:15] >> Witness: continue to evolve

[4:31:20] existing data and ai governance

[4:31:21] bullet number two, pursue

[4:31:23] increasingly complex

[4:31:24] applications of ai.

[4:31:24] Ullet

[4:31:26] number three explore potential

[4:31:28] for ai across borders, business

[4:31:28] units.

[4:31:33] >> thank you there is no

[4:31:36] timeframe associated with those

[4:31:37] steps is that there.

[4:31:39] >> Witness: there is not a

[4:31:44] tempera I might add that that I

[4:31:46] would characterize our position

[4:31:48] on this technology and others

[4:31:52] as a fast follower.

[4:31:53] Where today many of the

[4:31:56] articles that you provided on a

[4:31:57] daily basis

[4:31:58] , many vendors and

[4:32:02] consultants talk about what

[4:32:03] might happen.

[4:32:07] We are more as being a fast

[4:32:10] follower looking for show me

[4:32:12] where the value has been

[4:32:12] achieved?

[4:32:17] This is all very high potential

[4:32:19] very exciting technology. It

[4:32:22] has high high potential. I

[4:32:25] would liken it to the internet.

[4:32:26] Back in the 90s. If you will

[4:32:29] call all the speculation around

[4:32:34] the internet and runs on the

[4:32:36] stock market etc. Then the

[4:32:37] subsequent bust. We didn't

[4:32:39] start getting value out of the

[4:32:40] internet for a decade.

[4:32:42] This technology and its

[4:32:44] potential is emerging and it's

[4:32:48] in the same sort of category.

[4:32:50] I think it has higher potential

[4:32:51] than the internet does in the

[4:32:53] long term. Right now it is even

[4:32:55] more risky than the internet

[4:32:56] was back in the mid-90s.

[4:33:00] >> okay thank you.

[4:33:01] In your role that we talked

[4:33:03] about at the very outset of the

[4:33:03] questioning.

[4:33:06] Would it be fair to say as the

[4:33:09] cdl at emera and in your role

[4:33:10] at tampa electric you would

[4:33:17] have some significant level of

[4:33:20] awareness if there were it

[4:33:22] applications that were going to

[4:33:23] utilize generative ai machine

[4:33:25] learning is that correct.

[4:33:28] >> Witness: that is correct in

[4:33:30] fact I helped develop a

[4:33:35] strategy emera level that teco

[4:33:39] participated heavily in for ai.

[4:33:40] It is called the emera aia

[4:33:42] strategy I helped to put that

[4:33:43] together.

[4:33:45] >> I think there is as we read

[4:33:50] and hr pallet that is using

[4:33:53] some level of generative ai in

[4:33:54] limited applications.

[4:33:56] >> Witness: that was for annual

[4:33:58] enrollment and benefits yes.

[4:34:01] >> we were told that there is a

[4:34:04] vegetation management ai trial

[4:34:06] that is going on maybe up in

[4:34:14] canada that teco hopes to

[4:34:14] learn.

[4:34:16] >> Witness: this is correct I

[4:34:21] would characterize it as a

[4:34:23] proof of concept at this point.

[4:34:25] But yes that is true. They

[4:34:26] would like to pursue the use of

[4:34:28] generative area to help with

[4:34:30] their vegetation management.

[4:34:31] >> apart from those to proof of

[4:34:33] concept and pilot is there any

[4:34:37] other application that is being

[4:34:39] rolled out within tampa

[4:34:40] electric company in the sphere

[4:34:43] of this rate case 25, 26, and

[4:34:47] 27 that you are aware of

[4:34:47] .

[4:34:49] >> Witness: there is another

[4:34:50] proof of concept that is at

[4:34:52] tampa electric it is within the

[4:34:54] customer experience realm.

[4:34:56] Using generative ai in some

[4:35:00] capacity is very much potential

[4:35:02] it is a proof of concept to aid

[4:35:05] our customer service

[4:35:07] representatives humans being

[4:35:09] better customer service reps.

[4:35:12] >> okay is it sort of in

[4:35:16] concert with a cht gpt

[4:35:16] .

[4:35:19] >> this would be poor for

[4:35:20] something that would pop up on

[4:35:22] the screen for the customer

[4:35:24] service rep while they handle a

[4:35:24] call.

[4:35:27] >> apart from that anything

[4:35:27] that you

[4:35:28] are aware of.

[4:35:30] >> Witness: that is it for the

[4:35:33] entire time period that you

[4:35:33] mentioned.

[4:35:37] >> with respect to the customer

[4:35:38] experience area have there been

[4:35:44] any assumptions made about the

[4:35:45] efficiencies that might begin

[4:35:47] to through the use of that

[4:35:56] proof of concept effort

[4:35:56] .

[4:35:57] >> Witness: I would say it's

[4:35:59] far too early to have done that

[4:36:00] and no, we have not.

[4:36:02] >> okay beyond the three that

[4:36:04] we talked about it your

[4:36:05] testimony to the commission

[4:36:07] that with respect to the

[4:36:08] projected test year in the

[4:36:10] subsequent years at issue here,

[4:36:12] there are no known or under

[4:36:13] implementation ai efficiencies

[4:36:15] that you are aware of that are

[4:36:16] not being included in the

[4:36:18] revenue requirements.

[4:36:21] >> Witness: I would further

[4:36:25] clarify pricing generative ai

[4:36:25] .

[4:36:26] [Unclear audio] That is

[4:36:27] correct.

[4:36:30] >>

[4:36:30] .

[4:36:32] [Listing names] Thank you I

[4:36:34] just needed to go through that

[4:36:36] for the record I appreciate

[4:36:37] your help and

[4:36:38] information. Thank

[4:36:40] you very much MR. CHAIRMAN

[4:36:40] thank you.

[4:36:41] > Mike La

[4:36:43] Rosa,CHAIRMAN: thank you.

[4:36:44] [Listing names].

[4:36:46] >> thank you MR. CHAIRMAN good

[4:36:48] afternoon MR. Heck I believe

[4:36:49] all of my questions have been

[4:36:51] covered I'm going to take a

[4:36:53] quick second to make sure.

[4:36:55] I believe I don't have any

[4:36:56] other questions thank you.

[4:36:59] >> Mike La Rosa,CHAIRMAN: thank

[4:37:00] you. [Listing names]

[4:37:03] >> I have just a few questions.

[4:37:10] Page 8 line 4.

[4:37:11] >> Witness: of my testimony?

[4:37:18] >> yes sir.

[4:37:19] You have a sentence in here I

[4:37:22] will read it it says for

[4:37:25] cybersecurity emera maintains a

[4:37:26] set of standards based on

[4:37:28] national institute of standards

[4:37:30] and technology nist

[4:37:33] cybersecurity framework csf

[4:37:37] brian what is the national

[4:37:39] institute of standards and

[4:37:41] technology I was wondering is

[4:37:43] that a canadian organization.

[4:37:45] >> Witness: it is us

[4:37:46] government.

[4:37:49] It is indeed. I don't know what

[4:37:51] branch it rolls up into but it

[4:37:54] is an agency within the united

[4:37:55] states government.

[4:38:01] >> I will ask a few questions

[4:38:03] about your cybersecurity will

[4:38:05] hear a lot about that person if

[4:38:07] there's anything were not

[4:38:09] comfortable answering because

[4:38:11] of a security reason just say

[4:38:13] that you are not comfortable we

[4:38:14] will figure out how to deal

[4:38:15] with that.

[4:38:16] You put a lot in

[4:38:16] here about what

[4:38:18] you all are doing just a few

[4:38:20] questions it looks like you

[4:38:21] have a full-time staff.

[4:38:21] N

[4:38:22] your department of 18 folks

[4:38:24] that are tasked with

[4:38:26] cybersecurity operations but

[4:38:28] then you also say that you have

[4:38:29] a team that you contract with

[4:38:31] or others that you contract

[4:38:33] with can you share a little bit

[4:38:34] the relative composition of how

[4:38:37] that works and it works

[4:38:37] together?

[4:38:43] >> Witness: part of it is the

[4:38:44] realization you cannot go it

[4:38:46] alone. As talented as our 18

[4:38:50] people might be you need a

[4:38:52] broader perspective etc. We

[4:38:53] have a consulting firm I would

[4:38:55] call it and a strategic advisor

[4:38:58] or spread we have been other

[4:39:03] companies that do more

[4:39:04] repetitive routine type work.

[4:39:22] That would be as an example, 7

[4:39:23] x 24 monitoring particularly in

[4:39:25] the overnight hours they review

[4:39:27] all of our logs etc. And they

[4:39:29] are very falstaff to make sure

[4:39:31] we see every alert and everett

[4:39:32] handle every alert around the

[4:39:34] clock seven days a week. As an

[4:39:36] example both strategic and the

[4:39:37] more nuts and bolts of it as

[4:39:38] well.

[4:39:39] The 18 people they are loyal

[4:39:41] employees that investigate

[4:39:43] alerts and they do reporting to

[4:39:47] mitigate risk and understand

[4:39:49] risk etc.) That type of the

[4:39:51] core work is done within tampa

[4:39:52] electric by those 18 employees.

[4:39:54] >> are you aware of the

[4:39:57] situations in which cyber has

[4:40:01] been used worldwide to take

[4:40:04] down grades for extended

[4:40:07] periods of time?

[4:40:08] >> Witness: yes jiggly lately

[4:40:09] in ukraine.

[4:40:11] That would be the most dramatic

[4:40:14] example.

[4:40:16] >> any in the united states you

[4:40:17] are aware of?

[4:40:20] >> Witness: nothing material.

[4:40:24] Or it would have been reported.

[4:40:25] >> you said your job is to

[4:40:29] manage risk

[4:40:30] .

[4:40:31] >> Witness: that is one of them

[4:40:34] for cybersecurity absolutely!

[4:40:36] >> a lot of times people in the

[4:40:40] insurance business will save

[4:40:42] your managing to risk there is

[4:40:44] a policy for you. You have any

[4:40:45] way to manage risk through

[4:40:49] insurance and if so are you

[4:40:49] doing that?

[4:40:50] >> Witness: we do have

[4:40:53] cybersecurity insurance the

[4:40:53] aspirin.

[4:40:54] >> what is it called.

[4:40:57] >> Witness: cybersecurity

[4:40:57] insurance.

[4:40:59] >> that would cover revenue

[4:41:01] that were not able to receive

[4:41:03] because of a separate outage it

[4:41:05] would cover any damages to the

[4:41:07] customers explain that to me.

[4:41:12] >> Witness: it's an insurance

[4:41:14] policy that would basically

[4:41:15] after the developable capital

[4:41:17] losses from an incident where

[4:41:19] cybersecurity criminals got

[4:41:24] into our computer network and

[4:41:26] data center etc. And brought

[4:41:27] harm to the company.

[4:41:29] The entire cost to restore

[4:41:31] etc., they would cover a

[4:41:36] portion of that above the

[4:41:37] deductible

[4:41:37] .

[4:41:41] >> would it cover rent

[4:41:42] somewhere payments as well.

[4:41:48] >> Witness: it would cover that

[4:41:49] all of it has to be approved

[4:41:51] our cyber risk or audited by

[4:42:05] the insurers etc. To make sure

[4:42:07] we mitigate risk well good

[4:42:09] cyber security programs to be

[4:42:11] insured you have to go through

[4:42:12] a lot of hoops to get there.

[4:42:14] >> lost revenue because of

[4:42:16] businesses that part of what is

[4:42:17] insured.

[4:42:18] >> Witness: that is a better

[4:42:19] question for

[4:42:20] an insurance person

[4:42:21] I do not recall.

[4:42:23] >> just a few more a lot of

[4:42:24] acronyms in this spring.

[4:42:25] >> Witness: I'm sorry it comes

[4:42:30] with the territory.

[4:42:30] >>.

[4:42:30] [Listing names] Asked you a

[4:42:30] question about.

[4:42:31] [Listing names] What is.

[4:42:33] [Listing names]

[4:42:35] >> Witness: supervisor control

[4:42:37] data acquisition is aware human

[4:42:39] and operating center remotely

[4:42:40] control equipment on the grid

[4:42:42] basically. Within a generating

[4:42:43] plant.

[4:42:44] >> made a note in your answer

[4:42:45] you said hmi.

[4:42:47] >> Witness: human machine

[4:42:47] interface.

[4:42:49] >> you made a point about

[4:42:50] analysis of information that

[4:42:54] you received and there are two

[4:42:59] ways that analysis can be done

[4:43:00] heuristic is the word brian.

[4:43:04] >> Witness: heuristics

[4:43:05] .

[4:43:07] >> that is machine analysis is

[4:43:07] that correct.

[4:43:10] >> Witness: is a term used for

[4:43:11] the earliest forms of ai. I

[4:43:12] think the word means self

[4:43:15] learning.

[4:43:16] Something like that.

[4:43:19] >> you compared it with human

[4:43:19] analysis.

[4:43:22] Do you do both

[4:43:22] .

[4:43:29] >> Witness: for sure

[4:43:29] , analytics

[4:43:31] is a field where you can take a

[4:43:33] bunch of data and manipulate it

[4:43:35] in ways and I human can review

[4:43:37] the results and make decisions.

[4:43:38] Then artificial intelligence

[4:43:41] would be using the same data to

[4:43:42] make its own predictions

[4:43:46] instead of human making the

[4:43:47] analysis.

[4:43:48] Typically it would

[4:43:51] lead to human judgment.

[4:43:53] At this point especially. It is

[4:43:54] not meant to often to make its

[4:44:04] own decisions on the fly.

[4:44:05] >> here is what the

[4:44:06] machines are

[4:44:07] saying here is what the human

[4:44:09] folks are saying. In that

[4:44:11] decision ultimately would be

[4:44:12] made by a human at this point

[4:44:13] not a machine?

[4:44:14] >> Witness:).

[4:44:16] >> just a couple of other quick

[4:44:17] questions.

[4:44:19] The amide meters those are

[4:44:20] meters that are smart meters

[4:44:23] they can go on businesses and

[4:44:24] homes is that right.

[4:44:26] >> Witness: that is correct all

[4:44:27] of our meters other than

[4:44:28] exceptions are ami meters.

[4:44:29] >> are they settled in such a

[4:44:32] way that third parties cannot

[4:44:37] hack in to the smart meter and

[4:44:40] then begin access to turn on

[4:44:42] lights in your house and listen

[4:44:44] in and all of that self. Can

[4:44:45] you explain that.

[4:44:47] >> Witness: absolutely!

[4:44:48] Cybersecurity is a big concern

[4:44:51] with the ami they were designed

[4:44:52] from the ground up with

[4:44:53] cybersecurity in mind.

[4:44:56] What you engine is a nuisance

[4:44:58] but if they were to turn off

[4:44:59] all meters at once we would

[4:45:01] have a really bad day on the

[4:45:04] distribution network.

[4:45:06] So yes, a lot of cybersecurity

[4:45:09] controls architected for the

[4:45:10] ground up for cybersecurity

[4:45:16] they are very secured devices.

[4:45:16] Bless you.

[4:45:18] >> I notice in your testimony

[4:45:20] you did not list how many times

[4:45:22] you have given testimony before

[4:45:23] but I understand you have

[4:45:26] worked previously is this your

[4:45:28] first time testimony in a

[4:45:29] regulatory proceeding

[4:45:29] .

[4:45:31] >> Witness: this is the first

[4:45:32] time under oath.

[4:45:34] >> thank you for answering my

[4:45:38] questions.

[4:45:40] >> Mike La Rosa,CHAIRMAN:

[4:45:41] [Listing names]

[4:45:42] >> no questions.

[4:45:44] >> Mike La Rosa,CHAIRMAN:

[4:45:45] sierra club.

[4:45:50] >> no questions are on

[4:45:50] .

[4:45:50] >>.

[4:45:52] [Listing names] For retail

[4:45:53] federation no questions.

[4:45:55] >> Mike La Rosa,CHAIRMAN:

[4:45:55] walmart.

[4:45:56] >> no question thank you

[4:45:56] .

[4:45:58] >> Mike La Rosa,CHAIRMAN:

[4:45:59] [Listing names] Commissioners

[4:46:00] any questions.

[4:46:08] >> Giles Fay,Commissioner: that

[4:46:10] you MR. CHAIRMAN and thank you

[4:46:12] MR. Heck for being here it's an

[4:46:19] interesting subject matter and

[4:46:21] I can understand maybe why you

[4:46:23] have not testified before.

[4:46:24] It's a complicated thing to

[4:46:26] talk about publicly. I will am

[4:46:27] going to ask fairly specific

[4:46:29] questions if any way you feel

[4:46:31] that it's not appropriate to

[4:46:33] answer that question please

[4:46:34] feel free to do so.

[4:46:34] Ur

[4:46:36] commission like a lot of

[4:46:38] jurisdictions have processes in

[4:46:39] place that review the

[4:46:41] implementation and consistency

[4:46:42] of the sap standards through

[4:46:44] the american that's in your

[4:46:46] testimony you mentioned that

[4:46:48] but do interpret anything that

[4:46:49] this body does or the

[4:46:51] commission does to limit the

[4:46:52] utility's ability to go beyond

[4:46:55] those requirements?

[4:46:59] >> Witness: if I understand the

[4:47:00] question correctly I think my

[4:47:05] answer is no.

[4:47:06] We don't feel like there is

[4:47:08] limited funding for

[4:47:09] cybersecurity today.

[4:47:11] We are able to do what we think

[4:47:11] we need to do to

[4:47:12] satisfy.

[4:47:14] [Listing names] And the other

[4:47:15] standards.

[4:47:16] Am I answering the question

[4:47:17] that you asked.

[4:47:19] >> Giles Fay,Commissioner: let

[4:47:25] me ask it this way.

[4:47:27] With the implementation of what

[4:47:29] you do for both emera and more

[4:47:30] importantly teco it is driven

[4:47:34] by the mission to protect the

[4:47:40] systems and continue operations

[4:47:41] which you are able to do so in

[4:47:43] a way that allows for

[4:47:45] government coordination but

[4:47:47] also not interference when need

[4:47:48] be.

[4:47:50] >> Witness: it is accurate.

[4:47:55] I will add maybe a little bit

[4:48:00] tangentially but I will add.

[4:48:01] As I said you cannot go it

[4:48:01] alone.

[4:48:05] I think APRIL for

[4:48:08] government agencies where it is

[4:48:09] applicable would be to help

[4:48:12] coordinate information flow

[4:48:17] etc. With cybersecurity across

[4:48:20] the utility industry.

[4:48:22] There is ever sleep reporting

[4:48:25] requirements on our side.

[4:48:26] We would like to see some

[4:48:29] benefit from those reporting

[4:48:31] requirements as well with the

[4:48:33] two-way flow of information.

[4:48:34] Anything to help with that

[4:48:36] conduit would be helpful I

[4:48:36] think.

[4:48:38] >> Giles Fay,Commissioner:

[4:48:45] great!

[4:48:46] I appreciate what you do

[4:48:48] whenever we talk about this

[4:48:49] topic I think the more you know

[4:48:51] the less you sleep. I can

[4:48:52] appreciate the commitment that

[4:48:54] you have to keeping the grid

[4:48:55] save so thank you.

[4:48:56] Thank you MR. CHAIRMAN.

[4:48:57] >> Mike La Rosa,CHAIRMAN:

[4:48:58] back

[4:48:59] to teco for redirect.

[4:49:00] >> teco: no redirect.

[4:49:03] >> Mike La Rosa,CHAIRMAN: let's

[4:49:05] move the exhibits into the

[4:49:05] record.

[4:49:07] >> let's move exhibit 23.

[4:49:09] >> Mike La Rosa,CHAIRMAN:

[4:49:10] exhibit 23 is there an

[4:49:10] objection?

[4:49:11] >>

[4:49:11] .

[4:49:13] >> Mike La Rosa,CHAIRMAN: is

[4:49:16] there an objection I thought

[4:49:17] you were checking on. 23 I

[4:49:19] believe no objection?

[4:49:20] Show 23 is moved into the

[4:49:22] record.

[4:49:27] >> opc would move on?

[4:49:28] >> teco: no objection.

[4:49:31] >> Mike La Rosa,CHAIRMAN: no

[4:49:33] diction show entered into the

[4:49:34] record. Any other exhibits

[4:49:36] seeing none. MR. Heck thank

[4:49:38] you very much.

[4:49:44] You are excused.

[4:49:45] Teco I will forward back to you

[4:49:47] for your next witness.

[4:49:49] >> teco: thank you MR. CHAIRMAN

[4:49:50] tampa electric calls.

[4:49:55] [Listing names].

[4:49:59] >> Mike La Rosa,CHAIRMAN:

[4:50:00] miriam before you sit down to

[4:50:06] mind administering the oath.

[4:50:08] Thank you. Do you swear and

[4:50:10] affirm the testimony you're

[4:50:11] about to get but with the truth

[4:50:13] the whole truth and nothing but

[4:50:14] the truth?

[4:50:15] Excellent thank you.

[4:50:15] Feel

[4:50:16] free to get settled in.

[4:50:27] >> teco: thank you.

[4:50:29] Would you please state your

[4:50:30] name for the record.

[4:50:32] >> Witness: [Listing names].

[4:50:35] >> teco: who is your current

[4:50:36] employer and what is your

[4:50:43] business address.

[4:50:46] >> Witness: tampa electric

[4:50:47] company 702 n. Franklin temple

[4:50:49] for to. 11 to prepare and cost

[4:50:51] be filed in this document and

[4:50:52] APRIL 2 address.

[4:50:54] >> Witness: tampa electric

[4:50:56] company 702 n. Franklin temple

[4:50:57] for to. 11 to prepare and cost

[4:50:59] be filed in this document and

[4:51:01] APRIL 2, 2024 direct testimony

[4:51:02] consisting of 55 pages.

[4:51:04] >> Witness: visited.

[4:51:05] >> teco: do you prepare and

[4:51:07] cost be filed in this document

[4:51:09] rebuttal testimony consisting

[4:51:09] of 18 pages.

[4:51:11] >> Witness: yes I did.

[4:51:12] >> teco: do you have any

[4:51:14] additions or corrections to

[4:51:16] prepare direct rebuttal

[4:51:16] testimony.

[4:51:17] > Witness: yes I

[4:51:18] do.

[4:51:19] >> teco: would you please list

[4:51:20] them.

[4:51:21] >> Witness: in my direct

[4:51:23] testimony on page 30 line 19,

[4:51:24] the word million should be

[4:51:26] billion in both places.

[4:51:27] >> Witness:

[4:51:28] >> teco: do have another

[4:51:29] correct correction.

[4:51:30] >

[4:51:31] Witness: in my rebuttal

[4:51:32] testimony on page 8 line 23

[4:51:34] delete the words gulf power the

[4:51:36] first order is a florida power

[4:51:38] corporation and the second one

[4:51:38] is golf.

[4:51:40] > teco: with those

[4:51:44] provisions if I were to issue

[4:51:45] questions prepared in your

[4:51:47] direction rebuttal testimony

[4:51:48] would your answers be the same

[4:51:50] listed in the testimony.

[4:51:51] >> Witness: yes.

[4:51:53] >> teco: tampa electric

[4:51:55] requests the corrected prepared

[4:51:56] direction rebuttal testimony

[4:51:57] of.

[4:51:59] [Listing names] Be inserted

[4:52:00] into the record as the red.

[4:52:02] > Mike La Rosa,CHAIRMAN:

[4:52:05] okay.

[4:52:06] Did you prepare and cause to be

[4:52:08] filed with your direct

[4:52:09] testimony and exhibits marked

[4:52:10] mc b

[4:52:11] one consisting of 10

[4:52:12] documents.

[4:52:12] >> Witness: yes.

[4:52:14] >> teco: MR. CHAIRMAN tampa

[4:52:16] electric would note for the

[4:52:17] record that exhibit mc b

[4:52:17] one

[4:52:19] has been identified on the

[4:52:21] comprehensive exhibit list as

[4:52:22] exhibit 24.

[4:52:23] You did not have a rebuttal

[4:52:24] exhibited you?

[4:52:26] >> Witness: I did have a

[4:52:26] rebuttal.

[4:52:28] >> teco: you did have a

[4:52:29] rebuttal exhibit.

[4:52:29] Hat was

[4:52:42] that.

[4:52:42] It's.

[4:52:44] >> Witness: no did not.

[4:52:46] I'm sorry. [Laughter].

[4:52:50] >> teco: I was going to have to

[4:52:54] blame case lines for that.

[4:52:55] I thought I was wrong but I was

[4:52:56] wrong.

[4:53:01] Okay.

[4:53:02] Would you please

[4:53:03] summarize your

[4:53:04] direction rebuttal testimony.

[4:53:07] >> Witness: good afternoon

[4:53:08] commissioners my direct

[4:53:11] testimony provides an overview

[4:53:13] of the priorities that the

[4:53:15] human resource department it

[4:53:16] explains the elements of our

[4:53:19] employee compensation system.

[4:53:21] And it shows that the companies

[4:53:25] 2025 expenses for total direct

[4:53:27] composition and benefits are

[4:53:29] reasonable.

[4:53:30] We target our total direct

[4:53:32] compensation to be at market

[4:53:35] median so that we can balance

[4:53:37] the need to hire and retain

[4:53:39] quality team members without

[4:53:41] desire and commitment to

[4:53:42] maintain reasonable customer

[4:53:44] rates.

[4:53:46] Our current employee count is

[4:53:52] approximately 2550.

[4:53:53] In 2024 we expect to maintain

[4:53:56] that level in 2025.

[4:54:00] My rebuttal testimony response

[4:54:02] to criticisms from the office

[4:54:03] of public counsel and

[4:54:03] .

[4:54:04] [Listing names] About our

[4:54:05] variable pay programs and it

[4:54:07] shows that variable or at risk

[4:54:12] pay is commonly used by

[4:54:17] companies in the united states.

[4:54:19] These programs serve as

[4:54:20] valuable tools that both

[4:54:22] motivate and focus our

[4:54:23] employees and also help the

[4:54:25] company manage total direct

[4:54:32] composition expenses.

[4:54:34] I also show that the financial

[4:54:36] performance metrics within our

[4:54:38] short term incentive plans are

[4:54:39] part of a balanced scorecard

[4:54:41] performance goals that reflect

[4:54:46] the diverse priorities that all

[4:54:48] our employees or managers and

[4:54:50] senior leaders balance every

[4:54:52] day so that we can provide

[4:54:53] high-quality electric service

[4:54:55] to our customers and maintain

[4:54:56] reasonable rates.

[4:54:58] This concludes my summary.

[4:55:00] >> teco: the spec is available

[4:55:02] for cross-examination.

[4:55:04] >> Mike La Rosa,CHAIRMAN: thank

[4:55:04] you opc.

[4:55:05] >> thank you MR.

[4:55:06] CHAIRMAN and

[4:55:07] hello again.

[4:55:10] >> Witness: good afternoon.

[4:55:11] >> opc: I would like to start

[4:55:13] off if I could MR. CHAIRMAN

[4:55:14] within exhibit not

[4:55:16] confidential.

[4:55:18] It is opc b

[4:55:48] 42.

[4:55:50] That is 267.

[4:55:54] Yes.

[4:55:58] MS. Catcher tori I have a

[4:55:59] composite exhibit of the

[4:56:05] responses to opc

[4:56:11] interrogatories 12-17 cod 30 do

[4:56:21] you see that?

[4:56:24] >> Witness: yes.

[4:56:37] >> opc: okay.

[4:56:38] Going to response to

[4:56:41] interrogatory 12 it asked for a

[4:56:43] list of each of the company's

[4:56:44] existing incentive composition

[4:56:46] plans to see that.

[4:56:57] It refers the viewer to cod 30

[4:56:58] which contains the description

[4:57:01] of the existing compensation

[4:57:03] plans which is attached to this

[4:57:04] exhibit do see that.

[4:57:06] >> Witness: yes I do.

[4:57:07] >> opc: under the answer here

[4:57:14] on 53 5396.

[4:57:15] There is a variety of

[4:57:21] stock-based plans.

[4:57:23] Emera senior measurement stock

[4:57:24] option plan emera restricted

[4:57:28] share unit or as you plan.

[4:57:32] And emera deferred share unit

[4:57:33] bs you plan to see that.

[4:57:33] >> Witness:

[4:57:34] endo.

[4:57:37] >>

[4:57:37] .

[4:57:39] [Listing names] You mind moving

[4:57:39] correct phone

[4:57:40] closer as you

[4:57:41] speak.

[4:57:43] >> Witness: I would be glad to.

[4:57:46] >> opc: which long-term and

[4:57:48] short-term incentives which

[4:57:49] category do those stock plans

[4:57:50] on climax.

[4:57:52] >> Witness: the ones that apply

[4:57:56] to tampa electric is the emera

[4:57:58] restricted stock share unit

[4:57:59] yaris you plan the emera share

[4:58:09] unit drs you and that psu or

[4:58:11] long-term incentive plans that

[4:58:13] will apply to a small group of

[4:58:15] tampa electric senior leaders.

[4:58:16] Also the short term incentive

[4:58:19] plan and the teco

[4:58:19] .

[4:58:20] [Listing names] And the

[4:58:21] restoration plan.

[4:58:23] >> opc: the top one emera

[4:58:28] senior stock option plan is

[4:58:29] that not tampa electric

[4:58:29] .

[4:58:30] >> Witness: that is

[4:58:32] administered at emera it would

[4:58:37] not be within my purview it

[4:58:38] might be MR. Collins is the

[4:58:40] only one I'm not sure.

[4:58:41] >> opc: the cost of any awards

[4:58:48] under the emera senior

[4:58:50] management stock option plan

[4:58:51] does are included if any fear

[4:58:52] included in this rate case?

[4:58:54] >> Witness: that would be a

[4:58:55] good question for jeff.

[4:58:56] [Listing names]

[4:58:57] >> opc: do you know.

[4:59:03] >> Witness: I do not know.

[4:59:04] I assume so any costs incurred

[4:59:06] for tampa electric would appear

[4:59:07] in this.

[4:59:09] >> opc: okay but if I'm looking

[4:59:11] to divide this list of

[4:59:13] compensation incentive

[4:59:14] compensation plans between

[4:59:16] long-term short-term. The

[4:59:19] first 4 at the same emera was a

[4:59:26] long-term incentive plans that)

[4:59:26] Right?

[4:59:28] >> Witness: that is correct it

[4:59:29] would appear that way.

[4:59:39] >> opc: the pod 30 I don't want

[4:59:41] to it's a lengthy document.

[4:59:44] Would it suffice to say that

[4:59:45] this describes the incentive

[4:59:50] plan and it has some scorecards

[4:59:51] attached to it that show what

[4:59:56] is needed to achieve an award

[4:59:57] under the plan?

[4:59:59] >> Witness: that is correct.

[5:00:04] >> opc: would you agree that

[5:00:06] the long-term incentive plan

[5:00:07] purpose is to align the

[5:00:09] long-term incentive pay for

[5:00:11] senior leaders with corporate

[5:00:19] and shareholder goals?

[5:00:20] >> Witness: yes.

[5:00:21] >> opc: would you agree that

[5:00:23] 100% of the long-term incentive

[5:00:27] plan compensation is tied to

[5:00:29] reaching financial performance

[5:00:35] goals that include the emera

[5:00:36] stock price?

[5:00:38] >> Witness: can you repeat the

[5:00:39] question.

[5:00:43] >> opc: would you agree 100%

[5:00:45] long-term incentive

[5:00:46] compensation is tied to

[5:00:48] reaching financial performance

[5:00:50] goals that include the emera

[5:00:51] stock price.

[5:00:52] >> Witness: yes.

[5:00:54] >> opc: have you provided any

[5:00:57] evidence to the commission if

[5:00:59] they required long-term

[5:01:03] incentive plans cost to be

[5:01:07] borne by the shareholder that

[5:01:09] it would require the company to

[5:01:12] redesign its composition

[5:01:14] structure and replace long-term

[5:01:19] incentive with higher fixed

[5:01:20] base pay?

[5:01:21] >> Witness: yes.

[5:01:25] >> opc: what is that

[5:01:25] .

[5:01:26] >> Witness: the mercer data

[5:01:29] would show our total direct

[5:01:30] compensation is in market

[5:01:36] median verse or data would also

[5:01:38] show that 62% of companies

[5:01:39] leverage long-term incentive

[5:01:41] for this small population of

[5:01:42] senior leaders

[5:01:45] .

[5:01:51] Because we target market median

[5:01:53] for these executives it

[5:01:54] requires us the components of

[5:01:56] that as our base salary our

[5:01:58] short-term incentive and are

[5:01:59] long-term incentive mercer data

[5:02:01] market data would show this is

[5:02:07] common in and regularly used to

[5:02:10] attract and retain senior

[5:02:10] leaders

[5:02:11] .

[5:02:13] >> opc: the people at mercer do

[5:02:14] not require you to do anything

[5:02:15] right?

[5:02:17] >> Witness: mercer's role is to

[5:02:23] look at the market and report

[5:02:25] out on what is customary what

[5:02:27] is going on in the businesses.

[5:02:28] They do not dictate what we do

[5:02:30] they show us data that informs

[5:02:32] our decisions on our benefit

[5:02:32] packages?

[5:02:34] >> opc: have you provided any

[5:02:35] evidence to the commission in

[5:02:39] this case, that any utility has

[5:02:41] ever canceled or scrapped a

[5:02:42] long-term incentive plan

[5:02:44] because regulator disallowed

[5:02:47] ratepayer recovery of part or

[5:02:47] all of that.

[5:02:49] >> Witness: not that I am aware

[5:02:56] of.

[5:02:57] >> opc: is it your testimony

[5:02:59] from MR. Collins in the public

[5:03:00] counsel have the burden of

[5:03:05] proof to prove that incentive

[5:03:09] that incentive tampa electric

[5:03:14] executives to help bolster

[5:03:14] .

[5:03:20] >> I'm going to object to the

[5:03:21] question it calls for a legal

[5:03:23] conclusion about the burden of

[5:03:24] proof.

[5:03:26] >> opc: let's go to 400 of your

[5:03:34] testimony please.

[5:03:43] 400?

[5:03:45] I think that is in her direct

[5:03:46] testimony I'm sorry it is

[5:04:11] rebuttal testimony.

[5:04:12] On line number 10 dc where

[5:04:18] you'll fill testimony says MR.

[5:04:20] Colin has presented no evidence

[5:04:28] that denying cost recovery of

[5:04:30] the lt/ip of the element of the

[5:04:32] company total compensation

[5:04:33] program will not harm the

[5:04:35] company's ability to attract

[5:04:37] and retain executive team

[5:04:41] members were responsible for

[5:04:42] procuring the company's needs

[5:04:44] and obligation to its customers

[5:04:45] to see that.

[5:04:46] >> Witness: do.

[5:04:48] >> opc: are you not saying that

[5:04:52] it is MR. Collins burden of

[5:04:54] approving the lack of harm.

[5:04:56] >> I'm going to object she's

[5:05:01] just sitting what she things

[5:05:03] but the evidence is she's not

[5:05:04] making a

[5:05:05] comment in the burden

[5:05:07] prove that a legal concept and

[5:05:08] the org lawyers can argue about

[5:05:09] that in the brief.

[5:05:11] >> I will look over to

[5:05:11] my

[5:05:11] advisor.

[5:05:13] >> I think we need to let.

[5:05:17] [Listing names] Find

[5:05:17] .

[5:05:18] >> opc: this testimony

[5:05:21] literally says burden to

[5:05:24] demonstrate on climax.

[5:05:28] [Unclear audio].

[5:05:29] I'm not asking for legal

[5:05:37] conclusion this is literally

[5:05:38] what her testimony is.

[5:05:40] >> I don't think he is reading

[5:05:41] that correctly it says MR.

[5:05:43] Colin has presented no evidence

[5:05:45] it is not same it is his burden

[5:05:47] to present it. It says he is

[5:05:48] not presented it.

[5:05:50] There is a difference.

[5:05:52] But she can answer the question

[5:05:57] I will withdraw the objection.

[5:05:58] >> Witness: can you repeat the

[5:06:00] question of what time

[5:06:01] .

[5:06:02] >> opc: are you saying is MR.

[5:06:03] Colin response ability to

[5:06:04] demonstrate to this commission

[5:06:08] the lack of harm when he

[5:06:11] testifies that the shareholders

[5:06:19] should shoulder the cost of

[5:06:20] long-term compensation?

[5:06:22] >> Witness: no, what I would

[5:06:24] ask the commissioners to

[5:06:36] consider we are targeting

[5:06:37] market median for reasons we

[5:06:39] need to balance the ability to

[5:06:41] attract and retain our senior

[5:06:42] leaders with some cost putting

[5:06:45] say I do feel like the mercer

[5:06:46] data shows us what we need to

[5:06:47] be competitive especially in

[5:06:49] the tampa bay area is an

[5:06:50] extremely

[5:06:51] competitive job

[5:06:51] market.

[5:06:53] In order to retain our current

[5:06:55] leaders and attract new ones is

[5:06:57] important part is part of doing

[5:06:59] business as part of our total

[5:07:00] competition strategy.

[5:07:02] >> opc: would you agree that.

[5:07:04] [Listing names] The senior

[5:07:05] leadership of tampa electric

[5:07:07] company are provided incentives

[5:07:09] to increase rate base and cash

[5:07:11] flow in order to help emera

[5:07:12] earnings-per-share and stock

[5:07:15] price?

[5:07:18] >> Witness: that is one element

[5:07:20] of our overall balance

[5:07:24] financial goals.

[5:07:25] >> opc: you came to emera from

[5:07:28] another company you did not

[5:07:31] come because the incentive

[5:07:32] compensation tampa electric

[5:07:34] company was better than what

[5:07:42] you had with your then current

[5:07:43] employer is that correct?

[5:07:45] >> Witness: that is correct.

[5:07:47] >> opc: I have no further

[5:07:48] questions thank you.

[5:07:49] >> Mike La Rosa,CHAIRMAN:

[5:07:51] florida rising.

[5:07:52] >> thank you MR. CHAIRMAN we

[5:07:54] are one confidential exhibit to

[5:07:59] head out for this witness.

[5:08:01] >> Mike La Rosa,CHAIRMAN: go

[5:08:24] ahead and do that.

[5:08:26] >> Florida Rising,Inc.: I think

[5:08:36] MR. CHAIRMAN can we get

[5:08:36] started.

[5:08:38] > Mike La

[5:08:39] Rosa,CHAIRMAN: yes go ahead.

[5:08:42] >> Florida Rising,Inc.: before

[5:08:44] we get to that document had

[5:08:46] questions on non-confidential

[5:08:48] documents. If I can direct your

[5:08:49] attention to fl all b

[5:08:49] 197 this

[5:08:51] is gonna be MR. Kamber f 3.3 b

[5:08:56] 6487.

[5:08:58] This document shows the board

[5:08:59] expenses that teco customers

[5:09:04] are responsible for.

[5:09:05] >> Witness: guess.

[5:09:07] >> Florida Rising,Inc.: joe's

[5:09:08] for 2023 that amount was 573

[5:09:16] $507 for teco board and 189,006

[5:09:18] earned 7004 emera support for

[5:09:22] total 673,000.

[5:09:26] >> Witness: I see that.

[5:09:28] >> Florida Rising,Inc.: next I

[5:09:30] would like to direct your

[5:09:32] attention to exhibit f ll b

[5:09:32] the

[5:09:34] ninth is a webmaster number.

[5:09:49] [Listing names].

[5:09:53] This table is an interrogatory

[5:09:54] answer providing the estimated

[5:09:56] cost of the short-term

[5:09:58] incentive plan and the

[5:10:00] long-term incentive plan in the

[5:10:00] 2025 test year.

[5:10:01] >> Witness: yes.

[5:10:13] >> Florida Rising,Inc.: the

[5:10:15] long-term incentive plan is a

[5:10:17] little bit over $6.2 million

[5:10:18] that is attributed to teco?

[5:10:19] >> Witness:

[5:10:19] correct.

[5:10:22] >> Florida Rising,Inc.: the

[5:10:24] short-term incentive plan would

[5:10:25] be about 26.5 million.

[5:10:29] >> Witness: that is correct.

[5:10:31] >> Florida Rising,Inc.: keep in

[5:10:33] mind as we go to f ll b

[5:10:33] 101

[5:10:37] this will be MR. Number f-3

[5:10:37] .2 b

[5:10:38] 31.2 b

[5:10:55] 3126.

[5:11:04] This you see this interrogatory

[5:11:05] answer at the bottom.

[5:11:06] >> Witness: yes.

[5:11:09] >> Florida Rising,Inc.: this

[5:11:11] includes similar data but also

[5:11:12] includes seconded employee

[5:11:13] expense is that correct.

[5:11:13] >>

[5:11:15] Witness: that would be

[5:11:16] counted employee expense.

[5:11:19] >> Florida Rising,Inc.: what is

[5:11:26] a seconded employee

[5:11:27] .

[5:11:28] >> Witness: that is a employee

[5:11:30] from another country say canada

[5:11:32] working in the united states.

[5:11:34] > Florida Rising,Inc.: once

[5:11:35] include that those numbers go

[5:11:37] up a bit for short-term

[5:11:38] incentive and long-term

[5:11:40] incentive cost attributable to

[5:11:41] teco customers?

[5:11:43] >> Witness: they are working on

[5:11:45] tampa electric business so yes.

[5:11:47] >> Florida Rising,Inc.: long

[5:11:48] term incentive plan is

[5:11:50] administered through the emera

[5:11:51] performance share unit and it

[5:11:53] emera restricted share unit is

[5:11:54] the right be 13 yes.

[5:11:55] >> Florida

[5:11:57] Rising,Inc.: that

[5:11:58] refers to unit equivalent value

[5:12:00] of eight emera common share?

[5:12:01] >> Witness: that is correct.

[5:12:04] >> Florida Rising,Inc.: so it

[5:12:05] cannot share values affect the

[5:12:07] share price of the psu and rcu

[5:12:07] .

[5:12:08] >> Witness: truck.

[5:12:10] >> Commissioner: teco provides

[5:12:12] term incentive plan composition

[5:12:14] let me direct you to f ll b

[5:12:14] 93

[5:12:36] this will be f 3.1-2915 this is

[5:12:38] another interrogatory answer

[5:12:40] regarding the long-term

[5:12:40] incentive plan?

[5:12:41] >> Witness: yes.

[5:12:43] >> Florida Rising,Inc.: it

[5:12:48] shows that long-term incentive

[5:12:50] plans are made available

[5:12:51] predominantly at the director

[5:12:53] and above level at teco?

[5:12:54] >> Witness: does correct.

[5:12:57] >> Florida Rising,Inc.: the

[5:12:58] document referenced earlier if

[5:13:00] we can go to exhibit f ll b

[5:13:00] 53

[5:13:01] this week MR. Number

[5:13:10] f-3-1-1267.

[5:13:18] This is going to be one of the

[5:13:20] mercer benchmark survey data

[5:13:22] that you referenced earlier.

[5:13:24] >> Witness: that is correct.

[5:13:26] >> Florida Rising,Inc.: it

[5:13:27] shows that 53% of the companies

[5:13:29] in the survey do not offer

[5:13:31] long-term incentive plans?

[5:13:32] >> Witness: what I would call

[5:13:39] your attention to is under the

[5:13:40] long-term incentive eligibility

[5:13:42] that 66% of executives are

[5:13:44] offered long-term incentive

[5:13:46] that is really important part.

[5:13:48] What I would really ask for

[5:13:50] consideration is this lti

[5:13:59] therapy is a small part of the

[5:14:01] total composition strategy that

[5:14:03] is targeted at the market

[5:14:05] median that means is half the

[5:14:06] companies that more than we do

[5:14:08] in half of the companies pay

[5:14:10] less and we feel strongly that

[5:14:11] this market median is born it

[5:14:13] will be able to attract and

[5:14:14] retain the talent we need to

[5:14:15] serve our customers.

[5:14:18] >> Florida Rising,Inc.:

[5:14:19] directing your attention back

[5:14:21] to my question the survey

[5:14:23] indicates of the 3220

[5:14:25] organizations surveyed 53% do

[5:14:26] not operate any long-term

[5:14:27] incentive plans?

[5:14:28] >> Witness: does correct.

[5:14:31] >> Florida Rising,Inc.: if I

[5:14:32] could direct your attention to

[5:14:34] f ll-200 this will be MR.

[5:14:34] Number f-3 b

[5:14:44] 6641.

[5:14:51] This is going to be the

[5:14:52] equivalent survey for

[5:14:54] short-term incentive plan.

[5:14:55] >> Witness: does correct.

[5:14:58] >> Florida Rising,Inc.:

[5:14:59] 'ssurvey showed for

[5:15:00] short-term

[5:15:01] incentive plan that 80% of

[5:15:03] companies offer those.

[5:15:04] >> Witness: that is correct.

[5:15:07] >> Florida Rising,Inc.: if I

[5:15:09] get next direct your attention

[5:15:11] to f ll-269 that is master

[5:15:14] number f-3-five f-3-5-2451

[5:15:34] f-3-5-24515 this is a historic

[5:15:36] comparison of the short-term

[5:15:38] incentive budget for actuals

[5:15:46] for teco?

[5:15:47] >> Witness: correct.

[5:15:50] >> Florida Rising,Inc.: in 2023

[5:15:50] the budget was

[5:15:51] 26.1 million?

[5:15:52] >> Witness: yes.

[5:15:55] >> Florida Rising,Inc.: the

[5:15:55] actual for that

[5:15:57] year was 24.9

[5:15:57] million.

[5:15:59] >> Witness: that is correct.

[5:16:02] >> Florida Rising,Inc.: then

[5:16:04] teco's 2024 budget is $27.2

[5:16:06] million

[5:16:06] .

[5:16:07] >> Witness: that is correct.

[5:16:09] What I might add that we

[5:16:12] budgeted we are going to

[5:16:13] achieve target that is more of

[5:16:19] a accounting budgeting process

[5:16:21] then whatever we actually

[5:16:22] achieve that is what is paid

[5:16:22] out.

[5:16:26] That is why the discrepancy.

[5:16:28] >> Florida Rising,Inc.: if I

[5:16:30] can next direct your attention

[5:16:31] to f ll-101 this will be

[5:16:33] master number f-3-two-

[5:16:55] f-3-2-3124.

[5:16:56] This shows the number of

[5:16:57] employees eligible to receive

[5:17:00] incentive compensation.

[5:17:01] >> Witness: yes that is

[5:17:03] correct.

