1
00:00:13,448 --> 00:00:13,982
We're going to go ahead

2
00:00:13,982 --> 00:00:14,516
and get started here this

3
00:00:14,516 --> 00:00:15,983
morning.

4
00:00:15,983 --> 00:00:19,210
Just the kind of recap a

5
00:00:19,210 --> 00:00:19,488
little bit of what today

6
00:00:19,488 --> 00:00:22,488
and where we left off

7
00:00:23,125 --> 00:00:23,492
yesterday and what today

8
00:00:23,492 --> 00:00:24,926
will look like.

9
00:00:24,926 --> 00:00:25,460
So it's 8:00 now.

10
00:00:25,460 --> 00:00:27,562
I'm going to try to stay

11
00:00:27,562 --> 00:00:28,620
consistent with a break

12
00:00:28,620 --> 00:00:31,620
every two hours more or

13
00:00:32,934 --> 00:00:33,402
less depending on kind of

14
00:00:33,402 --> 00:00:33,935
where there is a good

15
00:00:33,935 --> 00:00:35,169
break in the questioning.

16
00:00:35,169 --> 00:00:36,938
12:00 we will break for

17
00:00:36,938 --> 00:00:38,938
lunch.

18
00:00:41,375 --> 00:00:41,877
We MAY go late today.

19
00:00:41,877 --> 00:00:42,244
I was kind of alluding

20
00:00:42,244 --> 00:00:42,711
that yesterday.

21
00:00:42,711 --> 00:00:45,247
So I want to plan for

22
00:00:45,247 --> 00:00:46,748
maybe a 9:00 finish if we

23
00:00:46,748 --> 00:00:47,783
need that much time this

24
00:00:47,783 --> 00:00:50,652
evening and then we will

25
00:00:50,652 --> 00:00:52,187
have a break at some point

26
00:00:52,187 --> 00:00:54,155
maybe as kind of a dinner

27
00:00:54,155 --> 00:00:57,155
break at some point maybe

28
00:00:57,692 --> 00:00:58,260
chat a little bit at the

29
00:00:58,260 --> 00:01:01,260
lunch hour figure out when

30
00:01:01,897 --> 00:01:02,164
the right time for that

31
00:01:02,164 --> 00:01:02,631
would be.

32
00:01:02,631 --> 00:01:05,631
So if we're good with

33
00:01:05,867 --> 00:01:08,867
that, let's go ahead and

34
00:01:17,846 --> 00:01:19,614
pick up where we left off.

35
00:01:19,614 --> 00:01:22,450
MR. Stryker is here in the

36
00:01:22,450 --> 00:01:24,450
witness box.

37
00:01:25,887 --> 00:01:26,254
Sierra club, I will kick

38
00:01:26,254 --> 00:01:28,654
it back to you.

39
00:01:28,990 --> 00:01:29,390
>> if you are member

40
00:01:29,390 --> 00:01:31,390
yesterday we were

41
00:01:31,493 --> 00:01:31,993
discussing limitation

42
00:01:31,993 --> 00:01:33,940
guidelines and your and

43
00:01:33,940 --> 00:01:35,494
teco's contention at big

44
00:01:39,834 --> 00:01:40,368
bend four and polk one

45
00:01:40,368 --> 00:01:40,935
discharging waste waters

46
00:01:40,935 --> 00:01:42,935
into underground injection

47
00:01:46,107 --> 00:01:46,741
wells, is that correct?

48
00:01:46,741 --> 00:01:46,975
>> MS. Sparkman: that is

49
00:01:46,975 --> 00:01:47,843
correct.

50
00:01:47,843 --> 00:01:50,843
>> can you please refer to

51
00:01:54,215 --> 00:01:54,783
cl exhibit cl exhibit 799

52
00:01:54,783 --> 00:01:57,183
purges f-6 207 and f6 208,

53
00:02:06,695 --> 00:02:08,695
please?

54
00:02:10,650 --> 00:02:13,650
So just staying on 206 --

55
00:02:16,370 --> 00:02:17,305
or sorry, 207, teco spent

56
00:02:17,305 --> 00:02:18,372
about $33.3 million to

57
00:02:18,372 --> 00:02:20,372
build underground

58
00:02:20,609 --> 00:02:21,843
injection wells at big

59
00:02:21,843 --> 00:02:22,444
bend, correct?