[5:17:06] >> Florida Rising,Inc.: and

[5:17:13] 2023 there were 722 employees

[5:17:14] that were eligible for the

[5:17:16] performance sharing program for

[5:17:17] union employees

[5:17:17] .

[5:17:17] >> Witness: yes.

[5:17:20] >> Florida

[5:17:26] Rising,Inc.: then there was

[5:17:27] 1860 eligible for the

[5:17:28] short-term incentive plan.

[5:17:30] >> Witness: that is correct.

[5:17:33] >> Florida Rising,Inc.: then

[5:17:35] went 24 were eligible for both

[5:17:36] long-term and short-term.

[5:17:37] >> Witness: yes.

[5:17:40] >> Florida Rising,Inc.: is a

[5:17:41] total of 2000 1006 employees

[5:17:43] eligible for incentive

[5:17:43] composition.

[5:17:45] >> Witness: what you have there

[5:17:47] is employees that were started

[5:17:49] the year then they left they

[5:17:50] might have been retired you

[5:17:55] might have some people know

[5:17:57] employees people or employees

[5:17:59] were there to get in than they

[5:17:59] (It's a combination.

[5:18:02] >> Florida Rising,Inc.: that's

[5:18:02] the right rate.

[5:18:04] >> Witness: visitors

[5:18:05] .

[5:18:07] >> Florida Rising,Inc.: in 2023

[5:18:07] only 40 teco

[5:18:09] employees did not

[5:18:10] receive incentive composition.

[5:18:12] >> Witness: that is correct

[5:18:14] spacing in the group of 40

[5:18:16] include business operation

[5:18:17] competitive student interns

[5:18:20] employs a voluntary resign

[5:18:22] before payout of the incentive

[5:18:24] composition and employees

[5:18:25] received a final performance

[5:18:27] review rating of it does not

[5:18:29] meet expectations or on a step

[5:18:31] of discipline during the

[5:18:32] performance plan year.

[5:18:33] >> Witness: tells

[5:18:34] correct.

[5:18:36] >> Florida Rising,Inc.: is not

[5:18:39] like I listed a bunch each one

[5:18:41] of those categories had people

[5:18:41] in it.

[5:18:43] >> Witness: the totality of

[5:18:43] that yes.

[5:18:45] >> Florida Rising,Inc.: if I

[5:18:47] can next direct your attention

[5:18:49] to fll-193 this will be master

[5:18:49] number

[5:19:11] f-3.3-3-633.

[5:19:13] This spreadsheet shows the

[5:19:14] comparison of the budget and

[5:19:16] actual for long-term incentive

[5:19:18] versus short-term incentive for

[5:19:20] 2020-2023.

[5:19:27] >> Witness: yes.

[5:19:29] >> Florida Rising,Inc.: looking

[5:19:31] at the actual for range ranges

[5:19:32] from 23.5 million-29.5

[5:19:38] million.

[5:19:42] >> Witness: that is correct.

[5:19:44] >> Florida Rising,Inc.: if I

[5:19:45] can next direct your attention

[5:19:47] to fll when and six this will

[5:19:49] be master number f-3

[5:20:02] .3-6485.

[5:20:04] This would show the total test

[5:20:07] your budget for both short-term

[5:20:09] incentive plan and long-term

[5:20:14] incentive plan that is

[5:20:24] attributable to teco the final

[5:20:25] expense on the

[5:20:26] general ledger.

[5:20:27] >> Witness: that is correct.

[5:20:30] >> Florida Rising,Inc.: if you

[5:20:31] add those numbers together

[5:20:33] there would be a little over

[5:20:34] $34 million budgeted.

[5:20:36] >> Witness: yes stp at target.

[5:20:38] >> Florida Rising,Inc.: if I

[5:20:39] can next direct your attention

[5:20:41] to fll-89 this will be master

[5:20:54] number f-3-one-1.23-eight.

[5:20:56] This was an interrogatory

[5:21:00] question regarding the amount

[5:21:02] of short-term and long-term

[5:21:11] incentive program cost that

[5:21:12] shareholders were responsible

[5:21:13] for?

[5:21:14] >> Witness: yes.

[5:21:16] >> Florida Rising,Inc.: it

[5:21:17] indicates that teco cannot

[5:21:19] calculate a precise amount

[5:21:20] because the actual amounts and

[5:21:22] the amount used to establish

[5:21:25] the revenue requirements MAY

[5:21:25] differ?

[5:21:27] >> Witness: I don't actually

[5:21:29] see that where are you reading

[5:21:38] that?

[5:21:40] >> Florida Rising,Inc.: I'm

[5:21:42] looking at the second left

[5:21:46] sentence after each because the

[5:21:48] shelter is impacted by the

[5:21:49] difference between actual

[5:21:51] amount and the amount used to

[5:21:57] establish revenue requirements

[5:21:59] in the prior rate case do see

[5:21:59] that?

[5:22:01] >> Witness: I do I don't think

[5:22:02] that was the question maybe you

[5:22:05] can repeat the question.

[5:22:07] >> Florida Rising,Inc.: let me

[5:22:09] ask in a different way what I'm

[5:22:10] trying to get up if the actual

[5:22:12] amount the amount used to

[5:22:14] establish revenue requirements

[5:22:15] of the same shareholders will

[5:22:18] not be impacted by short-term

[5:22:19] incentive program long-term

[5:22:21] incentive program cost better

[5:22:22] in the past year as part of

[5:22:23] this rate case?

[5:22:25] >> Witness: believe that to be

[5:22:27] true I think is a good question

[5:22:28] to direct to.

[5:22:29] [Listing names].

[5:22:31] >> Florida Rising,Inc.: if I

[5:22:33] can next direct your attention

[5:22:33] to

[5:22:35] fll-240 this will be master

[5:22:53] number f-3.4-1482 if I can

[5:22:55] direct your attention within

[5:22:57] this document to master number

[5:23:00] f-3

[5:23:12] .4-14971.

[5:23:13] >> Witness: this is it

[5:23:14] sideways.

[5:23:16] >> Florida Rising,Inc.: there

[5:23:18] should be a rotate right

[5:23:19] feature.

[5:23:20] [Laughter].

[5:23:23] >> Witness: thank you

[5:23:23] .

[5:23:25] >> teco: what is that I cannot

[5:23:30] read it.

[5:23:31] The number. The exhibit

[5:23:31] number?

[5:23:34] >> Florida Rising,Inc.: this is

[5:23:43] exhibit fll-240 I have the cll

[5:23:43] number here.

[5:23:48] 700.

[5:23:49] >> teco: thank you.

[5:23:59] >> Florida

[5:24:00] Rising,Inc.: this

[5:24:01] is the 2023

[5:24:02] corporate scorecard.

[5:24:03] >> teco Witness: that is

[5:24:08] correct what is the purpose of

[5:24:09] the corporate scorecard.

[5:24:11] >> teco Witness: I'm so glad

[5:24:13] you asked the balance scorecard

[5:24:14] really allows tampa electric

[5:24:19] employees and that is employees

[5:24:20] are managers and senior leaders

[5:24:23] to focus on all the different

[5:24:24] priorities that we need to

[5:24:27] focus on in a year. It is

[5:24:28] balanced because has the

[5:24:30] different categories called

[5:24:33] out.

[5:24:34] It mobilizes and focuses people

[5:24:36] on the things that are going to

[5:24:38] matter most for customers that

[5:24:41] your.

[5:24:43] >> Florida Rising,Inc.: this

[5:24:44] indicates if tampa electric

[5:24:45] does not meet their net

[5:24:46] income

[5:24:48] goal the entire scorecard

[5:24:50] cannot pay out more than the

[5:24:50] target.

[5:24:51] >> teco Witness: that is

[5:24:53] correct spacing measure with

[5:24:55] ice wheat and the scorecard is

[5:24:56] the tampa electric net income

[5:24:56] measure.

[5:24:58] >> teco Witness: or financial

[5:25:00] goals or 35% of our balanced

[5:25:02] scorecard but there is balance

[5:25:03] with the other priorities as

[5:25:04] well.

[5:25:05] >> Florida Rising,Inc.: does

[5:25:07] the higher weight and any other

[5:25:08] measure on there.

[5:25:10] >> teco Witness: that is

[5:25:11] correct.

[5:25:13] >> Florida Rising,Inc.: next I

[5:25:14] like to direct your question to

[5:25:14] fll b

[5:25:17] -298 that is the

[5:25:32] confidential.

[5:25:33] Are you familiar with this

[5:25:34] document.

[5:25:35] > teco Witness:

[5:25:36] actually this did not come from

[5:25:37] yes.

[5:25:39] The executive compensation

[5:25:40] strategy

[5:25:41] , is done at the emera

[5:25:48] level.

[5:25:50] >> Florida Rising,Inc.: you are

[5:25:52] the witness responsible for

[5:25:54] executive composition for teco

[5:25:56] in this case. The information

[5:25:58] that is not highlighted that is

[5:25:59] not confidential?

[5:25:59] >> teco Witness:

[5:26:01] the information

[5:26:01] that is.

[5:26:04] >> Florida Rising,Inc.: not

[5:26:05] highlighted is not

[5:26:05] confidential?

[5:26:09] Is that right?

[5:26:11] >> teco Attorney: are we

[5:26:15] getting ready to talk about fll

[5:26:24] 290 8c

[5:26:24] .

[5:26:26] >> teco Attorney: I'm going to

[5:26:28] object. This is detailed

[5:26:30] compensation information for

[5:26:32] individual employees. I'm not

[5:26:33] sure why it is relevant.

[5:26:35] Were helpful to the commission

[5:26:36] in this case.

[5:26:38] >> Florida Rising,Inc.: I

[5:26:39] believe teco are seeking

[5:26:41] recovery of these costs from

[5:26:42] the ratepayers and certainly

[5:26:44] those costs are reasonable or

[5:26:46] not reasonable it is certainly

[5:26:48] an issue in this case I

[5:26:48] believe.

[5:26:50] [Listing names]'s testimony is

[5:26:54] it is reasonable we think the

[5:26:54] numbers help can speak for

[5:26:56] themselves as to their

[5:26:58] reasonableness. We think there

[5:26:59] opposition is highly relevant

[5:27:00] to this case.

[5:27:02] >> teco Attorney: I just looked

[5:27:04] at your position in your

[5:27:06] prehearing statement you are

[5:27:07] suggesting that this is issue

[5:27:08] 53.

[5:27:09] Your position is that salaries

[5:27:11] and benefits expense should be

[5:27:13] produced for incentive

[5:27:14] compensation and to remove ds

[5:27:16] you are. But there is no

[5:27:17] allegation in your position

[5:27:19] that the general level of

[5:27:20] composition is inappropriate?

[5:27:22] >> Florida Rising,Inc.:

[5:27:24] >> teco Attorney: don't see how

[5:27:26] going through individual

[5:27:27] composition amounts for

[5:27:29] individual employees has

[5:27:30] anything to do with the

[5:27:33] positions you have taken in the

[5:27:34] prehearing order.

[5:27:36] >> Florida Rising,Inc.: unless

[5:27:38] I'm mistaken I don't get is

[5:27:40] confidential to state that

[5:27:43] short-term incentive and

[5:27:44] long-term incentive plan

[5:27:45] compositions within this

[5:27:47] document and certainly goes

[5:27:55] towards total composition.

[5:28:00] The objection is relevant can

[5:28:07] we limit the scope.

[5:28:08] >> MR. CHAIRMAN can have a

[5:28:11] quick conversation with your

[5:28:13] lawyers work this case

[5:28:13] .

[5:28:15] >> Mike La Rosa,CHAIRMAN: let's

[5:33:09] take three minute break.

[5:35:57] >> Mike La Rosa,CHAIRMAN:

[5:36:00] discussion with my advisor I

[5:36:05] will take it over to her to

[5:36:07] talk about the legal position.

[5:36:09] >> thank you MR. CHAIRMAN and

[5:36:12] thank you for letting us take a

[5:36:14] break to discuss this

[5:36:15] internally. I recognize that

[5:36:21] this is a highly sensitive area

[5:36:23] that we are doubling into now

[5:36:24] that MR. Marshall has brought

[5:36:26] us to. When I look at MR.

[5:36:29] Marshall's position and the

[5:36:30] prehearing order to me he is

[5:36:33] made an issue of the incentive

[5:36:34] compensation. As I understand

[5:36:36] this exhibit it addresses

[5:36:37] incentive compensation.

[5:36:39] I think it is relevant to

[5:36:44] discuss I think we need to talk

[5:36:46] about maybe a little bit about

[5:36:48] how to go about discussing it.

[5:36:50] This information is it has been

[5:36:51] presented to us as highly

[5:36:57] granular.

[5:36:58] Meaning there is persons names

[5:37:02] and specific numbers attached

[5:37:04] to each. I'm not sure from the

[5:37:05] company's perspective the names

[5:37:13] here are confidential because

[5:37:15] the way our process works

[5:37:17] usually it is the information

[5:37:19] that is highlighted in yellow

[5:37:20] that is confidential I'm

[5:37:22] confused about whether it is

[5:37:24] all information on the page or

[5:37:25] certain information on the

[5:37:26] page?

[5:37:27] Maybe if MR. Marshall can

[5:37:29] direct this question on a more

[5:37:31] global level instead of of a

[5:37:34] with a particular level.

[5:37:35] >> Florida Rising: I think that

[5:37:37] is the right approach to this

[5:37:39] document.

[5:37:41] We certainly believe it is

[5:37:42] relevant and within the scope

[5:37:44] of our position in the

[5:37:50] prehearing statement box.

[5:37:52] >> Mike La Rosa,CHAIRMAN: I

[5:37:53] want to make sure we clarify

[5:37:55] but it's confidential what is

[5:37:57] not confidential I'm confused

[5:37:58] about what is and what is not.

[5:38:00] >> teco Attorney: all the

[5:38:02] numbers on these pages are

[5:38:02] confidential.

[5:38:05] this is the specific employee

[5:38:06] compensation for specific

[5:38:08] people. I guess the point I'm

[5:38:09] trying to make is you don't

[5:38:11] need this information to

[5:38:12] calculate the adjustment we

[5:38:15] have just gone through about

[5:38:17] maybe half a dozen or one dozen

[5:38:18] documents that show up with the

[5:38:20] total amount of the

[5:38:21] compensation is. And the basis

[5:38:23] for their adjustment and what

[5:38:25] I'm trying to say is that this

[5:38:27] detailed information is not

[5:38:28] needed to calculate that

[5:38:29] adjustment.

[5:38:30] Or to prove their point. We

[5:38:32] don't think it is really

[5:38:34] probative or as much to the

[5:38:35] discussion except that it is

[5:38:37] really interesting to find out

[5:38:39] how much individual employees

[5:38:43] might be making. I just don't

[5:38:45] think that is appropriate.

[5:38:46] >> Florida Rising: if I MAY

[5:38:48] respond to that MR. CHAIRMAN if

[5:38:50] it was $10 million estate

[5:38:51] spread across 1 million

[5:38:55] employees at $10 each that's a

[5:38:56] very different scenario than

[5:38:58] $10 million being spread over

[5:39:02] one employee. The amount going

[5:39:03] for these top executives we

[5:39:05] think is a relevant issue as to

[5:39:07] whether the cost that are being

[5:39:09] charged to teco's customers are

[5:39:09] fair.

[5:39:10] Hat is what this

[5:39:13] document shows.

[5:39:14] >> teco Attorney: he is not

[5:39:17] offering any evidence that it

[5:39:19] is fair he just wants to talk

[5:39:20] about the amounts.

[5:39:25] There is no competing evidence

[5:39:27] that this is not the right

[5:39:29] answer. He just wants to talk

[5:39:30] about the amounts.

[5:39:31] >> Florida Rising: the amounts

[5:39:33] go to whether it is the right

[5:39:33] amount.

[5:39:37] >> teco Attorney: he is not

[5:39:39] contesting the amount with

[5:39:40] evidence he just wants to make

[5:39:42] a big deal out of the numbers.

[5:39:44] I just think it is

[5:39:45] inappropriate not needed for

[5:39:46] the calculation.

[5:39:48] That is our objection.

[5:39:50] >> Mike La Rosa,CHAIRMAN: I

[5:39:51] understand where both sides

[5:39:51] are.

[5:39:54] I will go back to my advisor.

[5:39:56] Straight-line looks to be on

[5:39:56] highlighted.

[5:39:57] That is probably what concerns

[5:40:00] me.

[5:40:02] I don't understand what is then

[5:40:03] confidential?

[5:40:04] From that point?

[5:40:10] >> teco Attorney: the

[5:40:11] information we claim is

[5:40:13] confidential and we put in our

[5:40:14] request for confidential

[5:40:16] classification is all the

[5:40:17] individual compensation amount

[5:40:19] shown on here for all of the

[5:40:22] individual employees.

[5:40:23] Everything that is highlighted

[5:40:25] in yellow is confidential.

[5:40:27] >> the first line for each

[5:40:28] employee where it said straight

[5:40:30] those are not highlighted is

[5:40:31] that information.

[5:40:33] >> teco Attorney: that has been

[5:40:35] disclosed in forum number one.

[5:40:36] >> MR. CHAIRMAN my recognition

[5:40:47] is understand there is grave

[5:40:49] concern on the part of the

[5:40:51] company with respect to this

[5:40:53] exhibit. I appreciate that. But

[5:40:55] MR. Marshall has not been able

[5:40:56] to ask a question. Maybe a

[5:40:58] better approach would be to

[5:41:00] have MR. Marshall as his

[5:41:02] question then we can see if

[5:41:04] there is a specific objection

[5:41:05] to the question because we

[5:41:07] don't know quite frankly how he

[5:41:08] plans on using it.

[5:41:09] I think we

[5:41:09] are all

[5:41:10] sensitive now to.

[5:41:12] >> teco Attorney: I'm sorry I

[5:41:13] was just following the

[5:41:15] instructions I got yesterday to

[5:41:17] announce in objection early.

[5:41:19] >> duly noted I apologize.

[5:41:24] [Laughter].

[5:41:25] I'm just trying to play along

[5:41:26] here.

[5:41:27] >> Florida Rising: MR. CHAIRMAN

[5:41:28] if I MAY have a moment

[5:41:29] to confer

[5:41:31] with MR. Whelan, questions to

[5:41:33] see if he thinks they are

[5:41:34] confidential or problematic.

[5:41:37] >> Mike La Rosa,CHAIRMAN: if

[5:41:39] that helps to be smoother

[5:42:14] absolutely.

[5:42:15] >> Florida Rising: thank you

[5:42:17] MR. CHAIRMAN MAY I proceed.

[5:42:19] >> teco Attorney: understand he

[5:42:21] will ask very general question

[5:42:23] will not identify specific

[5:42:24] people. But he does want this

[5:42:25] in the record.

[5:42:27] As long as we not going to talk

[5:42:29] about specific people in at the

[5:42:30] hearing I guess we will be

[5:42:30] okay.

[5:42:33] >> Mike La Rosa,CHAIRMAN: let's

[5:42:33] proceed.

[5:42:35] >> Florida Rising: thank you

[5:42:38] MR. CHAIRMAN this document does

[5:42:40] contain become position of top

[5:42:41] teco executives you

[5:42:41] added up is

[5:42:43] in the millions of dollars.

[5:42:44] >> teco Witness: yes.

[5:42:46] >> Florida Rising: in many

[5:42:48] cases the bonus another

[5:42:49] compensation exceed the base

[5:42:50] salary depicted.

[5:42:52] >> teco Witness: would have to

[5:42:54] look line by line before I

[5:42:54] confirm that.

[5:42:56] >> teco Witness: would you

[5:42:58] accept that subject object

[5:42:58] .

[5:43:00] >> Florida Rising: would do

[5:43:02] except in many cases long-term

[5:43:04] incentive compensation exceed

[5:43:06] the short-term extent of

[5:43:07] competition for those

[5:43:08] executives.

[5:43:09] >> teco Witness: yes that is

[5:43:11] based on compensation

[5:43:12] strategies to keep a long-term

[5:43:13] focus for customers.

[5:43:15] >> Florida Rising: thank you

[5:43:17] that's all my questions MR.

[5:43:17] CHAIRMAN.

[5:43:20] >> Mike La Rosa,CHAIRMAN:

[5:43:21] [Listing names] Sierra club.

[5:43:27] >> no questions.

[5:43:32] Walmart

[5:43:32] .

[5:43:34] >> no questions

[5:43:34] .

[5:43:36] >> Mike La Rosa,CHAIRMAN:

[5:43:38] commissioners any questions?

[5:43:39] Seeing no questions teco back

[5:43:43] in your hands for redirect

[5:43:43] .

[5:43:45] >> teco Attorney: think you

[5:43:47] want to thank you for taking

[5:43:49] the time to be careful about

[5:43:49] that.

[5:43:49] I

[5:43:51] appreciated very much for the

[5:43:53] snack one question.

[5:43:54] [Listing names] You were asked

[5:43:56] about whether the company

[5:43:57] executives were being

[5:44:01] incentivized to grow rate base

[5:44:04] do you remember that?

[5:44:06] >> teco Witness: yes.

[5:44:13] >> teco Attorney: you answered

[5:44:15] in terms the balanced scorecard

[5:44:16] is that correct.

[5:44:17] >> teco Witness: that is

[5:44:18] correct.

[5:44:19] >> teco Attorney: that goal is

[5:44:21] net income is not rate based.

[5:44:23] >> teco Witness: yes it is

[5:44:23] answered incorrectly.

[5:44:25] >> teco Attorney: that is all

[5:44:26] of our questions.

[5:44:28] >> Mike La Rosa,CHAIRMAN: let's

[5:44:29] move to the exhibits.

[5:44:31] >> teco Attorney: tampa

[5:44:32] electric would move exhibit

[5:44:33] number 24).

[5:44:34] > Mike La

[5:44:35] Rosa,CHAIRMAN: any objections?

[5:44:37] Seeing no objections show it

[5:44:38] entered into the record.

[5:44:45] Other exhibits?

[5:44:45] >> 267.

[5:44:47] >> Mike La Rosa,CHAIRMAN: any

[5:44:48] objection seeing no let's show

[5:44:50] that entered into the record.

[5:44:52] >> Florida Rising: we have a

[5:44:53] bit of a series.

[5:44:58] Exhibits 513, 549, 553, 561,

[5:45:09] 653, 656, 657, 660, 700, 729,

[5:45:11] and it 758,

[5:45:13] >> Mike La Rosa,CHAIRMAN: any

[5:45:17] objection

[5:45:17] .

[5:45:19] >> teco Attorney: we continue

[5:45:21] to object to the detailed

[5:45:23] compensation exhibit whatever

[5:45:24] that one is.

[5:45:25] 770.

[5:45:26] 16 758 that would be the last

[5:45:33] one.

[5:45:34] >> teco Attorney: understand

[5:45:36] that that has been ruled on but

[5:45:38] I will continue to object.

[5:45:40] >> Mike La Rosa,CHAIRMAN: let's

[5:45:42] show it into the record.

[5:45:43] Any other exhibits.

[5:45:44] Seeing none

[5:45:44] .

[5:45:45] [Listing names] You are

[5:45:50] excused.

[5:45:52] I will hand it back over to you

[5:45:53] for your next witness.

[5:45:53] >

[5:45:56] teco Attorney: tampa electric

[5:45:58] calls

[5:45:58] .

[5:46:13] [Listing names] To the stand.

[5:46:15] >> Mike La Rosa,CHAIRMAN: MS.

[5:46:17] Fuentes I don't believe you had

[5:46:19] been administered the oath

[5:46:21] whenever you're ready we will

[5:46:45] do that before you sit down.

[5:46:51] Please raise your right hand.

[5:46:53] do you swear and affirm the

[5:46:54] testimony you are about to give

[5:46:56] will be the truth the whole

[5:46:58] truth and nothing but the

[5:46:58] truth.

[5:46:59] >> teco Witness: I do.

[5:47:02] >> Mike La Rosa,CHAIRMAN: feel

[5:47:03] free to have a seat and get

[5:47:04] settled in.

[5:47:05] Will turn it

[5:47:10] over to teco when you're ready.

[5:47:11] >> teco Attorney: good

[5:47:13] afternoon would you state your

[5:47:16] full name for the record.

[5:47:18] >> Mike La Rosa,CHAIRMAN: moved

[5:47:20] the microphone closer.

[5:47:22] I'm sorry MS. Fuentes.

[5:47:24] >> teco Attorney: who is your

[5:47:30] current employer what is your

[5:47:31] business address.

[5:47:33] >> teco Witness: tampa electric

[5:47:35] company 702 w. Franklin st.,

[5:47:35] tampa, fl.

[5:47:37] >> teco Attorney: did you

[5:47:39] prepare and cause to be filed

[5:47:41] this document in APRIL 2, 2024

[5:47:43] prepared direct testimony

[5:47:55] consisting of 22 pages

[5:47:55] .

[5:47:56] >> teco Witness: his I did.

[5:47:58] >> teco Attorney: did you

[5:47:58] prepare and cause

[5:47:59] to be filed in

[5:48:01] this docket on JULY 2, 2024

[5:48:03] prepare rebuttal testimony

[5:48:04] consisting of 13 pages.

[5:48:06] >> teco Witness: kiss I did.

[5:48:07] >> teco

[5:48:08] Attorney: you have any

[5:48:09] additions or corrections to

[5:48:11] your prepared direct or

[5:48:11] rebuttal.

[5:48:13] >> teco Witness: yes I do.

[5:48:15] >> teco Attorney: do you have

[5:48:16] any additions or corrections to

[5:48:18] your direct or rebuttal

[5:48:18] testimony.

[5:48:19] >> teco Witness: no.

[5:48:20] Speed 11 about.

[5:48:21] >> teco Attorney:

[5:48:22] always

[5:48:24] cultures aggression prepared in

[5:48:26] your direct rebuttal testimony

[5:48:27] would treasures be the same as

[5:48:29] her insurance prepared therein

[5:48:29] .

[5:48:30] >> teco Witness: yes.

[5:48:32] >> Gabriella

[5:48:33] Passidomo,Commissioner: MR.

[5:48:37] CHAIRMAN electric request the

[5:48:37] direct rebuttal testimony be

[5:48:38] entered into the record. MISS

[5:48:40] Point as doom repair

[5:48:40] request be

[5:48:42] filed in your direct testimony

[5:48:44] and exhibits marked lc 1

[5:48:45] consisting of 11 documents.

[5:48:48] >> teco Witness: yes I did.

[5:48:53] >> teco Attorney: did you

[5:48:54] prepare and costly filed

[5:48:55] provisions to document number

[5:48:57] 32 exhibit lc 1 on MAY 21,

[5:48:58] 2024?

[5:48:59] >> teco Witness: yes I did.

[5:48:59] >

[5:49:00] teco Attorney: did you prepare

[5:49:02] and cause to be filed

[5:49:03] replacement nonconfidential

[5:49:05] pages for mfr schedule f7 and

[5:49:07] f8 on MAY 21, 2024.

[5:49:08] >> teco Witness: yes I did

[5:49:08] .

[5:49:11] >> teco Attorney: to prepare

[5:49:12] and cause be filed rebuttal

[5:49:23] testimony in exhibit marked lc

[5:49:25] 2 consisting seven documents.

[5:49:26] >> teco Witness: yes.

[5:49:28] >> teco Attorney: MR. CHAIRMAN

[5:49:30] logic would note for the record

[5:49:32] that exhibits lc one and lcm to

[5:49:34] have been identified on the cl

[5:49:35] as exhibits 25 and 146.

[5:49:37] MS. Fuentes did you personally

[5:49:39] discover an error on the

[5:49:40] company's answer to

[5:49:41] interrogatory number 177 and

[5:49:43] this 12 set of interrogatories

[5:49:45] as part of the content

[5:49:50] identified as exhibit 212

[5:49:50] .

[5:49:51] >> teco Witness: yes.

[5:49:54] >> teco Attorney: MR. CHAIRMAN

[5:49:55] electric would ask that the

[5:49:57] revised answer which is been

[5:49:59] dissipated to all parties and

[5:50:01] to the commissioners be marked

[5:50:02] and entered into the record.

[5:50:09] >> Mike La Rosa,CHAIRMAN: okay.

[5:50:10] >> I want to note for the

[5:50:12] record commissioners

[5:50:13] interminably that is exhibit

[5:50:23] 838.

[5:50:24] >> teco Attorney: this point as

[5:50:26] we do summarize your prepared

[5:50:29] and direct testimony.

[5:50:31] >> teco Witness: good afternoon

[5:50:33] commissioners. My direct

[5:50:34] testimony explains tampa

[5:50:40] electric's load forecasting

[5:50:41] process in the methodologies

[5:50:43] and assumptions that were used.

[5:50:45] It also describes the load

[5:50:46] forecast used in the companies

[5:50:48] test your budget that supports

[5:50:50] the request for a base rate

[5:50:52] increase. It demonstrates that

[5:50:53] the forecast are appropriate

[5:50:54] and reasonable.

[5:50:56] My rebuttal testimony explains

[5:50:58] by the commission should not

[5:51:03] adopt the office of public

[5:51:05] counsel's proposal as it

[5:51:07] relates to load forecast. Also

[5:51:09] demonstrate that the company's

[5:51:12] projected 2025 2026 and 2027

[5:51:13] retail energy sales forecast

[5:51:15] are appropriate and reasonable.

[5:51:17] This concludes my summary thank

[5:51:18] you.

[5:51:19] >> Gabriella

[5:51:20] Passidomo,Commissioner: tampa

[5:51:22] electric would enter MS.

[5:51:26] Pointers for testimony

[5:51:26] .

[5:51:28] >> opc: good afternoon would

[5:51:29] make sure I get this correct

[5:51:38] new world direct upload

[5:51:40] research and forecasting for

[5:51:41] temper electric.

[5:51:42] >> teco Witness: that's

[5:51:43] correct.

[5:51:44] >> opc: one of the

[5:51:45] many things

[5:51:46] the temple object forecasts is

[5:51:49] their expected energy sales.

[5:51:50] >> teco Witness: yes.

[5:51:51] >> opc: tampa electric use a

[5:51:53] process called econometric is

[5:51:55] physically adjusted and use

[5:51:57] forecasting models to develop

[5:51:57] the forecast.

[5:51:59] >> teco Witness: that is

[5:51:59] correct.

[5:52:01] >> opc: believe you just

[5:52:02] referred to this

[5:52:02] but you're

[5:52:04] worth it opc expert witness

[5:52:06] testimony challenging certain

[5:52:07] aspects of tampa

[5:52:08] electric's

[5:52:08] energy sales.

[5:52:10] >> teco Witness: I am aware

[5:52:11] that brian.

[5:52:12] >> teco Attorney: opc

[5:52:13] challenged out of model

[5:52:14] adjustments

[5:52:15] the temple it took

[5:52:15] me

[5:52:17] to the results of its energy

[5:52:17] sales forecast.

[5:52:19] That is your understanding.

[5:52:21] >> teco Witness: that is my

[5:52:22] understanding.

[5:52:23] >> teco Attorney: if we can go

[5:52:25] to mfr at five which would be

[5:52:27] page the case and number number

[5:52:31] would be j135 police j1325.

[5:52:38] Please. Hopefully that is

[5:52:39] showing up on the screen in

[5:52:45] front of you.

[5:52:46] Do you see it there.

[5:52:47] >> teco Witness: yes.

[5:52:49] >> opc: you might have a copy

[5:52:51] whichever is easier for you to

[5:52:51] look at.

[5:52:53] >> teco Witness: let me go to

[5:53:04] my copy.

[5:53:06] >> teco Attorney: adjustment to

[5:53:07] confirm that this

[5:53:07] page within

[5:53:09] the mfr is one that you

[5:53:10] cosponsored.

[5:53:11] >> teco Witness: yes it is.

[5:53:13] >> teco Attorney: this page is

[5:53:15] where the three out of model

[5:53:17] adjustments that we were just

[5:53:19] discussing are located within

[5:53:26] tampa electric's petition and

[5:53:27] mfr is that accurate.

[5:53:29] >> teco Witness: this is where

[5:53:31] the three separate forecasts

[5:53:32] are we refer to them as

[5:53:34] separate forecast versus an

[5:53:34] adjustment.

[5:53:36] >> teco Attorney: you would

[5:53:38] agree if the commission accepts

[5:53:39] some or all of these

[5:53:41] adjustments the customers bills

[5:53:42] would be higher than they

[5:53:43] otherwise would be without

[5:53:44] the

[5:53:45] adjustment.

[5:53:45] >> teco Witness: no I don't

[5:53:49] agree with that.

[5:53:51] That is just one piece of the

[5:53:54] picture if these were removed

[5:53:58] from the forecast it will have

[5:54:00] an effect on other things as

[5:54:01] well.

[5:54:03] >> opc: ultimately the effect

[5:54:05] that would have another things

[5:54:07] would lead to customers paying

[5:54:10] more than if they were to pay

[5:54:12] without these adjustments do

[5:54:13] agree with that?

[5:54:13] >> teco

[5:54:15] Witness: all other things

[5:54:15] equal. Yes.

[5:54:21] >> opc: if the commission were

[5:54:22] to reject each of these

[5:54:24] adjustments then that would

[5:54:41] result in a reduction of the

[5:54:43] 2025 revenue requirement of $12

[5:54:45] million to 2026 revenue

[5:54:46] requirement of $21 in the 2027

[5:54:47] revenue requirement of $26

[5:54:48] million?

[5:54:49] Is that correct?

[5:54:50] >> teco Witness: those are his

[5:54:51] estimates yes.

[5:54:53] >> opc: you have any reason to

[5:54:55] believe that those numbers are

[5:54:57] inaccurate if the commission

[5:54:58] were to reject those

[5:54:59] adjustments.

[5:55:01] >> teco Witness: yes I disagree

[5:55:01] with.

[5:55:03] [Listing names]'s analysis.

[5:55:04] Strongly disagree.

[5:55:05] Those adjustments that he is

[5:55:07] referring to are actually what

[5:55:09] we call exertion is forecasts

[5:55:10] there are three forecasts that

[5:55:12] would be very careless of the

[5:55:14] company if we left them out of

[5:55:15] our process.

[5:55:17] The conservation savings is a

[5:55:18] piece that we have been

[5:55:20] adjusting our forecast by for

[5:55:21] probably 30 years.

[5:55:23] It's been approved in every

[5:55:25] rate proceeding the electric

[5:55:26] vehicle adjustment he is

[5:55:28] wanting to exclude in the

[5:55:30] rooftop solar forecast that he

[5:55:31] is wanting to exclude have also

[5:55:33] been in all of our forecasts

[5:55:34] for 10 years.

[5:55:36] They have been approved in

[5:55:37] prior rate cases as well. All

[5:55:39] utilities in florida and

[5:55:41] throughout the nation if they

[5:55:47] have the electric vehicles and

[5:55:49] rooftop solar within the

[5:55:51] service territory they have to

[5:55:52] forecast them. There is

[5:55:54] absolutely no reason to exclude

[5:55:55] them from the forecasted

[5:55:56] results.

[5:55:59] >> opc: understand you disagree

[5:56:00] with.

[5:56:01] [Listing names] But my question

[5:56:03] is the numbers that he has

[5:56:04] associated with the 2025-

[5:56:05] 2026-2027 testers as being the

[5:56:07] amount the revenue requirement

[5:56:09] would be reduced by you dispute

[5:56:11] that those numbers are the

[5:56:12] correct numbers if

[5:56:12] the

[5:56:14] commission were to reject the

[5:56:14] adjustment.

[5:56:16] >> teco Witness: his math is a

[5:56:22] very high level calculation. He

[5:56:23] just takes a composite rate.

[5:56:25] And multiplies it by the energy

[5:56:27] to get to those numbers if it

[5:56:28] was done with the normal

[5:56:30] process using building

[5:56:31] determinants it could be

[5:56:31] different.

[5:56:35] >> opc: I need a

[5:56:37] yes or no do you agree with the

[5:56:39] numbers or do disagree with the

[5:56:39] numbers.

[5:56:41] >> teco Witness: no I don't

[5:56:42] believe there are hundred

[5:56:43] percent accurate.

[5:56:45] >> opc: regarding the eb sales

[5:56:47] adjustment if the eb sales were

[5:56:49] under stated that would have

[5:56:51] implications for the test your

[5:56:53] revenue requirements are

[5:56:54] failing to capture the impact

[5:56:56] that eb growth would have been

[5:56:58] company load is that accurate.

[5:57:04] >> teco Witness: yes.

[5:57:06] The ev sales adjustment relies

[5:57:08] on assumptions regarding future

[5:57:10] penetration levels of ev is

[5:57:14] that correct

[5:57:14] .

[5:57:15] >> teco Witness: yes the ev

[5:57:17] forecast relies on that.

[5:57:18] >> opc: you agree that the

[5:57:19] tampa area

[5:57:20] is one of the fastest

[5:57:22] growing regions in the country

[5:57:24] with one of the fastest growing

[5:57:26] states in the country.

[5:57:27] >> teco Witness: I would agree

[5:57:28] with that.

[5:57:29] >> opc: the company predicts

[5:57:31] customer growth of

[5:57:32] approximately 3%.

[5:57:33] >> teco Witness: no not 3% that

[5:57:40] is too high.

[5:57:42] >> opc: what is the number.

[5:57:43] >> teco Witness: we are

[5:57:45] projecting customer growth

[5:57:47] around 1.8% over the next few

[5:57:48] years over 10 years I believe

[5:57:49] is closer to 1.4%.

[5:57:50] >> opc: would you greet the

[5:57:52] customer growth has been

[5:57:53] significant enough to at least

[5:57:55] partially offset higher

[5:57:56] depreciation and all in them

[5:57:57] expense and net

[5:57:58] income year to

[5:57:58] date.

[5:58:00] >> teco Witness: I don't know

[5:58:00] the

[5:58:02] answer to that they'll be

[5:58:03] best answered by.

[5:58:08] [Listing names].

[5:58:12] >> opc: 2017 is the only time

[5:58:14] the company has reported sales

[5:58:16] decrease in the last decade.

[5:58:16] Correct?

[5:58:18] >> teco Witness: I would have

[5:58:22] to subject to check I will

[5:58:22] agree.

[5:58:27] >> opc: are you familiar with

[5:58:28] the decrease in 2017?

[5:58:30] >> teco Witness: I have to

[5:58:33] refer to the graph.

[5:58:44] >> opc: let me ask you a

[5:58:46] question if you need to refer

[5:58:47] to something let me know. Do

[5:58:49] agree the forecasted sales

[5:58:50] decreased in this case is

[5:58:52] almost 10 times larger than the

[5:58:53] 2017 sales decrease?

[5:58:55] >> teco Witness: the decrease

[5:58:57] in again would have to see some

[5:58:59] numbers to be able to confirm

[5:58:59] that.

[5:59:04] >> opc: with regard to usage

[5:59:11] per customer has that climbed

[5:59:13] by.6% on an annual average

[5:59:15] basis between 2013 and 2023?

[5:59:16] >> teco Witness: yes.

[5:59:19] >> opc: is in this

[5:59:20] significantly less than the

[5:59:21] customers forecasted forecasted

[5:59:23] decrease of 3.9% in 2024?

[5:59:28] >> teco Witness: yes but you

[5:59:29] are comparing apples and

[5:59:31] oranges we are talking about

[5:59:33] our historical average use

[5:59:36] decline really without the

[5:59:38] impacts of whether if you look

[5:59:42] at the forecast for 2024 and

[5:59:43] beyond it is based on normal

[5:59:48] weather.

[5:59:50] Decline your specifically talk

[5:59:52] about is from 2023 which was a

[5:59:54] very hot year. The forecast

[5:59:58] transitions to what is called

[5:59:59] what is based on normal

[6:00:01] weather.

[6:00:03] It is kind of apples to oranges

[6:00:10] comparison.

[6:00:11] I do have in my rebuttal

[6:00:13] testimony graph that

[6:00:14] illustrates this well.

[6:00:16] I think it is in the cel

[6:00:22] exhibit as well 146.

[6:00:23] >> opc: the answer to that

[6:00:25] question is you disagree that

[6:00:30] the.6 decrease between 2023

[6:00:39] and 2023 is significantly less

[6:00:40] then the company's forecasted

[6:00:42] usage per customer decrease of

[6:00:43] 3.0% in 2024.

[6:00:45] >> teco Witness: obviously the

[6:00:47] numbers are accurate but what

[6:00:49] I'm saying is the comparison

[6:00:51] that you are making is really

[6:00:53] apples to oranges comparison.

[6:00:54] >> opc: I'm not sure if you

[6:00:56] were in the room listening but

[6:00:58] if you could try to answer each

[6:00:59] question yes or no and then

[6:01:01] explain if you feel like you

[6:01:01] need to.

[6:01:03] It's important to try to get

[6:01:04] the answer.

[6:01:05] >> teco Witness: yes.

[6:01:09] >> opc: thank you.

[6:01:11] If we could can we go to page 8

[6:01:21] of your rebuttal testimony?

[6:01:22] I don't have the case center

[6:01:30] number here.

[6:01:31] >> teco Witness: okay.

[6:01:37] >> opc: on line 7-10 you

[6:01:39] mentioned load forecasters rely

[6:01:40] on normal or expected whether

[6:01:43] in terms of degrees.

[6:01:43] do see this.

[6:01:46] >> teco Witness: yes I do

[6:01:46] .

[6:01:51] >> opc: could you define what

[6:01:52] the company defines is normal

[6:01:54] or expected whether in terms of

[6:01:55] degree days.

[6:01:57] >> teco Witness: forecaster has

[6:01:58] to rely on some assumptions for

[6:01:59] the future.

[6:02:01] The future whether the

[6:02:03] seasonality throughout the

[6:02:04] year.

[6:02:05] Etc.. Since nobody can really

[6:02:07] project accurately the weather

[6:02:11] that far with the forecasters

[6:02:12] do israelite history.

[6:02:14] In the most common period of

[6:02:16] time to use is the past 20

[6:02:16] years.

[6:02:20] Although florida utilities are

[6:02:21] using 20 years or more I

[6:02:34] believe one might use one

[6:02:36] utility might use 30 years.

[6:02:38] Nobody is using less than 20

[6:02:39] years. What we do is we use a

[6:02:42] 20 year period that represents

[6:02:43] to us what normal weather will

[6:02:45] be and abuse of that in our

[6:02:46] projections.

[6:02:47] >> opc: thank you.

[6:02:49] Not true that the number of

[6:02:50] cooling degree days during the

[6:02:52] years 2015-2023 the past nine

[6:02:54] years is higher than during the

[6:02:55] remainder of the 20 year

[6:02:56] period.

[6:02:58] >> teco Witness: I would agree

[6:02:58] with that.

[6:03:01] >> opc: again by late exhibit

[6:03:02] illustrates that as well that

[6:03:04] is document number six it is

[6:03:08] also cel exhibit 216.

[6:03:10] >> opc: just for the record bc

[6:03:19] that identifying.

[6:03:20] If you could turn to page 10 of

[6:03:22] your rebuttal testimony.

[6:03:30] On

[6:03:32] lines 824 you dispute.

[6:03:33] [Listing names] Conclusion that

[6:03:35] a forecasting model has a

[6:03:36] history of understating energy

[6:03:40] sales productions you state

[6:03:42] that you claim that to assess

[6:03:44] the accuracy and reliability of

[6:03:46] your models it would be more

[6:03:48] reasonable to compare the

[6:03:49] company's prior forecasts to

[6:03:51] whether normalized sales

[6:03:53] whether is that an accurate

[6:03:54] characterization of your

[6:03:55] testimony.

[6:03:56] >> teco Witness: yes it is.

[6:03:58] >> opc: on pages four and five

[6:04:00] so lines of 15-25 then on to

[6:04:00] the

[6:04:02] next page I'm sorry what page.

[6:04:03] >> opc: starting at page 4 line

[6:04:06] 15-page 5 line 3 you state

[6:04:08] that the purpose of the

[6:04:10] forecasting model is to support

[6:04:13] rate case proceedings as well

[6:04:14] as a public plan for future

[6:04:16] generation and infrastructure

[6:04:17] needs that correct?

[6:04:19] >> teco

[6:04:19] Witness: yes.

[6:04:25] >> opc: would you agree the

[6:04:26] prices customers pay for

[6:04:28] electricity as well as utility

[6:04:30] system for liability is in part

[6:04:31] dependent on customer's actual

[6:04:33] usage and those given years?

[6:04:40] >> teco Witness: no not 100%.

[6:04:41] >> teco Witness: in part would

[6:04:44] you agree.

[6:04:57] In part.

[6:04:59] >> opc: this is somewhat of a

[6:05:00] more general question would you

[6:05:02] agree if a forecasting model

[6:05:04] I'm not speaking about anything

[6:05:05] specific.

[6:05:06] As far as what tampa uses but

[6:05:07] in general if a forecasting

[6:05:09] model is consistently

[6:05:10] inaccurate and at the same

[6:05:12] directions meaning consistently

[6:05:14] always overestimating or

[6:05:16] submitting something, when

[6:05:18] compared to the actuals it's

[6:05:20] reasonable to question the

[6:05:21] accuracy of that model?

[6:05:23] >> teco Witness: I would

[6:05:24] disagree with that.

[6:05:24] Ou

[6:05:26] actually in forecasting pickups

[6:05:29] the weather has such an impact

[6:05:31] on your actual usage to

[6:05:33] understand the accuracy of your

[6:05:34] bottles which are in a

[6:05:36] normalized basis and to

[6:05:38] understand if there is any

[6:05:39] other underlying trends that

[6:05:41] could be influencing customers

[6:05:43] usage you have to remove the

[6:05:48] impacts of whether we call that

[6:05:50] the weather normalization. What

[6:05:52] we do is look at the weather

[6:05:53] normalization trends

[6:05:55] historically and it is very

[6:05:59] consistent with our forecast.

[6:06:00] I just want to add one more

[6:06:03] thing. I agree and understand

[6:06:05] what you're saying about our

[6:06:07] forecast being over or too low

[6:06:09] for the past nine years.

[6:06:10] That is strictly a result of

[6:06:11] the weather.

[6:06:16] If we were to show you what the

[6:06:19] weather normalized accuracy

[6:06:21] which we do somewhere we are

[6:06:26] over and under it is not like

[6:06:27] we are consistently over and

[6:06:29] over the past 10 years are

[6:06:30] accuracy has been a tense 1%

[6:06:33] are forecast on the weather

[6:06:34] normalized basis has been very

[6:06:35] accurate.

[6:06:36] It is not skewed to one side or

[6:06:42] the other.

[6:06:43] >> opc: even though it always

[6:06:45] results in always

[6:06:46] overestimating or

[6:06:47] underestimating the same data?

[6:06:49] >> teco Witness: not on the

[6:06:50] weather delays basis that is

[6:06:51] that always the same.

[6:06:53] You have to realize you need to

[6:06:54] break your forecast down.

[6:06:56] residential forecast is what

[6:06:58] has been driving our work has

[6:07:00] to be on the low side because

[6:07:05] that is the most the weather

[6:07:06] sensitive sector that we have.

[6:07:08] It has been hot and have used

[6:07:11] more but if you were to look at

[6:07:13] the commercial and industrial

[6:07:15] our non-residential and

[6:07:16] governmental they eventually

[6:07:18] are forecast have been too

[6:07:18] high.

[6:07:19] >> opc: looking at the accuracy

[6:07:21] speaking of accuracy of the

[6:07:27] companies forecasting from MAY

[6:07:29] 2023 until APRIL 2024 each

[6:07:30] forecast has been under

[6:07:31] forecasted in total correct.

[6:07:32] >> teco Witness: you

[6:07:33] have

[6:07:34] someplace I can.

[6:07:35] >> opc: this is a florida

[6:07:37] rising exhibit if I can refer

[6:07:38] to that one?

[6:07:39] Florida rising 120 which is

[6:07:40] during exhibit 580.

[6:07:49] >> opc: we

[6:08:00] are pulling it up.

[6:08:01] The bottom line here at the

[6:08:03] totals for each of the customer

[6:08:05] average use and energy sales

[6:08:07] forecast each of those were

[6:08:08] under forecasted correct?

[6:08:10] >>

[6:08:11] teco Witness: you are talking

[6:08:13] of the total line?

[6:08:18] Yes by 2/10 of a percent.

[6:08:20] >> opc: that is underestimated

[6:08:21] that is what the graph means.

[6:08:25] >> teco Witness: if you look at

[6:08:27] the piece some are under some

[6:08:31] are over but to be off by 2/10

[6:08:33] of a percent is a very good

[6:08:33] forecast.

[6:08:35] >> opc: you do agree there were

[6:08:36] offspring nothing further.

[6:08:41] >> Florida Rising: thank you

[6:08:43] MR. CHAIRMAN.

[6:08:47] Good afternoon MS. Boyd says

[6:08:49] good to see you again.

[6:08:50] >> teco Witness: good

[6:08:51] afternoon.

[6:08:53] >> Florida Rising: to start off

[6:08:55] really quick I want to go over

[6:08:56] the revisions to your door

[6:08:58] response the newly filed

[6:09:00] response.

[6:09:01] I just want to make sure I'm

[6:09:03] reading it right the basically

[6:09:05] real changes here are that the

[6:09:07] difference also minus column on

[6:09:09] average is going from the

[6:09:15] original 153 to 539?

[6:09:16] >> teco Witness: what are we

[6:09:20] looking at

[6:09:20] .

[6:09:23] >> Florida Rising: and looking

[6:09:24] at a comparison of exhibit 212

[6:09:30] and exhibit a 38?

[6:09:32] Maybe the right way to do this

[6:09:34] would be to pull up master

[6:09:39] number 38210 if you can refer

[6:09:42] to the updated copy.

[6:09:43] Which would be 838.

[6:09:51] >> teco

[6:09:55] Witness: I'm sorry I didn't

[6:09:57] know we were talking about my

[6:09:58] revised one.

[6:09:59] >> Florida Rising: I apologize

[6:10:02] I'm just trying to get a feel

[6:10:05] for the changes. If you look at

[6:10:06] the difference: there is a bold

[6:10:08] number at the bottom for

[6:10:18] average.

[6:10:19] The original number was 153 now

[6:10:20] it is 539.

[6:10:21] >> teco Witness: yes.

[6:10:23] >> Florida Rising: the percent

[6:10:25] difference: the same bold

[6:10:26] number for average went from

[6:10:29] .08% to 2.8%.

[6:10:31] >> teco Witness: let me explain

[6:10:32] initially when we read the

[6:10:38] question it was talking about

[6:10:39] her accuracy and the weather

[6:10:41] normalized accuracy of 0.8%.

[6:10:43] Incorrectly we put under the

[6:10:45] table in the column that says

[6:10:46] actual sales we just put

[6:10:47] projected.

[6:10:48] then as we were reviewing

[6:10:54] things this week I realized

[6:10:56] that that mistake. We have

[6:10:57] corrected it and now we have

[6:10:59] our actual sales. The first

[6:11:01] time what you're seeing where

[6:11:02] you saw 0.8% was really our

[6:11:10] forecast versus the weather

[6:11:12] normalized sales. That is the

[6:11:14] accuracy look. Now I responded

[6:11:15] correctly and we are looking at

[6:11:17] the actual energy sales versus

[6:11:19] the weather normalized sales.

[6:11:20] Those differences basically

[6:11:22] represent our estimate of the

[6:11:23] impacted weather.

[6:11:24] >> Florida Rising: thank you

[6:11:27] and that's a very helpful

[6:11:28] clarification.

[6:11:29] In your role as the director

[6:11:31] for load research and

[6:11:31] forecasting.

[6:11:36] Your team developed inputs that

[6:11:39] will then be turned over to

[6:11:40] teco cost of service team?

[6:11:42] >> teco Witness: that is

[6:11:42] correct.

[6:11:45] >> Florida Rising: teco is

[6:11:45] recommending for cp cost of

[6:11:46] service in this case.

[6:11:49] >> teco Witness: yes.

[6:11:50] >> Florida Rising: know you

[6:11:52] know you just want to get it on

[6:11:53] the record the 4 specific peak

[6:11:55] months that teco uses is

[6:12:03] generally

[6:12:04] , JUNE, JULY, and

[6:12:05] AUGUST.

[6:12:06] >> teco Witness: I'm not really

[6:12:09] familiar with 4 cp but subject

[6:12:10] to check I would agree.

[6:12:13] >> Florida Rising: okay.

[6:12:14] I believe it comes from your

[6:12:15] testimony give me one second.

[6:12:44] We can come back to that.

[6:12:46] Would you agree that among

[6:12:47] other reasons it is important

[6:12:49] for teco to have an accurate

[6:12:50] sales forecast to ensure it

[6:12:52] will have enough generating

[6:12:54] capacity to meet demand at any

[6:12:54] given time?

[6:12:56] >> teco Witness: I would agree.

[6:12:58] >> Florida Rising: an accurate

[6:12:59] forecast is also important to

[6:13:01] make sure that teco has enough

[6:13:03] sales in a given year tour

[6:13:04] require its revenue requirement

[6:13:06] to recover its revenue

[6:13:08] requirement for that year.

[6:13:09] >> teco Witness: yes.

[6:13:11] >> Florida Rising: teco total

[6:13:13] rate based revenue requirement

[6:13:14] for any given year is recovered

[6:13:16] from customers through a

[6:13:18] combination of fixed and

[6:13:19] volumetric charges?

[6:13:20] > teco

[6:13:21] Witness: can you repeat that.

[6:13:25] >> Florida Rising: these are

[6:13:27] foundational questions it's not

[6:13:28] meant to be a trap. Just

[6:13:29] clarifying that teco recovers

[6:13:32] its revenue requirements for

[6:13:34] any given year from customers

[6:13:36] through a culmination of fixed

[6:13:38] and volumetric charges.

[6:13:38] >

[6:13:39] teco Witness: I would agree.

[6:13:41] >> Florida Rising: for the

[6:13:43] volumetric portion of that

[6:13:44] recovery and in very simple

[6:13:46] terms the rate for any given

[6:13:49] class are derived as a function

[6:13:50] basically of the revenue

[6:13:52] requirement that is allocated

[6:13:54] to that class divided by the

[6:13:56] kilowatt hours of load that

[6:14:01] class is expected to consume

[6:14:01] over that your.

[6:14:01] >> teco Witness: I think you're

[6:14:02] getting into an area that is

[6:14:05] not my area of expertise.

[6:14:06] >> would object is not in MS.

[6:14:08] Puente's testimony I believe

[6:14:15] these are questions directed to

[6:14:17] MR. Williams testimony there is

[6:14:18] no where in MS. Puente's

[6:14:20] testimony that addresses this.

[6:14:22] The subject you are being

[6:14:26] questions prior

[6:14:26] .

[6:14:28] >> Mike La Rosa,CHAIRMAN: any

[6:14:30] further thought if not I can

[6:14:30] roll.

[6:14:31] >> Florida Rising: I will try

[6:14:33] to reframe what I'm trying to

[6:14:36] get at is I believe is directly

[6:14:37] properly directed at MS.

[6:14:38] Fuentes inasmuch as it is the

[6:14:40] impact of the forecasting on

[6:14:41] the other piece bring a

[6:14:45] recognize that she's not a cost

[6:14:47] witness and trying to get a

[6:14:48] look at the pieces they go into

[6:14:48] that.

[6:14:50] > Mike La

[6:14:51] Rosa,CHAIRMAN: if you can point

[6:14:53] to her testimony then do that

[6:14:54] one or when applicable then she

[6:14:56] can state if it is not in her

[6:14:59] purview

[6:14:59] .

[6:15:01] >> Florida Rising: can attract

[6:15:02] one or two and then move on.

[6:15:04] >> Mike La Rosa,CHAIRMAN: yes.

[6:15:06] >> Florida Rising: essentially

[6:15:07] what I'm getting at is if teco

[6:15:09] is loaded forecast ended up

[6:15:11] being much higher or lower

[6:15:12] rather if the actual sales in a

[6:15:16] given year into being much

[6:15:18] higher or lower than its loaded

[6:15:20] forecast would you agree that

[6:15:22] could be a problem for revenue

[6:15:23] department recovery.

[6:15:28] >> teco Witness: I don't think

[6:15:33] I would agree with that.

[6:15:34] >> Florida Rising: can you

[6:15:35] explain why not.

[6:15:40] >> teco Witness: I am thinking

[6:15:41] in a given year if it is over

[6:15:43] or under there is other things

[6:15:44] also going on.

[6:15:46] Expenses, it is not the big

[6:15:47] picture I would need to make

[6:15:52] that determination on the

[6:15:54] revenue requirement

[6:15:55] calculation.

[6:15:56] >> Florida Rising: if we are

[6:15:58] looking at revenue requirement

[6:15:59] this is the picture that the

[6:16:01] company says it needs to

[6:16:02] recover for a given year.

[6:16:04] That is allocated across the

[6:16:05] classes and then broken down by

[6:16:07] the expected consumption of

[6:16:09] those numbers coming from your

[6:16:13] department I'm just asking if

[6:16:15] the actuals and up being for

[6:16:17] instance much lower than what

[6:16:18] you forecast is it possible

[6:16:20] that teco would end up not

[6:16:21] recovering the revenue

[6:16:22] requirement anticipated for the

[6:16:24] year

[6:16:24] .

[6:16:25] >> teco Witness: it is

[6:16:34] possible.

[6:16:35] >> Florida Rising: just one

[6:16:37] more thing we will move on.

[6:16:39] If teco is load were actually

[6:16:43] much higher than the forecast

[6:16:44] is it possible that teco could

[6:16:49] over recover versus the revenue

[6:16:50] requirement that they

[6:16:51] anticipated for that year?

[6:16:53] >> teco Witness: again all

[6:16:55] other things equal possibly but

[6:16:57] all things are not equal.

[6:16:59] >> Florida Rising: thank you if

[6:17:04] we can go to master number f1

[6:17:06] 6-nine for this is confidential

[6:17:18] exhibit a 31 it is f16-94.

[6:17:20] This is going to be an excel

[6:17:30] spreadsheet.

[6:17:31] MS. Fuentes are you familiar

[6:17:32] with this document?

[6:17:34] >> teco Witness:

[6:17:36] >> Florida Rising: once it

[6:17:38] comes up and you can see it.

[6:17:39] >> teco Witness: yes I am.

[6:17:44] >> Florida Rising: this is a

[6:17:46] workpaper used in developing

[6:17:46] your testimony.

[6:17:46] >>

[6:17:49] teco Witness: yes it is.

[6:17:50] >> Florida Rising: [Unclear

[6:17:50] audio].

[6:17:51] If we go to the tab in summary

[6:17:59] which we are on.

[6:18:01] This shows the variance between

[6:18:03] teco forecasts and actuals with

[6:18:04] respect to the number of

[6:18:05] customers and sales?

[6:18:07] >> teco Witness: yes.

[6:18:09] >> Florida Rising: teco is in

[6:18:11] your average sales actuals are

[6:18:13] 1.9% below the forecasted sales

[6:18:14] in this document?

[6:18:15] >> teco Witness: that is

[6:18:16] correct.

[6:18:18] >> Florida Rising: since 2021

[6:18:19] teco's three-year average

[6:18:21] actual sales were below 3.2 the

[6:18:22] actual sales.

[6:18:23] Her forecasted sales.

[6:18:25] >> teco Witness: that is

[6:18:27] correct spacing if we can go to

[6:18:33] master number 3.14

[6:18:33] .

[6:18:35] >> teco Witness: can we stay

[6:18:37] there or to point out that 3.2%

[6:18:38] commission on the weather

[6:18:40] normalized basis which is how

[6:18:41] you assess how your forecasts

[6:18:43] are doing our forecasts are

[6:18:44] only 1/10 of a percent off.

[6:18:46] Then he would mention 1.9 our

[6:18:48] tenure average 1.9% on the

[6:18:50] weather normalized basis was

[6:18:53] 0.8% off.

[6:18:54] That is the way we should look

[6:18:56] at forecast accuracy.

[6:19:02] >> Florida Rising: thank you

[6:19:04] for the additional context you

[6:19:06] would agree these numbers are

[6:19:07] accurate and the start.

[6:19:09] >> teco Witness: I agree with

[6:19:11] the numbers that they are

[6:19:12] accurate.

[6:19:13] >> Florida Rising: if we can

[6:19:15] move on to 3.4-6645.

[6:19:16] This is hearing exhibit this is

[6:19:27] hearing exhibit 663 or fll 203.

[6:19:31] Do you recognize this document?

[6:19:32] >> teco Witness: I see two

[6:19:34] different documents can I look

[6:19:35] at the one on my screen?

[6:19:37] >> Florida Rising: what is the

[6:19:39] number in the upper right-hand

[6:19:40] corner for you?

[6:19:41] >> teco Witness: [Listing

[6:19:44] names].

[6:19:49] >> Florida Rising: 6645.

[6:19:50] >> teco Witness: that is what

[6:19:52] we were looking at previously

[6:19:54] that matches what is up there

[6:19:54] now.

[6:20:12] >> Florida Rising: okay.

[6:20:13] This should be a different page

[6:20:16] than the one we're looking at

[6:20:17] before but it should have a

[6:20:19] very similar looking chart. I

[6:20:21] just want to confirm what we're

[6:20:22] looking at here is the response

[6:20:24] to a discovery request this is

[6:20:26] an updated copy of the last

[6:20:27] exhibit of your rebuttal

[6:20:27] testimony?

[6:20:30] >> teco Witness: I

[6:20:32] don't recall this being in my

[6:20:34] rebuttal testimony I have to

[6:20:34] check.

[6:20:36] >> Florida Rising: let me ask

[6:20:38] the question fisher. What

[6:20:39] changes were made to be updated

[6:20:41] document in your rebuttal

[6:20:44] testimony compared to your

[6:20:45] original testimony.

[6:20:45] > teco

[6:20:47] Witness: I believe in my

[6:20:48] rebuttal testimony what I

[6:20:50] updated was I re-created some

[6:20:53] numbers but on the weather

[6:20:54] normalized basis.

[6:21:01] No numbers were revised I just

[6:21:03] pulled out the numbers that I

[6:21:03] felt were the ones

[6:21:05] we should be

[6:21:06] looking at on the weather

[6:21:07] normalized basis.

[6:21:09] >> Florida Rising: as opposed

[6:21:11] to the non-weather normalized

[6:21:12] basis.

[6:21:13] >> teco Witness: no

[6:21:14] spreadsheets were revised.

[6:21:16] >> Florida Rising: thank you.

[6:21:21] If we can go to master number

[6:21:29] 16-95 hearing exhibit 831

[6:21:30] there will be a number of

[6:21:30] these.

[6:21:36] [Unclear audio].

[6:21:57] F 16-95.

[6:21:58] MS. Fuentes is this another

[6:22:01] workpaper of yours?

[6:22:02] >> teco Witness: I cannot see

[6:22:07] that.

[6:22:10] Yes this is.

[6:22:14] >> Florida Rising: yes we are

[6:22:16] in the tab year to date

[6:22:21] FEBRUARY.

[6:22:23] This tab shows the forecasted

[6:22:24] versus actual retail sales by

[6:22:28] the month from JUNE 2023 until

[6:22:28] FEBRUARY 2024.

[6:22:30] >> teco Witness: that is

[6:22:30] correct.

[6:22:32] >> Florida Rising: energy sales

[6:22:34] during the summer months trend

[6:22:35] above teco's forecast?

[6:22:37] >> teco Witness: that is

[6:22:37] correct.

[6:22:39] >> Florida Rising: 5% above in

[6:22:39] JULY?

[6:22:43] >> teco Witness: yes honey on

[6:22:45] the weather normalized basis it

[6:22:48] is have a percent

[6:22:48] .

[6:22:50] >> Florida Rising: I will be

[6:22:52] talking about than non-weather

[6:22:53] normalized basis and I respect

[6:22:55] your position that then

[6:22:57] normalized once is where we

[6:22:59] should be looking. It was 6%

[6:22:59] above in AUGUST?

[6:23:00] > teco

[6:23:00] Witness:

[6:23:01] yes.

[6:23:03] >> Florida Rising: 7.7 above in

[6:23:07] SEPTEMBER

[6:23:07] .

[6:23:09] >> teco Witness: that is

[6:23:09] correct.

[6:23:10] >> Florida Rising: on the other

[6:23:12] hand additional sales were

[6:23:14] lower than forecast between

[6:23:15] NOVEMBER and FEBRUARY?

[6:23:16] >> teco

[6:23:17] Witness: does correct.

[6:23:19] >> Florida Rising: you will

[6:23:21] create the biggest variances in

[6:23:23] JANUARY 5.1% less than the

[6:23:23] forecast.

[6:23:24] >> teco Witness: yes.

[6:23:26] Our forecast was too high.

[6:23:29] >> Florida Rising: can we go to

[6:23:31] master number e7770.

[6:23:36] This from exhibit 208.

[6:23:49] Admitted exhibit 208.

[6:23:53] Once there it might be better

[6:23:54] to do with the master number

[6:23:56] this is for derogatory number

[6:23:58] 139 master number associate

[6:24:00] with that is e master number

[6:24:18] associate with that is e7796.

[6:24:19] MS. Winters if you can give me

[6:24:21] a nod when it has come up for

[6:24:23] you. I recognize there is a

[6:24:23] lag.

[6:24:25] >> teco Witness: it is up.

[6:24:26] >> Florida Rising: did you

[6:24:28] sponsor the answer to this

[6:24:28] interrogatory

[6:24:28] .

[6:24:29] >> teco Witness: gas.

[6:24:31] >> Florida Rising: in this

[6:24:32] insert to attribute higher

[6:24:33] error rates and sales forecast

[6:24:34] to "hotter than normal

[6:24:35] weather".

[6:24:37] >> teco Witness: does correct.

[6:24:38] >> Florida Rising: go to the

[6:24:51] next page.

[6:24:56] Rather than zooming in on all

[6:24:57] this unless good general

[6:25:00] question about the spring you

[6:25:01] would agree that teco is

[6:25:03] forecast experienced greater

[6:25:05] variance for non-weather

[6:25:08] normalized sales and the

[6:25:10] weather normalized sales

[6:25:10] .

[6:25:11] >> teco Witness: I would agree

[6:25:12] with that.

[6:25:21] >> Florida Rising: okay.

[6:25:22] I guess what we are talking

[6:25:24] about normalization and a

[6:25:25] conversation with MS. Wessling

[6:25:28] about whether normalization we

[6:25:29] danced around the subject a

[6:25:31] little bit. How exactly does

[6:25:32] teco normalize for weather?

[6:25:33] >> teco Witness: let me see if

[6:25:35] I can explain where it makes

[6:25:35] sense.

[6:25:42] Whether normalizing is based on

[6:25:53] a coefficient which represents

[6:25:54] the kilowatt hour per degree

[6:25:56] day this coefficient comes from

[6:25:58] our regression models which

[6:26:00] correlates the weather and

[6:26:01] customer usage.

[6:26:03] That is one piece we have this

[6:26:05] coefficient that represent this

[6:26:07] relationship between energy and

[6:26:08] weather.

[6:26:09] Then we look at our whether

[6:26:10] what was normal what was

[6:26:15] expected and what we used the

[6:26:17] forecast and what actually

[6:26:19] happened. We take the

[6:26:20] difference in those degree days

[6:26:22] multiply them by the

[6:26:23] coefficient then multiplied

[6:26:25] them by the terms of customers

[6:26:27] that we have that gives you

[6:26:28] what the weather impact was

[6:26:30] that's how you normalize you

[6:26:32] remove that when they're back

[6:26:34] from your actual energy sales.

[6:26:36] That is how you do the weather

[6:26:36] normalization.

[6:26:38] >> Florida Rising: would be for

[6:26:40] the safe large loads and

[6:26:46] ecosystem by the end use would

[6:26:47] be space heating and cooling?

[6:26:48] Depending on the season?

[6:26:50] >> teco Witness: I would agree.

[6:26:52] >> Florida Rising: would you

[6:26:55] agree with those end-users are

[6:26:57] entirely temperature dependent

[6:26:59] entirely temperature dependent.

[6:27:01] >> teco Witness: yes.

[6:27:02] Specifically that is to go uses

[6:27:04] a 65b0f breakpoint above or

[6:27:06] below which each hvac systems

[6:27:08] are soon to be heating or

[6:27:08] cooling.

[6:27:10] >> teco Witness: 65b0 is the

[6:27:10] base yes.

[6:27:12] >> Florida Rising: would you

[6:27:14] agree there's a difference

[6:27:16] between weather and climate.

[6:27:17] >> teco Witness: I would agree.

[6:27:19] >> Florida Rising: would you

[6:27:21] agree that the weather would

[6:27:23] capture the kinds of day-to-day

[6:27:26] month to month even dirtier

[6:27:27] variation in temperature within

[6:27:28] a baseline.

[6:27:31] >> teco Witness: I'm not an

[6:27:33] expert in commonality but I

[6:27:39] would high-level yes

[6:27:39] .

[6:27:41] >> Florida Rising: in general.

[6:27:42] > teco Witness: gas.

[6:27:44] >> Florida Rising: would you

[6:27:46] also greet the comets more

[6:27:47] describes the meta-system or

[6:27:50] the baseline from which that

[6:27:51] day-to-day or seasonal

[6:27:52] variation is taking place?

[6:27:53] >> Florida Rising:

[6:27:53] > teco

[6:27:55] Witness: I could agree with

[6:27:55] that.

[6:27:57] >> Florida Rising: would you

[6:27:58] further agree that if the comet

[6:28:02] were to change it would shift

[6:28:04] the baseline around which that

[6:28:06] variation would call weather is

[6:28:06] occurring?

[6:28:08] >> teco Witness: it is possible

[6:28:10] but for the period of time I've

[6:28:19] been doing this it has not

[6:28:21] moved 65b0 is the base.

[6:28:22] >> Florida Rising: I'm not

[6:28:24] referring to that number

[6:28:25] specifically just in general

[6:28:27] terms if we talk about the

[6:28:29] weather as inter-day inter-week

[6:28:31] and inter-seasonal variation

[6:28:33] around general baseline would

[6:28:35] you agree that climate change

[6:28:37] or changing the climate would

[6:28:38] move the baseline in any

[6:28:40] direction it would move that

[6:28:40] baseline?

[6:28:41] > teco Witness: i

[6:28:42] believe it would be a gradual

[6:28:44] change over time.

[6:28:45] >> Florida Rising: there enough

[6:28:47] if you go to master number

[6:29:09] 3.2-3815.

[6:29:14] Do you have it up?

[6:29:15] >> teco Witness: yes if it is

[6:29:17] one that we have seen already?

[6:29:21] >> Florida Rising: yes this is

[6:29:25] one that opc pulled up.

[6:29:27] I will ask you questions around

[6:29:31] this but just to confirm this

[6:29:33] document provides build first

[6:29:35] projected energy versus use per

[6:29:39] class for APRIL 24

[6:29:39] .

[6:29:40] >> teco Witness: yes

[6:29:40] .

[6:29:43] >> opc:

[6:29:44] >> Florida Rising: if we go to

[6:29:48] pages down does this page show

[6:29:52] narrative explanations for the

[6:29:57] variance between predicted and

[6:29:58] actual sales.

[6:29:59] >> teco Witness: yes it does.

[6:30:01] >> Florida Rising: under the

[6:30:05] heading peak demand section

[6:30:06] does it note that predict

[6:30:08] winter peak months are now

[6:30:09] being driven by hunters rather

[6:30:10] than cold weather?

[6:30:12] >> teco Witness: I'm reading

[6:30:15] it.

[6:30:17] >> Florida Rising: it would be

[6:30:25] cel h 15

[6:30:25] .

[6:30:27] >> teco Witness: for that

[6:30:28] specific period but that is not

[6:30:30] consistent all winter months.

[6:30:31] For that period it was.

[6:30:33] >> Florida Rising: it is your

[6:30:35] testimony that the winter peaks

[6:30:37] on the teco system are driven

[6:30:38] by heating needs rather than

[6:30:39] cooling needs?

[6:30:41] >> teco Witness: can you repeat

[6:30:42] that

[6:30:42] .

[6:30:45] >> Florida Rising: the variance

[6:30:46] explanation on this page

[6:30:56] attributes winter peak to

[6:30:58] effectively it attributes them

[6:30:59] to cooling needs rather than

[6:31:01] heating needs because it is

[6:31:03] saying there happening and hot

[6:31:04] peak days and you're saying

[6:31:06] that explanation applies in

[6:31:07] this context to this time

[6:31:09] period that do not agree that

[6:31:11] it is representative of the

[6:31:12] peak on teco systems.

[6:31:14] >> teco Witness: I don't agree

[6:31:16] I feel still think heating

[6:31:17] degree will drive the winter

[6:31:19] peak at times but sometimes

[6:31:20] it's a cooling degree day. I

[6:31:22] will say this first quarter of

[6:31:24] it this year which is kind of

[6:31:26] overlaps into. Was the mildest

[6:31:29] period of time for those months

[6:31:30] in the past 50 years.

[6:31:32] Very mild.

[6:31:35] >> Florida Rising: okay.

[6:31:41] If we can go three pages down.

[6:32:01] Master number ending 3820.

[6:32:02] Looking at this page the

[6:32:05] production for non-peak demand

[6:32:06] shows a clear spike between

[6:32:09] DECEMBER non-peak demand shows

[6:32:11] a clear spike between DECEMBER

[6:32:12] 2023 and FEBRUARY 2024?

[6:32:14] >> teco Witness: I need to see

[6:32:19] that.

[6:32:21] >> Florida Rising: the orange

[6:32:21] line in the graph is the

[6:32:22] predicted.

[6:32:23] >> teco Witness: yes.

[6:32:28] >> Florida Rising: I'm sorry.

[6:32:29] You agree there is a predicted

[6:32:31] spike there?

[6:32:36] >> teco Witness: yes we predict

[6:32:38] our winter peaks to be 31b0

[6:32:38] days.

[6:32:39] >> Florida Rising: that spike

[6:32:41] does coincide with the teco is

[6:32:41] winter

[6:32:42] season.

[6:32:45] >> teco Witness: yes.

[6:32:47] It is evident that graph our

[6:32:50] first quarter was very mild.

[6:32:52] >> Florida Rising: would agree

[6:32:54] the predicted forecaster winter

[6:32:58] peak did not for materialize as

[6:32:58] expected.

[6:33:00] >> teco Witness: it did not.

[6:33:02] >> Florida Rising: for FEBRUARY

[6:33:05] this is looking up this will be

[6:33:12] cel number 5k 5 looking at the

[6:33:14] variance directory highlighted

[6:33:16] cel for FEBRUARY 2024 the

[6:33:20] actual peak was most 29% below

[6:33:21] the expected.

[6:33:25] >> teco Witness:

[6:33:26] yes again that was a very mild

[6:33:28] quarter

[6:33:28] .

[6:33:30] >> Florida Rising: for DECEMBER

[6:33:31] it was 30% below?

[6:33:32] >> teco Witness: for which

[6:33:34] month

[6:33:34] .

[6:33:36] >> Florida Rising: sorry for

[6:33:38] DECEMBER 2023.

[6:33:39] >> teco Witness: it was 4.4%.

[6:33:43] >> Florida Rising: I'm looking

[6:33:45] at the percent variance my

[6:33:45] apologies.

[6:33:50] This is cell I five.

[6:33:56] >> teco Witness: I see that

[6:33:56] .

[6:33:57] >> Florida Rising: simply for

[6:33:59] JANUARY 2020 fourth the peak

[6:34:01] was 52% lower than expected.

[6:34:02] >> teco Witness: yes.

[6:34:06] Can we go to master number

[6:34:07] before we move on can I add

[6:34:10] something if we were to extend

[6:34:11] this this ends in MARCH if we

[6:34:13] go through last month our JUNE

[6:34:18] and JULY summer peak I just

[6:34:20] want to point out the rolloff

[6:34:21] by 8 mw.

[6:34:23] In both JUNE and JULY. The peak

[6:34:24] demand forecast and at the

[6:34:25] forecast in this proceeding are

[6:34:28] basically dead on I would like

[6:34:32] to point out that we raised the

[6:34:37] forecast for this proceeding by

[6:34:38] almost 1% because we realized

[6:34:41] residential forecast had been

[6:34:42] on the low side.

[6:34:43] The residential forecast year

[6:34:45] to date in JULY is actually

[6:34:47] 3/10 of a percent below our

[6:34:52] budget.

[6:34:53] This forecast in this

[6:34:55] proceeding that leads into the

[6:34:56] test year is very very

[6:34:58] accurate.

[6:35:00] On a weather normalize basis

[6:35:01] which no I like to talk about

[6:35:02] it that way.

[6:35:05] We are 1/10 of a percent above

[6:35:07] because we had a hot JULY and

[6:35:12] we also had an upside with an

[6:35:14] industrial customer if we

[6:35:17] remove the impact of that

[6:35:19] customer we are actually

[6:35:22] forecast through JULY is 0.0%.

[6:35:24] We are below our budget by 3 gw

[6:35:24] hours.

[6:35:28] That's a very very good

[6:35:30] statistic for a forecast any

[6:35:31] proceeding.

[6:35:33] >> Florida Rising: I think you

[6:35:36] indicated but the reform or to

[6:35:38] confirm your talk about the

[6:35:44] weather normalized

[6:35:44] .

[6:35:45] >> teco Witness: both not

[6:35:47] innate weather normalized our

[6:35:48] presidential forecast is 3/10

[6:35:50] of a percent below our budget.

[6:35:51] Our budget is too high.

[6:35:53] In total because we had hotter

[6:35:55] weather last month as well as

[6:35:56] an industrial upside if we

[6:35:58] remove that industrial upside

[6:36:02] our non-weather normalized

[6:36:03] forecast is just off by 2/10 of

[6:36:08] a percent if you weather

[6:36:10] normalized at 2/10 of a percent

[6:36:12] we are 0.0% off on our

[6:36:13] forecast.

[6:36:14] That is 3 gw hours below our

[6:36:17] budget is where the actual

[6:36:18] comes in.

[6:36:20] >> Florida Rising: thank you

[6:36:21] for the can we move on to

[6:36:27] master number f16-89.

[6:36:29] this is from hearing exhibit

[6:36:51] 831.

[6:36:53] >> Mike La Rosa,CHAIRMAN: how

[6:36:55] many more questions do think

[6:36:56] you have for this witness

[6:36:56] .

[6:36:58] >> Florida Rising: I have a

[6:36:59] fairly significant amount of

[6:37:04] questions if it's time for a

[6:37:05] break this would be a good time

[6:37:06] for break.

[6:37:08] >> Mike La Rosa,CHAIRMAN: let's

[6:37:09] do that let's take a break

[6:37:25] until 3:45 pm.

[6:50:59] >> Mike La Rosa,CHAIRMAN: we

[6:51:06] can jump back in are you ready.

[6:51:09] >> Florida Rising: thank you

[6:51:10] MR. CHAIRMAN MS. Fuentes to

[6:51:12] recognize that document pulled

[6:51:15] up

[6:51:15] .

[6:51:16] >> teco Witness: yes I do.

[6:51:19] >> Florida Rising: this is a

[6:51:21] report from the peak demand

[6:51:21] from 2019.

[6:51:22] >> teco Witness: yes.

[6:51:26] >> Florida Rising: I apologize.

[6:51:40] One second.

[6:51:41] For context this is master

[6:51:47] number f-16-89 comprehensive

[6:51:52] exhibit 831.

[6:51:53] This report is from

[6:51:54] 2019.

[6:51:56] We will also go to separate

[6:52:04] documents you have from 2020

[6:52:06] -2023 will be as efficient as

[6:52:07] possible going through these

[6:52:09] all of these documents these

[6:52:10] are

[6:52:11] workpapers from the

[6:52:12] development of your testimony

[6:52:13] and mfr.

[6:52:14] > teco Witness: I

[6:52:15] believe they are

[6:52:15] .

[6:52:17] >> Florida Rising: please

[6:52:18] scroll down to the section

[6:52:20] which l peak demand this will

[6:52:25] be role 109.

[6:52:27] This section includes the real

[6:52:30] actual and forecasted for each

[6:52:34] month of 2019?

[6:52:35] >> teco Witness: that is

[6:52:36] correct.

[6:52:38] >> Florida Rising: for instance

[6:52:40] in 2019 JANUARY was forecast to

[6:52:42] have a peak of 4337 mw

[6:52:42] .

[6:52:45] >> teco Witness: that is

[6:52:46] correct.

[6:52:47] >> Florida Rising: the actual

[6:52:56] peak demand for JANUARY was

[6:52:57] 3091 mw.

[6:52:58] >> teco Witness: that is

[6:52:59] correct.

[6:53:01] >> Florida Rising: looking at

[6:53:01] the cell

[6:53:02] below the forecast

[6:53:04] number that represents a

[6:53:06] variance of-29%.

[6:53:07] >> teco Witness: that is

[6:53:07] correct.

[6:53:09] >> Florida Rising: put another

[6:53:09] way

[6:53:11] teco's forecast was 25%

[6:53:12] higher than the natural for

[6:53:14] JANUARY teco's forecast was 25%

[6:53:15] higher than the natural for

[6:53:16] JANUARY 2014.

[6:53:18] >> teco Witness: just to remind

[6:53:20] our winter forecast we

[6:53:21] requested 31b0 peak at the time

[6:53:23] to ensure we have the capacity

[6:53:25] to meet a winter load. We do

[6:53:26] have a occasional winter load

[6:53:28] and in fact we don't have the

[6:53:31] 2010 peak report but if we did

[6:53:31] that would show that peak in

[6:53:36] 2010 we had 14 consecutive days

[6:53:38] of cold weather that peak is

[6:53:39] actually only 50 mw or so off

[6:53:48] our 2024 and 2025 winter peak.

[6:53:49] If we have a winter peak we

[6:53:51] will have a pretty sharp spike

[6:53:53] in the demand.

[6:53:55] I just want to explain broken

[6:53:57] forecast for 31b0 and we don't

[6:53:58] meet that every year.

[6:54:00] Like I said when we have our

[6:54:03] winter we will meet it and then

[6:54:04] surpass it.

[6:54:06] >> Florida Rising: if I can

[6:54:08] draw your attention back to the

[6:54:09] forecast rope we look across

[6:54:11] the forecast role that has 4337

[6:54:12] for JANUARY if you look across

[6:54:14] that for the rest of the year

[6:54:15] JANUARY is actually forecast to

[6:54:24] be the peak for 2019.

[6:54:25] JANUARY 2019 was forecast to be

[6:54:27] the retail system peak for the

[6:54:31] year

[6:54:31] .

[6:54:32] >> teco Witness: yes.

[6:54:34] >> Florida Rising: the actual

[6:54:35] retail peak for that year was

[6:54:36] 4298 mw in JUNE?

[6:54:38] >> teco Witness: that is

[6:54:38] correct.

[6:54:43] >> Florida Rising: if we look

[6:54:45] at the actual peak demand for

[6:54:49] JANUARY, 2091 mw number we look

[6:54:51] across the rest of that row

[6:54:57] would you agree that the actual

[6:54:59] peak was higher than the actual

[6:55:01] peak in JANUARY for the months

[6:55:02] of FEBRUARY, MARCH, APRIL,

[6:55:04] MAY, JUNE, JULY, AUGUST,

[6:55:08] SEPTEMBER, OCTOBER, NOVEMBER

[6:55:15] NOVEMBER 2019

[6:55:15] .

[6:55:16] >> teco Witness: I would agree.

[6:55:18] >> Florida Rising: putting

[6:55:20] aside the months of JUNE-august

[6:55:22] that is seven months outside of

[6:55:24] the number four cp months that

[6:55:26] the code uses higher than

[6:55:26] .

[6:55:28] >> teco Witness: I don't want

[6:55:32] to speak about number four cp

[6:55:34] that's a question for jordan

[6:55:37] williams.

[6:55:38] >> Florida Rising: it is your

[6:55:40] forecast data that goes into

[6:55:44] MR. Williams models.

[6:55:45] >> teco Witness: yes they do.

[6:55:47] >> Florida Rising: it is the

[6:55:49] peak from those months the

[6:55:50] drive the cost of service that

[6:55:51] he uses.

[6:55:58] >> teco Witness: that as well

[6:55:59] as a number of other things.

[6:56:01] >> Florida Rising: as we sit

[6:56:02] here today is your

[6:56:04] understanding that the peaks

[6:56:05] using the 4 cp bottle is

[6:56:07] JANUARY JUNE JULY and AUGUST is

[6:56:08] that correct.

[6:56:09] >> teco Witness: that would be

[6:56:11] correct JUNE JULY and AUGUST

[6:56:12] the peak was that on.

[6:56:14] Can we go to the section net

[6:56:16] integrated retail firm peak

[6:56:16] data.

[6:56:18] Alone ron line 129.

[6:56:20] This

[6:56:23] section includes for each month

[6:56:25] total that was available for

[6:56:27] interruption.

[6:56:28] >> teco Witness: I'm sorry

[6:56:30] where are we looking

[6:56:30] .

[6:56:34] >> Florida Rising: on line 129

[6:56:34] .

[6:56:38] >> teco Witness: okay

[6:56:38] .

[6:56:40] >> Florida Rising: that line

[6:56:42] represent the monthly total

[6:56:45] available megawatts they can be

[6:56:45] interrupted?

[6:56:47] >> teco Witness: that's

[6:56:47] correct.

[6:56:49] >> Florida Rising: the actual

[6:56:51] the total megawatts actually

[6:56:53] curtailed for that months is

[6:56:55] represented by line 123 which

[6:56:59] is called curtailed megawatts

[6:56:59] interruptible.

[6:57:01] >> teco Witness: yes 123 and

[6:57:04] 128.

[6:57:04] 123 york).

[6:57:06] >> Florida Rising: subject to

[6:57:08] check looking across the row

[6:57:16] for potentially curtailed will

[6:57:17] that line 123 range is roughly

[6:57:19] 180-260 mw depending on the

[6:57:19] month.

[6:57:21] >> teco Witness: that is

[6:57:22] correct.

[6:57:23] >> Florida Rising: those

[6:57:25] potential portable megawatts or

[6:57:27] the basis for credits for

[6:57:28] interruptible customers.

[6:57:30] >> teco Witness: I'm not sure

[6:57:34] for these purposes it is we

[6:57:44] produce to get the firm load to

[6:57:46] do reserve margin calculations.

[6:57:48] As far as credits to customers

[6:57:50] I don't know if the same

[6:57:50] amount.

[6:57:52] >> Florida Rising: questions

[6:57:53] about how retail how the

[6:57:55] credits articulate for

[6:57:57] interruptible customers will be

[6:57:58] best directed to another

[6:57:59] witness.

[6:58:00] >> teco Witness: yes.

[6:58:00] >> Florida

[6:58:02] Rising: you agree if

[6:58:03] you look across the road the

[6:58:05] teco did not interrupt or

[6:58:07] curtail any load from those

[6:58:08] customers at any point over the

[6:58:09] year.

[6:58:10] >> teco Witness: at any time of

[6:58:12] the peak there could have been

[6:58:14] another hour there was not

[6:58:15] reported monthly peak that

[6:58:17] could have been an

[6:58:17] interruption.

[6:58:19] This was one point in time for

[6:58:20] each month.

[6:58:22] >> Florida Rising: sure. Do

[6:58:23] your knowledge does teco

[6:58:27] interrupt its curtail book

[6:58:28] customers a time other than the

[6:58:29] peak periods.

[6:58:31] >> teco Witness: I cannot

[6:58:32] answer that I'm not sure.

[6:58:40] I would think they could.

[6:58:41] >> Florida Rising: you don't

[6:58:43] have any evidence that they do.

[6:58:45] >> teco Witness: what would say

[6:58:47] if they did interrupt that

[6:58:48] would reduce the peak it MAY

[6:58:50] not show up as the monthly peak

[6:58:52] does that make sense?

[6:58:53] >> Florida Rising: if they

[6:58:55] interrupted it would show up as

[6:58:56] reducing the firm load is that

[6:58:57] not true?

[6:58:59] >> teco Witness: it would

[6:59:00] produce the firm load I don't

[6:59:02] know if it would reduce the

[6:59:04] actual peak load on these

[6:59:04] reports.

[6:59:06] >> Florida Rising: fair enough.

[6:59:08] We will move on now to the same

[6:59:10] report for 2020. The number

[6:59:13] there is f16-90.

[6:59:17] We did some groundwork on that

[6:59:18] first one I think we can move

[6:59:20] through the following years

[6:59:22] quickly.

[6:59:23] >> teco Witness: okay.

[6:59:36] >> Florida Rising: if we can go

[6:59:38] back down to the retail peak

[6:59:41] section beginning with row 115.

[6:59:44] Thank you. Four 2020 JANUARY

[6:59:54] was forecast to the peak of

[6:59:54] 4384 mw?

[6:59:56] >> teco Witness: that is

[6:59:56] correct.

[6:59:58] >> Florida Rising: three row

[7:00:00] above that the actual peak for

[7:00:01] JANUARY is 3538?

[7:00:03] >> teco Witness: that is

[7:00:04] correct it was 37b0 peak versus

[7:00:09] 31.

[7:00:10] >> Florida Rising: that

[7:00:12] forecast was 90% higher than

[7:00:12] actual.

[7:00:14] >> teco Witness: correct.

[7:00:15] >> Florida Rising: looking

[7:00:17] across the rest of the forecast

[7:00:19] row JANUARY was expected to be

[7:00:20] the peak for 2020?

[7:00:22] >> teco Witness: JANUARY was

[7:00:23] yes.

[7:00:24] >> Florida Rising: the actual

[7:00:26] p4 2020 was 4255 mw for

[7:00:26] SEPTEMBER.

[7:00:28] >> teco Witness: that is

[7:00:28] correct.

[7:00:30] >> Florida Rising: SEPTEMBER is

[7:00:32] not one of the fortune one

[7:00:33] months we discussed?

[7:00:36] >> teco Witness: no it is not.

[7:00:38] >> Florida Rising: looking at

[7:00:40] the actual peak for january

[7:00:42] 3538 mw actual peak was higher

[7:00:43] in MARCH APRIL MAY JUNE JULY

[7:00:51] AUGUST SEPTEMBER and OCTOBER.

[7:00:52] >> teco Witness: that is

[7:00:53] correct.

[7:00:55] >> Florida Rising: putting

[7:00:56] aside the month of JUNE until

[7:00:58] AUGUST that is high months with

[7:00:59] higher demand than JANUARY

[7:00:59] is

[7:01:00] 4cp months.

[7:01:00] >>

[7:01:02] teco Witness: that would be)

[7:01:02] .

[7:01:03] >> Florida Rising: if we go to

[7:01:05] the net integrated retail firm

[7:01:06] peak data looking across line

[7:01:12] 130.

[7:01:14] Teco did not interrupt or

[7:01:18] curtail any load for many of

[7:01:18] the interruptible

[7:01:19] curtailed

[7:01:21] customers during the year.

[7:01:22] >> teco Witness: that is

[7:01:25] correct.

[7:01:26] >> Florida Rising: we are

[7:01:28] flying we go to the report for

[7:01:29] 2021 the number on that is f16-

[7:01:36] 91.

[7:01:37] When that is open we will go

[7:01:39] back to the retail peak demand

[7:02:09] on row 126.

[7:02:23] If you look on row one 31

[7:02:25] JANUARY 2021 was forecast of a

[7:02:26] peak of 4400 mw?

[7:02:27] >> teco Witness: yes.

[7:02:29] >> Florida Rising: actual peak

[7:02:40] demand for JANUARY is 2195 mw

[7:02:40] .

[7:02:42] >> Florida Rising: trench was

[7:02:44] forecast with 31% higher than

[7:02:44] actual.

[7:02:45] > teco Witness: yes.

[7:02:47] >> Florida Rising: JANUARY was

[7:02:49] forecast to be the annual peak

[7:02:50] for 2021.

[7:02:51] >> teco Witness: yes.

[7:02:53] >> Florida Rising: actual peak

[7:02:54] for 2021 was 4293 mw in

[7:02:54] AUGUST?

[7:02:56] >> teco Witness: that is

[7:02:57] correct.

[7:02:58] >> Florida Rising: looking

[7:03:00] official pay for JANUARY >>

[7:03:01] Florida Rising: looking

[7:03:03] official pay for JANUARY 2000

[7:03:05] 905 mw the peak was higher in

[7:03:07] every single other month of the

[7:03:07] year.

[7:03:08] > teco Witness: that

[7:03:10] is usually the case in JANUARY

[7:03:12] if we don't have a winter peak.

[7:03:13] JUNE JULY and AUGUST the peaks

[7:03:15] are typically higher ones.

[7:03:16] Like I said we forecast for a

[7:03:17] cold winter peak.

[7:03:19] We cannot avoid that.

[7:03:21] >> Florida Rising: once again

[7:03:23] putting aside the month of JUNE

[7:03:24] -AUGUST is eight months higher

[7:03:26] than JANUARY outside of their

[7:03:28] 4cp months if we go to the net

[7:03:30] integrated firm data.