60
00:02:22,444 --> 00:02:23,645
>> MR. Stryker: that's

61
00:02:23,645 --> 00:02:24,612
correct.

62
00:02:24,612 --> 00:02:27,612
>> and then moving on to

63
00:02:28,149 --> 00:02:29,417
the next page, teco spent

64
00:02:29,417 --> 00:02:31,817
over $30 million to build

65
00:02:31,820 --> 00:02:33,820
underground injection

66
00:02:39,270 --> 00:02:39,661
wells at polk, correct?

67
00:02:39,661 --> 00:02:39,961
>> MR. Stryker: that is

68
00:02:39,961 --> 00:02:40,428
not correct.

69
00:02:40,428 --> 00:02:40,862
The total cost of the

70
00:02:40,862 --> 00:02:41,329
wells was about 30

71
00:02:41,329 --> 00:02:43,329
million, but 50% was

72
00:02:43,665 --> 00:02:43,998
funded by swift mud.

73
00:02:43,998 --> 00:02:45,998
>> okay.

74
00:02:49,437 --> 00:02:49,971
To map that out, that

75
00:02:49,971 --> 00:02:50,272
would be about 15 million

76
00:02:50,272 --> 00:02:50,839
and half --

77
00:02:50,839 --> 00:02:51,339
>> MR. Stryker: about 7.5

78
00:02:51,339 --> 00:02:53,208
million was funded by

79
00:02:53,208 --> 00:02:54,743
water management district.

80
00:02:54,743 --> 00:02:56,743
>> sorry, you said 22.5

81
00:02:57,445 --> 00:02:58,120
million?

82
00:02:58,120 --> 00:02:58,647
>> MR. Stryker: 7.5

83
00:02:58,647 --> 00:03:00,647
million.

84
00:03:07,822 --> 00:03:08,557
>> in total somewhere

85
00:03:08,557 --> 00:03:10,258
around 55 million total

86
00:03:10,258 --> 00:03:11,626
spent on underground

87
00:03:11,626 --> 00:03:14,260
injection wells in total?

88
00:03:14,596 --> 00:03:14,896
>> MR. Stryker: sounds

89
00:03:14,896 --> 00:03:16,896
about right.

90
00:03:17,265 --> 00:03:17,799
>> and were these wells

91
00:03:17,799 --> 00:03:19,400
built to comply with the

92
00:03:19,400 --> 00:03:21,102
eog rule, which was

93
00:03:21,102 --> 00:03:23,502
imposed last year and

94
00:03:23,571 --> 00:03:25,140
adopted earlier this year?

95
00:03:25,140 --> 00:03:27,175
>> the primary purpose of

96
00:03:27,175 --> 00:03:29,944
the polk wells to was to

97
00:03:29,944 --> 00:03:32,344
reclaim to reduce its

98
00:03:34,115 --> 00:03:34,615
groundwater withdrawal and

99
00:03:34,615 --> 00:03:35,150
consume reclaimed water

100
00:03:35,150 --> 00:03:37,851
from the city of lakeland

101
00:03:37,851 --> 00:03:40,851
and the injection was part

102
00:03:44,359 --> 00:03:44,792
of the treatment process.

103
00:03:44,792 --> 00:03:45,327
-- one of which was

104
00:03:45,327 --> 00:03:45,860
compliance with eog rule.

105
00:03:45,860 --> 00:03:47,950
The other reason was an

106
00:03:47,950 --> 00:03:49,495
additional way to manage

107
00:03:56,671 --> 00:03:57,338
stormwater on the side.

108
00:03:57,338 --> 00:04:00,338
>> can you please refer to

109
00:04:03,278 --> 00:04:06,278
cel exhibit c4 starting on

110
00:04:11,852 --> 00:04:13,621
f-6 06?

111
00:04:13,621 --> 00:04:15,230
So this is big bend's

112
00:04:15,230 --> 00:04:16,825
revised national pollutant

113
00:04:16,825 --> 00:04:18,293
distribution system permit

114
00:04:18,293 --> 00:04:19,293
application.

115
00:04:19,293 --> 00:04:22,293
Are you familiar with it?

116
00:04:23,230 --> 00:04:25,630
>> I am somewhat familiar

117
00:04:29,504 --> 00:04:29,971
with it, yes.