[7:03:31] On line 41 shows teco did not

[7:03:33] interrupt or curtail any load

[7:03:35] from interruptible or curtail

[7:03:36] book customers during any

[7:03:38] monthly peaks of the year.

[7:03:39] >> teco Witness: thumbs

[7:03:40] correct.

[7:03:42] >> Florida Rising: let's move

[7:03:51] on to 2020 2f.6-92.

[7:03:54] Retail peak demand row 131 in

[7:04:03] this document.

[7:04:10] Okay a few lines below that

[7:04:12] JANUARY 2022 was forecast of a

[7:04:14] peak of 4461 mw?

[7:04:14] >> teco Witness: yes.

[7:04:16] >> Florida Rising: actual peak

[7:04:18] demand was 3731 mw.

[7:04:18] > teco

[7:04:19] Witness:

[7:04:19] yes.

[7:04:20] >> Florida Rising: teco's

[7:04:23] forecast was 3% higher than

[7:04:27] actual if you look across the

[7:04:29] forecast bro general response

[7:04:32] to bp for JANUARY 2022

[7:04:32] annually.

[7:04:33] >> teco Witness: yes.

[7:04:39] >> Florida Rising: actual peak

[7:04:40] for 2022 was 4385 mw in JUNE.

[7:04:42] >> teco Witness: yes.

[7:04:43] >> Florida Rising: looking at

[7:04:45] the actual peak demand for

[7:04:46] JANUARY the actual peak was

[7:04:50] higher in MAY-september?

[7:04:51] >> teco Witness: yes.

[7:04:53] >> Florida Rising: that is two

[7:04:54] months with higher peak in

[7:04:56] JANUARY outside of the 4cp

[7:04:56] months.

[7:04:58] >> teco Witness: correct

[7:04:58] .

[7:05:00] >> Florida Rising: at line 146

[7:05:06] confirming teco did not

[7:05:07] interrupt or

[7:05:08] curtail any

[7:05:09] customers during any of the

[7:05:11] monthly peaks of the year.

[7:05:11] >

[7:05:12] teco Witness:

[7:05:13] that is correct.

[7:05:15] >> Florida Rising: moving onto

[7:05:16] the last one in the special

[7:05:18] that is f16-93 the 2023 peak

[7:05:43] demand.

[7:05:44] JANUARY 2020 was forecast of a

[7:05:51] peak of 4004 61 mw actual peak

[7:05:52] with 3247 mw.

[7:05:53] >> teco

[7:05:53] Witness: gas.

[7:05:56] >> Florida Rising: which was a

[7:05:58] variance 25% higher than

[7:05:59] actual.

[7:06:01] >> teco Witness: yes

[7:06:01] .

[7:06:03] >> Florida Rising: JANUARY was

[7:06:07] expected to do peak for 2023.

[7:06:09] >> teco Witness: JANUARY is

[7:06:10] always the peak.

[7:06:12] >> Florida Rising: actual peak

[7:06:13] was AUGUST for 4659 mw.

[7:06:15] >> teco Witness: yes.

[7:06:16] >> Florida Rising: looking at

[7:06:20] the monthly peaks were higher

[7:06:21] in MARCH through NOVEMBER.

[7:06:22] >> teco Witness: yes.

[7:06:24] >> Florida Rising: that is six

[7:06:26] months with therapies outside

[7:06:28] of teco is 4cp months

[7:06:28] .

[7:06:29] >> teco Witness: yes.

[7:06:31] >> Florida Rising: if we go to

[7:06:32] line 143 looking across at

[7:06:36] NOVEMBER teco curtailed 109 mw

[7:06:37] of interruptible customers.

[7:06:40] >> teco Witness: in NOVEMBER.

[7:06:50] That was the only instance of

[7:06:51] curtailment we seen in the five

[7:06:53] years of annual review we have

[7:06:54] two review.

[7:06:55] >> teco Witness: within five

[7:06:58] years I thought we reported one

[7:06:58] more don't know when that was.

[7:07:00] It did not fall obviously on

[7:07:02] any of the peak times.

[7:07:04] >> Florida Rising: you might be

[7:07:09] right I think you are right.

[7:07:17] If we can also look in row 130

[7:07:20] and 131 I'm looking at

[7:07:22] NOVEMBER.

[7:07:27] There peak for the month of

[7:07:29] NOVEMBER occurred in the hour

[7:07:30] ending in 5 pm?

[7:07:36] >> teco Witness: in NOVEMBER

[7:07:36] .

[7:07:38] >> Florida Rising: I'm looking

[7:07:45] at the cells and 130 I'm sorry

[7:07:47] that is the hour ending at 4

[7:07:48] pm. You are right.

[7:07:54] The mint temperature at the

[7:07:54] time was 87b0.

[7:07:55] >> teco Witness: that is

[7:07:56] correct.

[7:07:58] >> Florida Rising: I left one

[7:07:59] thing out in the 2022 report if

[7:08:01] we can go back to that really

[7:08:01] quickly.

[7:08:06] F16-92.

[7:08:12] Thank you.

[7:08:14] There if we can go to the same

[7:08:15] place looking at the peak for

[7:08:17] NOVEMBER the time and

[7:08:21] temperature. For NOVEMBER 2022

[7:08:23] at the peak occurred in the

[7:08:26] hour ending in 5 pm

[7:08:26] .

[7:08:28] >> teco Witness: I don't have

[7:08:29] between two up yet.

[7:08:34] 2022 up

[7:08:36] yet. I cannot see (.

[7:08:38] >> Florida Rising: that is

[7:08:59] fair.

[7:09:00] >> teco Witness: thank you.

[7:09:05] >> Florida Rising: I apologize

[7:09:07] for missing this when we were

[7:09:08] on the document.

[7:09:10] >> teco Witness: what are we

[7:09:11] looking at again

[7:09:11] .

[7:09:13] >> Florida Rising: looking at

[7:09:18] the NOVEMBER peak row 133 and

[7:09:21] 134.

[7:09:23] The peak for the month of

[7:09:24] NOVEMBER occurred in at the

[7:09:26] hour ending at 5 pm

[7:09:26] .

[7:09:27] >> teco Witness: that is

[7:09:30] correct

[7:09:30] .

[7:09:31] >> Florida

[7:09:32] Rising: the ambient

[7:09:33] temperature at the time was 86b0

[7:09:34] .

[7:09:34] >> teco Witness: yes.

[7:09:35] >

[7:09:36] Florida Rising: we are done.

[7:09:39] >> teco Witness: you don't have

[7:09:41] the 2024 peak demand report I

[7:09:42] want to reiterate in our

[7:09:46] JANUARY peak I'm not talking

[7:09:48] 4cp I'm just talking in general

[7:09:50] are generally peaks are always

[7:09:51] going to be our highest peak

[7:09:53] because with the plan for the

[7:09:56] 31b0 winter peak we need to make

[7:09:59] sure we have enough capacity

[7:10:01] underground to serve a winter

[7:10:02] peak.

[7:10:03] We don't have one every year

[7:10:05] but we still have the plan for

[7:10:06] that.

[7:10:07] I just want to point out again

[7:10:09] our JUNE and JULY are less two

[7:10:11] months the peaks are within 8

[7:10:12] mw that is 2/10 of a percent

[7:10:15] our current forecast are used

[7:10:17] in this proceeding are very

[7:10:22] accurate.

[7:10:24] >> Florida Rising: can we go to

[7:10:42] f1 6-97 exhibit 831 we will go

[7:11:08] to the tab total retail.

[7:11:09] Are you there.

[7:11:10] >> teco Witness: I am here.

[7:11:16] >> Florida Rising: this

[7:11:18] document with establishing the

[7:11:19] historical retail peak from

[7:11:26] 1973 until 2023?

[7:11:27] >> teco Witness: this

[7:11:28] is one of

[7:11:29] our working files.

[7:11:31] >> Florida Rising: the bold

[7:11:33] blue numbers in this chart

[7:11:34] represents summer peaks.

[7:11:36] >> teco Witness: I think that

[7:11:37] was the intent.

[7:11:39] >> Florida Rising: presumably

[7:11:42] the blue is for cooling

[7:11:43] compared to the red for heating

[7:11:45] for the other bullet numbers.

[7:11:47] >> teco Witness: it is called

[7:11:48] peak versus hot peak.

[7:11:59] >> Florida Rising: generally

[7:12:01] speaking called peaks and

[7:12:02] heartbeats are interchangeable

[7:12:04] the summer and winter peaks.

[7:12:06] Amanda flipped those but that

[7:12:07] is the idea.

[7:12:08] >> teco Witness: yes. I get

[7:12:09] what you're saying.

[7:12:11] >> Florida Rising: started with

[7:12:14] the blue bullet numbers one

[7:12:15] year had looking at the role we

[7:12:17] will look at MAY.

[7:12:19] Are you on the tab total

[7:12:25] retail?

[7:12:26] >> Florida Rising: if you go to

[7:12:28] the column for MAY you would

[7:12:30] agree scrolling down that there

[7:12:35] is one year for which the

[7:12:35] summer peak

[7:12:36] fell in MAY?

[7:12:38] >> teco Witness: yes.

[7:12:38] >

[7:12:39] Florida Rising: if we look over

[7:12:42] at SEPTEMBER and count five

[7:12:45] years the summer peak fell in

[7:12:48] SEPTEMBER?

[7:12:49] >> teco Witness: yes.

[7:12:51] >> Florida Rising: looking at

[7:12:52] the red numbers going first to

[7:12:55] the column for FEBRUARY would

[7:12:57] you agree there are 13 years

[7:13:00] with a winter peak in FEBRUARY?

[7:13:01] I will give you a second to

[7:13:02] count.

[7:13:06] >> teco Witness: how many did

[7:13:07] you say.

[7:13:09] >> Florida Rising: 13?

[7:13:13] >> teco Witness: I counted 15?

[7:13:14] >> Florida Rising: we can take

[7:13:18] 15.

[7:13:19] >> teco Witness: now I counted

[7:13:21] 12 I will go with your number.

[7:13:26] >> Florida Rising: I genuinely

[7:13:27] believe it is 13 but it's

[7:13:29] entirely possible I miscounted.

[7:13:30] Looking now at the column for

[7:13:32] MARCH.

[7:13:33] There are five printer peak

[7:13:36] spring with the winter peak

[7:13:37] occurring in MARCH?

[7:13:42] Then moving to the column for

[7:13:44] NOVEMBER there were four with

[7:13:46] printer peak NOVEMBER?

[7:13:49] >> teco Witness: yes.

[7:13:51] >> Florida Rising: looking at

[7:13:52] the column for DECEMBER there

[7:13:55] were three years with a winter

[7:13:55] peak in DECEMBER

[7:13:55] .

[7:13:57] >> teco Witness: yes.

[7:13:58] >> Florida Rising: you would

[7:14:00] agree that MARCH MAY SEPTEMBER

[7:14:02] NOVEMBER and DECEMBER or onset

[7:14:03] of the 4cp months?

[7:14:05] >> teco Witness: can you repeat

[7:14:06] that

[7:14:06] .

[7:14:08] >> Florida Rising: MARCH MAY

[7:14:09] SEPTEMBER DECEMBER

[7:14:10] are not

[7:14:11] within the 4cp months we are

[7:14:12] talking about.

[7:14:14] >> teco Witness: correct if you

[7:14:16] will accept my representation

[7:14:18] on the separation that would be

[7:14:23] 25 years with which at least

[7:14:24] one seasonal peak occurred

[7:14:25] outside of the 4cp month

[7:14:28] subject to check

[7:14:28] .

[7:14:30] >> teco Witness: subject check.

[7:14:32] >> Florida Rising: that is 25

[7:14:33] years out of 50 years of data

[7:14:34] shown

[7:14:34] .

[7:14:35] >> teco Witness: if your

[7:14:37] numbers are correct

[7:14:37] .

[7:14:39] >> Florida Rising: roughly 50%?

[7:14:40] >> teco Witness: yes.

[7:14:45] >> Florida Rising:

[7:14:46] >> teco Witness: want to point

[7:14:51] out JANUARY we see all the red

[7:14:53] in JANUARY we have numerous

[7:14:55] winter peaks.

[7:14:56] When we do have one it is a

[7:15:00] pretty high peak. Looking at

[7:15:01] 2010. That's been our highest

[7:15:03] one of our highest peaks winter

[7:15:07] peaks ever.

[7:15:09] I just want to point that out

[7:15:10] JANUARY is we have a winter in

[7:15:13] JANUARY the peaks they are very

[7:15:14] high.

[7:15:17] >> Florida Rising: can we

[7:15:19] scroll down to six can we

[7:15:21] scroll down to 6l 52.

[7:15:23] You will see that if you click

[7:15:28] on that row or hover over it

[7:15:32] there is a note that pops up.

[7:15:35] MR. Schultz you might have to

[7:15:37] enable it

[7:15:37] .

[7:15:38] >> teco Witness: I just enabled

[7:15:42] it.

[7:15:48] >> Florida Rising: MS. Fuentes

[7:15:50] are you able to read without

[7:15:51] notes as.

[7:15:52] >> teco Witness: not yet I'm

[7:15:54] trying to make it bigger.

[7:15:55] Give me one minute.

[7:15:55] > Florida

[7:16:00] Rising: I'm in no rush.

[7:16:08] Okay.

[7:16:09] Can you make out what the note

[7:16:10] says?

[7:16:12] > teco Witness: I'm

[7:16:15] trying to read it now.

[7:16:16] >> Florida Rising: you can read

[7:16:18] it.

[7:16:19] >> teco Witness: yes I

[7:16:20] understand the note.

[7:16:22] >> Florida Rising: essentially

[7:16:24] the note is indicating that the

[7:16:27] peak for that winter occurred

[7:16:29] on hot tape that was televised

[7:16:31] megawatts usage in the NOVEMBER

[7:16:34] MARCH season the counted and

[7:16:36] winter for the 18/19 peak

[7:16:36] .

[7:16:37] >> teco Witness:

[7:16:37] that is correct

[7:16:38] .

[7:16:39] >> Florida Rising: can we hover

[7:16:44] over the row for d 54 it should

[7:16:48] be a red bold.

[7:16:49] Is that the same idea for the

[7:16:53] peak for the winter of

[7:16:55] 2019-2020 fell on hot day?

[7:16:56] >> teco Witness: that is

[7:16:59] correct.

[7:17:04] >> Florida Rising: for the cell

[7:17:06] directly below that there is

[7:17:07] another note to indicate the

[7:17:08] same thing.

[7:17:10] >> teco Witness: the same thing

[7:17:12] we tend to mark those we need

[7:17:14] to separate cold and hot peaks.

[7:17:16] >> Florida Rising: for the two

[7:17:18] bold peaks for 2020 2022 and

[7:17:19] 2023 there is not a note on

[7:17:27] those days will be in column l.

[7:17:28] Neither of those has a note

[7:17:28] from

[7:17:28] .

[7:17:31] >> teco Witness: that would be

[7:17:32] because it was a cold

[7:17:37] temperature.

[7:17:38] >> Florida Rising: can I recall

[7:17:40] or focus on the never peaks on

[7:17:47] the 2022 and 2023 demand report

[7:17:49] we can go back to establish my

[7:17:50] representation we

[7:17:51] establishedoccurred on an

[7:17:53] afternoon with the

[7:17:53] temperatures

[7:17:55] in the high upper 80s or in the

[7:17:56] upper 80s.

[7:17:57] >> teco Witness: I do recall

[7:17:59] that we just did not put a

[7:18:00] footnote for those.

[7:18:01] > Florida

[7:18:02] Rising: that's perfectly fine

[7:18:03] that is not a track.

[7:18:05] Just trying to confirm for 4/5

[7:18:07] years for which that has been

[7:18:10] provided 4cp's winter peaks are

[7:18:12] driven by air conditioning use

[7:18:14] on holidays rather than heating

[7:18:17] on cold days.

[7:18:19] >> teco Witness: can you repeat

[7:18:19] that.

[7:18:21] >> Florida Rising: looking at

[7:18:22] the three notes we just looked

[7:18:25] at then the other 2 notes the

[7:18:29] other two that did not have the

[7:18:30] notes.

[7:18:40] This is actually it is 5/6 of

[7:18:42] the most recent years to which

[7:18:44] we have data that the winter

[7:18:47] peak is driven by air

[7:18:47] conditioning use?

[7:18:48] >> teco Witness: it doesn't

[7:18:49] look like that.

[7:18:51] >> Florida Rising: can we go to

[7:18:54] c 10 b

[7:19:01] -six 112 this is your

[7:19:03] exhibit lc 1 is document number

[7:19:27] h. 8. Do you have the document

[7:19:30] up?

[7:19:31] >> teco Witness: I have to

[7:19:35] scroll it.

[7:19:40] Which one are you at?

[7:19:41] >> Florida Rising: I'm on

[7:20:06] document number eight 's this

[7:20:08] shows an increase in the

[7:20:09] expected winter peak beginning

[7:20:10] in 2024?

[7:20:12] >> teco Witness: correct.

[7:20:13] >> Florida Rising: it also

[7:20:15] shows a decrease in the summer

[7:20:17] peak beginning in 2024.

[7:20:18] >> teco Witness: that is

[7:20:19] correct.

[7:20:20] >> Florida Rising: you

[7:20:21] attributed the projected growth

[7:20:23] in the winter peaks to which

[7:20:26] you characterize as recent mild

[7:20:26] winters?

[7:20:28] >> teco Witness: yes you can

[7:20:30] see 2023 was a mild winter is

[7:20:31] transitioning to 2024 which is

[7:20:33] based on 31b0 winter peaks.

[7:20:35] In the summer of 2023 it was

[7:20:37] very hot summer we had our hair

[7:20:38] higher summer peak number

[7:20:40] versus 2024 we are

[7:20:41] transitioning back to normal

[7:20:42] weather.

[7:20:43] That is why is lower.

[7:20:45] >> Florida Rising: think you

[7:20:52] can we go to number f16-100.

[7:21:21] We will go to tab cp.

[7:21:23] >> Florida Rising: this tab

[7:21:25] shows the console data for the

[7:21:36] peak in 2023.

[7:21:37] >> teco Witness: yes this is

[7:21:38] 2023.

[7:21:40] >> Florida Rising: for JANUARY

[7:21:41] 2023 there was a peak of 3347

[7:21:46] mw the resident coincident peak

[7:21:49] was 1845 mw

[7:21:49] .

[7:21:50] >> teco Witness: that is

[7:21:51] correct.

[7:21:52] >> Florida Rising: subject to

[7:21:57] check you would divide if the

[7:21:59] residential coincident peak

[7:22:03] into the overall peak would you

[7:22:05] agree that number is roughly

[7:22:07] 55% does that sound right I

[7:22:09] have a calculator.

[7:22:10] >> teco Witness: that looks

[7:22:11] about right.

[7:22:17] >> Florida Rising: okay.

[7:22:19] That is the percentage is the

[7:22:20] amount of the

[7:22:21] JANUARY retail

[7:22:22] peak attributable to the

[7:22:24] residential customer demand.

[7:22:25] >> teco Witness: subject to

[7:22:26] check yes.

[7:22:27] >> teco Witness:

[7:22:29] >> Florida Rising: would you

[7:22:31] accept my representation that

[7:22:33] if you did that same

[7:22:35] calculation for each row of the

[7:22:42] year that none of the

[7:22:43] percentages for the residential

[7:22:44] classes above 60%?

[7:22:46] Does that sound

[7:22:46] .

[7:22:48] >> teco Witness: I would have

[7:22:52] to do the math I don't know.

[7:22:53] >> Florida Rising: in the

[7:22:55] interest of doing or moving us

[7:23:00] along I will not ask.

[7:23:02] >> teco Witness: subject to

[7:23:03] check I will agree.

[7:23:06] >> Florida Rising: as we sit

[7:23:08] here today although residential

[7:23:09] customers are being given 60%

[7:23:11] of system cost under the 4cp

[7:23:12] model being driven permanently

[7:23:14] by the JANUARY peak the

[7:23:17] forecast peak you are not aware

[7:23:20] of any month for which in the

[7:23:23] actual data the residential

[7:23:29] class resented 60% of the

[7:23:30] coincident peak?

[7:23:32] >> teco Witness: can you repeat

[7:23:33] that.

[7:23:34] >> Florida Rising: residential

[7:23:36] customers are 60% responsible

[7:23:37] for the peaks cost wise under

[7:23:40] teco 4cp cost of service

[7:23:41] methodology.

[7:23:46] >> teco Witness: you are

[7:23:48] starting to get out of my areas

[7:23:49] of expertise I think this

[7:23:50] should be directed at the

[7:23:51] witness williams.

[7:23:53] >> Florida Rising: we will move

[7:23:55] past this.

[7:23:57] We can go to master number

[7:24:29] f16-96.

[7:24:30] We are going to go to the tab

[7:24:33] request forecast.

[7:24:41] Let me know when you are there.

[7:24:48] >> teco Witness: I am there.

[7:24:49] >> Florida Rising: this shows

[7:24:51] teco forecast for the 2025

[7:24:52] energy sales by class and

[7:24:53] month?

[7:24:54] >> teco Witness: yes.

[7:24:57] >> Florida Rising: so with the

[7:24:59] exception of the lighting class

[7:25:03] which is presumably varies in

[7:25:05] the length and gsl d all of the

[7:25:05] classes shown here

[7:25:06] objected to

[7:25:07] peak in SEPTEMBER.

[7:25:10] >> teco Witness: I'm trying to

[7:25:12] make it so I can see better

[7:25:17] hold on.

[7:25:19] You said with the exception of

[7:25:19] .

[7:25:23] >> Florida Rising: of lighting

[7:25:27] and gsl d or all of the other

[7:25:30] classes pictured here are the

[7:25:35] remaining do the residential gs

[7:25:38] and gst classes are they

[7:25:40] projected to peak in SEPTEMBER?

[7:25:45] >> teco Witness: we are talking

[7:25:46] megawatts hours in energy not

[7:25:47] peak demand?

[7:25:49] >> Florida Rising: is the peak

[7:25:51] usage here

[7:25:51] .

[7:25:56] >> teco Witness: there are

[7:25:58] reasons for the schools and

[7:25:59] universities are out part of

[7:26:02] those summer months JULY and

[7:26:04] AUGUST. SEPTEMBER everybody is

[7:26:04] back.

[7:26:06] That's what we have more energy

[7:26:13] in at those months.

[7:26:14] >> Florida Rising: looking at

[7:26:19] the numbers the gst class usage

[7:26:21] from 25 ranges from a low in

[7:26:22] FEBRUARY from about half give

[7:26:24] go what do I in SEPTEMBER from

[7:26:29] a high of 6 kwh would you

[7:26:34] accept my map that is roughly

[7:26:35] 35% increase.

[7:26:36] >> teco Witness: I will accept

[7:26:38] your math.

[7:26:43] >> Florida Rising: if we look

[7:26:45] at the gsl d class there

[7:26:47] productive use ranges from a

[7:26:49] low in FEBRUARY we look at the

[7:26:51] gsl d class there productive

[7:26:54] use ranges from a low in

[7:26:55] FEBRUARY 2.15 gw hours to high

[7:26:56] in JULY of.18 kwh.

[7:26:57] Would you accept my map that is

[7:27:02] about a 15% increase.

[7:27:04] >> teco Witness: apple etc.

[7:27:06] (*speaker14* you would agree to

[7:27:08] large industrial and commercial

[7:27:10] customers are not projected

[7:27:12] toward fat consumption across

[7:27:13] the year.

[7:27:14] >> teco Witness: these are by

[7:27:15] rate schedules.

[7:27:17] There is nonindustrial

[7:27:20] customers in all of these rate

[7:27:22] classes.

[7:27:23] This is just not an industrial

[7:27:28] rate

[7:27:28] .

[7:27:30] >> Florida Rising: you would

[7:27:30] agree that the gs d and gsl d

[7:27:33] classes are associated with

[7:27:36] larger commercial and

[7:27:40] industrial customers

[7:27:41] .

[7:27:42] >> teco Witness: the gsl d

[7:27:43] would be larger.

[7:27:47] >> Florida Rising: that class

[7:27:49] does not have flat consumption

[7:27:50] for each of the year

[7:27:50] but has

[7:27:51] variation.

[7:27:53] > teco Witness:

[7:28:00] no it is not completely flat.

[7:28:02] You have other things that

[7:28:07] influence it.

[7:28:08] Like seasonal weather the

[7:28:10] number of days in the typical

[7:28:12] billing period that fluctuate.

[7:28:14] You will see differences

[7:28:15] because of that not just

[7:28:17] because of their consumption

[7:28:20] pattern.

[7:28:21] >> Florida Rising: you are

[7:28:23] aware of the are we the teco is

[7:28:24] seeking in this case.

[7:28:25] >> teco

[7:28:26] Witness: I'm aware.

[7:28:28] >> Florida Rising: that is

[7:28:28] 11.5%.

[7:28:29] >> teco Witness: yes.

[7:28:32] >> Florida Rising: you are

[7:28:34] where the teco is justifying

[7:28:36] this requested 11.5% are we in

[7:28:37] part on the basis that high

[7:28:39] prices from present future

[7:28:44] inflation estate higher return

[7:28:46] you need to speak with.

[7:28:51] [Listing names] Can we turn to

[7:28:53] the confidential exhibit that

[7:28:56] is been passed out.

[7:28:58] This is hearing exhibit this is

[7:29:04] hearing exhibit 766 it is fll

[7:30:01] -306c.

[7:30:08] >> teco Witness: I have it

[7:30:08] .

[7:30:10] >> Florida Rising: do you

[7:30:11] recognize this document.

[7:30:13] >> teco Witness: yes I do.

[7:30:14] >> Florida Rising: this was

[7:30:16] produced from your workpapers.

[7:30:19] This is a confidential document

[7:30:20] that shows the parts on this

[7:30:21] document that are confidential

[7:30:23] are highlighted in yellow?

[7:30:26] >> teco Witness: yes, those

[7:30:27] were productions.

[7:30:29] >> Florida Rising: in general

[7:30:31] terms, this document shows

[7:30:33] patient escalation rates for

[7:30:34] nonproduction cpi and

[7:30:41] production hwi

[7:30:41] .

[7:30:42] >> teco Witness: yes.

[7:30:44] >> Florida Rising: just to

[7:30:45] clarify for the record cpi is

[7:30:47] the consumer price index.

[7:30:49] >> teco Witness: that is

[7:30:49] correct.

[7:30:51] >> Florida Rising: h wi is the

[7:30:53] handy equipment index according

[7:30:55] to this memo teco uses the cpa

[7:30:57] to guide escalation cost of

[7:30:59] expenses.

[7:31:00] >> teco Witness: what I can

[7:31:02] speak to is we provide this

[7:31:03] memo we get these projections

[7:31:09] from moody's analytics. We

[7:31:10] prepared this memo and

[7:31:12] submitted throughout the

[7:31:14] company in four areas of the

[7:31:15] company that do not have any

[7:31:17] other indices to protect their

[7:31:24] o&m expenses by praying it is

[7:31:26] not used I don't know who uses

[7:31:27] it. Like I said it is just

[7:31:29] available for them as a guide

[7:31:30] if they need value to escalate

[7:31:31] their expenses by.

[7:31:32] >> Florida Rising: if I can

[7:31:34] return to my question.

[7:31:36] The cpi is used by teco to

[7:31:38] escalate content cost?

[7:31:40] As a guide.

[7:31:43] Would it be helpful

[7:31:43] .

[7:31:47] >> teco Witness: it would not

[7:31:47] be all o&m cost I don't know

[7:31:52] which o&m cost apply to the

[7:31:52] cpi?

[7:31:54] >> Florida Rising: if we look

[7:31:56] at the first page of this memo

[7:31:58] the uc under the chart do see

[7:32:00] that all that is bold consumer

[7:32:02] price index?

[7:32:04] >> teco Witness: yes I do

[7:32:04] .

[7:32:06] >> Florida Rising: can you read

[7:32:08] the sentence below that heading

[7:32:13] the cpi at the most widely used

[7:32:14] measure of inflation is a guide

[7:32:17] use when escalating o&m temp

[7:32:18] electric company.

[7:32:20] >> Florida Rising:

[7:32:25] >> teco Witness: it is a guide

[7:32:27] there is many areas of the

[7:32:29] company that haven't thrown

[7:32:30] indices that they use to

[7:32:32] escalate the roof o&m expenses.

[7:32:33] >> Florida Rising: my question

[7:32:35] is whether it was used as a

[7:32:37] guide at teco for escalating

[7:32:38] close expenses. Similarly does

[7:32:40] teco use the handy equipment

[7:32:42] index to escalate costs for

[7:32:45] capital projects to guide the

[7:32:47] escalation of cost for capital

[7:32:53] projects?

[7:32:55] >> teco Witness: we provided

[7:32:56] whether it is used or not I'm

[7:32:58] not sure I would assume some

[7:33:00] areas MAY use it.

[7:33:02] >> Florida Rising: can you read

[7:33:04] the two sentences on the second

[7:33:05] page below the heading that

[7:33:12] reads and equipment index?

[7:33:14] >> teco Witness: the h wi is a

[7:33:15] widely used utility closet next

[7:33:17] the trucks cause based on the

[7:33:19] uniform consistent and related

[7:33:21] plant items for the purposes of

[7:33:23] peak it's a guide to use when

[7:33:25] escalating projects associated

[7:33:28] with our assets.

[7:33:29] Again if they have no other

[7:33:31] indices I don't know who is

[7:33:32] using it or not.

[7:33:34] >> Florida Rising: this is a

[7:33:37] guidance memo that is issued to

[7:33:38] departments at teco to use.

[7:33:40] >> teco Witness: we issue this

[7:33:42] annually

[7:33:42] .

[7:33:43] >> teco Witness: if we can go

[7:33:47] back to the first page.

[7:33:49] Without verbalizing any of the

[7:33:50] highlighted numbers.

[7:33:54] Can you confirm that this chart

[7:34:00] for forecast both the cpi and h

[7:34:11] wi numbers for the next period?

[7:34:13] Basically, it begins in 21, 22,

[7:34:14] 23 the highlighted numbers

[7:34:16] represent the forecast for

[7:34:17] 24-2030?

[7:34:19] >> teco Witness: what was the

[7:34:22] specific question

[7:34:22] .

[7:34:24] >> Florida Rising: making if it

[7:34:25] is a correct characterization

[7:34:27] of the highlighted values on

[7:34:29] this page are the projected

[7:34:30] values for that cpi and h wi

[7:34:37] over that time period between

[7:34:37] 2024 and 2030?

[7:34:39] >> teco Witness: yes those were

[7:34:41] the projections of the time

[7:34:42] that this was prepared 2023.

[7:34:48] >> Florida Rising: and without

[7:34:49] without verbalizing

[7:34:51] confidential information could

[7:34:54] you give an indication of the

[7:34:59] general trend of those

[7:35:00] forecasts?

[7:35:05] I am actually this is also to

[7:35:07] the council please let me know

[7:35:08] if we're getting anywhere we

[7:35:09] should not be?

[7:35:11] >> understood thank you.

[7:35:20] >> teco Witness: for 2024

[7:35:23] inflation is actually higher

[7:35:28] than what we have on this memo.

[7:35:30] >> Florida Rising: I am just

[7:35:32] asking what the memo is

[7:35:34] referring to what does this

[7:35:36] memo forecast in terms of

[7:35:37] inflation. Does it dissipate

[7:35:39] inflation increasing or

[7:35:40] decreasing by these metrics?

[7:35:41] >> teco Witness: we can see in

[7:35:44] 2022 we had a high it has been

[7:35:49] coming down and the production

[7:35:50] period for 2024 and 2025 and

[7:35:54] beyond we expect 2024 to come

[7:36:00] down. We expect 2025 inflation

[7:36:03] to also come down some. Then we

[7:36:04] expect 26-30 to remain at the

[7:36:05] same level as 2025.

[7:36:05] > Florida

[7:36:06] Rising: thank you

[7:36:06] .

[7:36:09] >> teco Witness: I believe

[7:36:11] inflation has been higher in

[7:36:14] 2024.

[7:36:15] >> Florida Rising: are you

[7:36:17] familiar with any documents

[7:36:22] that cooperate that on this

[7:36:23] record that you can point me

[7:36:23] to?

[7:36:27] >> teco Witness: not that I can

[7:36:29] think of

[7:36:30] .

[7:36:32] >> Florida Rising: thank you

[7:36:59] can we move on to f16-9h.

[7:37:00] Just give me a nod when you're

[7:37:02] ready.

[7:37:03] >> teco Witness: I am there.

[7:37:06] >> Florida Rising: okay.

[7:37:15] Do you recognize this document.

[7:37:17] The teco uses a 20 year

[7:37:18] historical to forecast its

[7:37:22] load.

[7:37:23] That 20 year period is also

[7:37:25] used for the predictive period

[7:37:26] for normal weather.

[7:37:28] Teco's normal weather is

[7:37:29] developed by I want to make

[7:37:31] sure I have this right it is by

[7:37:35] averaging them monte carlo

[7:37:37] simulation for the weather in

[7:37:38] those years that directly from

[7:37:40] the 20 years of actual usage

[7:37:41] rather of actual weather data?

[7:37:43] >> teco Witness: we are not

[7:37:45] averaging anything from the

[7:37:47] monte carlo simulation using

[7:37:49] numbers directly from the monte

[7:37:50] carlo simulation on the summary

[7:37:55] tab to 50% probability is what

[7:37:57] we are using to assume as

[7:37:59] normal.

[7:38:02] That is very similar to an

[7:38:08] average of over the 20 years.

[7:38:10] >> Florida Rising: I appreciate

[7:38:12] the clarification. Let's talk

[7:38:13] about the monte carlo

[7:38:15] simulation for the moment.

[7:38:19] Can you explain in general

[7:38:21] terms how they work and are

[7:38:23] used to establish teco's

[7:38:23] baseline?

[7:38:27] >> teco Witness: years back we

[7:38:31] just did a simple average like

[7:38:33] many utilities do. We started

[7:38:35] incorporating the monte carlo

[7:38:37] assimilation so we could get a

[7:38:38] range of possible degree days.

[7:38:42] What them monte carlo

[7:38:44] assimilation do the run through

[7:38:45] numerous iterations and they

[7:38:58] will give you a chart like this

[7:39:00] that says okay there is zero

[7:39:02] probability of having degree

[7:39:04] days at this level present a 5%

[7:39:06] at this level etc. All the way

[7:39:08] to hundred percent probability.

[7:39:10] We used the 50% point that is

[7:39:11] basically minimizing the risk

[7:39:12] of the company.

[7:39:14] It is saying there is a 50%

[7:39:15] chance it is going to be harder

[7:39:17] or there is a 50% chance it

[7:39:18] will be not as hot.

[7:39:20] That is how we use the monte

[7:39:21] carlo simulation.

[7:39:23] The reason we use the software

[7:39:24] versus a simple average is we

[7:39:25] are asked to do different

[7:39:26] scenarios whether scenarios

[7:39:30] which I have provided several

[7:39:32] of those. What we can do is say

[7:39:34] okay what kind of risks are we

[7:39:41] looking at kara we want as

[7:39:42] winterson does only a 5%

[7:39:43] probability of this occurrence

[7:39:45] that we have the numbers

[7:39:47] already we don't have to figure

[7:39:49] out a way like some utilities

[7:39:50] have to do.

[7:39:51] What is a 5% probability.

[7:39:53] We have that available.

[7:39:55] It is just convenient to use

[7:39:58] the monte carlo simulations.

[7:39:59] >> Florida Rising: would be a

[7:40:01] fair comparison to the if you

[7:40:02] want to know the distribution

[7:40:04] of outcomes for rolling to dice

[7:40:05] 1000 times to get that

[7:40:12] distribution curve of the

[7:40:13] possible outcomes.

[7:40:15] >> teco Witness: I don't think

[7:40:15] I will relate

[7:40:16] it to rolling

[7:40:17] dice.

[7:40:18] > Florida Rising: by

[7:40:18] not.

[7:40:22] >> teco Witness: I think I

[7:40:24] can't explain exactly why. I

[7:40:26] don't believe that it is the

[7:40:33] same thing.

[7:40:34] >> Florida Rising: I'm not an

[7:40:36] expert in forecasting I'm

[7:40:38] trying to have something to

[7:40:39] compare it to. That is totally

[7:40:41] fine.

[7:40:42] Looking across the tabs for

[7:40:44] this spreadsheet as a whole.

[7:40:49] There are runs for each month

[7:40:50] which are indicated by the

[7:40:52] number following the simulation

[7:40:53] results.

[7:40:54] > teco Witness: that

[7:40:56] is correct automatically

[7:40:58] created by the software.

[7:40:59] >> Florida Rising: the months

[7:41:01] where teco can experience

[7:41:03] heating or cooling those there

[7:41:04] is an hcd and sed run.

[7:41:05] >> teco Witness: that is

[7:41:06] correct

[7:41:06] .

[7:41:08] >> Florida Rising: for the

[7:41:09] summer months there is one run

[7:41:10] for cdd?

[7:41:16] > teco Witness: yes.

[7:41:27] If we can turn to f3.1-3150

[7:41:40] or fll 51.

[7:41:44] You recognize this exhibit?

[7:41:46] When it comes up?

[7:41:48] >> teco Witness: yes I do.

[7:41:51] >> Florida Rising: the attached

[7:41:53] table on this exhibit shows per

[7:41:58] table for 2022 countries

[7:42:00] forecast or stated the heating

[7:42:04] degree days by 50% on average

[7:42:04] .

[7:42:05] >> teco Witness: yes.

[7:42:07] >> Florida Rising: it

[7:42:08] understated cooling degree days

[7:42:13] by roughly 20% on average

[7:42:13] .

[7:42:14] >> teco Witness: that is

[7:42:15] correct.

[7:42:16] >> Florida Rising: for JANUARY

[7:42:18] but teco expected the annual

[7:42:20] retail peak demand heating

[7:42:21] degrees world fleet 80% and

[7:42:22] cooling is roughly hundred 10%

[7:42:30] higher than charges forecast

[7:42:30] .

[7:42:31] >> teco Witness: that is

[7:42:33] correct the weather is very hot

[7:42:36] in 2022

[7:42:37] .

[7:42:39] >> Florida Rising: that was my

[7:42:40] next question to attribute this

[7:42:42] to the record-breaking weather.

[7:42:44] >> teco Witness: some of the

[7:42:44] months.

[7:42:46] >> Florida Rising: if we can go

[7:42:48] to e >> Florida Rising: if we

[7:42:49] can go to e268.

[7:43:00] It is exhibit 216.

[7:43:02] I gave the wrong number. Can we

[7:43:20] go to e 8 271.

[7:43:21] Do you recognize this document?

[7:43:25] >> teco Witness: yes.

[7:43:29] >> Florida Rising: this is late

[7:43:32] filed exhibit from your desk

[7:43:34] the person this is comparing

[7:43:36] the expected energy sales based

[7:43:42] on degree days for teco is twin

[7:43:44] near-normal versus tenure

[7:43:44] normal.

[7:43:46] >> teco Witness: that is

[7:43:48] correct.

[7:43:49] >> Florida Rising: this chart

[7:43:51] shows that if weather is in

[7:43:53] line with the 10 year normal as

[7:43:54] compared to the 20 year normal

[7:43:56] teco should expect JANUARY

[7:44:02] weather usage to be 20% low

[7:44:02] .

[7:44:04] >> teco Witness: can you repeat

[7:44:04] that.

[7:44:09] >> Florida Rising: if the

[7:44:11] weather for the year is in line

[7:44:12] with the 10 year normal instead

[7:44:14] of the 20 near-normal that

[7:44:18] would be associated with

[7:44:19] roughly 1% decrease in energy

[7:44:20] use is for JANUARY.

[7:44:22] >> teco Witness: for JANUARY

[7:44:24] I'm sorry I was looking at the

[7:44:25] total

[7:44:25] .

[7:44:27] >> Florida Rising: for APRIL

[7:44:28] and MAY sales would be about 2%

[7:44:35] higher given use a 20

[7:44:36] near-normal as reference

[7:44:38] chemical that the reference?

[7:44:41] >> teco Witness: I'm following

[7:44:42] you.

[7:44:43] > Florida Rising: for

[7:44:45] APRIL and MAY it would be about

[7:44:45] 2% higher than the

[7:44:46] reference.

[7:44:47] >> teco Witness: yes.

[7:44:49] >> Florida Rising: for NOVEMBER

[7:44:51] would be to percent higher.

[7:44:52] So similarly the effects of a

[7:44:54] one year of weather that is

[7:44:56] more in line with the 10 year

[7:44:57] normal than the 20 near-normal

[7:44:58] will be associated with an

[7:45:01] additional 204 gw hours of

[7:45:03] energy sales.

[7:45:06] Looking at the summary row at

[7:45:09] the bottom?

[7:45:10] For the difference?

[7:45:12] >> teco

[7:45:13] Witness: which month were

[7:45:14] you

[7:45:15] referring to.

[7:45:20] >> teco Witness: this would be

[7:45:21] row 13 the total annual

[7:45:22] difference yes.

[7:45:24] >> Florida Rising: thank you if

[7:45:29] we could just scroll down to it

[7:45:31] this is late filed 4 does if we

[7:45:38] can scroll to late filed 6 this

[7:45:45] is 8/02/06 I'm sorry 8275.

[7:45:47] >> teco Witness: want to point

[7:45:48] something out before we move

[7:45:49] on.

[7:45:50] We talk about the 20 years

[7:45:54] versus 10 years.

[7:45:59] If we look at things other than

[7:46:01] the last 10 years it has been

[7:46:05] hot.

[7:46:06] I mentioned earlier today 20

[7:46:08] years is kind of the industry

[7:46:13] standard.

[7:46:15] It is actually for standard in

[7:46:16] florida. There is no utility

[7:46:19] using tenures or anything lower

[7:46:20] than 20 years. There is a

[7:46:21] reason for that person sample

[7:46:24] size is the reason when you use

[7:46:25] 20 years you have a large

[7:46:28] sample of it degree days. You

[7:46:30] have 20 years. 10 years we

[7:46:32] consider a small sample. Let's

[7:46:34] import about a large sample is

[7:46:35] stability. Every year when we

[7:46:37] update our normals it's a

[7:46:40] rolling lock.

[7:46:41] Would dropping off your all

[7:46:43] this year and adding your

[7:46:44] newest year. Those two years

[7:46:46] that are changing are very

[7:46:47] different.

[7:46:49] It is going to impact your new

[7:46:50] normal degree days.

[7:46:52] When you've assembled that is

[7:46:56] 20 years old it's a stable

[7:46:59] transition from year to year

[7:47:01] which is very important for the

[7:47:03] company's long-term planning.

[7:47:05] Which like you said before our

[7:47:07] forecasts are not just used for

[7:47:09] revenue it is used for

[7:47:10] long-term planning of

[7:47:12] generation of transmission

[7:47:14] distribution infrastructure

[7:47:16] also used for estate planning

[7:47:18] at the florida liability court

[7:47:20] and counsel this transition of

[7:47:21] our normals is important.

[7:47:23] When you go to attend your

[7:47:25] simple regardless of what has

[7:47:26] been happening with the weather

[7:47:28] when it tenure simple there is

[7:47:30] more instability when you drop

[7:47:32] one year and add your new year

[7:47:33] they are very different

[7:47:35] near-normal will change.

[7:47:38] It MAY change significantly.

[7:47:39] That impacts expansion plans

[7:47:41] the company's infra structure

[7:47:42] planning.

[7:47:43] Ou don't when you

[7:47:44] plan you don't want these

[7:47:50] sudden changes we need to add a

[7:47:52] lot of generation not for sure

[7:47:54] where to take it away. That is

[7:47:55] why we use 20 years.

[7:47:57] That's why am opposed to moving

[7:47:58] to a 10 year look even if it

[7:48:04] has been harder.

[7:48:06] Our normal over 20 years the

[7:48:07] gap is closing between 20 and

[7:48:09] 10 because we have these 10 hot

[7:48:10] years in our 20

[7:48:11] years. That gap

[7:48:13] is closing our normals are very

[7:48:15] very hot and warm here is.

[7:48:16] I illustrate that I've said

[7:48:19] that in my late filed exhibit

[7:48:21] number six bullet it is the

[7:48:27] exhibit number 16 this last

[7:48:29] nine years not that it's just a

[7:48:31] small sample it is anomalous

[7:48:34] compared to the 40 or 50 years

[7:48:36] our. I want to make that

[7:48:37] point. Yes it has been hot

[7:48:39] these past 10 years it is not

[7:48:41] good forecasting practice to

[7:48:45] just look at that back in time.

[7:48:47] >> Florida Rising: it is your

[7:48:49] testimony for the last nine

[7:48:53] years are anomalous.

[7:48:55] >> Florida Rising: compared to

[7:48:57] what we see historically they

[7:48:57] are.

[7:48:59] >> Florida Rising: you would I

[7:49:01] don't think anybody knows that.

[7:49:07] But because there have been

[7:49:09] some number of anomalies during

[7:49:11] that period of time I just

[7:49:13] don't believe that it's a good

[7:49:14] period of time to use as

[7:49:15] normals and to plan the

[7:49:19] company's future with.

[7:49:21] A lot of uncertainty there and

[7:49:23] is not any utilities in florida

[7:49:25] that are willing to do that

[7:49:25] either.

[7:49:27] >> Florida Rising: if I can

[7:49:28] redirect you to my question.

[7:49:34] You would agree that I will

[7:49:36] withdraw the question and move

[7:49:38] on.

[7:49:39] If we can look at the document

[7:49:41] we pulled up next.

[7:49:50] This is e 8 275 this shows the

[7:49:51] cooling degree days in the

[7:49:53] total three days in the cooling

[7:49:59] degree days from 1990-2023.

[7:50:00] I apologize I think it should

[7:50:01] be 1970.

[7:50:03] -2023.

[7:50:06] >> teco Witness: yes.

[7:50:08] >> Florida Rising: looking at

[7:50:09] the heating degree day chart

[7:50:13] which should be I believe the

[7:50:18] second.

[7:50:27] The average 40 monte carlo is

[7:50:28] it the average or the 20 year

[7:50:31] normal for the monte carlo

[7:50:31] simulation.

[7:50:36] >> teco Witness: it is the 50%

[7:50:36] probability.

[7:50:38] >> Florida Rising: the 50%

[7:50:40] probability which we called the

[7:50:41] 20 near-normal that number is

[7:50:45] 431 heating degree days

[7:50:45] .

[7:50:46] >> teco Witness: yes

[7:50:46] .

[7:50:49] >> Florida Rising: if we look

[7:50:56] at this chart it shows that the

[7:50:58] heating degree days have gone

[7:51:00] down dramatically over time not

[7:51:01] just in the last nine years.

[7:51:03] >> teco Witness: they have gone

[7:51:07] down. If we scroll to a few

[7:51:09] more it is illustrated much

[7:51:09] easier to see?

[7:51:10] >> Florida Rising: we will get

[7:51:16] there.

[7:51:17] Would you accept subject to

[7:51:21] check for the 54 years of data

[7:51:25] that are shown here there are

[7:51:27] 23 years for which the total

[7:51:28] heating degree days were fewer

[7:51:32] than teco is 20 near-normal

[7:51:32] .

[7:51:33] >> teco Witness: subject to

[7:51:34] check yes.

[7:51:36] >> Florida Rising: subject to

[7:51:37] check their work tenures with

[7:51:39] fewer heating degree days lower

[7:51:44] than the current 20 near-normal

[7:51:47] in the 34 years between 1970

[7:51:50] and 2003.

[7:51:52] >> teco Witness: subject to

[7:51:53] check.

[7:51:54] >> Florida Rising: 10 out of

[7:52:04] 10/24 hours is roughly 1/3

[7:52:06] subject to check this chart

[7:52:08] shows there were 13 years with

[7:52:09] fewer heating degree days than

[7:52:11] the current 20 near-normal

[7:52:12] between 2004 and 2023?

[7:52:13] >> teco Witness: yes.

[7:52:14] >> Florida Rising: would you

[7:52:15] accept my map that 13/20 is

[7:52:16] roughly 2/3.

[7:52:17] >> teco Witness: yes.

[7:52:20] >> Florida Rising: this one I

[7:52:24] don't think we have to subject

[7:52:26] to check there are fewer of

[7:52:32] them none of tenures had a

[7:52:32] fewer heating to read days the

[7:52:33] 20b0 normal.

[7:52:33] >> teco

[7:52:35] Witness: subject to

[7:52:35] check aspirin.

[7:52:37] >> Florida Rising: that would

[7:52:40] be a rate of 90%

[7:52:40] .

[7:52:41] >> teco Witness: subject to

[7:52:42] check your math yes.

[7:52:44] >> Florida Rising: it's looking

[7:52:46] at the next sheet cooling

[7:52:48] degree days go through the same

[7:52:48] exercise.

[7:52:50] Again there is 54 years of data

[7:52:51] shown on this chart.

[7:52:57] I by my count there are 16

[7:52:59] years for which the total

[7:53:00] cooling degree days were higher

[7:53:02] than teco 20 year normal.

[7:53:08] Would you agree.

[7:53:10] Would you accept there just six

[7:53:12] years with more cooling degree

[7:53:15] days than the current 20

[7:53:16] near-normal in the 34 years

[7:55:33] between 1970 and 2003.

[7:55:34] >> teco Witness: the top left

[7:55:36] is the heating degree days you

[7:55:37] can see that I drafted the

[7:55:39] solid red line is a 20

[7:55:41] near-normal the dotted line is

[7:55:42] the 10 year normal.

[7:55:43] To do the degree days have been

[7:55:45] going down the graph next to it

[7:55:47] is cooling degree days you can

[7:55:49] see it has been higher in the

[7:55:49] last 10 years.

[7:55:51] The point I want to make

[7:56:02] customers are using more energy

[7:56:04] and at the heating degree days

[7:56:06] when it's the heating degree

[7:56:07] date; degree day. In other

[7:56:09] words 10 heating degree days

[7:56:10] customers are going to use a

[7:56:12] lot more than 10 cooling degree

[7:56:12] days.

[7:56:18] Door heating appliances just

[7:56:20] use more electricity vendor

[7:56:21] cooling appliances. We would be

[7:56:23] losing some load on the heating

[7:56:25] site. We are making it up on

[7:56:26] the cooling side.

[7:56:27] if you look at it together

[7:56:29] which is important was on the

[7:56:30] bottom two graphs.

[7:56:32] The bottom left to start with

[7:56:34] you can see the solid red line

[7:56:35] which is my 20 near-normal.

[7:56:37] It is way above those

[7:56:42] historical values.

[7:56:43] All the way back to 1970. We

[7:56:45] are hovering over the highest

[7:56:46] hottest years.

[7:56:55] During that period yes we are

[7:56:57] below the past nine which is a

[7:56:58] are anomalous. Which leads me

[7:57:01] to the second graph. The bottom

[7:57:02] graph on the right. That has

[7:57:03] buxton you see I've put a box

[7:57:05] between 1970 and 2014.

[7:57:06] That looks pretty stable if you

[7:57:08] were to draw a trend line

[7:57:10] through that it would be

[7:57:16] relatively flat and maybe take

[7:57:17] up a little bit one of those

[7:57:19] years in their 2010 which was a

[7:57:21] cold winter not even in a hot

[7:57:22] year. It was a cold year which

[7:57:24] made those total degree days

[7:57:26] spike. That is a stable trend.

[7:57:27] Now boxed in the past nine

[7:57:28] years that we keep talking

[7:57:28] about.

[7:57:41] O me anomalous means

[7:57:43] different than what you expect

[7:57:44] different than what you've seen

[7:57:46] in the past. That is why I'm

[7:57:48] saying those tenures are

[7:57:50] anomalous to me david been

[7:57:51] extremely hot I agree.

[7:57:53] It is nothing like what we have

[7:57:55] seen. To say that those nine

[7:57:56] years there are going to be our

[7:57:58] new normal no utilities ready

[7:57:59] to say that.

[7:58:01] This to me is an important

[7:58:01] illustration.

[7:58:03] I work 20 years is somewhere we

[7:58:09] have those nine years in that

[7:58:11] box area then we have the 10

[7:58:12] years prior to it. Our normals

[7:58:14] are right in between there. Our

[7:58:16] normals are getting harder and

[7:58:16] harder.

[7:58:19] I believe that is just the best

[7:58:20] representation for future

[7:58:22] weather for load forecasting.

[7:58:23] >> Florida Rising: looking at

[7:58:25] these illustrations as you note

[7:58:27] you have your tenure or your 20

[7:58:28] near-normal and retain your

[7:58:29] normal as flatlands you would

[7:58:33] agree that those are not best

[7:58:34] lines for the date on this

[7:58:36] chart on any of these charts.

[7:58:43] >> teco Witness: albert 20 year

[7:58:44] monte carlo 20 year average in

[7:58:46] our monte carlo tenure average.

[7:58:48] >> teco Witness: the data

[7:58:49] points in this chart are not

[7:58:52] monte carlo they are not monte

[7:58:56] carlo numbers correct those are

[7:58:57] actuals.

[7:58:58] >> Florida Rising: you agree

[7:59:00] that tenant 20 year monte carlo

[7:59:01] lines

[7:59:01] .

[7:59:03] >> teco Witness: they are only

[7:59:07] bested for the 20 year period

[7:59:11] not for this entire period.

[7:59:12] >> Florida Rising: even for the

[7:59:15] 20 year period if I understand

[7:59:16] the cancellation.

[7:59:21] >> teco Witness: is an average.

[7:59:23] >> Florida Rising: to your

[7:59:24] point if you draw a neat box

[7:59:26] around the last nine years and

[7:59:29] disaggregate that.

[7:59:30] You would agree if you have one

[7:59:34] year that is an outlier perhaps

[7:59:36] it is not worth changing how

[7:59:37] the system operates.

[7:59:38] Is that fair to say?

[7:59:39] >> teco Witness: that is fair

[7:59:41] to say

[7:59:41] .

[7:59:43] >> Florida Rising: this is nine

[7:59:47] years in a row

[7:59:47] .

[7:59:48] [Unclear audio].

[7:59:50] >> teco

[7:59:52] Witness: that's correct it is

[7:59:54] still anomalous we had a lot of

[7:59:58] winter or the weather events

[7:59:58] such as el nic

[8:00:00] a number of

[8:00:02] those.

[8:00:05] During that period that we do

[8:00:07] not have in the period before

[8:00:11] it.

[8:00:13] I just don't believe those

[8:00:15] tenures should represent our

[8:00:18] future.

[8:00:19] If we did obviously guess our

[8:00:21] retail energy cells would go up

[8:00:23] and all revenues would go up it

[8:00:25] does not viscerally mean that

[8:00:27] the income would go up.

[8:00:29] We would have duet additional

[8:00:33] infrastructure. That costs

[8:00:35] money. There are two sides you

[8:00:37] have to look at.

[8:00:38] Not just the story on energy

[8:00:44] cells.

[8:00:45] >> Florida Rising: recognizing

[8:00:47] we've been talking about up

[8:00:52] time and again 2023 now we are

[8:00:53] in 2024 has 2024 been

[8:00:54] returned

[8:00:56] to normal for teco system.

[8:00:57] >> teco Witness: through JUNE

[8:00:59] we were below our normal degree

[8:00:59] days.

[8:01:09] Through JUNE.

[8:01:10] >> Florida Rising: I think we

[8:01:12] have good document to

[8:01:13] illustrate this to me go to the

[8:01:15] late filed number five this

[8:01:25] will be e 8 274.

[8:01:27] Do you by any chance have a

[8:01:32] copy of your late file that you

[8:01:33] can look at I think it would be

[8:01:35] helpful to go back and forth

[8:01:37] between the heating and cooling

[8:03:11] degree days on the

[8:03:11] .

[8:03:13] >> Florida Rising: it is just

[8:03:20] for heating degree days about

[8:03:21] the tenure normal.

[8:03:22] >> teco Witness: that is

[8:03:23] correct.

[8:03:24] >> Florida Rising: for MARCH it

[8:03:26] is 40 heating degree days

[8:03:27] written aspirin.

[8:03:29] >> teco Witness: that is pure

[8:03:31] heating to read is about the 10

[8:03:31] and 20 near-normal.

[8:03:33] >> teco Witness: I'm sorry what

[8:03:35] was the last thing you said.

[8:03:37] >> Florida Rising: 40 heating

[8:03:38] degree days will be below the

[8:03:40] 40 and 10 near-normal spread.

[8:03:41] > teco Witness: you are in

[8:03:45] MARCH looking at APRIL there

[8:03:46] were three heating degree days

[8:03:50] in APRIL 2024?

[8:03:51] >> teco Witness: that is

[8:03:55] correct.

[8:03:55] >> Florida Rising: that is

[8:03:55] below the 20 near-normal and

[8:03:55] the 10 near-normal fred

[8:03:56] .

[8:03:57] >> teco Witness: yes.

[8:04:00] >> Florida Rising: then of

[8:04:02] course we don't expect heating

[8:04:04] degree days in MAY and JUNE.

[8:04:05] >> teco Witness: that is

[8:04:07] correct if we go to the cooling

[8:04:10] degree days.

[8:04:11] There were 43 cooling degree

[8:04:15] days in JANUARY there were 43

[8:04:17] cooling degree days in JANUARY

[8:04:17] 2024.

[8:04:18] >> teco Witness: that is

[8:04:20] correct that is below the 20

[8:04:21] and 10 year normal.

[8:04:23] >> Florida Rising: yes.

[8:04:24] There were 46 cooling degree

[8:04:29] days in FEBRUARY

[8:04:29] .

[8:04:30] >> teco Witness: that is

[8:04:32] correct again below the 10 and

[8:04:33] 20 near-normal.

[8:04:33] > Florida

[8:04:36] Rising: MARCH there were 122

[8:04:38] cooling degree days and that is

[8:04:40] above the 20 year normal.

[8:04:40] >

[8:04:42] teco Witness: that is.

[8:04:43] >> Florida Rising: for APRIL

[8:04:46] there was 212 cooling degree

[8:04:48] days.

[8:04:50] >> teco Witness: I believe that

[8:04:54] is normal

[8:04:54] .

[8:04:56] >> Florida Rising: that is

[8:04:58] exactly the 20 near-normal.

[8:04:59] >> teco Witness: correct.

[8:05:01] >> Florida Rising: for me to

[8:05:03] work hundred 82 cooling degree

[8:05:04] days.

[8:05:05] >> teco Witness: yes.

[8:05:06] >> Florida Rising: which is

[8:05:09] above the 20 and 10 near-normal

[8:05:09] spread.

[8:05:11] > teco Witness: for

[8:05:12] JUNE the most recent month for

[8:05:14] which you have degree data at

[8:05:16] the time this was produced

[8:05:17] there were 5178 cooling degree

[8:05:18] days.

[8:05:19] That is above the 20 year

[8:05:20] normal.

[8:05:21] >> teco Witness: yes.

[8:05:22] >> Florida Rising: and

[8:05:23] the 10

[8:05:23] for normal.

[8:05:25] >> teco Witness: if we take a

[8:05:26] moment to scroll up through

[8:05:27] that column.

[8:05:29] >> teco Witness: I can tell you

[8:05:30] the total even the 1383 that is

[8:05:32] the lowest we'd seen in 10

[8:05:32] years.

[8:05:34] >> teco Witness: 1383.

[8:05:35] >> Florida Rising: I'm sorry

[8:05:37] I'm on cooling degree days.

[8:05:40] For JUNE I'm comparing that to

[8:05:42] your late filed if we look up

[8:06:26] through JUNE

[8:06:26] .

[8:06:27] >> teco Witness: we are

[8:06:29] planning for the whole theorem

[8:06:30] 1383 is the lowest cooling

[8:06:32] degree days with seen in

[8:06:32] tenures.

[8:06:34] >> Florida Rising: a 10 year

[8:06:38] period which you have 10 year

[8:06:40] period which you characterize

[8:06:40] as

[8:06:40] .

[8:06:40] [Unclear audio].

[8:06:43] >> teco

[8:06:50] Witness:

[8:06:52] >> Florida Rising: it's lowest

[8:06:52] in the 10 year

[8:06:54] period that you

[8:06:55] characterize as higher elevated

[8:06:56] .

[8:06:57] >> teco Witness: that is lower

[8:06:59] than the anomalous period we

[8:07:11] are moving I'm just saying it

[8:07:12] is lower than what we've seen

[8:07:26] in the past 10 years.

[8:07:27] >> Florida Rising: give me a

[8:07:29] moment and try to see if I can

[8:07:34] find a few questions.

[8:07:37] If you can go to your late

[8:07:40] filed number seven this should

[8:07:42] be just a few pages that is not

[8:07:44] included in the staff exhibit

[8:07:49] that is 3.F 3.1-3152

[8:07:51] comprehensive exhibit

[8:07:56] comprehensive exhibit 512.

[8:08:11] Thank you.

[8:08:15] If we can go to page 10 of this

[8:08:53] document.

[8:08:55] I believe it is consistent with

[8:08:56] earlier testimony I want to

[8:09:00] confirm that teco still just on

[8:09:01] point.

[8:09:05] Even though many of the more

[8:09:08] recent years they are being

[8:09:09] driven by cooling not heating.

[8:09:10] >> teco Witness: that is

[8:09:13] correct like I said we need to

[8:09:15] plan for the winter peak for

[8:09:30] capacity planning.

[8:09:31] >> Florida Rising: we are

[8:09:43] getting very close.

[8:09:50] >> Florida Rising: I would like

[8:09:52] to follow up on something as

[8:09:54] true in our conversations

[8:09:55] during

[8:09:57] your deposition as we sit here

[8:09:58] today

[8:09:59] everywhere if emera has

[8:10:01] taken a position on climate

[8:10:01] change.

[8:10:03] >> teco Witness: I'm not aware

[8:10:04] .

[8:10:05] >> Florida Rising: the same

[8:10:06] question for teco.

[8:10:07] >> teco Witness: I don't know.

[8:10:09] >> Florida Rising: in directing

[8:10:11] the activities of local

[8:10:13] researching forecasting for

[8:10:14] temporal letter

[8:10:14] company your

[8:10:16] team acknowledge the coming

[8:10:18] change is consistently

[8:10:19] increasing the average

[8:10:21] temperature of the teco service

[8:10:22] territory.

[8:10:24] >> teco Witness: whether it is

[8:10:25] climate change or not I don't

[8:10:27] know but I would agree it has

[8:10:29] been hotter as we just

[8:10:30] discussed.

[8:10:31] Climate change is a gradual

[8:10:34] change I've seen sudden changes

[8:10:35] as far as I'm concerned.

[8:10:38] >> Florida Rising: does

[8:10:40] temperature increase as the

[8:10:42] demand for air conditioning

[8:10:46] increases

[8:10:46] .

[8:10:47] >> teco Witness: say that one

[8:10:48] time.

[8:10:49] >> Florida Rising: as to

[8:10:51] average temperature grison is

[8:10:53] it fair to say demand for air

[8:10:54] conditioning increases.

[8:10:56] >> teco Witness: the demand

[8:10:57] will increase in the winter

[8:10:57] months

[8:10:59] it can actually decrease

[8:10:59] .

[8:11:01] >> Florida Rising: that is fair

[8:11:03] I guess let's say given the

[8:11:05] data that we look out for last

[8:11:07] number of years which was

[8:11:08] available we were seeing peaks

[8:11:09] in the summer.

[8:11:10] >> teco Witness: yes.

[8:11:16] >> Florida Rising: as the

[8:11:17] temperature in the summer

[8:11:18] increased we would

[8:11:19] expect to see

[8:11:22] higher air-conditioning usage

[8:11:23] during those months.

[8:11:25] >> teco Witness: yes just based

[8:11:25] on that.

[8:11:27] But consumers to change their

[8:11:28] behavior and do conserve at

[8:11:30] times.

[8:11:36] But in general guess.

[8:11:38] >> Florida Rising: because I

[8:11:43] will put it this way we spoke

[8:11:45] about that breakpoint at 65b0

[8:11:46] breakpoint brain that is

[8:11:50] embedded in teco's forecasting

[8:11:51] model.

[8:11:52] > teco Witness: that

[8:11:53] is correct.

[8:11:54] >> Florida Rising: that does

[8:11:56] not assume customers will

[8:11:57] change their

[8:11:57] behavior.

[8:11:59] >> teco Witness: the 65b0 does

[8:11:59] not.

[8:12:01] >> Florida Rising: I recognize

[8:12:04] you make model adjustments for

[8:12:06] energy efficiency and other

[8:12:08] behavioral changes looking at

[8:12:10] just the model itself you would

[8:12:11] agree that if the ambient

[8:12:13] temperature is increasing

[8:12:14] further away from 65b0 there

[8:12:16] would be more load associated

[8:12:18] with returning climate

[8:12:19] controlled spaces to 65b0.

[8:12:21] >> teco Witness: I would say

[8:12:23] because our normal heating

[8:12:24] degree days are increasing then

[8:12:30] I would say even if the 65b0

[8:12:34] points do not change for

[8:12:36] calculating the heating and

[8:12:37] cooling degree days on

[8:12:39] historical basis the future

[8:12:49] normal has changed.

[8:12:51] >> Florida Rising: to clarify

[8:12:51] something I might

[8:12:52] have been

[8:12:54] served I thank you said heating

[8:12:56] degree days increasing did you

[8:12:57] mean cooling degrees.

[8:12:59] >> teco Witness: I meant

[8:13:00] cooling probably.

[8:13:01] >> Florida Rising: I just want

[8:13:03] to make sure I am not cracking

[8:13:04] up.

[8:13:05] recalling our earlier

[8:13:07] discussion on the accuracy of

[8:13:08] load forecasting and its

[8:13:10] potential impacts for revenue.

[8:13:12] Could ignoring the change in

[8:13:13] weather baseline in teco

[8:13:14] service territory benefit teco

[8:13:20] by allowing for higher revenue

[8:13:21] recovery and what is forecasted

[8:13:24] for the year

[8:13:24] .

[8:13:26] >> teco Witness: can you repeat

[8:13:30] that

[8:13:30] again.

[8:13:33] >> Florida Rising: if teco is

[8:13:36] forecast do not take into

[8:13:40] account potentially the new

[8:13:44] normal or you acknowledged the

[8:13:48] temperatures leased and left

[8:13:49] tenures have been elevated for

[8:13:51] what you consider to be at the

[8:13:52] baseline?

[8:13:53] If teco is forecast

[8:13:56] forward-looking forecast treats

[8:14:00] those years anomalies and

[8:14:02] continues to expect lower load

[8:14:04] than his actual could it teco

[8:14:05] be benefiting by recovering

[8:14:09] more energy sales then is

[8:14:10] forecast through the commission

[8:14:15] as part of this rate.

[8:14:17] >> teco Witness: save the last

[8:14:17] part

[8:14:18] of the question I got the

[8:14:19] beginning.

[8:14:20] > Florida Rising:

[8:14:25] diego is making a forecast

[8:14:27] through this commission about

[8:14:29] the amount of energy it expects

[8:14:30] to sell to customers.

[8:14:32] That forecast as we discussed

[8:14:34] as part of the predicate from

[8:14:36] which the ultimate tariff sheet

[8:14:38] and drive to make sure that the

[8:14:43] company can recover its revenue

[8:14:45] requirements. That is based on

[8:14:46] an expected percentage of

[8:14:47] sales.

[8:14:49] >> teco Witness: yes

[8:14:50] .

[8:14:52] >> Florida Rising: rather an

[8:14:53] expected total sales.

[8:14:55] >> teco Witness: correct.

[8:14:56] >> Florida Rising: if teco is

[8:14:58] actual sales or above that

[8:14:59] number it can over recover.

[8:15:03] >> teco Witness: as of this

[8:15:05] before you're looking at just

[8:15:07] one part of the equation. You

[8:15:08] need to look at the expense

[8:15:10] side to if energy sales will

[8:15:11] increase there will be

[8:15:12] increases in the expense side.

[8:15:14] I don't know what that net

[8:15:15] impact is.

[8:15:16] Hen you say

[8:15:18] increase on the expense side

[8:15:19] premium if energy sales are

[8:15:21] higher there could be

[8:15:25] additional content expenses

[8:15:27] maintenance for operational

[8:15:28] purposes. Things like that.

[8:15:30] We are not looking at that burn

[8:15:32] if you are talking long-term

[8:15:33] there could be additional

[8:15:35] capital infrastructure

[8:15:36] expenses.

[8:15:41] You can't just look at the

[8:15:42] impact on energy sales and

[8:15:44] revenue you have to look at the

[8:15:45] big picture to determine what

[8:15:47] the impact would be on the

[8:15:48] revenue requirements.

[8:15:50] >> Florida Rising: for the

[8:15:51] three year rate period that is

[8:15:55] at issue in this case you would

[8:16:00] agree that that we are not

[8:16:02] talking about long-term impacts

[8:16:04] we are talking about the things

[8:16:07] that are forecast for the next

[8:16:07] three years.

[8:16:08] >> teco Witness: it was either

[8:16:10] late filed exhibit or my

[8:16:11] rebuttal testimony were

[8:16:12] actually did a scenario 10

[8:16:14] years and yes revenues went up

[8:16:16] 8/10 of a percent energy went

[8:16:17] up peak demand went up by close

[8:16:22] to 170 mw.

[8:16:24] In the test year of 2025. I

[8:16:25] would think there would be some

[8:16:27] additional cost associated with

[8:16:29] that.

[8:16:32] >> Florida Rising: do you

[8:16:34] recall we looked that peak

[8:16:35] demand charts the general range

[8:16:38] that was offered the

[8:16:40] interruptible and curtail bull

[8:16:43] customers subject to check the

[8:16:53] mid 160-280 I forget what it

[8:16:54] was is it fair to say that

[8:16:57] there was 200 mw that teco can:

[8:16:57] for

[8:16:58] curtailment.

[8:16:59] >> teco Witness: yes

[8:16:59] .

[8:17:01] >> Florida Rising: to the other

[8:17:05] just briefly mentioned increase

[8:17:07] energy sales can be associated

[8:17:09] with increased trend

[8:17:09] that o&m

[8:17:10] expense.

[8:17:11] >> teco Witness: I would

[8:17:17] believe it has an impact.

[8:17:19] >> Florida Rising: that is not

[8:17:21] recovered as part of the base

[8:17:21] rate

[8:17:22] .

[8:17:23] >> teco Witness: I'm getting

[8:17:25] out of my area of expertise I

[8:17:26] will save the current 24 peak

[8:17:28] demand forecast over the past

[8:17:29] two months we've been 8

[8:17:33] megawatts lower than forecast

[8:17:35] 2/10 of a percent or forecast

[8:17:38] based on these 20 year

[8:17:40] forecasts are very much in

[8:17:43] line.

[8:17:44] >> Florida Rising: based on the

[8:17:46] weather normalization.

[8:17:48] >> teco Witness: we don't

[8:17:50] delete weather normalized to

[8:17:51] the men it is more complicated

[8:17:53] on an actual basis the peak

[8:17:54] demands over the past two

[8:17:57] months we've been the actuals

[8:17:59] have been 8 megawatts lower

[8:18:03] 2/10 of a percent or forecast

[8:18:05] the mid forecast online as well

[8:18:07] as the energy forecast for this

[8:18:08] proceeding.

[8:18:09] >> Florida Rising: I have one

[8:18:11] more thing for you can we

[8:18:30] please go to f16-99.

[8:18:32] We are going to go to tab ma

[8:19:49] price.

[8:20:30] [Unclear audio].

[8:20:32] >> Florida Rising: that will

[8:20:33] get you close we are just

[8:20:35] looking for the graph that is

[8:20:41] there.

[8:20:57] [Unclear audio].

[8:20:58] >> teco Witness: I can try to

[8:21:09] scroll to it.

[8:21:12] >> Florida Rising: I figured

[8:21:16] out the cell hoping I can

[8:21:17] figure out and save some time

[8:21:18] from scrolling.

[8:21:26] I apologize.

[8:21:27] >> teco Witness: are you on the

[8:21:29] moving average price.

[8:21:31] >> Florida Rising: moving

[8:21:33] average price it should be

[8:21:35] delete 700 spring you will need

[8:21:42] to go over to the right.

[8:21:43] >> teco Witness: we are getting

[8:21:49] there slowly.

[8:21:55] Got it.

[8:21:58] I am there.

[8:22:00] >> Florida Rising: thank you.

[8:22:01] This is one of your workpapers?

[8:22:05] >> teco Witness: this is done

[8:22:07] under my guidance. I did not

[8:22:08] prepare it myself.

[8:22:10] >> Florida Rising: this track

[8:22:15] we are looking at tracks the

[8:22:17] moving average price of

[8:22:18] electricity per customer).

[8:22:19] >> teco Witness: yes.

[8:22:21] >> Florida Rising: really quick

[8:22:23] about that while we talk about

[8:22:29] ma does replace me and it is

[8:22:31] adjusted for inflation.

[8:22:32] >> teco Witness: correct this

[8:22:34] the total price of inflation

[8:22:37] not the base rate portion.

[8:22:49] >> Florida Rising: I know you

[8:22:51] are not here during MR. Collins

[8:22:53] testimony you MAY not know the

[8:22:55] answer to this. I don't know if

[8:22:56] you're able to listen in but

[8:22:58] MR. Collins testified earlier

[8:23:00] this week when adjusted for

[8:23:01] inflation teco is great not

[8:23:03] increase in left tenures.

[8:23:05] Would you agree with that

[8:23:05] representation.

[8:23:08] >> teco Witness: do you know

[8:23:13] what he was talking about.

[8:23:16] >> Florida Rising: he set in

[8:23:18] this commission he said they

[8:23:20] are not increased in the last

[8:23:21] 10 years.

[8:23:22] I assume he's talking about

[8:23:23] today.

[8:23:24] And years ago.

[8:23:30] >> teco Witness: 2023 if I put

[8:23:33] my cursor on the residential

[8:23:36] aqua colored line

[8:23:38] .

[8:23:41] >> Florida Rising: I'm assuming

[8:23:43] he was talking 2024

[8:23:43] .

[8:23:47] >> teco Witness: I don't know

[8:23:49] if this is the appropriate

[8:23:51] comparison. This is done to

[8:23:52] come up with a price of

[8:23:53] electricity trying to put into

[8:23:55] our consumption models it MAY

[8:24:00] not really be what MR. Collins

[8:24:03] was using.

[8:24:04] >> Florida Rising: let's talk

[8:24:06] about that trend for second.

[8:24:09] The rockwell plan that is the

[8:24:12] residential)

[8:24:12] .

[8:24:14] >> teco Witness: I will say

[8:24:15] this is a 12 month moving

[8:24:16] average.

[8:24:17] The peak that we have because

[8:24:19] of the fuel would be pushed

[8:24:20] would be seen out into the

[8:24:23] future.

[8:24:25] One year or so. That is why I'm

[8:24:26] saying it is not a good

[8:24:33] comparison.

[8:24:34] >> Florida Rising: is a 12

[8:24:36] month moving average this chart

[8:24:37] would flatten the highest

[8:24:38] peaks.

[8:24:39] you might see on a

[8:24:41] month-to-month basis.

[8:24:42] >> teco Witness: it would

[8:24:44] smooth out the month-to-month

[8:24:44] variations.

[8:24:46] >> Florida Rising: looking at

[8:24:50] that blueline you would agree

[8:24:52] that residential prices on this

[8:24:53] chart are shown to be the

[8:24:55] highest they've been in about

[8:24:56] 15 years.

[8:24:58] The moving average price for

[8:24:59] residential customers.

[8:25:01] >> teco Witness: again, I would

[8:25:03] have to recall how we came up

[8:25:07] with all of these numbers.

[8:25:08] >> Florida Rising: looking at

[8:25:10] the documents you provided us.

[8:25:12] That is what it shows?

[8:25:13] >> teco Witness: that is what

[8:25:14] it looks like.

[8:25:16] >> Florida Rising:

[8:25:17] >> teco Witness: that MAY not

[8:25:19] be reality.

[8:25:21] >> Florida Rising: that is

[8:25:22] because of the big spikes

[8:25:25] starting in 2022?

[8:25:28] >> teco Witness: possibly with

[8:25:29] the fuel increases that

[8:25:30] we

[8:25:31] celebrated.

[8:25:37] >> Florida Rising: there is a

[8:25:39] note the one we had to move so

[8:25:41] we can see the blue line. That

[8:25:42] note indicates the spike is due

[8:25:44] to the rate increases following

[8:25:46] the 2021 settlement agreement.

[8:25:48] >> teco Witness: I would assume

[8:25:48] that

[8:25:51] does include the 2022 rate

[8:25:51] increases.

[8:25:52] Speed 14.

[8:25:54] >> Florida Rising: the note.

[8:25:55] [Unclear audio].

[8:25:56] It does not mention fuel prices

[8:25:56] .

[8:26:11] >> teco Witness: no.

[8:26:13] It could be including the fuel

[8:26:15] prices we just don't specify

[8:26:17] these are comments for our own

[8:26:17] use.

[8:26:18] >> Florida Rising: you would

[8:26:20] agree that the aqua blue line

[8:26:27] is higher than the lines for

[8:26:29] industrial and commercial

[8:26:30] commercials which are

[8:26:31] represented by

[8:26:32] purple and dark

[8:26:32] blue.

[8:26:34] >> teco Witness: guess.

[8:26:36] >> Florida Rising: would agree

[8:26:37] following the rate case in 2021

[8:26:40] the residential line increase

[8:26:42] proportionally higher and more

[8:26:43] sharply than the lines for the

[8:26:47] cna classes.

[8:26:48] >> teco Witness: that is what

[8:26:50] it looks like unless it is a

[8:27:02] skill.

[8:27:04] This shows the 12 month moving

[8:27:05] average.

[8:27:07] This is looking only at

[8:27:09] residential.

[8:27:10] And commercial customers.

[8:27:12] >> teco Witness: that is

[8:27:13] correct

[8:27:13] .

[8:27:15] >> Florida Rising: to your

[8:27:16] knowledge does not commercial

[8:27:18] include industrial is it meant

[8:27:20] to be business versus

[8:27:22] residential was that strictly

[8:27:23] commercial.

[8:27:24] >> teco Witness: I am not sure.

[8:27:26] >> Florida Rising: would agree

[8:27:28] at every point on this graph

[8:27:30] blue line is higher than the

[8:27:30] red line?

[8:27:34] >> teco Witness: the rate in

[8:27:36] general is higher for

[8:27:38] residential. So yes.

[8:27:39] >> Florida Rising: when we look

[8:27:41] you see the data plans to come

[8:27:42] up in the key under the x axis

[8:27:46] describes those as residential

[8:27:48] last year and commercial last

[8:27:49] year those represent a forecast

[8:27:52] of what prices would do that

[8:27:54] was made years before this

[8:27:59] document was produced.

[8:28:00] >> teco Witness: those would've

[8:28:02] been the assumption that we had

[8:28:06] used in the prior forecast.

[8:28:07] If this was updated

[8:28:08] correctly

[8:28:09] sometimes we don't update every

[8:28:10] graph friend.

[8:28:12] >> Florida Rising: assuming the

[8:28:14] teco document is correct this

[8:28:16] forecast shows that following

[8:28:18] 2022 prices would decrease for

[8:28:21] customers.

[8:28:23] At least the residential and

[8:28:27] commercial classes shown here.

[8:28:28] >> teco Witness: in real terms

[8:28:30] that is what it looks like.

[8:28:32] >> Florida Rising: the fact

[8:28:34] they increased pretty

[8:28:35] significantly from that point.

[8:28:38] >> teco Witness: again it could

[8:28:39] be the cpi we were using we had

[8:28:48] 8% inflation at some point.

[8:28:49] >> Florida Rising: I am just

[8:28:51] asking what the graph shows.

[8:28:53] You agree with that

[8:28:53] characterization?

[8:28:55] >> teco Witness: repeat your

[8:28:56] characterization.

[8:28:58] >> Florida Rising: instead of

[8:29:00] the client after 2022 prices

[8:29:01] have increased?

[8:29:08] I'm sorry after from 2022

[8:29:10] prices have increased on this

[8:29:10] chart?

[8:29:12] >> teco Witness: that is what

[8:29:14] the graph shows.

[8:29:16] >> Florida Rising: I think this

[8:29:18] gives us a better definition of

[8:29:20] what I was trying to ask on the

[8:29:22] other chart you would agree

[8:29:23] looking at the two lines

[8:29:25] following the last rate case

[8:29:27] the line for the blue class the

[8:29:30] presidential class is a much

[8:29:31] steeper slope associated with

[8:29:37] it.

[8:29:39] >> teco Witness: it does look

[8:29:41] like it there is a foot note

[8:29:42] talking about the.

[8:29:43] [Listing names] I'm not

[8:29:45] familiar with those components

[8:29:46] and what would drive the

[8:29:48] residential higher.

[8:29:50] >> teco

[8:29:51] Witness: is it fair to say

[8:29:52] that.

[8:29:53] [Listing names] Increases

[8:29:55] general rate-based adjustment

[8:29:59] increases is a modification to

[8:30:00] the rate made in the context of

[8:30:02] rate case?

[8:30:04] Are you familiar with the term.

[8:30:09] [Listing names]

[8:30:11] >> teco Witness: guess I'm just

[8:30:13] saying these step increases

[8:30:14] that are being reflected in the

[8:30:16] graphs I don't know if that is

[8:30:19] what is causing the steeper

[8:30:20] increase in the residential

[8:30:22] there MAY be a difference in

[8:30:24] those step increases from the

[8:30:27] different classes.

[8:30:28] This is not my area of

[8:30:30] expertise. When it comes to the

[8:30:31] actual rate.

[8:30:31] >> teco Witness:

[8:30:33] >> Florida Rising: looking at

[8:30:34] this document which was

[8:30:36] produced under your direction

[8:30:38] you would agree that if we look

[8:30:42] at the data point for 2024

[8:30:46] doesn't look cute like there

[8:30:48] has ever been a time in this

[8:30:50] chart when reverential

[8:30:53] customers were further apart

[8:30:54] from the commercial class in

[8:30:56] terms of the higher price that

[8:30:58] they were paying?

[8:30:59] >> teco Witness: not looking at

[8:31:01] this chart but again this chart

[8:31:03] MAY not reflect the same things

[8:31:16] that the witness collins was

[8:31:16] looking at.

[8:31:18] >> Florida Rising: I'm not

[8:31:20] concerned with MR. Collins

[8:31:21] testimony we will keep it to

[8:31:23] this since you are not here.

[8:31:25] You would agree on this chart I

[8:31:26] will ask it this way. Is there

[8:31:28] any point in the history of

[8:31:31] this chart where reverential

[8:31:32] customers have paid a higher

[8:31:34] have been further above the

[8:31:36] commercial class than they are

[8:31:36] currently?

[8:31:38] In terms of the real average.

[8:31:40] The moving average the real

[8:31:40] price?

[8:31:42] >> teco Witness: not on this

[8:31:43] graph.

[8:31:44] >> Florida Rising: thank you

[8:31:46] very much for your patience

[8:31:47] that's all the questions that I

[8:31:48] have.

[8:31:50] >> Mike La Rosa,CHAIRMAN: let's

[8:31:50] move to.

[8:31:56] >> fipug: I have a question for

[8:31:58] you I think I need

[8:31:59] clarification on an answer you

[8:32:00] gave to previously you were

[8:32:02] asked a lot of questions about

[8:32:04] a lot of things and

[8:32:05] temperatures the peak and

[8:32:07] everything that I hear you just

[8:32:09] say the cultists they that has

[8:32:12] ever occurred I assume that

[8:32:13] translates into the highest

[8:32:18] peak was in JANUARY the day is

[8:32:19] that ever since you been with

[8:32:33] the company?

[8:32:35] >> teco Witness: the coldest

[8:32:36] temperature occultist cement

[8:32:37] but

[8:32:38] be different.

[8:32:39] >> Florida Rising: you just

[8:32:41] made a reference he said

[8:32:43] JANUARY was the coldest day I

[8:32:44] remember.

[8:32:45] >> teco Witness: I was speaking

[8:32:46] to JANUARY 2010.

[8:32:47] That is been

[8:32:48] our coldest winter

[8:32:48] peak.

[8:32:50] >> Florida Rising: how long

[8:32:51] have you been with the company

[8:32:51] .

[8:32:58] >> teco Witness: 37 years.

[8:33:03] Thank you that is all I have.

[8:33:05] >> fea: no questions.

[8:33:09] >> Sierra Club: no questions

[8:33:10] thank you.

[8:33:12] >> Florida Retail Federation:

[8:33:12] no questions.

[8:33:21] >> Walmart: no questions.

[8:33:31] >> all right good afternoon MS.

[8:33:32] Fuentes.

[8:33:33] >> teco Witness: good

[8:33:34] afternoon.

[8:33:35] >> has teco's calculated its

[8:33:37] cooling degree days for JULY

[8:33:39] 2020 fourth using international

[8:33:41] airports recorded temperature

[8:33:41] data?

[8:33:43] >> teco Witness: for JULY this

[8:33:45] past month yes we have.

[8:33:46] >> what is that number.

[8:33:48] >> teco Witness: I don't have

[8:33:49] that in front of me.

[8:33:55] >> are you able to locate it.

[8:33:56] I'm going to look to see if I I

[8:34:03] know I had JUNE.

[8:34:06] I will say it was hot.

[8:34:08] It was probably about or about

[8:34:15] our normals I'm sure earlier I

[8:34:20] believe I heard you indicate

[8:34:21] that no florida utility is

[8:34:23] using less than 20 years of

[8:34:25] historical temperatures to

[8:34:26] determine normal weather that I

[8:34:30] hear you correctly.

[8:34:35] >> would it surprise you to

[8:34:36] learn on AUGUST 22 of this year

[8:34:38] for a public utility company

[8:34:40] filed testimony with his

[8:34:43] commission basing its energy

[8:34:45] use per customer forecast on 10

[8:34:47] year normals for cooling degree

[8:34:49] days in docket no: 2024 basing

[8:34:50] its energy use per customer

[8:34:51] forecast on 10 year

[8:34:52] normals for

[8:34:54] cooling degree days in docket

[8:34:55] no: 2020 40099 b

[8:34:55] ei.

[8:34:57] >> teco Witness: that would

[8:34:58] surprise me as of MAY 1 all the

[8:34:59] utilities met there

[8:35:00] was not any

[8:35:01] I'm not sure if they were

[8:35:03] represented at the florida

[8:35:04] reliability coordinating

[8:35:05] council

[8:35:05] .

[8:35:07] >> when you testified earlier

[8:35:08] today and you were unaware of

[8:35:09] that fact.

[8:35:12] >> teco Witness: yes I was.

[8:35:14] >> I would like to go back to

[8:35:20] the monte carlo simulation

[8:35:21] probabilities if we could. Did

[8:35:25] I understand correctly that

[8:35:26] teco's production of annual

[8:35:28] cooling does have a 15%

[8:35:29] probability of being higher

[8:35:31] than actual cooling degree

[8:35:31] days.

[8:35:33] >> teco Witness: that is

[8:35:33] correct.

[8:35:38] >> also the converse 50%

[8:35:40] probability of being lower than

[8:35:43] actual cooling days.

[8:35:44] >> that's basically the same as

[8:35:46] using the simple average.

[8:35:46] >

[8:35:49] for the last nine years or

[8:35:53] 2015-2023 every year teco's

[8:35:54] projected cooling degree days

[8:35:57] that were lower than actual

[8:35:58] cooling degree days is that

[8:35:59] correct.

[8:36:00] >> teco Witness: that is

[8:36:04] correct.

[8:36:05] >> can you explain the method

[8:36:08] for calculating the probability

[8:36:09] of that occurrence.

[8:36:10] >> teco Witness: it's an

[8:36:12] automatic regulation by the

[8:36:16] monte carlo demolition and

[8:36:18] software. We provide the 20

[8:36:19] years worth of data monthly.

[8:36:21] And we have it go through 500

[8:36:25] or 1000 iterations of

[8:36:28] distribution and it comes up

[8:36:33] with the probabilities from

[8:36:37] 0-100 automatically.

[8:36:38] >> I'm asking about the

[8:36:40] specific sequence that occurred

[8:36:41] of those nine years.

[8:36:43] Do you know how to calculate

[8:36:44] the probability of that

[8:36:45] occurring?

[8:36:46] The nine years of

[8:36:47] data from 2015

[8:36:47] .

[8:36:49] >> teco Witness: we did do a

[8:37:00] scenario where we used they

[8:37:02] told us to use I'm not sure if

[8:37:03] it was the staff or another

[8:37:05] intervener had us run the monte

[8:37:09] carlo simulation for a tenure

[8:37:10] scenario. We did that and we

[8:37:11] look at that earlier increased

[8:37:12] our sales by 1%.

[8:37:13] Increased revenues by

[8:37:15] approximately 8/10 of a

[8:37:15] percent.

[8:37:17] We have done that scenario.

[8:37:18] >> let me ask you this would

[8:37:20] you agree that nine straight

[8:37:23] years of actual cooling degree

[8:37:24] days being above the 50%

[8:37:26] probability level is

[8:37:34] represented by the no meal of

[8:37:36] one over two to the ninth power

[8:37:39] or 1/512 which would be 0.2%.

[8:37:40] >> teco Witness: I will trust

[8:37:42] your mouth I cannot do that in

[8:37:43] my head.

[8:37:44] >> thank you very much MS.

[8:37:45] Fuentes I know it was a long

[8:37:47] day I appreciate you answering

[8:37:48] my questions.

[8:37:50] We have nothing further for

[8:37:50] her.

[8:37:57] >> Mike La Rosa,CHAIRMAN: thank

[8:37:58] you commissioners any

[8:37:59] questions?

[8:38:02] Seeing no questions let's send

[8:38:03] it back to teco's for redirect

[8:38:03] .

[8:38:05] >> teco Attorney: no redirect.

[8:38:07] >> Mike La Rosa,CHAIRMAN: let's

[8:38:09] talk about the exhibits and

[8:38:10] entering them into the organ

[8:38:12] spent tampa electric would like

[8:38:14] to move exhibits 25 and 146 and

[8:38:16] the newly identified 138 into

[8:38:16] the record.

[8:38:19] >> Mike La Rosa,CHAIRMAN: any

[8:38:19] objection?

[8:38:21] seeing none I show them entered

[8:38:23] into the record.

[8:38:30] Porter rising would move into

[8:38:30] .

[8:38:31] [Unclear audio].

[8:38:33] >> Mike La

[8:38:36] Rosa,CHAIRMAN: objection no

[8:38:37] objection show that entered

[8:38:38] into the record.

[8:38:41] >> Florida Rising: we would

[8:38:46] move in hearing exhibit 511,

[8:38:50] 512, 766.

[8:38:57] , 663.

[8:39:01] , I don't know how we want to

[8:39:04] approach the step exhibit

[8:39:08] number three which is 831 do

[8:39:10] you want to move those and by

[8:39:11] attachment or move in the

[8:39:12] entire document?

[8:39:17] Or the entire exhibit

[8:39:17] .

[8:39:19] >> Mike La Rosa,CHAIRMAN: I'm

[8:39:21] not familiar with what else is

[8:39:23] attached to it I will look to

[8:39:23] staff.

[8:39:24] > Staff: I would

[8:39:26] recommend just making it a

[8:39:28] competent exhibit it's already

[8:39:29] been numbered as a 31.

[8:39:31] >> Mike La Rosa,CHAIRMAN: the

[8:39:32] whole exhibit.

[8:39:34] >> Florida Rising: I didn't

[8:39:35] want to draw an objection

[8:39:36] bringing in too many things I

[8:39:36] will

[8:39:37] bring 831.

[8:39:40] >> Mike La Rosa,CHAIRMAN: is

[8:39:42] that all anything else is there

[8:39:42] objection?

[8:39:44] Seeing no objection I show that

[8:39:44] entered

[8:39:44] .

[8:39:50] >> Staff: MR. CHAIRMAN when you

[8:39:52] said the last exhibit did you

[8:39:55] same 838 or 138

[8:39:55] .

[8:39:58] >> opc: I said 838

[8:39:58] .

[8:40:02] >> Mike La Rosa,CHAIRMAN: let's

[8:40:03] move 838 if there are no

[8:40:05] objections and exhibit that

[8:40:07] porter rising his offered into

[8:40:07] the record.

[8:40:09] Anything else.

[8:40:09] Any other exhibits.

[8:40:13] Seeing none MS. Fuentes. Your

[8:40:19] excuse.

[8:40:25] I'm sorry you are excused.

[8:40:26] >> she wants to stay longer if

[8:40:27] she could.

[8:40:29] >> Mike La Rosa,CHAIRMAN:

[8:40:30] normally a witness does not

[8:40:31] deny that.