118
00:04:29,971 --> 00:04:31,673
>> this revised

119
00:04:31,673 --> 00:04:33,673
application was submitted

120
00:04:35,760 --> 00:04:35,309
in FEBRUARY 2024, is that

121
00:04:35,309 --> 00:04:37,245
correct?

122
00:04:37,245 --> 00:04:37,745
>> MR. Stryker: it was

123
00:04:37,745 --> 00:04:39,745
originally submitted in

124
00:04:40,148 --> 00:04:40,682
2015, but the renewal

125
00:04:40,682 --> 00:04:42,317
process has been delayed

126
00:04:42,317 --> 00:04:43,485
and my understanding

127
00:04:43,485 --> 00:04:44,219
updated app application

128
00:04:44,219 --> 00:04:44,786
because so much has

129
00:04:44,786 --> 00:04:47,786
changed since the time the

130
00:04:49,230 --> 00:04:49,290
application was originally

131
00:04:49,290 --> 00:04:51,920
submitted.

132
00:04:51,920 --> 00:04:51,626
>> right, so that update

133
00:04:51,626 --> 00:04:53,962
was submitted in FEBRUARY

134
00:04:53,962 --> 00:04:54,629
of this year.

135
00:04:54,629 --> 00:04:54,996
>> MR. Stryker: I believe

136
00:04:54,996 --> 00:04:56,996
that's correct.

137
00:04:57,650 --> 00:04:59,650
>> and this application

138
00:04:59,434 --> 00:05:01,434
generally covers teco's

139
00:05:02,804 --> 00:05:03,338
application at big bend in

140
00:05:03,338 --> 00:05:03,871
their compliance with the

141
00:05:03,871 --> 00:05:06,207
clean water act, is that

142
00:05:06,207 --> 00:05:06,808
right?

143
00:05:06,808 --> 00:05:07,750
>> MR. Stryker: that's

144
00:05:07,750 --> 00:05:09,900
correct.

145
00:05:09,900 --> 00:05:09,544
>> can you please refer to

146
00:05:09,544 --> 00:05:11,944
page 10 of this document,

147
00:05:22,689 --> 00:05:23,157
which is f-6 515?

148
00:05:23,157 --> 00:05:25,157
This permit generally

149
00:05:25,593 --> 00:05:26,594
refers to eog rules permit

150
00:05:26,594 --> 00:05:28,594
requirements, is that

151
00:05:29,630 --> 00:05:29,664
right?

152
00:05:29,664 --> 00:05:31,664
>> MR. Stryker: that's

153
00:05:31,900 --> 00:05:33,167
correct, this document is

154
00:05:33,167 --> 00:05:36,167
a fact sheet by the

155
00:05:36,737 --> 00:05:37,271
environmental --

156
00:05:37,271 --> 00:05:37,571
department of environment

157
00:05:37,571 --> 00:05:39,571
protection.

158
00:05:41,420 --> 00:05:41,609
>> no untreatable water

159
00:05:41,609 --> 00:05:42,377
can be discharged into the

160
00:05:42,377 --> 00:05:42,577
united states, is that

161
00:05:42,577 --> 00:05:44,445
right?

162
00:05:44,445 --> 00:05:46,470
>> MR. Stryker: I believe

163
00:05:46,470 --> 00:05:48,470
that's correct, yeah.

164
00:05:48,816 --> 00:05:49,984
>> so there's a revision

165
00:05:49,984 --> 00:05:51,686
in this fact sheet that is

166
00:05:51,686 --> 00:05:54,860
attached to the permit

167
00:05:55,560 --> 00:05:57,456
application on this page

168
00:05:57,692 --> 00:06:00,920
that states "the facility

169
00:06:01,161 --> 00:06:03,161
does generate fgd

170
00:06:05,200 --> 00:06:07,200
wastewater and therefore

171
00:06:11,239 --> 00:06:13,207
the limitations of cfr --

172
00:06:13,207 --> 00:06:14,442
for fgd wastewater are not

173
00:06:14,442 --> 00:06:15,843
applicable in this case.

174
00:06:15,843 --> 00:06:18,243
Do you see that?

175
00:06:20,470 --> 00:06:20,648
>> MR. Stryker: I do.

176
00:06:20,648 --> 00:06:21,181
>> and fgd is bluegrass

177
00:06:21,181 --> 00:06:23,181
diesel fertilization,

178
00:06:24,419 --> 00:06:28,190
which is a result of polk

179
00:06:29,323 --> 00:06:29,924
combustion?