[8:40:32] >> teco Witness: I

[8:40:34] thought you asked if I had any

[8:40:36] questions

[8:40:36] .

[8:40:38] >> Florida Rising: MS. Fuentes

[8:40:39] if you want to do any more

[8:40:49] questions we can do this all

[8:40:49] night.

[8:40:51] >> Mike La Rosa,CHAIRMAN: as

[8:40:53] long as there is not a 30 year

[8:40:54] comparison we are all) Thank

[8:40:56] you for your testimony I will

[8:40:58] kick this over to diego for the

[8:40:59] introduction of the next

[8:41:00] witness.

[8:41:01] >> teco Attorney: tampa

[8:41:10] electric calls ned ellis.

[8:41:12] >> Mike La Rosa,CHAIRMAN: do

[8:41:16] not believe you had been

[8:41:18] administered euros if you mind

[8:41:20] standing in raising the right

[8:41:21] handprint do swear or affirm

[8:41:23] that this is money you're about

[8:41:25] to give will be the truth the

[8:41:27] whole truth and nothing but the

[8:41:27] truth?

[8:41:28] >> teco Witness: yes.

[8:41:30] >> Mike La Rosa,CHAIRMAN: as he

[8:41:32] gets settled still the plan is

[8:41:35] to take a break at 6 pm we are

[8:41:37] still on target we will see how

[8:41:38] this line of questioning goes

[8:41:41] we will break halfway in the

[8:41:41] middle if we need to.

[8:41:48] I will send it over to teco's.

[8:41:49] >> teco Attorney: good

[8:41:50] afternoon are you settled.

[8:41:52] >> teco Witness: yes.

[8:41:53] >> teco Attorney: will you

[8:41:54] state your full name for the

[8:41:55] record.

[8:41:58] >> teco Witness: my name is

[8:41:58] .

[8:42:02] [Listing names]

[8:42:03] >> teco Attorney: who is your

[8:42:05] current employer and what is

[8:42:06] your business address.

[8:42:08] >> teco Witness: smith at smith

[8:42:09] at 207 senate ave.

[8:42:14] MS. Mac

[8:42:14] .

[8:42:16] >> teco Attorney: did you

[8:42:18] prepare and cause to be filed

[8:42:19] in this docket on APRIL 2,

[8:42:19] 2024

[8:42:21] prepare direct testimony

[8:42:22] consisting of 46 pages.

[8:42:24] >> teco Witness: yes.

[8:42:25] >> teco Attorney: did you

[8:42:27] prepare or cause to be filed

[8:42:31] this document on JULY 22 22

[8:42:33] four prepare for battle because

[8:42:35] many consisting of 43 pages.

[8:42:36] >> teco Witness: yes.

[8:42:38] >> teco Attorney: you have any

[8:42:40] additions or corrections to

[8:42:41] your prepared direct or

[8:42:42] rebuttal testimony.

[8:42:44] >> teco Witness: I do not.

[8:42:49] >> teco Attorney: if I were to

[8:42:51] ask you the questions contained

[8:42:52] in your prepared direct and

[8:42:54] rebuttal testimony today would

[8:42:56] your answers be the same as

[8:42:57] those contained therein.

[8:42:58] >> teco Witness: yes.

[8:43:01] >> teco Attorney: MR. CHAIRMAN

[8:43:02] tampa electric request the

[8:43:03] prepared direct rebuttal

[8:43:04] testimony of.

[8:43:06] [Listing names] Be inserted

[8:43:07] into the record as the red did

[8:43:09] you prepare and caused to be

[8:43:11] filed with your direct

[8:43:12] testimony and exhibit marked na

[8:43:14] 1 consisting of four documents.

[8:43:15] >> teco Witness: yes.

[8:43:17] >> teco Attorney: did you also

[8:43:19] prepare and cause to be filed

[8:43:21] with your rebuttal testimony

[8:43:22] and exhibit marked na 2

[8:43:24] consisting of three documents.

[8:43:25] >> teco Witness: yes.

[8:43:27] >> teco Attorney: MR. CHAIRMAN

[8:43:29] tampa electric would note for

[8:43:30] the record that exhibits na one

[8:43:32] in any 2 have been identified

[8:43:34] under ce l as exhibits 26 and

[8:43:34] 147.

[8:43:36] >> teco Attorney: would you

[8:43:38] summarize your prepared and

[8:43:39] summarize your direct and

[8:43:40] rebuttal testimony.

[8:43:42] >> teco Witness: good afternoon

[8:43:44] CHAIRMAN And commissioners my

[8:43:45] name is.

[8:44:14] [Listing names] I performed the

[8:44:16] depreciation study on behalf of

[8:44:17] temperature company my direct

[8:44:19] testimony presents and explains

[8:44:21] that study. The depreciation

[8:44:24] study was conducted based on

[8:44:26] industry-standard methods and

[8:44:27] procedures that are consistent

[8:44:29] with prior depreciation studies

[8:44:31] performed for utilities in

[8:44:32] florida. The study equipment

[8:44:34] service life and salvage as

[8:44:35] misplaced property account as

[8:44:37] well as lifespan estimates for

[8:44:39] each of the companies

[8:44:41] generating facilities those are

[8:44:42] then used along with the

[8:44:44] current company's current

[8:44:46] balance is to catholic

[8:44:47] depreciation rates for each of

[8:44:49] these property groups.

[8:44:51] Estimates that are recommended

[8:44:53] incorporate statistical

[8:44:55] analysis of historical data

[8:44:57] information obtained from site

[8:44:59] visits meetings with company

[8:45:01] personnel. As well as the

[8:45:02] overall experience of myself

[8:45:04] and my staff which includes

[8:45:06] conducting similar depreciation

[8:45:08] studies for utilities across

[8:45:09] the country.

[8:45:10] Including other florida

[8:45:11] utilities as well.

[8:45:13] The study results and overall

[8:45:15] increase in depreciation

[8:45:17] expense of approximately $40.7

[8:45:19] million. As of DECEMBER 31 2024

[8:45:20] does overall increase the

[8:45:22] result of several factors the

[8:45:24] largest of which is actually

[8:45:26] just the mechanical updating of

[8:45:27] depreciation rates to

[8:45:29] incorporate current balances

[8:45:30] that accounts for about 36 of

[8:45:32] the $40 million increase. The

[8:45:34] recommended service life and

[8:45:36] that some adjustments are made

[8:45:38] study for transmission

[8:45:40] distribution accounts result in

[8:45:41] increased offset by a decrease

[8:45:43] in due to longer service life

[8:45:45] for generation accounts net to

[8:45:46] about a $4 million increase.

[8:45:48] My rebuttal testimony response

[8:45:50] to the depreciation blended

[8:45:52] testimony of opc related

[8:45:52] witness.

[8:45:54] [Listing names] MR. Collins

[8:45:55] proposed adjustment to lifespan

[8:45:57] the sewer facilities as well as

[8:45:59] to the average solvers life

[8:46:00] energy storage which anderson

[8:46:02] has been for the belated we

[8:46:04] propose longer lifespans for

[8:46:06] cycle facilities as well as

[8:46:08] different interim survivor for

[8:46:10] production plan accounts longer

[8:46:12] service life for underground

[8:46:14] dissolution conductors and less

[8:46:16] negative that salvage estimates

[8:46:18] for several) That this customer

[8:46:19] bottle has money does agree

[8:46:21] with each of these

[8:46:22] recommendations opc and that

[8:46:24] the proposal for longer

[8:46:25] lifespans for solar and cycle

[8:46:27] plans do not in my opinion

[8:46:28] adequately consider factors

[8:46:30] will contribute to the

[8:46:32] retirement of these facilities

[8:46:33] just changing technology

[8:46:35] changes the operating

[8:46:37] environment and other economic

[8:46:38] factors that I believe are

[8:46:40] likely to limit the overall

[8:46:42] lifespan of these facilities.

[8:46:43] The proposed survivor curves

[8:46:46] are a set of best practices and

[8:46:47] typical estimates in the

[8:46:49] industry example the estimate

[8:46:51] of no three survivor curve is

[8:46:53] very unusual and does not

[8:46:55] really suit the property study

[8:46:56] particularly well.

[8:46:58] Additionally I think MR. Enders

[8:47:00] testimony did not interpret

[8:47:02] historical data is also true

[8:47:03] with the net salvage estimates

[8:47:05] and made in general I think my

[8:47:06] recommendations are better

[8:47:08] aligned with the data was

[8:47:10] properly interpreted and

[8:47:12] analyzed prints in summary

[8:47:13] think the other party's

[8:47:15] proposals are based on limited

[8:47:17] information analysis and failed

[8:47:18] to consider the

[8:47:19] many ways the

[8:47:20] company and really the entire

[8:47:22] industry will change in the

[8:47:24] coming decades. I think my

[8:47:26] regulations for each of these

[8:47:27] accounts reflect the future

[8:47:29] life and that salvage estimates

[8:47:31] life net salvage expectations

[8:47:33] based on the information and

[8:47:35] data we have today. Thank you I

[8:47:36] concludes my summary.

[8:47:38] >> teco Attorney: we tender the

[8:47:39] spec for

[8:47:40] cross-examination.

[8:47:42] >> opc: thank you MR. Chair

[8:47:43] hello MR. [Listing names] If

[8:47:45] you don't mind milliken jumped

[8:47:46] right into questioning.

[8:47:48] You recommended a 30 year

[8:47:49] average

[8:47:50] service life for solar

[8:47:51] facilities

[8:47:51] correct.

[8:47:52] >> teco Witness: yes.

[8:47:54] >> opc: isn't true that the

[8:47:56] teco service life as officers

[8:47:57] is 35 years.

[8:47:59] >> teco Witness: not exactly.

[8:48:01] Based on the settlement of the

[8:48:02] prior case if there is a b

[8:48:03] 35

[8:48:04] lifespan and the company

[8:48:06] proposed a 30 year lifespan of

[8:48:08] the prior depreciation study.

[8:48:09] >> Florida Rising:

[8:48:11] >> opc: thank you and 2021 you

[8:48:13] testified on behalf of florida

[8:48:15] power & light companies

[8:48:16] depreciation study.

[8:48:17] >> teco Witness: yes.

[8:48:18] >> Florida Rising:

[8:48:19] >> opc: ur b

[8:48:20] 35 lifespan for

[8:48:22] solar facilities.

[8:48:23] >> teco Witness: I don't make a

[8:48:24] cushion at the request of

[8:48:26] witness ferguson ever was a 30

[8:48:28] year lifespan for solar

[8:48:29] facilities.

[8:48:31] >> opc: fpl current levels all

[8:48:32] facilities in 35 years.

[8:48:34] >> teco Witness: based on the

[8:48:36] result of that case.

[8:48:37] >> opc: in this case you

[8:48:39] provided calculations for a 35

[8:48:40] year average service life.

[8:48:42] >> teco Witness: I did in my

[8:48:44] rebuttal testimony want to make

[8:48:46] sure that dk collated

[8:48:48] depreciation rates from other

[8:48:50] proposals were performed

[8:48:51] consistent with how we have

[8:48:53] done depreciation studies

[8:48:56] everywhere that mary bottle has

[8:48:56] money.

[8:48:57] >> opc: that's on exhibit any 2

[8:48:58] page 1 of

[8:48:58] two.

[8:49:00] >> teco Witness: correct.

[8:49:02] >> opc: your calculations are

[8:49:04] not original in support of a 35

[8:49:06] year overall service life for

[8:49:07] solar generation facilities.

[8:49:09] >> teco Witness: I'm not sure I

[8:49:11] fully understand the question.

[8:49:14] >> opc: are your calculations

[8:49:16] for a 35 year service life for

[8:49:17] tampa electric solar

[8:49:18] generation

[8:49:20] facilities reasonable.

[8:49:21] >> teco Witness: I've proposed

[8:49:24] 30 your life I would expect I

[8:49:25] believe that to be the most

[8:49:26] reasonable. 35 is appose

[8:49:28] outside the range of

[8:49:30] possibilities I think a 30 year

[8:49:32] lifespan is more reasonable

[8:49:34] regarding a 35 year lifespan is

[8:49:35] reasonable.

[8:49:36] >> teco Witness: that is not

[8:49:38] what it said it is within range

[8:49:40] of potential more reasonable

[8:49:42] possibilities for the future.

[8:49:42] >>

[8:49:44] opc: thank you that's all

[8:49:44] from opc.

[8:49:46] >> Florida Rising: I just have

[8:49:47] very short questions.

[8:49:50] Thank you CHAIRMAN Brintnall

[8:49:51] good afternoon good

[8:49:52] evening.

[8:49:53] [Listing names] Generally would

[8:49:55] you agree it makes sense as a

[8:49:57] practice to match depreciation

[8:49:58] with service life?

[8:49:59] >> teco Witness: yes.

[8:50:01] >> Florida Rising: thank you so

[8:50:03] much of those are my questions

[8:50:03] .

[8:50:04] >> fipug: I just have a few

[8:50:05] questions.

[8:50:07] In response to the question

[8:50:08] about the combined cycle she

[8:50:10] said there is a range that is

[8:50:11] reasonable what is the range?

[8:50:13] >> teco Witness: he asked me

[8:50:14] about the solar lifespans.

[8:50:17] >> fipug: what was your range

[8:50:18] when you said there was a

[8:50:19] range.

[8:50:20] >> teco Witness: for solar we

[8:50:22] typically seen lifespans in the

[8:50:23] 25-35 year range

[8:50:24] kind of the

[8:50:25] midpoint of that.

[8:50:27] >> fipug: have you looked do

[8:50:29] have knowledge a lot of leases

[8:50:30] being dealt with solar or 35

[8:50:39] years with five years options

[8:50:40] those type of things.

[8:50:42] >> teco Witness: I'm not sure

[8:50:44] if you are referring to any

[8:50:46] specific ones I know some solar

[8:50:47] cells have leases in the map

[8:50:48] during terms.

[8:50:50] >> fipug: I'm just asking you

[8:50:52] do this pretty regularly with

[8:50:52] solar rights?

[8:50:54] >> teco Witness: I'm not

[8:50:56] familiar with every lease term

[8:50:57] until their lease terms and

[8:50:59] things like that but I been

[8:51:01] involved in the studies that

[8:51:03] had hundreds of different solar

[8:51:03] facilities.

[8:51:05] >> fipug: in europe and he said

[8:51:08] the entire industry will change

[8:51:08] materially in the

[8:51:09] future what

[8:51:10] did you mean by that.

[8:51:12] >> teco Witness: there is quite

[8:51:13] a bit to it.

[8:51:15] First of all technology.

[8:51:16] Technology has changed a lot.

[8:51:18] I look back to when I started

[8:51:20] about 18 years ago when most of

[8:51:21] the generating fleet was a

[8:51:24] coal-fired generation and

[8:51:26] things in the past 18 years we

[8:51:27] saw that turnover a lot sooner

[8:51:28] than people expected.

[8:51:37] That is been driven by new gas

[8:51:39] fire cycle technology that is

[8:51:40] gotten much more efficient and

[8:51:42] solar and other things like

[8:51:44] that. I think in the future we

[8:51:45] will see a lot more of those

[8:51:47] type of changes that will

[8:51:49] potentially impact the existing

[8:51:50] generation might be there new

[8:51:52] things without thought of yet.

[8:51:54] I think were seeing changes in

[8:51:56] load growth electrification and

[8:51:57] things like that will have an

[8:51:59] impact obviously there is need

[8:52:01] to make system resilient and

[8:52:02] reliable does a lot of

[8:52:03] investments going on.

[8:52:05] Really for my experience I

[8:52:06] think there is a lot that is

[8:52:08] going to change in the coming

[8:52:08] two decades.

[8:52:10] Hat will impact

[8:52:11] public just about everything.

[8:52:13] >> fipug: that's all I have

[8:52:13] thank you.

[8:52:15] >> Mike La Rosa,CHAIRMAN:

[8:52:17] >> fea: no questions.

[8:52:23] >> Sierra Club: no questions.

[8:52:24] >> Fuel Retailors: no

[8:52:25] questions.

[8:52:26] >> Walmart: no questions.

[8:52:32] >> yes MR. CHAIRMAN.

[8:52:36] MR. [Listing names] Is it

[8:52:44] correct that teco recently

[8:52:46] filed an updated revenue

[8:52:48] requirement which includes an

[8:52:49] increase of battery storage

[8:52:51] life from your proposal of

[8:52:54] b,10-20 years?

[8:52:55] >> teco Witness: I don't know

[8:52:57] exactly what was filed my

[8:52:58] understanding is that yes they

[8:52:59] stipulated to a 20 your life

[8:53:00] for energy storage.

[8:53:03] >> will that increase in

[8:53:04] service life have any impact on

[8:53:10] teco's theoretical reserve

[8:53:14] balance as of DECEMBER 21 of

[8:53:14] 2024.

[8:53:16] >> teco Witness: yes it will

[8:53:18] although was a fairly masses I

[8:53:26] would not have it fairly big

[8:53:28] impact brian box when you say

[8:53:29] you don't expected to have that

[8:53:31] much of an impact you have any

[8:53:33] sort of estimate or number that

[8:53:34] you can give me roughly?

[8:53:36] >> teco Witness: that might be

[8:53:37] in the I think we did

[8:53:39] calculations with the 20 year

[8:53:40] period in my rebuttal

[8:53:49] testimony.

[8:53:50] i don't know I have that

[8:53:52] information it is certainly

[8:53:53] something that we can

[8:53:53] calculate.

[8:53:55] >> also want to ask you is it

[8:54:00] correct that opc proposed use

[8:54:02] 35 year service life for the

[8:54:04] sole facilities and set up your

[8:54:04] 30?

[8:54:06] >> teco Witness: yes 35 year

[8:54:08] average service life instead of

[8:54:09] three years.

[8:54:11] >> if the commission approved a

[8:54:15] b,35 service life what would be

[8:54:17] the impact again on the reserve

[8:54:18] balance?

[8:54:20] >> teco Witness: similarly it

[8:54:23] would change.

[8:54:26] I don't know thereby have been

[8:54:27] discovery that we responded to

[8:54:28] that.

[8:54:31] >> teco Witness: up or down

[8:54:32] with a longer life the

[8:54:34] theoretical reserve would

[8:54:37] decrease which would it would

[8:54:39] make the reserve in balance it

[8:54:49] depends on whether positive or

[8:54:49] negative number. It

[8:54:50] would change

[8:54:52] the theoretical reserve which

[8:54:54] might make it larger or smaller

[8:54:54] depending.

[8:54:56] >> thank you I have nothing

[8:54:57] further for that witness.

[8:54:59] >> Mike La Rosa,CHAIRMAN: thank

[8:55:01] you commissioners. Any

[8:55:02] questions.

[8:55:03] Seeing none I sent it back to

[8:55:04] you for redirect

[8:55:04] .

[8:55:08] >> teco Attorney: no redirect

[8:55:08] .

[8:55:10] >> Mike La Rosa,CHAIRMAN: let's

[8:55:12] talk about exhibits on the

[8:55:12] record.

[8:55:14] >> teco Attorney: tampa

[8:55:15] electric like to move exhibit

[8:55:17] 26 and 147 into the record.

[8:55:21] >> Mike La Rosa,CHAIRMAN: any

[8:55:21] objection?

[8:55:21] seeing none I sure them entered

[8:55:25] into the record.

[8:55:27] Opc any of the units.

[8:55:28] >> opc: no exhibits.

[8:55:30] >> Mike La Rosa,CHAIRMAN: any

[8:55:31] other parties have exhibits.

[8:55:33] Seeing none thank you for being

[8:55:34] here today.

[8:55:35] You are excused.

[8:55:40] All rights it's about seven

[8:55:44] minutes before 6 o'clock I said

[8:55:46] we will take a break at 6

[8:55:47] o'clock let's take a break

[8:55:49] early we can reconvene at 6:30

[8:55:50] pm.

[8:55:56] We will see you guys then.

[9:33:53] >> Mike La Rosa,CHAIRMAN: I

[9:33:54] think we are ready to

[9:34:03] reconvene.

[9:34:05] Where we have left off.

[9:34:09] It is now back in teco's hand

[9:34:12] to introduce the next witness.

[9:34:14] >> teco Attorney: thank you MR.

[9:34:17] CHAIRMAN tampa electric called.

[9:34:19] [Listing names] To the stand.

[9:34:21] >> Mike La Rosa,CHAIRMAN: do

[9:34:22] you mind standing up to

[9:34:24] administer the oath to swear or

[9:34:26] affirm the testimony you're

[9:34:28] about to give will be the truth

[9:34:30] the whole truth and nothing but

[9:34:31] the truth.

[9:34:32] Thank you.

[9:34:34] >> teco Attorney: good evening.

[9:34:35] [Listing names] Would you

[9:34:37] please state your full name for

[9:34:38] the record.

[9:34:40] >> teco Witness: [Listing

[9:34:41] names]

[9:34:42] >> Mike La Rosa,CHAIRMAN: I

[9:34:44] think your microphone might be

[9:34:44] off.

[9:34:45] The green light?

[9:34:47] >> teco Witness: [Listing

[9:34:52] names].

[9:34:53] >> teco Attorney: who is your

[9:34:53] current

[9:34:55] employer what is your

[9:34:56] business address.

[9:34:58] >> teco Witness: [Listing

[9:35:18] names] Address 1400 1400 merck

[9:35:20] pkwy., kansas city, mo. Spinner

[9:35:22] did you prepare and cause to be

[9:35:24] filed in this docket and APRIL

[9:35:25] 2, 2024 prepared direct

[9:35:27] testimony consisting of 19

[9:35:27] pages.

[9:35:29] >> teco Witness: kisha davis.

[9:35:31] >> teco Attorney: did you

[9:35:32] prepare and caused

[9:35:32] to be filed

[9:35:34] in this docket on JULY 2, 2024

[9:35:36] prepared rebuttal testimony

[9:35:37] consisting of 16 pages.

[9:35:38] >> teco Witness: yes.

[9:35:40] >> teco Attorney: do you have

[9:35:42] any additions or corrections to

[9:35:42] your

[9:35:44] prepared direct or rebuttal

[9:35:45] testimony.

[9:35:46] >> teco Witness: no.

[9:35:48] >> teco Attorney: if I were to

[9:35:50] ask you the questions prepared

[9:35:51] in your direct and rebuttal

[9:35:53] testimony today would your

[9:35:54] answers be the same as your

[9:35:56] answers contained therein.

[9:35:56] >

[9:35:57] teco Attorney: MR. CHAIRMAN

[9:35:59] tampa electric would like to

[9:36:01] prepared direct and rebuttal

[9:36:02] testimony of.

[9:36:03] [Listing names] To be inserted

[9:36:05] into the record is so red.

[9:36:07] Did you also prepare and cause

[9:36:09] to be filed with your direct

[9:36:11] testimony and exhibits marked j

[9:36:11] kate 1 consisting

[9:36:12] of three

[9:36:13] documents.

[9:36:14] >> teco Witness: yes.

[9:36:16] >> teco Attorney: tampa

[9:36:17] electric would note for the

[9:36:19] record that exhibit jk one has

[9:36:20] been identified in the ctl as

[9:36:21] exhibit 27.

[9:36:23] Would you please summarize your

[9:36:25] prepared direct and rebuttal

[9:36:25] testimony.

[9:36:27] >> teco Witness: commissioners

[9:36:29] i provided direct testimony in

[9:36:31] this case regarding the

[9:36:32] dismantlement study prepared by

[9:36:44] me and my team at 1898 for

[9:36:46] electric company. As outlined

[9:36:48] in my direct estimate the

[9:36:49] purpose of the study was to

[9:36:51] review tampa electric's fleet

[9:36:53] of generating assets and make

[9:36:55] recommendations to the company

[9:36:56] regarding the total cost of

[9:36:58] this metal the facilities at

[9:36:59] the end of their useful life.

[9:37:01] My team and I previously

[9:37:03] prepared a similar study for

[9:37:04] the company in 2020 in support

[9:37:06] of the company's depreciation

[9:37:08] filing the qantas military

[9:37:09] service to update the cost

[9:37:11] presented in the 2020 study for

[9:37:13] changes to market conditions

[9:37:14] physical changes that have

[9:37:16] occurred at the plants and

[9:37:17] incorporating new facilities

[9:37:20] that have been constructed or

[9:37:21] acquired since 2020. My team

[9:37:23] and I relied upon our vast

[9:37:25] experience and in-house data as

[9:37:26] well as information from

[9:37:29] electric company to perform the

[9:37:30] study. The total dismantling

[9:37:32] cost is determined by 1898 and

[9:37:33] reflected in the dismantlement

[9:37:35] study are net of salvage value

[9:37:37] for scrap materials at each

[9:37:38] plant. This mental exhaustion

[9:37:40] study brutalize as an input

[9:37:42] into killing dismantlement

[9:37:43] approvals in this case.

[9:37:46] The estimates of dismantlement

[9:37:47] cost were repaired with the

[9:37:49] intent of most accurately

[9:37:51] representing what 1898 wooden

[9:37:53] displayed contractors bidding

[9:37:54] to dismantle the equipment

[9:37:56] address environmental issues

[9:37:58] and restore the site through a

[9:38:00] competitive bidding process.

[9:38:01] Site-specific cost estimates

[9:38:03] were developed using a bottom

[9:38:05] up cost estimating approach

[9:38:06] request estimates are developed

[9:38:08] from scratch through the

[9:38:10] development of site-specific

[9:38:12] quantity estimates and that the

[9:38:13] application of unit pricing

[9:38:15] rates to the quantity

[9:38:15] estimates.

[9:38:17] The dismantlement study is

[9:38:18] consistent with the rule 25-

[9:38:20] 6.0436 four of the florida

[9:38:21] administrative code regarding

[9:38:23] electric utilities

[9:38:25] dismantlement study's inc.'s

[9:38:26] methodologies used in prior

[9:38:28] studies we are prepared that

[9:38:29] have been approved by this

[9:38:31] commission and other utility

[9:38:33] commissions throughout the

[9:38:35] country. And incorporates

[9:38:36] industry-standard data. The

[9:38:38] study results and cost

[9:38:40] estimates are reasonable

[9:38:41] estimates and appropriate for

[9:38:43] the company to rely on their

[9:38:44] dismantlement preserve needs.

[9:38:46] My rebuttal testimony addresses

[9:38:49] three issues raised by the

[9:38:50] direct testimony of florida

[9:38:52] office of public counsel

[9:38:53] witness was back witness

[9:38:55] recommends dismantlement

[9:38:57] expense should exclude all

[9:38:58] forecasts growth in the

[9:39:00] dismantlement cost and expense

[9:39:01] beyond the end of the test year

[9:39:03] over rule 25-6.0436 four of the

[9:39:05] florida administrative code

[9:39:07] regarding electric utilities

[9:39:09] dismantlement study's

[9:39:10] specifically includes

[9:39:12] escalation rates used in

[9:39:13] converting the current

[9:39:15] estimated dismantlement cost to

[9:39:16] future estimated dismantlement

[9:39:18] cost. It is reasonable and

[9:39:20] appropriate that the 2023 cost

[9:39:21] I provided my dismantlement

[9:39:23] study should be escalated to

[9:39:25] future years to account for the

[9:39:26] impact of inflation to put them

[9:39:28] in the year dollars in which

[9:39:30] they will be expended and to

[9:39:31] most accurately reflect the

[9:39:33] actual cost to be incurred

[9:39:35] consistent with this role.

[9:39:37] Witness: recommend the of the

[9:39:39] dismantlement cost on the solar

[9:39:40] generating assets because he

[9:39:43] suggest removing or for site

[9:39:44] restoration activities each of

[9:39:48] these facilities. Rule 25-

[9:39:48] 6.0436 four of the four

[9:39:48] admission of code regarding

[9:39:50] electric utilities

[9:39:52] dismantlement study's

[9:39:54] specifically includes site

[9:39:55] restoration and its definition

[9:39:57] of dismantling cost. These are

[9:39:59] reasonable and appropriate cost

[9:40:01] that should be included in the

[9:40:03] garden for the solar generating

[9:40:05] asset facilities. Just as they

[9:40:07] are at the other generating

[9:40:08] facilities.

[9:40:10] Lastly MR. Collins states that

[9:40:11] the company's contingency

[9:40:13] assumptions are extremely

[9:40:15] speculative and not known and

[9:40:16] measurable. Again rule

[9:40:18] 25-6.0436 four of the florida

[9:40:19] mission of code regarding

[9:40:21] electric utilities

[9:40:23] dismantlement study is also

[9:40:25] specifically addressed this

[9:40:27] contingency is a component of

[9:40:29] dismantlement study spread

[9:40:30] furthermore the application of

[9:40:31] contingency is not only

[9:40:33] appropriate but also entered

[9:40:35] industry practice which is been

[9:40:36] approved by this commission on

[9:40:38] prior cases electric and other

[9:40:39] utilities.

[9:40:40] This concludes my

[9:40:40] summary.

[9:40:42] >> teco Attorney: MR. CHAIRMAN

[9:40:43] we tender.

[9:40:45] Listing names] For

[9:40:46] cross-examination.

[9:40:46] > opc:

[9:40:48] thank you MR. CHAIRMAN and good

[9:40:49] evening.

[9:40:52] [Listing names]

[9:40:53] >> teco Witness: good evening.

[9:40:57] >> opc: I will go and

[9:40:57] get into

[9:40:57] the questioning would you agree

[9:40:59] that a lease agreement

[9:41:00] typically states the

[9:41:02] requirements for the lease land

[9:41:04] which the solar facilities

[9:41:04] constructed.

[9:41:06] >> teco Witness: ps.

[9:41:08] >> opc: those requirements MAY

[9:41:10] impact decommissioning

[9:41:11] assumptions.

[9:41:12] >> teco Witness: ps.

[9:41:13] >> opc: MAY impact

[9:41:14] decommissioning obligations.

[9:41:16] >> teco Witness: ps.

[9:41:18] >> opc: requirements such as

[9:41:19] environmental remediation.

[9:41:21] >> teco Witness: test

[9:41:21] that can

[9:41:22] be one components.

[9:41:24] >> opc: requirements are set

[9:41:25] restoration.

[9:41:26] >> teco Witness: yes.

[9:41:28] >> opc: is it true that you do

[9:41:30] not review the lease at 25/35

[9:41:30] solar sites.

[9:41:32] >> teco Witness: some of the

[9:41:34] lease agreements were not

[9:41:35] available for review.

[9:41:37] >> opc: new do not build the

[9:41:39] rimadyl remediation performance

[9:41:40] for the 25 sites.

[9:41:42] >> teco Witness: I don't know

[9:41:48] if there were any additional

[9:41:49] .

[9:41:50] >> opc: can you please answer

[9:41:52] the question with a yes or not

[9:41:53] then answer the question.

[9:41:55] >> teco Witness: yes no I don't

[9:41:58] know if there any requirements

[9:41:59] specifically stated in those

[9:42:01] leases but typically those

[9:42:02] requirements are above and

[9:42:04] beyond our standards

[9:42:05] assumptions for site

[9:42:07] restoration would typically

[9:42:07] include a minimum

[9:42:09] level of site

[9:42:10] restoration that is appropriate

[9:42:12] and we reviewed those leases to

[9:42:14] see if there is additional

[9:42:15] requirements beyond those

[9:42:16] minimal requirements.

[9:42:18] >> opc: thank you for your time

[9:42:19] today opc

[9:42:20] has no more questions.

[9:42:22] >> Florida Rising: thank you

[9:42:23] CHAIRMAN Good evening.

[9:42:25] I have one question for you

[9:42:26] generally

[9:42:27] speaking do you teco

[9:42:28] future projected peaks

[9:42:29] affect

[9:42:30] dismantling cost.

[9:42:31] >> teco Witness:?

[9:42:33] >> Florida Rising: that's my

[9:42:34] question.

[9:42:35] > fipug: good

[9:42:35] evening.

[9:42:37] [Listing names] For the.

[9:42:39] [Listing names] You mention you

[9:42:40] reviewed some places do recall

[9:42:42] if those were 35 year leases.

[9:42:44] >> teco Witness: I don't recall

[9:42:46] it is not looking for the

[9:42:48] duration of lease just the site

[9:42:49] requirements or site

[9:42:51] restoration performance were

[9:42:51] included.

[9:42:53] >> fipug: you have any

[9:42:54] information with respect to

[9:42:56] property owners possibly not

[9:42:57] wanting to solar facilities

[9:42:59] removed from their property if

[9:43:01] they are continuing to produce

[9:43:04] energy. If that was the case

[9:43:06] there would not be any

[9:43:07] dismantlement cost associated

[9:43:08] with that correct.

[9:43:10] >> teco Witness: are not aware

[9:43:12] of any of the leases I guess

[9:43:13] I'm not quite sure I understand

[9:43:14] the question.

[9:43:16] >> fipug: if you own the

[9:43:18] property and lease it for 30 or

[9:43:20] 35 years to a utility utility

[9:43:21] comes in and put a bunch of

[9:43:23] solar assets on it but say

[9:43:24] after 15 years they said you

[9:43:26] know what there are no more

[9:43:28] efficient solar and they put

[9:43:29] solar assets on it have another

[9:43:31] 15 years on the lease at the

[9:43:33] end if the landowner had the

[9:43:35] option to say thank you the

[9:43:35] lease is over.

[9:43:37] Go about your business you

[9:43:39] don't need to get the solar off

[9:43:43] the property.

[9:43:44] Just leave it here I will take

[9:43:46] it over I will sell the energy

[9:43:47] from it.

[9:43:48] And operate the solar field

[9:43:50] have you ever seen that or her

[9:43:51] of that.

[9:43:52] >> teco Witness: I've heard of

[9:43:54] it being an option in the

[9:43:55] lease.

[9:43:56] Our studies are all looking at

[9:43:58] the liability at the end of the

[9:44:00] useful life of the facility.

[9:44:02] This is what is the cost for

[9:44:05] restoring the site and that

[9:44:07] obligation is still typically

[9:44:08] on the utility at the end of

[9:44:12] the life to take it out.

[9:44:13] >> fipug: if you're looking at

[9:44:15] a lease and saw that provision

[9:44:17] would you make an adjustment

[9:44:17] for that?

[9:44:19] Or would you assume that they

[9:44:20] will come get this up and have

[9:44:21] to take it out?

[9:44:23] >> teco Witness: I haven't seen

[9:44:25] leases that include the option

[9:44:26] for the owner to make their

[9:44:28] decision about living in things

[9:44:31] like

[9:44:32] , roads at a windfarm or

[9:44:34] things like that. But the

[9:44:36] obligation is still always on

[9:44:38] the lessor I'm sorry to lessee

[9:44:39] the utility to take out

[9:44:40] everything at the end of life.

[9:44:47] >> fipug: that's all I have.

[9:44:51] >> fea: no question thank you

[9:44:51] .

[9:44:52] >> Sierra Club: no questions

[9:44:54] MR. CHAIRMAN

[9:44:55] .

[9:44:57] >> Florida Retail Federation:

[9:44:57] no questions.

[9:44:58] >> Walmart: no question thank

[9:44:58] you.

[9:45:04] >> no question thank you

[9:45:04] .

[9:45:06] >> Mike La Rosa,CHAIRMAN:

[9:45:07] commissioners see none teco

[9:45:09] back in your hands for

[9:45:12] redirects.

[9:45:13] >> teco Attorney: no redirects.

[9:45:16] >> Mike La Rosa,CHAIRMAN: let's

[9:45:18] talk about exhibits teco any

[9:45:19] exhibits to enter into the

[9:45:23] record

[9:45:23] .

[9:45:25] >> teco Attorney: yes MR.

[9:45:26] CHAIRMAN we would move exhibit

[9:45:28] 27 into the record please.

[9:45:30] >> Mike La Rosa,CHAIRMAN: any

[9:45:32] objection I show that entered

[9:45:33] into the record opc none any

[9:45:35] other parties that have

[9:45:36] objections seeing non-excellent

[9:45:37] . Thank you for being here

[9:45:43] today you are excused.

[9:45:44] Teco back in your hands to

[9:45:45] produce your next witness.

[9:46:01] >> teco Attorney: I will do the

[9:46:03] oath if you don't mind stand

[9:46:05] and raise your hand to affirm

[9:46:06] that this is the money you're

[9:46:08] about to give is the truth the

[9:46:10] whole truth and nothing but the

[9:46:11] truth.

[9:46:12] >> teco Witness: yes.

[9:46:14] >> Mike La Rosa,CHAIRMAN: thank

[9:46:14] you.

[9:46:15] >> teco Attorney: good

[9:46:16] evening.

[9:46:18] >> teco Witness: good evening

[9:46:20] spinning can you state your

[9:46:21] full name for the record.

[9:46:23] >> teco Witness: [Listing

[9:46:29] names]

[9:46:31] >> teco Attorney: who is your

[9:46:32] current employer and what

[9:46:32] is

[9:46:34] your business address.

[9:46:35] >> teco Witness: it is.

[9:46:37] [Listing names] My business

[9:46:45] address is 3000 atrium way

[9:46:46] suite 200 in mount laurel new

[9:46:46] jersey.

[9:46:48] > teco Attorney: did

[9:46:49] you prepare and caused to be

[9:46:51] filed in this docket and APRIL

[9:46:53] 2, 2020 fourth prepare direct

[9:46:55] testimony consisting of 92

[9:47:18] pages

[9:47:18] .

[9:47:20] >> teco Witness: yes.

[9:47:22] >> Fuel Retailors: you prepare

[9:47:23] and cause to be filed in this

[9:47:25] docket on JULY 2, 2024 prepare

[9:47:27] rebuttal testimony consisting

[9:47:28] of 135 pages.

[9:47:29] >> teco Witness: yes.

[9:47:31] >> teco Attorney: you have any

[9:47:32] additions or corrections to

[9:47:34] your prepared direct or

[9:47:35] rebuttal testimony?

[9:47:36] >> teco Witness: no.

[9:47:38] >> teco Attorney: if I were to

[9:47:39] ask you the questions contained

[9:47:41] in your prepared direct or

[9:47:43] rebuttal testimony today would

[9:47:44] your answers be the same as

[9:47:46] those contained therein.

[9:47:48] >> teco Witness: they would.

[9:47:50] >> teco Attorney: MR. CHAIRMAN

[9:47:52] electric requests that prepared

[9:47:54] and direct and rebuttal

[9:47:55] testimony of.

[9:47:56] [Listing names] Be inserted

[9:47:58] into the record as though

[9:47:58] ready.

[9:48:00] Did you also prepare and cause

[9:48:02] to be filed with your direct

[9:48:03] testimony and exhibits marked

[9:48:05] dw d 1 consisting of 15

[9:48:05] documents.

[9:48:07] >> teco Witness: ps spinning

[9:48:09] did you also prepare and cause

[9:48:11] to be filed with your testimony

[9:48:12] and exhibits marked dw d 2

[9:48:14] consisting of 19 documents.

[9:48:15] >> teco Witness: yes.

[9:48:17] >> teco Attorney: MR. CHAIRMAN

[9:48:19] tampa electric would note for

[9:48:20] the record that exhibits dw d 1

[9:48:23] 2 have been identified on the

[9:48:24] cl as exhibit 28 and 148.

[9:48:26] Would you please summarize your

[9:48:28] prepared direct and rebuttal

[9:48:28] testimony.

[9:48:31] >> teco Witness: good evening

[9:48:33] commissioners thank you for the

[9:48:35] opportunity to appear today. My

[9:48:35] name is.

[9:48:37] [Listing names] I'm a partner

[9:48:39] at scott madden inc. The

[9:48:41] purpose of my testimony is to

[9:48:43] provide a recommendation

[9:48:45] regarding the return on common

[9:48:46] equity referred to as are we

[9:48:48] our cost of equity. For tampa

[9:48:49] electric company.

[9:48:51] Which I also referred to as

[9:48:53] teco. As well as provide an

[9:48:54] assessment of the company's

[9:48:56] capital structure is to be used

[9:48:58] for ratemaking purposes.

[9:48:59] Please note I felt direct

[9:49:00] testimony and exhibits on

[9:49:02] behalf of teco as well as

[9:49:04] submitted rebuttal testimony to

[9:49:05] respond to the florida office

[9:49:07] of public counsel or opc

[9:49:07] witness.

[9:49:09] [Listing names] Federal

[9:49:11] executive agencies or fea

[9:49:12] witness christopher walters

[9:49:14] florida retail federation or

[9:49:16] afar witness stephen chris.

[9:49:23] [Listing names] With respect to

[9:49:27] the companies roe in this case

[9:49:29] I will refer to those parties

[9:49:31] as the intervener roe

[9:49:32] witnesses.

[9:49:36] In a few of current markets and

[9:49:38] the results of my analytical

[9:49:39] models presented in my

[9:49:42] testimony the reasonable range

[9:49:44] of roe applicable to teco is

[9:49:48] between 10.31% and 11.93%.

[9:49:49] Within that range I recommend

[9:49:51] that the commission to

[9:49:57] authorize and roe of 11.50%.

[9:49:59] My recommended roe considers of

[9:50:01] various factors to get sitter

[9:50:02] the required return to the

[9:50:04] equity investors of the

[9:50:04] company.

[9:50:08] My testimony discusses the

[9:50:10] multiple analytical approaches

[9:50:12] that were evaluated to develop

[9:50:15] my roe recommendations my

[9:50:17] testimony explains that no

[9:50:19] single model is inherently so

[9:50:29] precise that it can be allowed

[9:50:31] on to the exclusion of other

[9:50:32] theoretically sound models.

[9:50:34] Using multiple models as a

[9:50:35] liability to the estimated

[9:50:37] common equity cost ratio and

[9:50:39] supported both the financial

[9:50:41] literature and regulatory

[9:50:42] precedent.

[9:50:44] My testimony explains how the

[9:50:46] analysis to determine an

[9:50:48] appropriate roe is affected by

[9:50:49] the various business and

[9:50:51] financial risk faced by the

[9:50:52] company.

[9:50:53] My roe recommendation also

[9:50:55] considers factors as effective

[9:50:57] rotation cost of the company's

[9:50:58] bond rating. As well as the

[9:51:00] company's high level customer

[9:51:02] growth whether risk and capital

[9:51:04] investment plans relative to

[9:51:06] the companies in the proxy.

[9:51:08] The analysis presented in my

[9:51:10] testimony support the company's

[9:51:11] requested ratemaking capital

[9:51:13] structure which includes a

[9:51:15] common equity ratio of 54%.

[9:51:16] That common equity ration is

[9:51:18] consistent with equity ratio

[9:51:20] maintained by the proxy groups

[9:51:22] and their operating utilities

[9:51:24] subsidiary companies.

[9:51:26] Finally my testimony response

[9:51:28] to the issues raised by the and

[9:51:29] addresses the shortcomings

[9:51:31] within the intervening roe

[9:51:33] witness testimony none of the

[9:51:35] arguments changed by conclusion

[9:51:37] that the company should be

[9:51:38] authorized an opportunity to

[9:51:40] earn a roe of 11.50% likewise

[9:51:44] the analysis should not

[9:51:46] persuade the commission to

[9:51:48] approve a roe for teco up below

[9:51:50] my regulation. That includes my

[9:51:50] summary.

[9:51:52] >> teco Attorney: we tender.

[9:51:52] [Listing

[9:51:54] names] For

[9:51:55] cross-examination.

[9:51:55] > opc:

[9:51:56] good evening.

[9:51:58] [Listing names] How are you

[9:51:59] doing.

[9:52:00] >> teco Witness: doing well.

[9:52:02] >> opc: I would ask you to take

[9:52:09] a look at let me start with

[9:52:10] this, you have testified or

[9:52:12] filed testimony in a proximally

[9:52:13] 150 predatory

[9:52:15] proceedings

[9:52:15] correct.

[9:52:16] >> teco Witness: yes.

[9:52:18] >> opc: it would be true to say

[9:52:19] in all of those cases you

[9:52:23] testified on behalf of of

[9:52:23] utilities right.

[9:52:24] > teco

[9:52:25] Witness: yes.

[9:52:27] >> opc: let me direct your

[9:52:29] attention to page 19 of your

[9:52:36] testimony.

[9:52:38] >> teco Witness: yes ma'am

[9:52:38] .

[9:52:44] >> opc: it looks like we are

[9:52:46] there as well. In this section

[9:52:47] of your testimony this is where

[9:52:50] you start your discussion about

[9:52:51] capital structure.

[9:52:53] >> teco Witness: yes the bottom

[9:52:54] of page 19 starting at line

[9:52:55] 22.

[9:52:58] >> opc: okay.

[9:52:59] am I correct that tampa

[9:53:01] electric is requesting a

[9:53:06] capital structure of 41.57%

[9:53:08] long-term debt and 54% equity?

[9:53:10] >> teco Witness: common equity

[9:53:10] yes.

[9:53:17] >> opc: you use a proxy group

[9:53:19] to be representative of teco

[9:53:21] and the equity ratio and the

[9:53:22] return on equity it

[9:53:23] should

[9:53:24] receive correct.

[9:53:25] >> teco Witness: yes ma'am.

[9:53:27] >> opc: in looking at page 23

[9:53:29] of that testimony of your

[9:53:36] testimony, [Unclear audio].

[9:53:37] I'm assuming you are looking at

[9:53:37] 918.

[9:53:40] Of that portion?

[9:53:43] >> teco Witness: you mean lines

[9:53:49] 9-18?

[9:53:50] >> opc: let me get there just

[9:53:52] one second?

[9:53:55] I'm specifically looking at the

[9:53:56] sentence that starts at line

[9:54:00] 18.

[9:54:01] It says the equity ratios of

[9:54:03] your proxy group of companies

[9:54:09] range from 28.9%-56-56.13%

[9:54:13] for the fiscal year 2022 as

[9:54:18] shown in pages three and four

[9:54:20] of your document number three

[9:54:24] is that correct.

[9:54:24] >> teco Witness: that is right.

[9:54:25] >> opc: would you agree the

[9:54:26] simple average for the 14

[9:54:27] companies in your proxy group

[9:54:32] is a 33 is a 33.46% equity

[9:54:34] ratio subject to check

[9:54:34] .

[9:54:34] >> opc:

[9:54:38] >> teco Witness: if you look at

[9:54:39] document number three page 4 of

[9:54:51] five there is the simple

[9:54:53] average of the proxy group

[9:54:56] companies.

[9:55:03] That is there.

[9:55:04] The common equity ratio the

[9:55:06] simple average is 41.49 but my

[9:55:08] testimony faith that the 54%

[9:55:08] equity ratio is within the

[9:55:10] range of capital structures

[9:55:14] ,

[9:55:15] maintained by the proxy group

[9:55:17] person and their operating

[9:55:19] subsidiaries. Like I said it's

[9:55:21] appropriate because it is

[9:55:25] representative of an electric

[9:55:26] utility company.

[9:55:30] >> opc: just want to make sure

[9:55:34] heard you correctly.

[9:55:36] This simple average which you

[9:55:38] said you calculated is actually

[9:55:38] 44%?

[9:55:40] For the proxy group.

[9:55:41] >> teco Witness: no it would be

[9:55:43] bates number I guess 107.

[9:55:44] >>

[9:55:46] opc: I'm sorry which page are

[9:55:50] you looking at it and if you're

[9:55:51] looking at document number

[9:55:53] three page number four go to

[9:55:54] the bottom it says proxy group

[9:55:56] 14 electric utility companies.

[9:55:59] You will see the average of the

[9:56:01] 14 utility companies it is 55%

[9:56:04] or 55.3% long-term debt.

[9:56:07] 2.72% short-term debt.

[9:56:12] 0.49% preferred stock and 41.49

[9:56:13] common equities do you see

[9:56:15] that?

[9:56:16] >> opc: that is what I'm trying

[9:56:19] to say.

[9:56:20] >> teco Witness: it is up

[9:56:20] there.

[9:56:27] >> opc: I'm seeing that now.

[9:56:29] That is divided by years

[9:56:30] correct

[9:56:30] .

[9:56:33] >> teco Witness: if you look at

[9:56:37] the top row of that schedule

[9:56:41] you will see it is 2022 /2021.

[9:56:43] What I was looking at their

[9:56:48] four 2022 is that number.

[9:56:54] >> opc: okay.

[9:56:56] You are just looking at 2022 of

[9:56:58] the five year average for the

[9:56:59] proxy group would be 53.4%?

[9:57:01] >> teco Witness: the long-term

[9:57:02] debt ratio is 53.4%.

[9:57:09] >> opc: the five year average

[9:57:10] for the

[9:57:11] common equity is 43.26%?

[9:57:12] >> teco Witness: that is

[9:57:13] correct.

[9:57:16] >> opc: you would agree based

[9:57:21] on this average that we've

[9:57:24] looked at on page 4/5 the only

[9:57:28] company actually let me take

[9:57:32] you to page 3 of this exhibit.

[9:57:33] The only company that I see

[9:57:37] that has a higher equity ratio

[9:57:43] then tampa electric is I corp.

[9:57:45] Which is an equity ratio of 56%

[9:57:46] is that correct

[9:57:46] .

[9:57:47] >> teco Witness: that is

[9:57:50] correct like a said my

[9:57:52] testimony is that it is

[9:57:54] consistent with the range if of

[9:57:57] both the holding company and

[9:57:59] the operating subsidiary

[9:58:01] companies of the proxy group

[9:58:03] companies if you take a look at

[9:58:06] the page 5/5 of that document

[9:58:08] you'll see that a lot of the

[9:58:09] operating companies are in that

[9:58:22] low 50 52 mid 50 range.

[9:58:23] >> opc: these were at the proxy

[9:58:25] group companies that you

[9:58:26] actually chose as a

[9:58:30] preventative correct

[9:58:30] .

[9:58:32] >> teco Witness: the issue with

[9:58:34] using operating subsidiary

[9:58:36] companies in a roe analysis is

[9:58:39] that you cannot use them is

[9:58:40] they don't have the market

[9:58:42] data. In an ideal world you

[9:58:46] would have publicly traded

[9:58:48] utility companies to do your

[9:58:50] roe analysis. In this case you

[9:58:52] have to use these holding

[9:58:52] companies.

[9:58:58] The more appropriate proxy when

[9:59:00] you look at the appropriate

[9:59:02] capital structure would be the

[9:59:05] operating subsidiaries. But

[9:59:07] anyway you slice it if you use

[9:59:18] holding companies

[9:59:19] .

[9:59:21] >> opc: commissioners can I ask

[9:59:22] to answer the question that

[9:59:24] asked witches this was the

[9:59:26] proxy group that he chose?

[9:59:27] That was the question.

[9:59:29] >> Mike La Rosa,CHAIRMAN: if

[9:59:31] you have a sufficient answer to

[9:59:33] the question let's move on to

[9:59:34] the next question.

[9:59:35] >> opc: thank you.

[9:59:37] Conversely the lower the

[9:59:38] percentage of the debt the

[9:59:38] company

[9:59:40] has in its capital

[9:59:41] structure the lower the return

[9:59:43] on equity or exposure to

[9:59:44] financial risk the common

[9:59:46] equity investors expect correct

[9:59:46] .

[9:59:48] >> teco Witness: can you repeat

[9:59:49] that please.

[9:59:50] >> opc: let me ask you this

[9:59:52] first brian would you agree

[9:59:54] that the higher the percentage

[9:59:56] of debt in the capital

[9:59:57] structure fire at the financial

[9:59:59] risk the common equity owners

[10:00:01] they would expect a higher

[10:00:02] return on common equity

[10:00:04] forbearing desire financial

[10:00:04] risk?

[10:00:05] >> teco Witness: agree.

[10:00:07] >> opc: conversely, the lower

[10:00:09] the percentage of debt the

[10:00:11] company has in its capital

[10:00:12] structure the lower the return

[10:00:14] on equity for exposure to

[10:00:15] financial risk the common

[10:00:17] equity investor would expect?

[10:00:19] >> teco Witness: this is all

[10:00:20] equal.

[10:00:22] >> opc: all else being equal.

[10:00:24] >> teco Witness: then I would

[10:00:25] agree with you.

[10:00:26] >> opc: looking at your

[10:00:30] document number one your

[10:00:34] exhibit 1 document number two

[10:00:47] let me see if let's get there.

[10:00:52] Okay, this shows the models

[10:01:00] that you used for excuse me

[10:01:02] preparation of your recommended

[10:01:03] roe correct?

[10:01:04] >> teco Witness: yes ma'am it

[10:01:15] was superseded in my exhibit dw

[10:01:17] d 2 my initial analysis is what

[10:01:18] you are referring to.

[10:01:20] >> opc: in other words this is

[10:01:21] your 4 miles that you use with

[10:01:23] your updated results.

[10:01:24] >> teco Witness: the government

[10:01:26] did not rely on the non-

[10:01:28] regulated proxy group in this

[10:01:29] case nor did I rely on the

[10:01:31] pr/pm in this case. Just

[10:01:32] predictive risk model.

[10:01:34] >> opc: we will get that in the

[10:01:34] second.

[10:01:36] In this case you are

[10:01:37] recommending a roe of 11.5 is

[10:01:38] that

[10:01:38] correct.

[10:01:47] >> teco Witness: that is)

[10:01:47] .

[10:01:48] >> opc: you are recommending

[10:01:50] the 11.5 a roe despite the

[10:01:52] company's capital structure and

[10:01:52] that cost.

[10:01:54] >> teco Witness: despite?

[10:01:56] I'm going to disagree with your

[10:02:02] question. If you look at dw d1

[10:02:03] or d to schedule a tour

[10:02:05] document to the first thing you

[10:02:07] do you look at your model

[10:02:09] results then you compare them

[10:02:10] with you compare teco with the

[10:02:15] proxy group company.

[10:02:16] To figure out whether or not

[10:02:18] they have extremely risk or

[10:02:19] not. When you look at lines 6

[10:02:28] and seven on document number

[10:02:30] two page number one. You will

[10:02:32] see that the credit risk

[10:02:34] adjustment on line 6 is a

[10:02:36] negative risk adjustment. Based

[10:02:37] on bond spreads.

[10:02:38] Credit rating is a common

[10:02:39] measurement of both business

[10:02:41] and financial risk. Any type of

[10:02:43] lower financial risk that the

[10:02:45] company has like a higher

[10:02:48] equity ratio would

[10:02:51] >> opc: you would agree that

[10:02:55] the negative credit risk

[10:02:56] adjustment is your adjustment

[10:02:59] because teco is less risky than

[10:03:04] the proxy group that you chose,

[10:03:05] correct?

[10:03:05] >> teco Witness: as far as

[10:03:09] credit risk, yes.

[10:03:10] >> opc: in this document the

[10:03:15] report to results for your

[10:03:15] approaches is that correct?

[10:03:17] >> yes.

[10:03:20] When includes the prpm and one

[10:03:22] excludes it.

[10:03:28] >> opc: okay.

[10:03:29] Now, looking at the column

[10:03:30] which shows the results with

[10:03:34] dep rpm which the commission

[10:03:37] rejected previously, you would

[10:03:38] agree that this commission

[10:03:41] previously rejected the

[10:03:42] approach because the results

[10:03:44] could not be duplicated,

[10:03:45] correct?

[10:03:46] >> I do not agree.

[10:03:48] I have given the commission

[10:03:51] staff ample opportunity to

[10:03:53] access my model and they have

[10:03:57] not taken it up, or taken me up

[10:04:00] on it.

[10:04:06] In the people's case or in this

[10:04:06] case.

[10:04:07] >> opc: that was not the

[10:04:07] question.

[10:04:08] My question was whether the

[10:04:09] commission rejected it because

[10:04:15] they said they could not

[10:04:16] duplicate the results.

[10:04:16] Is that correct?

[10:04:17] >> you will have to point me to

[10:04:18] where it says that.

[10:04:22] >> opc: looking at your range

[10:04:23] of results with indicative

[10:04:24] common equity and cost rate

[10:04:26] before adjustments.

[10:04:31] If you look further down

[10:04:32] indicated in common equity cost

[10:04:34] rate after adjustments.

[10:04:36] those are your ranges based on

[10:04:38] the four predictive models,

[10:04:39] correct?

[10:04:41] >> teco Witness: no.

[10:04:46] I have it in my testimony.

[10:04:47] I will just point to this

[10:04:47] document instead.

[10:04:50] If you look at line number 5,

[10:04:56] it is the low number which is

[10:04:57] the dcf model.

[10:05:02] And the high model from the m

[10:05:04] model does not contemplate or

[10:05:06] use the fourth line which is

[10:05:11] the market models comparable

[10:05:12] risk.

[10:05:15] It is the three models, the

[10:05:20] dcf, the risk premium model.

[10:05:23] >> opc: with that caveat that

[10:05:26] the market model is applied,

[10:05:27] nonprice regulated companies

[10:05:30] were rooted from that range.

[10:05:31] That the range of results

[10:05:35] online five and then further

[10:05:36] down with your other

[10:05:38] adjustments, those would be the

[10:05:41] results from the remodel

[10:05:41] correct?

[10:05:42] >> teco Witness: yes.

[10:05:48] That is correct.

[10:05:50] In that range without dep rmp

[10:05:54] is with your adjustments as 9.9

[10:05:57] to 12.42 correct?

[10:06:01] >> teco Witness: yes.

[10:06:01] Correct.

[10:06:07] >> opc: isn't it true that your

[10:06:08] recommended roe is above this

[10:06:18] range which would be 11.16?

[10:06:18] >> teco Witness: yes.

[10:06:19] But I did explain why went

[10:06:20] above the range in my rebuttal

[10:06:21] testimony.

[10:06:21] Believe it is

[10:06:22] easier to show you on the

[10:06:22] graph.

[10:06:27] If you would turn to exhibit

[10:06:44] dwd to.

[10:06:46] >> teco Witness: I disagree.

[10:06:48] You asked how it was and I am

[10:06:52] explaining why it was.

[10:06:55] >> teco Attorney: let's move on

[10:07:09] to the next question.

[10:07:10] Would you agree that teco has

[10:07:25] not paid any location cost?

[10:07:27] >> teco Witness: when you talk

[10:07:27] about flotation cost equity

[10:07:36] that's is infused has flotation

[10:07:37] costs.

[10:07:37] And they have to be returned

[10:07:39] back or they will not be able

[10:07:40] to attract the capital that

[10:07:45] they are supposed to.

[10:07:46] >> so the answer to my question

[10:07:50] is no.

[10:07:57] >> teco Witness: yes.

[10:07:58] But when you're talking about

[10:07:59] the cost of capital you have to

[10:07:59] cover the flotation costs from

[10:08:01] the parent company.

[10:08:02] If you do not, they will not

[10:08:06] get their full return on

[10:08:06] investment.

[10:08:07] >> so, and other words the

[10:08:11] flotation cost that you have

[10:08:12] included are costs that they

[10:08:14] have for issuing stock on their

[10:08:17] behalf correct?

[10:08:18] >> teco Witness: the flotation

[10:08:24] cost which you are including in

[10:08:27] this as an adjustment is a cost

[10:08:35] that is born by the company.

[10:08:41] >> teco Witness: not exactly.

[10:08:42] When we issue the stock, they

[10:08:45] incur costs.

[10:08:47] When it is in the form of a

[10:08:48] percent.

[10:08:51] If you take a look and this is

[10:08:54] where I have to explain this.

[10:08:56] If you look at document number

[10:09:03] 9 page 1 then you will see the

[10:09:05] issuances.

[10:09:09] Those issuances like I said

[10:09:10] document nine page one of one.

[10:09:16] The flotation costs are

[10:09:17] expressed in percent.

[10:09:18] So it is two percent of what

[10:09:19] the net proceeds are.

[10:09:24] >> teco Attorney: can I ask a

[10:09:25] question and get him to answer

[10:09:27] a yes, sir no?

[10:09:31] >> opc: please restate the

[10:09:31] question.

[10:09:34] >> teco Attorney: is a correct

[10:09:35] that they are issuing stock at

[10:09:38] their level?

[10:09:43] >> teco Witness: yes.

[10:09:44] >> teco Attorney: thank you.

[10:09:44] I'll move on.

[10:09:45] He highest roe

[10:09:49] is 12.9 percent for your

[10:09:53] nonregulated group, correct?

[10:09:57] >> teco Witness: it is 12.95.

[10:10:00] >> okay.

[10:10:01] You did not include that in

[10:10:02] your range correct?

[10:10:09] >> I did not.

[10:10:10] >> looking at document three,

[10:10:11] your cash flow model is 9.89

[10:10:14] percent, correct?

[10:10:15] >> teco Witness: it is

[10:10:17] superseded by my rebuttal

[10:10:17] testimony.

[10:10:18] And that result is 10.29

[10:10:18] percent.

[10:10:28] If you look up dwd, a

[10:10:29] discounted model using updated

[10:10:35] data is 10.29 percent.

[10:10:37] This model does not require you

[10:10:44] to estimate risk, correct?

[10:10:47] >> the risk is in the stock

[10:10:52] prices which runs in the

[10:10:52] dividend yield.

[10:10:54] I am not estimating risk.

[10:10:57] It is estimated in the price

[10:11:00] that we used to calculate the

[10:11:00] model.

[10:11:05] >> teco Attorney: so I believe

[10:11:06] the answer to my question is

[10:11:07] yes.

[10:11:11] You did not calculate risk.

[10:11:12] >> teco Witness: the point of

[10:11:13] every cost of capital model is

[10:11:16] to get a measure of risk to

[10:11:21] have a return on the risk.

[10:11:22] So, in that aspect the answer

[10:11:25] is yes.

[10:11:28] >> teco Attorney: your two

[10:11:28] highest results are for your

[10:11:31] risk premium model, is that

[10:11:31] correct?

[10:11:41] >> teco Witness: yes.

[10:11:42] >> teco Attorney: and in both

[10:11:43] of those you had to give a risk

[10:11:51] premium for those is that

[10:11:51] correct?

[10:11:52] >> teco Witness: yes.

[10:11:53] >> teco Attorney: you would

[10:11:54] agree that the 30 year treasury

[10:11:54] is about 4.61 percent.

[10:11:55] Is that current?

[10:11:58] >> it is not.

[10:12:00] >> what is the current 30 year

[10:12:02] treasury yield?

[10:12:06] >> I believe it is around 4.2.

[10:12:10] It is generally around her

[10:12:16] projected interest rates.

[10:12:20] So, it is not, the current

[10:12:22] interest rate sometimes is not

[10:12:25] as accurate or applicable as

[10:12:32] the others.

[10:12:33] >> teco Attorney: you would

[10:12:33] agree that the 30 year treasury

[10:12:36] yield is down about five

[10:12:41] percent from earlier this year

[10:12:41] correct?

[10:12:42] >> teco Witness: yes.

[10:12:43] But it is up one percent from

[10:12:46] the pandemic.

[10:12:47] >> teco Attorney: and you have

[10:12:48] included a credit risk

[10:12:49] adjustment for your roe

[10:12:49] correct:

[10:12:50] >> teco Witness: that is

[10:13:04] correct.

[10:13:05] >> teco Attorney: would you

[10:13:06] have any reason to disagree

[10:13:08] with me if I said, are you

[10:13:12] aware that the commission has

[10:13:15] recently approved a 10.3 rop

[10:13:19] for duke energy operating in

[10:13:20] florida?

[10:13:32] >> MR. CHAIRMAN, same

[10:13:33] objection.

[10:13:45] Which is f21 6124.

[10:13:46] This is opc's exhibit of the rr

[10:13:47] inventory of awarded and

[10:13:53] historic roe's.

[10:13:54] >> MR. CHAIRMAN, I would object

[10:13:59] to this as showing out-of-state

[10:13:59] decisions that are irrelevant

[10:14:00] in this matter.

[10:14:03] i request other utilities that

[10:14:07] fit these conditions.

[10:14:08] >> not the kind that this

[10:14:15] commission considers.

[10:14:17] >> one, I think we've already

[10:14:17] admitted the exhibit.

[10:14:20] Two, the gentleman is actually

[10:14:21] estimating roe's based on what

[10:14:29] the market will actually hold

[10:14:29] and approve.

[10:14:30] And what kind of competition

[10:14:34] for capital that teco would

[10:14:35] have to be up against.

[10:14:45] In fact, approved roe's are

[10:14:46] extremely relevant information.

[10:14:46] He is the witness.

[10:14:47] So he would be the person to

[10:14:48] ask about this information.

[10:14:53] I do think it is highly

[10:14:53] relevant.

[10:14:54] >> and this was entered into

[10:14:58] the record.

[10:15:04] >> this is the exhibit that MR.

[10:15:15] Weiland took issue with.

[10:15:16] >> could I approach the witness

[10:15:20] and provide him a copy with of

[10:15:22] this.

[10:15:25] >> approved.

[10:15:26] >> could we have a couple

[10:15:28] minutes to confer with the

[10:15:29] staff who deals with this on a

[10:15:30] regular basis?

[10:15:35] That would not be me.

[10:15:35] >> absolutely.

[10:17:20] Let's take three minutes.

[10:22:03] >> just rehashing a little bit

[10:22:04] of all discussion.

[10:22:08] Let's reconvene.

[10:22:10] And I will go to marianne on

[10:22:15] what we just discussed.

[10:22:17] >> thank you MR. CHAIRMAN.

[10:22:25] My suggestion is to go forward

[10:22:26] and allow MS. Christiansen to

[10:22:26] ask a couple of questions.

[10:22:30] From there, I think you can

[10:22:35] determine whether we think that

[10:22:36] the questions are relevant to

[10:22:42] this proceeding in the way that

[10:22:43] this commission sets the rotc

[10:22:44] based on the filings that have

[10:22:47] been made.

[10:22:48] >> commissioner, MAY I be

[10:22:53] briefly heard?

[10:22:54] >> yes.

[10:22:55] In order number pse 2023 038

[10:23:01] eight fo

[10:23:05] , the rate proceeding

[10:23:09] on page 71 and the conclusion

[10:23:17] staff indicated that it relied

[10:23:18] on, I apologize.

[10:23:24] The commission relied on the

[10:23:25] national average of awarded

[10:23:27] roadies of approximately 9.5

[10:23:36] percent and should enable us to

[10:23:37] enable the cash flow for

[10:23:37] near-term financial obligations

[10:23:38] and make the capital

[10:23:39] investments needed to maintain

[10:23:41] expanded systems to fund

[10:23:44] unexpected events and sustained

[10:23:55] confidence in florida's

[10:23:56] regulatory environment among

[10:23:57] the created agencies and

[10:23:57] investors.

[10:23:58] This is the type of information

[10:23:59] that this commission has relied

[10:24:00] on to make a recommendation.

[10:24:04] I would suggest that this is

[10:24:07] highly relevant information.

[10:24:10] I am sure if the company

[10:24:12] believes that we are being

[10:24:12] repetitive they can certainly

[10:24:17] make whatever interjections

[10:24:18] they like at the time.

[10:24:21] But I believe I should be given

[10:24:22] the leeway necessary to explore

[10:24:27] this relevant information.

[10:24:28] >> I will not respond by saying

[10:24:30] this is in the record.

[10:24:31] If we want to spend the next

[10:24:38] three hours having our witness

[10:24:39] questions about what ever other

[10:24:41] information they have about

[10:24:47] other states, I guess we can do

[10:24:47] that.

[10:24:48] But we are trying to move this

[10:24:50] thing along.

[10:24:55] I know it does not feel like

[10:24:55] it.

[10:24:56] But the commission has

[10:24:57] historically relied primarily

[10:24:59] on the models and the models

[10:25:04] are not based on returns or

[10:25:11] requested returns.

[10:25:11] This is in the record.

[10:25:12] I hope we do not have to go

[10:25:13] line by line through every one

[10:25:15] of these decisions and talk

[10:25:15] about it.

[10:25:19] I was asked yesterday to object

[10:25:19] to early.

[10:25:22] So that is what I am doing.

[10:25:26] >> okay.

[10:25:27] I will allow the questions to

[10:25:28] start.

[10:25:31] We will take the direction and

[10:25:33] see how relevant they are in

[10:25:34] comparison.

[10:25:38] And of course how the witness

[10:25:38] answers.

[10:25:43] I will allow questions to

[10:25:43] begin.

[10:25:44] >> MAY I approach the witness

[10:25:46] to give him the larger copy?

[10:25:47] >> yes.

[10:25:56] Thank you.

[10:25:57] Are you familiar with smp's

[10:26:05] capital iq rate history?

[10:26:10] >> yes.

[10:26:11] >> and you would agree this is

[10:26:13] the summary of awarded

[10:26:16] summaries by smp.

[10:26:17] Otherwise you are generally

[10:26:18] familiar with the content,

[10:26:20] correct?

[10:26:21] >> I have not gotten through

[10:26:22] the entire document.

[10:26:27] Is there pending roe's, further

[10:26:27] down?

[10:26:39] >> looking at page I think it

[10:26:46] is the last page of the

[10:26:46] document.

[10:26:50] This list of pending cases.

[10:26:52] Do you see that?

[10:26:57] >> sure.

[10:26:58] >> there are cases listed there

[10:27:01] for pennsylvania electric and

[10:27:01] pennsylvania power.

[10:27:05] O you see

[10:27:05] those?

[10:27:08] >> do you mean the next next to

[10:27:15] the last page?

[10:27:16] >> yes.

[10:27:16] Do you see that there is a

[10:27:19] request for an 11.3 percent are

[10:27:20] oe?

[10:27:20] >> yes.

[10:27:24] I am the witness in that case.

[10:27:25] >> so you are the witness in

[10:27:26] those cases.

[10:27:31] Are you also the witness in

[10:27:31] the.

[10:27:39] [Listing names] Case?

[10:27:46] >> no.

[10:27:50] Do you know.

[10:27:51] [Listing names]?

[10:27:55] >> professionally, yes.

[10:27:56] >> and are you closely aligned

[10:27:57] with him in providing these

[10:28:03] roe's on behalf of the

[10:28:07] utilities?

[10:28:07] >> I disagree with everything

[10:28:08] you just said.

[10:28:09] >> in 2020 when did you conduct

[10:28:14] his testimony in a kentucky ray

[10:28:20] case?

[10:28:20] >> he was in a coma and the

[10:28:26] company reached out for me to

[10:28:26] do what was it, it was

[10:28:30] discovery responses.

[10:28:31] So no I did not adopt his

[10:28:34] testimony nor defendant.

[10:28:35] While he was in the hospital

[10:28:41] recovering, I did the right

[10:28:42] thing and gave responses to

[10:28:45] discovery for a client that we

[10:28:45] share.

[10:28:52] >> okay.

[10:29:01] One moment please.

[10:29:02] I think that MAY be all the

[10:29:05] questions I have for this

[10:29:06] exhibit.

[10:29:49] There MAY be others.

[10:29:49] Sure.

[10:29:50] Okay.

[10:29:54] Are we ready again?

[10:29:54] >> yes.

[10:29:55] >> would you agree that the

[10:30:01] florida commission has made roe

[10:30:02] rewards that are higher than

[10:30:05] the national average?

[10:30:05] >> yes.

[10:30:06] I would like to take some time

[10:30:10] and talk about that.

[10:30:11] >> I will object.

[10:30:13] This is going well beyond.

[10:30:23] I did not even ask him the

[10:30:24] question.

[10:30:24] >> would you agree that doctor

[10:30:25] woolrich has recommended a roe

[10:30:25] of 9.54 teco?

[10:30:31] >> yes, in this case, yes.

[10:30:36] >> isn't it true that on page 9

[10:30:37] of your direct testimony, line

[10:30:41] 14 that you acknowledged that

[10:30:42] authorized roe's, I believe

[10:30:44] this is actually on your

[10:30:50] rebuttal testimony.

[10:30:56] >> yes, ma'am, I am there.

[10:30:57] >> looking at line 14 which you

[10:30:58] acknowledged that authorized

[10:31:08] roe's are reasonable benchmarks

[10:31:09] of acceptable roe's?

[10:31:10] >> the end of the sentence says

[10:31:11] they do not reflect the current

[10:31:12] cost of common equity.

[10:31:16] >> if you go to the top of the

[10:31:17] next page, you then claim that

[10:31:24] simple comparisons of roe are

[10:31:24] of little value, correct?

[10:31:26] >> yes, ma'am. They are not

[10:31:27] timely.

[10:31:31] They do not reflect the risks

[10:31:32] of the specific companies

[10:31:32] involved.

[10:31:37] Some of these, if we want to go

[10:31:40] back to this, you could take a

[10:31:49] look and see that you have

[10:31:50] companies that start their rate

[10:31:54] case in 2020 and do not get

[10:31:54] resolved until 2022 or 2023.

[10:31:57] Even though the data MAY seem

[10:32:01] recent, it is not recent nor

[10:32:02] timely.

[10:32:02] >> I believe he is going past

[10:32:14] the questions.

[10:32:15] >> do you know what the most

[10:32:17] recently authorized roe was?

[10:32:20] >> fully litigated?

[10:32:24] >> no.

[10:32:24] settled.

[10:32:25] >> objection.

[10:32:30] >> sustained.

[10:32:35] >> hold on.

[10:32:38] Can I have just a moment

[10:32:39] please?

[10:32:39] >> sure.

[10:35:32] Let's take two minutes.

[10:35:37] >> MR. CHAIRMAN?

[10:35:44] Yes, sir?

[10:35:49] >> public council is in a

[10:35:53] difficult spot.

[10:35:54] We asked the question and we

[10:35:56] were given an answer.

[10:35:57] We have a document from the

[10:36:00] state of kentucky, in order

[10:36:02] that shows that the witness's

[10:36:05] statement was inconsistent with

[10:36:07] the state of kentucky's order.

[10:36:11] We have no way of impeaching

[10:36:17] the witness.

[10:36:19] We have advised council for the

[10:36:22] company about the situation.

[10:36:25] It is a serious matter and we

[10:36:33] need to get to the bottom of

[10:36:33] it.

[10:36:34] >> we are happy to have them

[10:36:37] read the order to him.

[10:36:37] He can answer if he thinks that

[10:36:41] is what happened.

[10:36:42] This is not a big deal.

[10:36:46] We are not going to get hung up

[10:36:47] on whether or not the document

[10:36:50] is in case center.

[10:36:54] >> we heard testimony that did

[10:36:58] not adopt testimony.

[10:36:59] When he said that, we abandoned

[10:37:12] a plot of questioning about

[10:37:12] 321.

[10:37:16] I don't know if it's possible

[10:37:17] here to get a court reporter to

[10:37:19] read the question back.

[10:37:27] But this is a serious matter.

[10:37:28] >> I have suggested that they

[10:37:30] just ask about the order.

[10:37:37] And then see what happens.

[10:37:38] >> I will go to my advisor from

[10:37:47] a procedural position.

[10:37:48] >> MR. Wallin, as I understand

[10:37:51] it has offered to allow

[10:37:52] cross-examination about the

[10:37:57] order from kentucky.

[10:37:59] It seems to me that we could go

[10:38:03] forward on that way.

[10:38:09] Do we need to stop and make a

[10:38:09] couple of copies of the order

[10:38:15] for people to have it?

[10:38:15] >> okay.

[10:38:17] >> so, procedurally they will

[10:38:19] make the copies is there

[10:38:26] anything else that we need?

[10:38:28] Should we awake the copies?

[10:38:34] >> before we do that, is there

[10:38:35] anything else that we need to

[10:38:36] do to instruct during this time

[10:38:36] out?

[10:38:39] >> not that I am aware of.

[10:38:40] I'm not sure if anyone else has

[10:38:45] the suggestion.

[10:38:46] >> let's take five minutes.

[10:38:47] When the copies are ready we

[10:38:47] can reconvene.

[10:38:50] And then we will go from there.

[10:38:51] >> certainly.

[10:58:21] Thank you.

[10:58:24] >> we are good.

[10:58:26] All right.

[10:58:32] Let's reconvene here.

[10:58:36] I will go to opc who handed out

[10:58:38] some paperwork.

[10:58:46] >> yes we did.

[10:58:53] Once we are ready to roll,

[10:58:56] >> before we get started, we

[10:58:56] are getting a couple of other

[10:58:58] items printed out that are

[10:59:02] relevant to this.

[10:59:03] I do not know if you want to

[10:59:07] wait for all of it.

[10:59:07] >> I do.

[10:59:11] I would prefer not to stop

[10:59:11] again.

[10:59:16] How far along are we in that

[10:59:16] process?

[10:59:17] >> I am not sure who is doing

[10:59:25] the printing.

[10:59:26] >> let's hold tight and not go

[10:59:27] too far.

[10:59:27] We will reconvene once

[10:59:38] everything is back.

[10:59:41] >> commissioner, they MAY have

[10:59:42] their copies ready by the time

[10:59:45] redirect is up.

[10:59:46] He can introduce those as part

[10:59:48] of his redirect.

[10:59:50] We can continue to move along

[10:59:56] if that is the CHAIRMAN's wish.

[10:59:57] >> let's still hold for a few

[10:59:57] seconds.

[11:01:07] But I MAY take you up on that.

[11:01:07] >>.

[11:01:11] >> okay.

[11:01:12] Let's go ahead and get started.

[11:01:16] There is something printed but

[11:01:19] we should have it shortly.

[11:01:23] We were about to start to talk

[11:01:27] about the other things.

[11:01:32] >> have you had an opportunity

[11:01:33] to have a conversation with

[11:01:34] your attorney about the order

[11:01:40] that I am about to show you?

[11:01:45] >> yes.

[11:01:51] >> for clarification of the

[11:01:52] record, can we ask that the

[11:02:02] court reporter read back the

[11:02:03] question regarding the kentucky

[11:02:03] in the adoption of the

[11:02:07] testimony in kentucky in your

[11:02:07] response.

[11:02:11] >> court reporter, is that

[11:02:11] possible?

[11:02:15] We MAY have to give a bit of

[11:02:15] direction.

[11:02:21] >> how far back?

[11:02:26] >> I don't think it was too far

[11:02:26] back.

[11:02:27] >> I would say in the last two

[11:02:28] or three minutes.

[11:02:29] >> I will give her a moment to

[11:02:51] find it.

[11:03:17] >> take your time please.

[11:03:18] >> if you could play back the

[11:03:22] question in response, that

[11:03:22] would be helpful.

[11:03:28] Thank you.

[11:03:28] >>

[11:04:11] [Audio unclear]

[11:04:15] >> thank you MADAM Court

[11:04:18] reporter.

[11:04:18] Sir, can you see the order from

[11:04:26] the commonwealth of kentucky

[11:04:27] and the matter of electronic

[11:04:28] application of delta natural

[11:04:29] gas company inc. For an

[11:04:39] adjustment in its rates for

[11:04:40] being public convenience and

[11:04:41] necessity case number 2020

[11:04:41] 100185?

[11:04:41] > I do.

[11:04:42] >> can you read the second

[11:04:42] paragraph of that order on the

[11:04:43] first page?

[11:04:50] >> sure.

[11:04:50] >> in support of this motion,

[11:04:51] delta explains that it learned

[11:04:54] on JULY 20 that one of its

[11:04:55] witness MR. [Listing names] Was

[11:04:58] in a bicycle accident which

[11:04:59] prohibits him from giving

[11:05:00] responses.

[11:05:02] Further it delta states that we

[11:05:08] have adopted another person for

[11:05:13] direct testimony which seeks an

[11:05:20] extension of time.

[11:05:21] >> let me take you back to

[11:05:22] exhibit 96.

[11:05:23] Which is the list of the rra

[11:05:24] comparative.

[11:05:29] Do you see on that second to

[11:05:34] last page where it says

[11:05:34] pennsylvania light company?

[11:05:37] >> yes, ma'am.

[11:05:39] >> well, not yet.

[11:05:47] But I am sure it is there.

[11:05:48] >> yes.

[11:05:49] And do you see the 11.5 percent

[11:05:49] there?

[11:05:51] >> yes, ma'am.

[11:05:58] >> is not testimony where he is

[11:06:04] seeking an 11.5 are roe.

[11:06:10] >> I have no further questions.

[11:06:11] >> commissioner, could I get

[11:06:18] the order marked for

[11:06:19] identification?

[11:06:19] Or given an identification

[11:06:20] number to move it into evidence

[11:06:23] at the end?

[11:06:25] >> let's give it a number.

[11:06:27] I will have to ask my staff for

[11:06:31] a little bit of help.

[11:06:32] >> MR. CHAIRMAN, I do believe

[11:06:34] that is 839.

[11:06:34] >> thank you.

[11:06:37] >> moving on to

[11:06:41] florida rising.

[11:06:42] >> good evening MR. CHAIRMAN.

[11:06:48] >> good evening!

[11:06:49] >> if I could direct your

[11:06:52] attention to master number

[11:06:53] 83443.

[11:07:00] It should splash up on your

[11:07:00] screen.

[11:07:01] This is from admitted exhibits

[11:07:06] staff 177.

[11:07:07] So, this document contains the

[11:07:09] reference documents for your

[11:07:10] testimony.

[11:07:17] Is that correct?

[11:07:18] >> okay.

[11:07:18] The specific one that we are

[11:07:19] looking at is the smp global

[11:07:20] rating score snapshot.

[11:07:21] If you look at the bottom of

[11:07:26] the page there is a key

[11:07:32] strength that the electric

[11:07:32] company says that this is a low

[11:07:33] risk utility.

[11:07:39] Is that correct?

[11:07:40] >> yes.

[11:07:40] It is the same description it

[11:07:41] gives to every single utility

[11:07:42] company that it covers.

[11:07:44] >> as a key risk it says very

[11:07:46] large capital programs will

[11:07:48] pressure credit metrics.

[11:07:50] >> yes, sir.

[11:07:53] >> if I could direct your

[11:07:57] attention to two pages later.

[11:07:58] >> that is 23632.

[11:08:02] On the bottom.

[11:08:03] >> yes.

[11:08:08] That is correct.

[11:08:14] >> it says that the negative

[11:08:15] outlook on tec reflects the

[11:08:19] negative outlook of its parent.

[11:08:19] [Listing names].

[11:08:22] It reflects its current minimal

[11:08:23] financial condition from the

[11:08:27] downgrade threshold.

[11:08:36] >> yes, sir.

[11:08:37] >> if I could direct your

[11:08:37] attention to master number

[11:08:45] e3454 within the same document.

[11:08:46] >> you said e3454 correct?

[11:08:48] >> yes.

[11:08:49] This would be moody's credit

[11:08:57] opinion for teco from DECEMBER

[11:08:57] 2023.

[11:08:58] If I could direct your

[11:08:58] attention to the last paragraph

[11:09:08] of that page.

[11:09:08] It says that tampa electric's

[11:09:09] credit rating is restrained by

[11:09:12] the week parent company of its

[11:09:20] parent company.

[11:09:21] Most notably, this puts

[11:09:22] pressure on tampa electric.

[11:09:23] Therefore they MAY rely more

[11:09:23] heavily on tampa electric and

[11:09:24] MAY need the utility to

[11:09:28] upstream dividends for high

[11:09:33] company debt and other

[11:09:33] obligations.

[11:09:34] >> did I read that correctly?

[11:09:35] >> yes.

[11:09:36] If I could direct your

[11:09:42] attention next to master number

[11:09:42] 83459.

[11:09:49] This is just a few pages down.

[11:10:04] That is part of that same

[11:10:04] document.

[11:10:10] It says under the second

[11:10:11] heading that they issued a

[11:10:14] significant amount of debt and

[11:10:16] subordinated hybrid notes to

[11:10:17] finances acquisition of.

[11:10:22] [Listing teco.

[11:10:22] Is that right?

[11:10:28] >> yes, sir.

[11:10:29] >> you are not aware of any

[11:10:30] time that you have recommended

[11:10:33] a lower returnreturn on equity

[11:10:33] correct?

[11:10:36] >> I am not aware.

[11:10:41] >> as far as you are aware of,

[11:10:42] as far as their subsidiaries,

[11:10:43] the author's return is highest

[11:10:43] at teco.

[11:10:49] >> yes.

[11:10:53] Based on basis points.

[11:10:54] Ask and that is at the current

[11:10:54] authorized rate of return

[11:10:55] correct?

[11:10:57] >> that's right.

[11:11:08] >> you say that the roe should

[11:11:09] be raised correct?

[11:11:09] >> yes.

[11:11:09] Based on my analysis.

[11:11:10] >> who would agree that canada

[11:11:18] generally has lower roe's?

[11:11:20] They provide an opportunity for

[11:11:23] higher return as compared to

[11:11:26] for example, nova scotia power?

[11:11:27] >> yes.

[11:11:31] This was all in my deposition.

[11:11:32] We were talking about how other

[11:11:34] canadian companies have

[11:11:35] invested in american companies

[11:11:38] because generally, the risk is

[11:11:39] the same but the return is

[11:11:45] higher in america.

[11:11:46] Given basic financial precepts

[11:11:47] you will want to spend money

[11:11:53] where you can get the highest

[11:11:54] return.

[11:11:54] >> other than in alaska you are

[11:11:55] not aware of any other

[11:11:57] utilities being returned 11.5

[11:11:57] percent or higher?

[11:11:59] >> I am not aware.

[11:12:06] But we use it generally this

[11:12:06] stuff.

[11:12:07] They don't have an entire

[11:12:12] picture of roe's.

[11:12:12] But generally, no.

[11:12:19] Not at the size.

[11:12:20] >> and just to clarify your

[11:12:20] testimony.

[11:12:21] You are not offering an opinion

[11:12:23] on whether customer costs are

[11:12:24] reasonable, correct?

[11:12:24] >> correct.

[11:12:27] My testimony is the appropriate

[11:12:29] rate of return that investors

[11:12:33] require on, equity investors

[11:12:35] require in teco.

[11:12:45] >> thank you.

[11:12:46] >> I have a handful of

[11:12:46] questions.

[11:12:47] I would like to refer to the

[11:12:48] witness if I could just

[11:12:49] briefly.

[11:12:50] They have a chart that MR.

[11:12:53] Pollick will talk about

[11:12:53] tomorrow.

[11:12:57] It has not been admitted yet.

[11:13:09] It is 6027? 2859.

[11:13:10] It should be pulled up on the

[11:13:14] screen in front of you.

[11:13:19] >> this is a two-page chart.

[11:13:20] This is the first page.

[11:13:30] Page one of two.

[11:13:36] And on the second page the

[11:13:37] screen will need to be scroll

[11:13:37] down.

[11:13:41] That is the second page.

[11:13:42] I know you briefly looked at

[11:13:43] the first page.

[11:13:46] Do you see any cases in their

[11:13:47] that you testified upon on the

[11:13:54] first page?

[11:13:55] >> louisiana southwestern

[11:14:00] electrical power company.

[11:14:01] >> that is number 5.

[11:14:01] >> yes.

[11:14:13] Number 5, number 9, maybe

[11:14:18] number 20.

[11:14:19] I did testify in kentucky.

[11:14:20] I do not know if it is the

[11:14:31] recent one or not.

[11:14:36] 21, if we go on the next page,

[11:14:36] 50.

[11:14:44] >> 50.

[11:14:44] Yes.

[11:14:52] What they did is similar to the

[11:14:53] other exhibit where he has gone

[11:14:54] back and looked at the last

[11:14:56] couple of years and looked at

[11:14:59] the roe's that have been

[11:15:00] reported.

[11:15:01] And has calculated an average

[11:15:06] for 2023.

[11:15:07] In an average for 2024 of 9.72.

[11:15:08] Is that correct?

[11:15:09] >> that is correct.

[11:15:14] >> I assume that you identified

[11:15:14] and testified about all of

[11:15:16] those with the exception.

[11:15:23] Number 8 in california.

[11:15:23] They all ended up at

[11:15:24] single-digit roe.

[11:15:24] is that correct?

[11:15:26] >> yes.

[11:15:27] There were some gas cases that

[11:15:28] were over time.

[11:15:31] But they are not on this list.

[11:15:34] >> I want to spend a moment and

[11:15:35] talk about what has been done

[11:15:35] here.

[11:15:41] I think walmart has a similar

[11:15:41] approach.

[11:15:43] I asked the PRESIDENT Yesterday

[11:15:50] whether this type of

[11:15:50] information had a lot of

[11:15:54] comparisons being made.

[11:15:55] This type of information is

[11:15:57] probative and meaningful.

[11:15:59] He said yes.

[11:16:04] Do you similarly agree that

[11:16:05] this can be used as an approach

[11:16:11] to roe.

[11:16:16] It is different ways of perhaps

[11:16:17] getting to a similar point.

[11:16:19] It's a long-winded question.

[11:16:20] But if you can answer it I

[11:16:20] would appreciate it.

[11:16:23] >> sure.

[11:16:27] I will start with no.

[11:16:28] It is because of a couple

[11:16:31] things that I said earlier.

[11:16:32] There are different companies

[11:16:33] with different sets of

[11:16:33] circumstances.

[11:16:35] All you have to do is look at

[11:16:42] the people discuss and what the

[11:16:42] commission did in that case.

[11:16:43] They ran their models and

[11:16:44] looked at the companies.

[11:16:47] They looked at the models and

[11:16:52] then they made the

[11:16:53] determination.

[11:16:53] MS. Christiansen was right when

[11:16:55] she read her order.

[11:16:57] But, they did not adjust their

[11:17:00] model results up or down based

[11:17:08] on what the average was.

[11:17:09] So it MAY be a guidepost.

[11:17:10] But like the commission has

[11:17:10] done so much in the past and

[11:17:11] what they should continue to do

[11:17:13] is to follow the model.

[11:17:16] the model is the market.

[11:17:19] The outcomes of these cases are

[11:17:21] results of things like this.

[11:17:24] Where I have my number, the

[11:17:29] doctor has his number, MR.

[11:17:29] Walters has his number and it

[11:17:33] is up to the commission to try

[11:17:35] and balance those interests.

[11:17:38] My opinion is that the roe is

[11:17:44] 11.5 percent.

[11:17:45] A lot of the parties don't have

[11:17:45] that.

[11:17:46] But when you are talking about

[11:17:47] using that as market data, it

[11:17:50] is not.

[11:17:51] Because it does not move with

[11:17:54] market rates.

[11:17:55] When the stock price changes,

[11:17:57] or dcf changes.

[11:18:00] Everything affects everything.

[11:18:04] These are stuck in the mud.

[11:18:05] There are several different

[11:18:05] things of why you do not use

[11:18:09] author's returns as reference

[11:18:18] to roe.

[11:18:19] That is your opinion, correct?

[11:18:20] >> yes.

[11:18:24] >> and you are aware that

[11:18:25] others have different opinions.

[11:18:29] Orrect?

[11:18:31] >> no.

[11:18:35] The witnesses that are expert

[11:18:36] witnesses and they do these

[11:18:38] types of things, they have

[11:18:41] these models and don't use

[11:18:43] author's returns.

[11:18:48] And neither does MR. Walters.

[11:18:49] And neither does MR. Garrett

[11:18:50] before him.

[11:18:50] One of the

[11:18:55] witnesses use author's returns

[11:18:58] as their number.

[11:19:00] As opposed to some of the other

[11:19:00] witnesses.

[11:19:04] It is not high or low.

[11:19:08] He does not say what number he

[11:19:08] wants.

[11:19:09] He just cautions you about one

[11:19:18] thing or another.

[11:19:19] >> the five cases that you

[11:19:20] testified here today, do they

[11:19:21] all go through the process that

[11:19:27] you are describing?

[11:19:28] >> the models that you use and

[11:19:35] the discounted cash flow model.

[11:19:36] Do they provide that testimony

[11:19:37] in the five that you referenced

[11:19:38] here?

[11:19:39] >> yes.

[11:19:43] Because you bring it up?

[11:19:44] If it is settled, it is based

[11:19:46] on other things.

[11:19:47] If you could bring that exhibit

[11:19:51] up again,

[11:19:52] >> there is nowhere that tells

[11:19:57] you if it was or it was not.

[11:19:59] >> here is the question.

[11:20:06] With respect to the ability, if

[11:20:08] all the states do these things

[11:20:11] with these approaches and this

[11:20:15] is a high-level document that

[11:20:16] just says well, they don't all

[11:20:21] work, here is where the rates

[11:20:21] are.

[11:20:22] That is a way in which you

[11:20:24] could determine relevant

[11:20:24] information.

[11:20:25] Do you agree with that?

[11:20:30] >> I do not.

[11:20:31] >> there are further reasons

[11:20:34] why I said it already.

[11:20:34] >> if you are satisfied with

[11:20:44] the answer, that is

[11:20:44] satisfactory.

[11:20:48] >> were you here today or did

[11:20:54] you listen to the witness talk

[11:20:55] about how duke establishes

[11:20:59] their salaries?

[11:21:04] >> which witness?

[11:21:06] >> I do apologize.

[11:21:07] Teco.

[11:21:09] It was a witness today from

[11:21:10] teco who talked about how they

[11:21:15] establish their salaries.

[11:21:16] Are you familiar?

[11:21:16] >> no.

[11:21:17] >> do you know that some

[11:21:20] utilities use the median as a

[11:21:27] way for establishing salaries?

[11:21:28] >> some utilities will use a

[11:21:29] median to look at their other

[11:21:30] utilities and say what is the

[11:21:33] median price that other

[11:21:35] utilities are paying executives

[11:21:41] for a way of making a decision?

[11:21:46] >> that is not relevant.

[11:21:46] It MAY be relevant to how you

[11:21:49] do compensation.

[11:21:51] >> I will ask the question.

[11:21:58] If this similar to teco?

[11:22:02] >> this is a comparison of the

[11:22:02] median.

[11:22:03] It is the same thing.

[11:22:04] It's just the point I wanted to

[11:22:19] make.

[11:22:28] >> sierra club?

[11:22:30] >> f rf?

[11:22:32] Thank you MR. CHAIRMAN.

[11:22:43] Good evening.

[11:22:51] Quick question if I could ask

[11:22:52] MR. Schultz to please bring up

[11:22:55] what is identified as f rf

[11:22:55] five.

[11:22:59] They are in our exhibit list.

[11:23:05] F7? 44 and f7? 79 is the

[11:23:10] first page.

[11:23:15] These are simply copies of hope

[11:23:15] and bluefield to which you are

[11:23:19] referring your testimony.

[11:23:20] I would just like to say yes,

[11:23:22] this is what they are.

[11:23:27] Thank you.

[11:23:28] I will move these later.

[11:23:29] But that is all I need to do

[11:23:33] with those for now.

[11:23:36] I will ask a few questions.

[11:23:38] About exhibit 321 out of

[11:23:45] respect for my friend and

[11:23:46] everybody's time, I will

[11:23:47] condense my questions and not

[11:23:51] go line by line.

[11:23:52] I have identified results for

[11:23:55] several of the operating

[11:23:56] companies that are owned by the

[11:23:59] parent companies in your proxy

[11:23:59] group.

[11:24:00] Your proxy group is as shown on

[11:24:05] page 19 of your direct

[11:24:06] testimony, correct?

[11:24:06] > I do

[11:24:06] believe I updated it.

[11:24:14] But I get the just.

[11:24:18] >> I will ask you is this

[11:24:21] company owned by such and such?

[11:24:23] And then we will go on from

[11:24:24] there.

[11:24:26] I don't think it will take

[11:24:27] long.

[11:24:29] Is it true that duke energy

[11:24:30] carolinas into energy progress

[11:24:34] are owned by duke energy

[11:24:34] corporation?

[11:24:36] In wisconsin power and light is

[11:24:38] owned by.

[11:24:44] [Listing names].

[11:24:45] Brooklyn general electric

[11:24:46] company appears to be the same

[11:24:48] name as the operating utility

[11:24:48] company.

[11:24:53] Is that correct?

[11:24:54] >> it MAY be the only operating

[11:24:56] company that is publicly

[11:24:57] traded.

[11:24:57] >> and they are owned by

[11:24:59] southern company?

[11:25:04] And nsp is owned by xl?

[11:25:04] > it

[11:25:05] is.

[11:25:07] >> thank you.

[11:25:08] >> my next question is very

[11:25:09] simple.

[11:25:13] Would you agree that the smp

[11:25:19] global exhibit compilation that

[11:25:20] is shown as exhibit 321 which

[11:25:20] does include both recently

[11:25:25] awarded and pending rate

[11:25:26] increase requests shows what it

[11:25:27] purports to show.

[11:25:28] >> yes.

[11:25:30] Thank you.

[11:25:38] >> if we could go back to the

[11:25:39] document that MR. Boyle was

[11:25:43] just asking, it is identified

[11:25:54] as c 27? 2859.

[11:25:55] In your discussion with MR.

[11:25:59] Boyle just now, you identified

[11:26:00] several of the cases in which

[11:26:00] you testified.

[11:26:12] My question for you is which of

[11:26:12] these are operating utility

[11:26:13] companies owned by members of

[11:26:14] your proxy group?

[11:26:15] If you could just run down the

[11:26:25] list, that would be great.

[11:26:26] >> out of these 52 companies,

[11:26:27] you want me to tell you which

[11:26:28] ones I testified for and if

[11:26:29] they are a member of my proxy

[11:26:29] group?

[11:26:32] >> no sir.

[11:26:33] I just wanted to ask you which

[11:26:34] of these are members of your

[11:26:38] proxy group?

[11:26:39] You already told us which ones

[11:26:41] you testified in.

[11:26:46] >> I believe it is five, nine,

[11:27:12] 12, 13, 15, 18, 20, 21, 23, 25,

[11:27:26] 26, 35, 36, 39, 31, I think 42

[11:27:34] came in on my rebuttal.

[11:27:37] 43.

[11:27:38] And 52.

[11:27:41] And this is just looking at it

[11:27:41] now.

[11:27:42] I could have gotten some and

[11:27:46] missed some.

[11:27:47] But looking at it right now,

[11:27:48] that is what sounds about

[11:27:48] right.

[11:27:58] >> thank you.

[11:27:59] >> are you aware of any

[11:28:01] evidence that any of these

[11:28:02] utilities, the ones that you

[11:28:09] just identified as members of

[11:28:10] operating utility companies

[11:28:11] owned by the members of your

[11:28:11] proxy group, any evidence that

[11:28:13] any of these utilities has not

[11:28:15] been able to provide safe and

[11:28:18] reliable service?

[11:28:21] >> I cannot tell you.

[11:28:25] >> similar question any

[11:28:26] evidence that these utilities

[11:28:31] have not been able to obtain

[11:28:34] significant capital?

[11:28:49] >> I could not tell you.

[11:28:49] >> I'm pretty confident that

[11:28:55] you are aware that since

[11:28:56] JANUARY 2022, tampa electric

[11:29:00] has operated first, for the

[11:29:17] first six months of an.

[11:29:18] during that time, their equity

[11:29:19] ratio has been 54 percent,

[11:29:19] correct?

[11:29:25] >> yes.

[11:29:26] >> are you aware of any

[11:29:27] evidence that they have been

[11:29:28] unable to provide the needed

[11:29:28] capital to provide service at

[11:29:29] the time?

[11:29:38] >> I do not think so.

[11:29:38] >> are you aware of any

[11:29:39] evidence that in 2025 tampa

[11:29:40] electric would not be able to

[11:29:41] obtain the needed capital to

[11:29:42] make the necessary investments?

[11:29:45] >> I do not know.

[11:29:51] >> is it not true that tampa's

[11:29:52] affiliate has been able to make

[11:29:53] needed investments with rates

[11:29:55] based on its approved board of

[11:30:01] public service commission

[11:30:02] approved roe of 10.15 percent

[11:30:03] since the rates took effect in

[11:30:06] JANUARY of this year?

[11:30:07] >> I am not part of the

[11:30:10] treasury team.

[11:30:11] I do not know what kind of

[11:30:15] issues they have raising

[11:30:16] capital.

[11:30:22] >> I will ask you a similar

[11:30:23] question.

[11:30:24] Have you been aware of anything

[11:30:25] that they have not been able to

[11:30:26] make and necessary investments?

[11:30:27] >> I do not know.

[11:30:31] Probably, probably not.

[11:30:32] >> and you were a witness in

[11:30:33] the case correct?

[11:30:43] >> yes I was.

[11:30:44] >> I think we have covered

[11:30:44] this.

[11:30:48] Is it true that the 10.15

[11:30:49] percent at the psc approved for

[11:30:51] peoples was 65 basis points

[11:30:52] above the us national average

[11:30:57] for gas utilities.

[11:30:58] >> yes.

[11:30:58] Octor shows how

[11:31:01] little weight the commission

[11:31:07] staff have on national average

[11:31:07] roe's.

[11:31:12] >> I think we will allow them

[11:31:14] to decide on their averages.

[11:31:16] Do you agree with that?

[11:31:16] >> sure.

[11:31:20] >> thank you.

[11:31:21] That is all my questions.

[11:31:24] I told you I would be quick.

[11:31:24] How about walmart?

[11:31:25] >> yes.

[11:31:34] Thank you.

[11:31:35] You are not a teco employee are

[11:31:35] you?

[11:31:35] >> I am not.

[11:31:36] >> and you are not an employee

[11:31:37] of the teco affiliate?

[11:31:44] >> I am not.

[11:31:45] You are part of the consulting

[11:31:45] firm in new jersey, correct?

[11:31:46] >> it is based in raleigh.

[11:31:49] But I am stationed in new

[11:31:49] jersey.

[11:31:50] >> and that is where you have

[11:31:56] come from to testify for us

[11:31:57] today?

[11:31:57] You are a paid consultant for

[11:31:58] teco in this matter.

[11:31:59] Is that correct?

[11:32:03] >> I am.

[11:32:03] >> like some of my colleagues,

[11:32:04] I will ask you a few questions

[11:32:05] about your opinions on your

[11:32:07] return in equity.

[11:32:10] On page 31 of your direct

[11:32:15] testimony, you discussed the

[11:32:16] risk premium model.

[11:32:18] Do you recall that discussion,

[11:32:18] generally?

[11:32:21] >> sure.

[11:32:28] >> then, on page 38 you also

[11:32:29] discussed a predictive risk

[11:32:33] premium model or prp m. Do you

[11:32:40] recall that discussion?

[11:32:40] >> yes.

[11:32:41] It is a mouthful.

[11:32:52] I believe on page 41, at lines

[11:32:53] 13? 14 of your direct

[11:32:54] testimony, you mentioned that

[11:32:54] the south carolina public

[11:32:55] service commission found your

[11:32:56] arguments persuasive in a 2017

[11:32:57] document involving blue-green

[11:32:58] water company.

[11:32:58] Do you recall that?

[11:33:06] >> yes.

[11:33:07] Would you agree that it is not

[11:33:08] an electric utility case?

[11:33:08] >> it is not.

[11:33:09] >> and that decision was six

[11:33:09] years ago.

[11:33:12] >> that is right.

[11:33:13] >> on page 42 at lines 7

[11:33:13] through 19 you then also

[11:33:15] reference a north carolina city

[11:33:19] commission approval of your rpn

[11:33:27] analyses and docket w3 54 sides

[11:33:28] 363, 364, and 365.

[11:33:40] Do you see that?

[11:33:41] >> yes, ma'am.

[11:33:42] >> and would you also agree

[11:33:42] that it was a water case?

[11:33:43] >> yes, ma'am.

[11:33:44] >> for your direct testimony

[11:33:45] exhibit, dwt one which I

[11:33:50] believe is cl exhibit 20 a.

[11:33:51] That north carolina case looks

[11:33:54] like it occurred in JUNE 2019.

[11:33:59] >> that sounds correct.

[11:34:00] It MAY have gone into 2020 by

[11:34:03] the time the decision went.

[11:34:08] >> sure.

[11:34:10] In your direct testimony

[11:34:11] exhibit, was that you were

[11:34:12] trying to capture times where

[11:34:22] you worked on those cases the

[11:34:23] month or the year that you

[11:34:24] worked on this case is?

[11:34:24] >> yes.

[11:34:25] Generally witnesses have their

[11:34:26] cvs and expert witness

[11:34:26] appearances.

[11:34:29] It is simply that.

[11:34:32] >> sure.

[11:34:36] I heard you tell MS.

[11:34:42] Christiansen that you have

[11:34:43] provided testimony and many

[11:34:44] other states which includes

[11:34:45] kentucky and maryland.

[11:34:46] Is that correct?

[11:34:49] >> yes.

[11:34:50] i believe in kentucky you

[11:34:51] presented testimony in case

[11:34:58] number 2020 100190 which was

[11:34:59] the electric application duke

[11:35:00] energy kentucky inc. For an

[11:35:01] adjustment of the natural gas

[11:35:01] rates.

[11:35:07] And all required waivers which

[11:35:12] is kentucky psc ordered

[11:35:17] DECEMBER 20, 2021.

[11:35:18] Does that sound familiar?

[11:35:18] >> yes.

[11:35:23] I believe it was a settlement.

[11:35:24] >> do you recall the duke

[11:35:28] equity recommended at 10.3?

[11:35:29] >> that sounds about right.

[11:35:30] >>

[11:35:32] and you recall whether you

[11:35:33] provided testimony on the stand

[11:35:36] or simply provided testimony

[11:35:38] prior to the matter at

[11:35:38] resolving?

[11:35:43] >> settled and we did go to

[11:35:44] frankfurt and there was no

[11:35:44] questions.

[11:35:51] I was there.

[11:35:52] >> do you recall what the

[11:35:53] kentucky commission said in its

[11:35:53] order about your testimony on

[11:36:00] behalf of of duke kentucky?

[11:36:01] >> I believe they talked about

[11:36:02] the nonregulated proxy group

[11:36:06] giving little weight to it and

[11:36:06] rejecting the prp m and

[11:36:07] similarly, I believe we

[11:36:08] explained earlier that I did

[11:36:09] not consider those in this case

[11:36:13] for my recommendation.

[11:36:14] >> sure.

[11:36:16] Just for the record and to make

[11:36:18] sure that that is accurate, can

[11:36:23] you pull up walmart five which

[11:36:26] is cl 820?

[11:36:26] That is the order in kentucky

[11:36:34] case number 2021? 00110.

[11:36:39] >> and again, that is a

[11:36:39] settlement.

[11:36:40] >> and there is a commission

[11:36:45] order following that case I

[11:36:45] wanted to ask you about that

[11:36:46] order.

[11:36:46] You said you provided

[11:36:47] testimony.

[11:36:48] Correct?

[11:36:49] >> you provided testimony on

[11:36:52] behalf of of duke kentucky,

[11:36:53] correct?

[11:36:55] >> yes.

[11:37:02] I was characterizing this order

[11:37:02] as a settlement.

[11:37:03] >> can you turn to page 14 of

[11:37:04] the commission please?

[11:37:10] >> sure.

[11:37:11] >> I do apologize that I do not

[11:37:14] have the jump page.

[11:37:21] >> it looks like it is fine at

[11:37:21] 127.

[11:37:22] >> on page 14 do you agree that

[11:37:24] the commission stated quote due

[11:37:25] to kentucky's use of the

[11:37:26] predictive use premium model

[11:37:34] the the prpm has only been

[11:37:35] addressed and three regulatory

[11:37:36] commissions and is not

[11:37:38] universally accepted in the

[11:37:39] commission further stated that

[11:37:40] they are concerned about the

[11:37:51] blackhawk aspects of the prpm.

[11:37:51] >> MR. CHAIRMAN, I am not sure

[11:37:52] why this is relevant.

[11:37:56] He has indicated that he has

[11:37:57] not used that model in this

[11:37:57] case.

[11:37:57] I do not know why we are

[11:37:59] cross-examining about a model

[11:38:00] that MAY have been rejected by

[11:38:05] another commission and had not

[11:38:10] been used in this commission.

[11:38:11] >> it is included in his direct

[11:38:13] testimony.

[11:38:14] He also said that he did still

[11:38:15] model it in this case.

[11:38:19] In addition, I believe he said

[11:38:27] that he offered commission

[11:38:27] staff and opc the opportunity

[11:38:28] to use this model.

[11:38:29] He disagreed with this

[11:38:30] commission's opinion.

[11:38:41] But it was relevant.

[11:38:42] >> he can answer the question.

[11:38:42] that is fine.

[11:38:48] I do not think he has used it.

[11:38:49] >> that is fine.

[11:38:51] I agree with what the order

[11:38:51] says.

[11:38:54] Like MR. Whelan said, if you

[11:38:56] take a look at page 44 of my

[11:38:59] direct testimony, line 12

[11:39:08] through 45 line 4 says that I

[11:39:10] have changed my application of

[11:39:15] the prpm and I have not

[11:39:17] considered it in my analysis

[11:39:18] while leaving it for you to

[11:39:20] look at.

[11:39:21] In my analysis, this does not

[11:39:28] hold any weight.

[11:39:29] >> in your direct on page 44,

[11:39:32] starting at line 24 that is

[11:39:36] your full answer.

[11:39:38] While I respectfully disagree

[11:39:41] with the commission and by the

[11:39:42] commission you are speaking of

[11:39:44] this commission, correct.

[11:39:45] >> yes.

[11:39:49] >> while you respectfully

[11:39:50] disagree with this commission's

[11:39:55] finding order esc 2023? 3088?

[11:40:03] Fof? G you have presented my

[11:40:09] roe prp m as can be gleaned

[11:40:12] from document number 2. My

[11:40:12] recommendation is still within

[11:40:20] the range of roe's produce

[11:40:20] without the prpm.

[11:40:21] Did I read that correctly?

[11:40:22] >> yes you did.

[11:40:26] But if you look at, I do not

[11:40:29] want to get into semantics.

[11:40:38] I am not considering it in this

[11:40:38] case.

[11:40:39] >> sure.

[11:40:39] I was presenting this kentucky

[11:40:40] order because I did not want

[11:40:41] you to have to just recall it

[11:40:42] off memory.

[11:40:43] I believe you have answered my

[11:40:45] questions as to what it stated.

[11:40:47] I would like to move on to

[11:40:49] asking you some questions about

[11:41:00] a case you presented testimony

[11:41:00] for in maryland.

[11:41:01] do you recall presenting our ot

[11:41:02] testimony in maryland.

[11:41:08] Case number 9490 in the matter

[11:41:09] of the potomac edison company

[11:41:10] to reach retail rates for the

[11:41:10] distribution of electric

[11:41:11] energy.

[11:41:16] Which was a maryland decision.

[11:41:16] MARCH 22, 2019.

[11:41:18] Do you recall?

[11:41:18] >>.

[11:41:25] It was five years ago.

[11:41:25] I do recognize it.

[11:41:26] >> do you recall that you

[11:41:27] recommended a roe of 10.8

[11:41:29] percent?

[11:41:35] >> can I see the order please?

[11:41:40] >> yes it is cl 821.

[11:41:41] And on page 2 of that

[11:41:47] commission order, can you see

[11:41:50] what the maryland commission,

[11:41:51] do you have that?

[11:41:54] >> not yet.

[11:41:58] I do apologize.

[11:41:59] It takes a second to pull it

[11:41:59] up.

[11:42:01] It's very good technology but

[11:42:12] there is definitely a bit of a

[11:42:12] lag.

[11:42:13] >> I will let you know.

[11:42:22] It is still chugging along.

[11:42:22] Okay.

[11:42:25] I think I am there.

[11:42:31] Master of 1974?

[11:42:38] >> do you recall that you had

[11:42:39] recommended a roe of 10.8.

[11:42:39] And that the maryland

[11:42:40] commission ordered a roe of

[11:42:45] 9.65 percent?

[11:42:45] >> yes.

[11:42:46] This thing is breaking down.

[11:42:52] But I do recall.

[11:42:53] Can we go to page 74 of that

[11:42:53] order?

[11:43:03] >> I do not think so.

[11:43:10] >> this is pollock staff.

[11:43:11] >> by pollock you are

[11:43:12] referencing MR. Pollick who is

[11:43:12] referenced in this case

[11:43:13] correct?

[11:43:21] >> this is old stuff.

[11:43:22] Do you see on page 74 where the

[11:43:23] maryland commission refers to

[11:43:24] the baltimore gas and electric

[11:43:26] case?

[11:43:27] 2011.

[11:43:32] Do you see that reference?

[11:43:39] >> yes.

[11:43:40] >> in that footnote 269, the

[11:43:40] maryland commission states that

[11:43:41] they have previously found that

[11:43:45] included regulated proxy groups

[11:43:48] that are significantly out of

[11:43:53] line for regulated distribution

[11:43:53] company.

[11:43:54] Do you see that?

[11:43:56] >> yes.

[11:43:59] On page 75, the commission

[11:44:00] further finds that the

[11:44:05] adjustments proposed by potomac

[11:44:06] edison were business risk,

[11:44:11] credit risk, and flotation

[11:44:12] should be rejected.

[11:44:12] O you see

[11:44:12] that?

[11:44:15] >> yes.

[11:44:16] >> and those are

[11:44:16] recommendations that you made,

[11:44:22] correct?

[11:44:23] >> yes.

[11:44:23] But in the people's gas case,

[11:44:24] they accepted my flotation cost

[11:44:25] analysis using the same parent

[11:44:28] company and same sister

[11:44:28] company.

[11:44:29] And that was last year.

[11:44:32] Not five years ago.

[11:44:32] It was in florida.

[11:44:34] Not in maryland.

[11:44:38] The more relevant decision

[11:44:41] would be the people's gas case.

[11:44:46] As far as my recommendation as

[11:44:47] compared to if we want to go up

[11:44:51] to page 73,

[11:44:51] >> no.

[11:44:52] I finished my questions.

[11:45:00] I would like to move along.

[11:45:07] I have prepared a chart which

[11:45:08] charts the kentucky case that

[11:45:09] we just looked at.

[11:45:12] in the maryland case as well as

[11:45:13] others for which you have

[11:45:16] testified the information about

[11:45:18] which cases you have testified

[11:45:21] in comes from your cv.

[11:45:22] Which is exhibit dwd one to

[11:45:26] your direct testimony I would

[11:45:30] like to pull up chart which has

[11:45:32] been marked as cl 819 and it is

[11:45:36] walmart four.

[11:45:43] This is intended to make it a

[11:45:44] little bit faster and easier

[11:45:45] than going through all the

[11:45:45] cases.

[11:45:47] I have simply selected a few.

[11:45:52] Do you see the chart yet?

[11:45:53] >> the kentucky and maryland

[11:45:57] cases are on the chart as well

[11:45:58] as others.

[11:46:03] Is that correct?

[11:46:04] >> kentucky is a settlement.

[11:46:05] New jersey is a settlement.

[11:46:06] The north carolina ones are

[11:46:06] settlements.

[11:46:09] Both texas are settlements.

[11:46:11] These are fully litigated.

[11:46:18] In the second one is not.

[11:46:19] >> to do all of these cases

[11:46:20] appear to be cases in which you

[11:46:21] have provided testimony?

[11:46:22] >

[11:46:22] yes.

[11:46:26] Does the chart show recommended

[11:46:29] rotc made as well as either

[11:46:38] stipulated or litigated

[11:46:38] outcomes?

[11:46:39] >> subject to check, do you

[11:46:40] agree that the recommendations

[11:46:41] accurately reflect your

[11:46:45] recommendations in these cases?

[11:46:46] >> there MAY be times where

[11:46:48] recommended a range.

[11:46:49] But I would take that subject

[11:46:58] to change.

[11:46:59] >> do you agree that these

[11:47:00] outcomes reflect the actual

[11:47:01] release that were stipulated or

[11:47:05] authorized after litigation?

[11:47:05] >> yes.

[11:47:06] I do believe we have talked

[11:47:07] enough about the circumstances

[11:47:09] surrounding settled roe's.

[11:47:11] They are part of a package.

[11:47:14] If one piece falls apart then

[11:47:16] everything falls apart.

[11:47:19] It is a product of give and

[11:47:20] take.

[11:47:20] These are not specifically

[11:47:22] market-based numbers.

[11:47:27] Or precedent-setting.

[11:47:29] >> I do appreciate your

[11:47:29] opinion.

[11:47:30] I need you to stick to the

[11:47:31] questions so that we can get

[11:47:35] through this.

[11:47:36] Have any stipulated or

[11:47:37] litigated outcomes come out on

[11:47:39] this chart match the release

[11:47:48] that you have recommended?

[11:47:48] >> no.

[11:47:49] >> many of these outcomes are

[11:47:50] 100 basis points lower than

[11:47:56] your recommendation is that

[11:47:57] correct?

[11:48:07] >> if you are.

[11:48:08] >> would you not agree that the

[11:48:09] roe's that utilities agree to

[11:48:10] reflect roe's that the

[11:48:14] utilities agree can support

[11:48:18] sufficient capital needed for

[11:48:19] investments?

[11:48:20] >> I do not know why they enter

[11:48:21] the settlements.

[11:48:26] I am never in the room with

[11:48:27] them.

[11:48:27] Generally they come up with a

[11:48:29] package with the other

[11:48:34] interveners and they move on.

[11:48:35] >> do you contend that any of

[11:48:40] the utilities on this chart

[11:48:41] have not been able to provide

[11:48:42] safe and reliable service with

[11:48:43] the roe's that they were

[11:48:44] awarded?

[11:48:47] >> it depends.

[11:48:48] Some of them went right back in

[11:48:50] and filed these cases.

[11:48:51] Because they did not get what

[11:48:56] they wanted.

[11:48:59] Like sps.

[11:49:01] they went right back in.

[11:49:11] The next year.

[11:49:12] >> would you consider duke

[11:49:12] energy florida the closest peer

[11:49:16] to teco in the same state?

[11:49:19] As in a similar environment

[11:49:27] I.E., in florida coastal and

[11:49:27] hurricane risk?

[11:49:27] > no.

[11:49:28] >> what would you consider a

[11:49:34] look closest peer?

[11:49:41] >> you cannot compare the two.

[11:49:42] There is a fair amount of

[11:49:42] discussion with MR. Collins

[11:49:45] about how much bigger duke

[11:49:46] florida is compared to teco.

[11:49:53] In preparation of my testimony

[11:49:55] and of this cross-examination,

[11:50:02] I reviewed the teco danger

[11:50:03] scores of the counties served

[11:50:05] by duke florida and tampa

[11:50:06] electric.

[11:50:11] The danger score for teco is

[11:50:11] 98.

[11:50:13] Which is categorically high.

[11:50:16] And the danger score for duke

[11:50:19] florida is 83 which is

[11:50:23] significantly less.

[11:50:27] You cannot talk about

[11:50:28] comparability.

[11:50:33] Every company has unique risks.

[11:50:33] >> we have to stick to the

[11:50:34] question I ask you.

[11:50:38] You said no.

[11:50:43] So with respect to duke energy,

[11:50:44] is it duke energy corporation

[11:50:48] and some of its subsidiaries

[11:50:49] part of your proxy group?

[11:50:52] >> yes.

[11:50:53] When you select a proxy group

[11:50:59] you do not get exact replicas

[11:51:01] of teco energy.

[11:51:04] I am asking you whether or not

[11:51:05] it is okay to say yes, sir no

[11:51:08] to this?

[11:51:09] Is duke energy florida the

[11:51:19] closest peer utility to teco in

[11:51:20] florida?

[11:51:21] >> how many more qualifiers.

[11:51:24] I would say they are similar.

[11:51:28] as they are 100 percent

[11:51:41] regulated it electric utility

[11:51:47] companies.

[11:51:47] >> want to ask you some

[11:51:50] questions about your rebuttal

[11:51:51] testimony.

[11:51:53] On page 3 line 6? Seven you

[11:51:58] reiterate your recommendation

[11:51:59] of the 11 and a half roe.

[11:51:59] Is that correct?

[11:51:59] >> yes.

[11:52:03] In your rebuttal you responded

[11:52:08] with witnesses direct testimony

[11:52:09] on the issue 39 which is the

[11:52:09] roe issue.

[11:52:10] Is that correct?

[11:52:15] >> yes.

[11:52:16] >> on page 2 of your rebuttal,

[11:52:24] line 6? 19 you identified the

[11:52:25] opposing roe witnesses that you

[11:52:29] are addressing.

[11:52:37] But as

[11:52:37] .

[11:52:37] That is.

[11:52:38] [Listing names].

[11:52:41] Do you understand that doctor.

[11:52:49] [Listing names] Is working with

[11:52:56] the other people.

[11:52:57] >> subject to check.

[11:52:58] That is what the office of

[11:52:59] public council represents.

[11:53:00] Christopher walters, the

[11:53:01] federal executive agencies is

[11:53:05] testifying on behalf of of

[11:53:06] those military and other

[11:53:10] federal agencies.

[11:53:14] >> steve chris is a witness for

[11:53:18] the florida retail iteration

[11:53:20] including my client, walmart

[11:53:21] incorporated.

[11:53:23] And MR. Pollick is a witness on

[11:53:26] behalf of of all industrial

[11:53:28] user customers.

[11:53:29] >> yes.

[11:53:35] And carl is also representing

[11:53:36] residential customers correct?

[11:53:40] >> yes.

[11:53:41] >> that means that all five

[11:53:42] witnesses disagreed that teco

[11:53:47] should be given an 11.5 hourly

[11:53:47] is that correct?

[11:53:49] >> yes.

[11:53:50] Only two of them provided

[11:54:03] market analysis.

[11:54:04] >> I believe that was one of

[11:54:12] the criticisms that you had of

[11:54:12] MR. Chris's testimony.

[11:54:13] But he did not undertake a

[11:54:21] market-based analysis of.

[11:54:23] Teco's roe.

[11:54:29] When you look at regulated

[11:54:38] teco, they do not look at

[11:54:38] market.

[11:54:39] >> when you're talking about

[11:54:40] market-based analyses, the

[11:54:41] market data moves with market

[11:54:41] actions.

[11:54:47] Authoress returns do not.

[11:54:48] >> do you consider what MR.

[11:54:49] Chris did was analyze market

[11:54:49] data.

[11:54:52] >> yes.

[11:54:57] More observations and analysis.

[11:54:59] >> so, they did use analytical

[11:55:06] models because they used the

[11:55:07] dcf.

[11:55:07] Is that correct?

[11:55:07] >> yes.

[11:55:08] And MR. Walters uses the risk

[11:55:12] premium model.

[11:55:13] >> would you agree that this

[11:55:13] commission is not bound to

[11:55:16] adopt any analysis and setting

[11:55:23] an authorized early?

[11:55:23] Roe?

[11:55:24] >> and you would say that this

[11:55:25] commission has broad discretion

[11:55:29] to talk about a number of

[11:55:30] variables correct?

[11:55:34] >> yes.

[11:55:35] In fact we MAY talk about

[11:55:35] recent roe's that we have

[11:55:37] approved correct?

[11:55:38] >> it would be against what is

[11:55:42] usually done.

[11:55:45] But yes.

[11:55:50] Isn't that true?

[11:55:51] >> again, it's against what

[11:55:52] they usually do.

[11:55:54] But yes, they could.

[11:55:56] >> I would like to return to

[11:56:01] the previous roe's in this

[11:56:02] docket.

[11:56:10] Do you recall these were

[11:56:10] recommended?

[11:56:13] >> idea.

[11:56:17] >> I can list them off.

[11:56:18] And ask you for subject to

[11:56:25] check if you would like.

[11:56:26] >> I'm sure you will try.

[11:56:28] Subject to check, to doctor

[11:56:31] woolridge, the witness

[11:56:39] recommend an rotc of 9.5

[11:56:40] percent?

[11:56:40] >> for christopher walters

[11:56:41] recommended an rotc of 9.6

[11:56:42] percent?

[11:56:51] >> within a range of 880? It

[11:56:54] looks like 1143.

[11:56:56] MR. Walters at an indicated

[11:57:01] rotc of 1143.

[11:57:02] This is all shown in my

[11:57:04] document number 11 which is the

[11:57:09] histogram of his indicated

[11:57:09] rotc.

[11:57:09] >> what did you call it?

[11:57:14] I histogram?

[11:57:15] >> if you could pull up

[11:57:19] document number 11, page 1.

[11:57:20] Could you describe in words

[11:57:24] what you mean as a histogram?

[11:57:26] >> pictures are typically more

[11:57:32] than words.

[11:57:33] >> it is exhibit w d2, document

[11:57:33] 11.

[11:58:14] Page 101.

[11:58:15] So,

[11:58:18] >> there it is.

[11:58:27] This is a histogram of MR.

[11:58:27] Walters our ot results.

[11:58:28] This is the history of data.

[11:58:34] Within a population of results.

[11:58:34] If you see the histogram, you

[11:58:37] could see that the majority of

[11:58:40] this is beyond recommendation.

[11:58:42] >> are you calling the

[11:58:44] histogram the bar chart?

[11:58:50] >> that's all I was asking you.

[11:58:51] So, you disagreed that MR.

[11:58:55] Walters in this case

[11:58:58] recommended a roe of 9.6

[11:58:59] percent?

[11:59:03] >> I was expressing a range.

[11:59:04] >> did you see his

[11:59:06] recommendation at 9.6?

[11:59:09] >> that does not reflect his

[11:59:09] results.

[11:59:13] And it was in my rebuttal

[11:59:13] testimony.

[11:59:14] >> did you see MR. Pollick

[11:59:19] recommend a roe of 9.8 percent?

[11:59:20] >> I do believe that was based

[11:59:22] on the average.

[11:59:25] >> subject to check.

[11:59:30] >> do you recall the doctor

[11:59:33] recommending a roe of 9.5

[11:59:33] percent?

[11:59:36] Do you recall MR. Chris, the

[11:59:39] witness for f art of

[11:59:44] referencing a range to date the

[11:59:48] 2021? 2024 average as of the

[11:59:50] time his testimony was 9.62 and

[11:59:55] thus far was 9.72?

[11:59:56] >> I do not believe he provided

[11:59:58] a recommendation.

[12:00:02] >> he did not recommend a

[12:00:02] range.

[12:00:07] Frankly, he did not conduct an

[12:00:07] analysis.

[12:00:08] >> do you recall that

[12:00:08] testimony?

[12:00:12] >> yes.

[12:00:13] >> would you agree that none of

[12:00:14] these witnesses recommend or

[12:00:19] support a roe above 9.7

[12:00:19] percent?

[12:00:21] >> I agree with that.

[12:00:23] Their individual model results

[12:00:28] indicate higher roe's.

[12:00:31] >> would you say that there is

[12:00:31] a significant difference

[12:00:35] between these?

[12:00:36] >> would you also agree that

[12:00:37] the difference between 11 and

[12:00:40] half percent and 9.8 percent is

[12:00:48] over $100 million subject to

[12:00:48] check?

[12:00:54] >> still, I do not know.

[12:01:00] >> stop has no questions.

[12:01:01] Commissioners:

[12:01:03] >> this is quick.

[12:01:07] When you pick proxy groups, a

[12:01:09] number that you put in for your

[12:01:10] analysis, is that the same for

[12:01:13] every time there appears a

[12:01:19] witness for another utility?

[12:01:24] >> it depends on the type of

[12:01:25] company.

[12:01:25] If it is an electric group,

[12:01:26] since there is a large

[12:01:27] population of them, I am able

[12:01:29] to tighten the screws down

[12:01:33] unregulated assets attributable

[12:01:35] to regulated service to try and

[12:01:39] get them closer to 100 percent

[12:01:42] pure play.

[12:01:44] But, if there is a water

[12:01:48] company that has a limited

[12:01:49] number, you kind of relax the

[12:01:49] range.

[12:01:54] To get where you can to have a

[12:01:58] robust analysis.

[12:01:58] >> thank you.

[12:02:01] >> no further questions.

[12:02:03] >> thank you MR. CHAIRMAN.

[12:02:04] And thank you for the help of

[12:02:06] the staff getting a couple of

[12:02:11] these things printed out.

[12:02:12] We are handing out a couple of

[12:02:20] orders and filings in the case

[12:02:26] that was subject to the

[12:02:27] document and identified as

[12:02:29] exhibit 839.

[12:03:13] I would like to ask about

[12:03:16] these.

[12:03:16] MR. CHAIRMAN, just for

[12:03:16] simplicity purposes, I wonder

[12:03:17] if we could get a document

[12:03:20] number four and exhibit number

[12:03:20] 4.

[12:03:23] Delta natural gas companies

[12:03:26] notice of witness every

[12:03:27] substitution.

[12:03:29] That would be 8:40.

[12:03:38] >> I believe we are at 8:40.

[12:03:39] Within the second document

[12:03:40] which is entitled order and

[12:03:47] appears to be dated NOVEMBER

[12:03:53] 12, we can make that 841?

[12:03:55] >> yes.

[12:03:59] >> if you recall, you were

[12:04:02] asked about document 839 which

[12:04:05] is an order that indicates that

[12:04:16] you adopted MR. Mel's direct

[12:04:17] testimony after he had been in

[12:04:23] a bicycle accident?

[12:04:24] I would like you to look at

[12:04:24] document 840.

[12:04:25] Are you familiar with that

[12:04:25] document?

[12:04:30] >> yes.

[12:04:32] And is that a filing that the

[12:04:38] utility made is not based

[12:04:39] number 202100185?

[12:04:42] >> yes.

[12:04:47] Would you read for the record,

[12:04:53] just read the whole thing.

[12:04:53] >> sure.

[12:04:54] >> on JULY 27, 2021 delta

[12:04:56] natural gas company provided

[12:05:04] the notice that the direct

[12:05:05] testimony was directed by.

[12:05:06] [Listing names] Due to a

[12:05:12] serious accident that prevented

[12:05:13] MR. [Listing names] As serving

[12:05:13] as a witness.

[12:05:17] On AUGUST 13, MR. [Listing

[12:05:22] names] Had data requests that

[12:05:23] were important to MR. [Listing

[12:05:28] names]'s testimony.

[12:05:29] His health now does not allow

[12:05:30] him to continue with equity

[12:05:31] matters.

[12:05:34] As such, he redirects his

[12:05:38] testimony to MR. [Listing

[12:05:38] names].

[12:05:41] The commission staff requests

[12:05:50] for information from the

[12:05:51] attorney general's first

[12:05:52] request for information.

[12:05:53] MR. [Listing names] Is not

[12:05:54] expected to have further

[12:05:55] involvement in this proceeding.

[12:05:56] >> did you have any further

[12:05:58] involvement in that case after

[12:06:01] SEPTEMBER 20?

[12:06:01] >> no.

[12:06:02] >> I would not ask you to look

[12:06:05] at the document we have

[12:06:10] identified as number 841.

[12:06:10] do you see that?

[12:06:14] >> yes.

[12:06:15] >> without reading the whole

[12:06:15] thing.

[12:06:17] Could you just focus on the

[12:06:22] second paragraph.

[12:06:23] Generally describe what this

[12:06:27] order does.

[12:06:29] >> it says that there is good

[12:06:36] cause to grant delta's notion.

[12:06:37] >> so he readopted his

[12:06:40] additional testimony and then

[12:06:40] testified on behalf of the

[12:06:41] utility.

[12:06:45] And you did not?

[12:06:45] >> yes.

[12:06:47] That is correct.

[12:06:50] Do you think that explains the

[12:06:53] confusion for the order that

[12:06:55] was identified as 349?

[12:07:06] >> absolutely.

[12:07:10] >> during your

[12:07:13] cross-examination by MS.

[12:07:14] Christiansen, she was asking

[12:07:17] you some questions and you

[12:07:23] wanted to explain your

[12:07:25] histogram and why you ended up

[12:07:33] with your 11.5 roe and MS.

[12:07:34] Christiansen did not allow you

[12:07:37] to answer that question.

[12:07:38] Could you briefly explain why

[12:07:42] you landed on 11.5?

[12:07:45] >> yes I can.

[12:07:46] If you look at my document

[12:07:52] number 2, that would be the

[12:07:58] rebuttal testimony 187 the

[12:08:07] number the number is at the

[12:08:08] bottom.

[12:08:14] I will wait.

[12:08:15] It would start at page 1 and go

[12:08:21] to page 4. It will show that I

[12:08:25] did a similar analysis to what

[12:08:29] I did with MR. Walters about my

[12:08:31] indicated results.

[12:08:33] In the distribution of them.

[12:08:38] If you look at those and look

[12:08:40] at the bottom percentile rank

[12:08:54] of my recommended roe of 11.5

[12:08:55] and falls in the middle of my

[12:08:55] indicated results.

[12:08:56] even though my recommendation

[12:08:57] is about the midpoint of my

[12:08:57] analyses.

[12:08:58] My recommendation is right in

[12:09:06] the middle of my indicative

[12:09:06] roe's.

[12:09:07] >> thank you.

[12:09:18] No further questions.

[12:09:18] >>.

[12:09:22] >> any objection?

[12:09:23] >> seen him, I show them

[12:09:27] entered into the record.

[12:09:31] >> opc would ask to have

[12:09:34] exhibit 321, which I believe

[12:09:36] has already been admitted in

[12:09:38] the record.

[12:09:44] And 839 admitted into the

[12:09:44] record.

[12:09:45] >> any objection?

[12:09:47] >> no objection.

[12:09:48] Seeing none, it is entered into

[12:09:53] the record.

[12:09:54] >> MR. CHAIRMAN, florida retail

[12:09:59] federation is 814 and 815.

[12:10:00] Those are the two cases that we

[12:10:01] identified already.

[12:10:05] >> is there objection?

[12:10:06] >> seeing none, show it entered

[12:10:10] into the record.

[12:10:13] >> j p1 exhibit 82 for a

[12:10:15] comprehensive exhibit list.

[12:10:18] >> I will object to that.

[12:10:21] That is MR. Pollock's

[12:10:27] testimony.

[12:10:31] >> it is not his exhibit.

[12:10:34] I cannot object it when MR.

[12:10:36] Pollock talks about it

[12:10:36] tomorrow.

[12:10:39] I'm not sure I want him to talk

[12:10:46] about it tomorrow.

[12:10:47] >> whichever way you want to do

[12:10:49] it is fine with me.

[12:10:50] I do not have strong feelings

[12:10:56] about it.

[12:10:56] >> I believe it is better when

[12:10:57] MR. Pollock comes up to admit

[12:10:58] that one.

[12:11:05] It has already been used.

[12:11:06] Anything else?

[12:11:06] >> yes.

[12:11:10] we would like walmart 819 on

[12:11:13] the cal through 828.

[12:11:18] That is the chart that I showed

[12:11:19] as well as the orders that

[12:11:21] support the information on the

[12:11:22] chart.

[12:11:26] >> any objection?

[12:11:26] Seeing none, I show those

[12:11:32] entered into the record.

[12:11:33] >> we have a scheduling matter

[12:11:41] before we adjourn tonight.

[12:11:41] Let's excuse the witness.

[12:11:42] S

[12:11:44] that fair?

[12:11:46] >> we are paying him by the

[12:11:47] minute.

[12:11:51] So let's get him.

[12:11:52] >> thank you sir for your

[12:11:55] witness testimony.

[12:11:58] >> we have had some very

[12:12:01] productive discussions today

[12:12:02] with the consumer parties.

[12:12:05] I do appreciate it.

[12:12:06] Our proposal for the

[12:12:07] commission's consideration, if

[12:12:09] I get it wrong I will invite

[12:12:11] the interveners to correct me.

[12:12:13] We would propose that beginning

[12:12:17] tomorrow morning we would start

[12:12:19] with the intervener witnesses

[12:12:21] as listed in the prehearing

[12:12:21] order.

[12:12:25] On page 6 and try to get

[12:12:31] through all of them.

[12:12:32] >> is starting off with MR.

[12:12:39] [Listing names]

[12:12:48] >> once we are through with all

[12:12:53] the intervener witnesses, we

[12:12:54] can pick back up with the tampa

[12:12:55] electric border of witnesses

[12:12:59] with type c strickland

[12:13:00] chronister sizemore and

[12:13:02] williams with a twist that we

[12:13:04] would go ahead and have MR.

[12:13:07] [Listing names] And MR.

[12:13:10] Williams present their direct

[12:13:13] rebuttal together instead of

[12:13:13] separately.

[12:13:14] Which I believe will be more

[12:13:15] efficient.

[12:13:20] i got that wrong, somebody

[12:13:21] please pipe up.

[12:13:22] But I do believe that's what

[12:13:25] was contemplated.

[12:13:28] >> MR. Wallin is correct.

[12:13:29] With one other twist.

[12:13:34] Which is I would hope there is

[12:13:36] a little bit of flexibility

[12:13:40] that we can take by agreement

[12:13:41] with the intervener witnesses

[12:13:44] among ourselves.

[12:13:45] Doctor woolridge asked to give

[12:13:48] a deposition in the morning

[12:13:50] that he is going to do

[12:13:50] remotely.

[12:13:54] From some location here in

[12:13:54] tallahassee.

[12:13:55] He expects that it will be 10

[12:13:58] by 11.

[12:13:59] I do ask for some flexibility

[12:14:00] to work through that among the

[12:14:04] parties if it suits the

[12:14:04] commission.

[12:14:08] >> we have no objection.

[12:14:09] >> I think we can definitely

[12:14:12] accommodate that.

[12:14:14] >> MR. CHAIRMAN, stop and offer

[12:14:15] that staff witnesses could go

[12:14:18] first then tomorrow to provide

[12:14:21] more time to accommodate

[12:14:26] everyone's schedule as they are

[12:14:27] proposing.

[12:14:27] >> that could definitely be

[12:14:29] better for the witnesses.

[12:14:31] So, tomorrow we will start with

[12:14:34] stops witnesses.

[12:14:37] Then we will go to opc's

[12:14:38] witnesses and then we will pick

[12:14:43] back up where we left off.

[12:14:46] >> I think the idea was that

[12:14:52] they were all fine.

[12:14:53] I think we would go through all

[12:14:57] of the witnesses and then go

[12:15:00] back and resume with the

[12:15:02] witnesses as my understanding.

[12:15:05] >> that was my mistake.

[12:15:06] All right.

[12:15:08] Good deal.

[12:15:09] I think we have a reshuffled

[12:15:13] deck for tomorrow.

[12:15:16] >> MR. CHAIRMAN, sierra club

[12:15:19] would like to waive the rights

[12:15:23] of the rest of the cross and be

[12:15:24] excused for the last couple of

[12:15:28] days while remaining a pretty

[12:15:28] record.

[12:15:29] >> you don't want to say?

[12:15:38] >> I'd love to.

[12:15:39] >> that is fine.

[12:15:40] If no other parties have any

[12:15:40] objections.

[12:15:43] >> no objections.

[12:15:45] >> thank you.

[12:15:47] >> tomorrow morning, we will

[12:15:50] start at 8:00 A.M.. Similarly

[12:15:52] to how we did today.

[12:15:55] We will gauge it as we go

[12:15:55] along.

[12:16:02] Every two hours we will have a

[12:16:02] break and try to break for

[12:16:05] lunch around the 12:00 hour.

[12:16:06] If we have to go into the

[12:16:06] evening and we will again.

[12:16:10] Similarly with the dinner

[12:16:10] break.

[12:16:11] I will keep you guys updated as

[12:16:18] we go along.

[12:16:19] >> before sierra club gets

[12:16:20] excused, do you need to move

[12:16:21] your witness testimony into the

[12:16:22] record?

[12:16:22] >> we stipulated at the

[12:16:27] beginning of his hearing.

[12:16:28] >> just wanted to make sure.

[12:16:29] >> I appreciate that.

[12:16:38] >> that will be tomorrow's

[12:16:38] schedule.

[12:16:39] If we are all good, no further

[12:16:40] business we will reconvene

Hearing: 20240026/20230090/20230139-EI (Day 3)

Agenda

Transcript