180
00:06:29,924 --> 00:06:30,491
>> MR. Stryker: it's a

181
00:06:30,491 --> 00:06:31,492
product of coal combustion

182
00:06:31,492 --> 00:06:33,492
afterwards treated to

183
00:06:34,228 --> 00:06:36,228
remove emissions.

184
00:06:37,799 --> 00:06:38,266
>> and uic stands for

185
00:06:38,266 --> 00:06:39,501
underground injection

186
00:06:39,501 --> 00:06:40,133
control is?

187
00:06:40,133 --> 00:06:41,102
>> MR. Stryker: that is

188
00:06:41,102 --> 00:06:43,102
correct.

189
00:06:43,538 --> 00:06:44,500
>> based on the

190
00:06:44,500 --> 00:06:46,500
highlighting of this

191
00:06:46,741 --> 00:06:47,308
provision, it looks like

192
00:06:47,308 --> 00:06:49,708
the revision was published

193
00:06:50,311 --> 00:06:50,812
in MARCH 29, 2023.

194
00:06:50,812 --> 00:06:51,379
Teco went from stating

195
00:06:51,379 --> 00:06:53,147
that it's fgd wastewater's

196
00:06:53,147 --> 00:06:56,147
are subject to the fgd

197
00:06:56,517 --> 00:06:57,510
rule to subject that it's

198
00:06:57,510 --> 00:06:57,552
fgd wastewater's are not

199
00:06:57,552 --> 00:06:59,952
subject because it will

200
00:06:59,954 --> 00:07:01,422
now inject wastewater into

201
00:07:01,422 --> 00:07:03,358
these uic wells, is that

202
00:07:03,358 --> 00:07:03,991
correct?

203
00:07:03,991 --> 00:07:04,559
>> MR. Stryker: I don't

204
00:07:04,559 --> 00:07:06,194
know if we ever said the

205
00:07:06,194 --> 00:07:08,129
waters are subject to the

206
00:07:08,129 --> 00:07:09,464
elg.

207
00:07:09,464 --> 00:07:12,464
This is in our document.

208
00:07:15,168 --> 00:07:17,710
This is the florida dep's

209
00:07:17,710 --> 00:07:17,638
document.

210
00:07:17,638 --> 00:07:20,380
>> it looks like the

211
00:07:23,144 --> 00:07:23,444
florida dep said added the

212
00:07:23,444 --> 00:07:24,145
word "not".

213
00:07:24,145 --> 00:07:25,813
So.

214
00:07:25,813 --> 00:07:26,313
>> MR. Stryker: I don't

215
00:07:26,313 --> 00:07:28,713
know that the highlight

216
00:07:29,150 --> 00:07:29,417
means this wasn't an

217
00:07:29,417 --> 00:07:29,817
addition.

218
00:07:29,817 --> 00:07:30,818
I don't know who

219
00:07:30,818 --> 00:07:32,820
highlighted this or why it

220
00:07:32,820 --> 00:07:34,820
was highlighted.

221
00:07:38,590 --> 00:07:40,590
>> okay.

222
00:07:40,610 --> 00:07:42,610
Presumably, the florida

223
00:07:42,563 --> 00:07:43,300
dep works with teco in

224
00:07:43,300 --> 00:07:44,932
order to produce this

225
00:07:44,932 --> 00:07:46,932
document, correct?

226
00:07:47,201 --> 00:07:47,768
>> MR. Stryker: it is a

227
00:07:47,768 --> 00:07:49,503
collaborative process, but

228
00:07:49,503 --> 00:07:51,272
once again I don't know

229
00:07:51,272 --> 00:07:51,605
who wrote what.

230
00:07:51,605 --> 00:07:53,740
>> okay.

231
00:07:53,740 --> 00:07:55,740
Understand.

232
00:07:55,543 --> 00:07:57,943
But you nevertheless agree

233
00:07:59,480 --> 00:08:00,114
with this statement?

234
00:08:00,114 --> 00:08:02,183
>> MR. Stryker: I agree

235
00:08:02,183 --> 00:08:05,183
with the statement as it

236
00:08:08,689 --> 00:08:09,323
is currently written.

237
00:08:09,323 --> 00:08:11,723
>> has epa confirmed this

238
00:08:12,692 --> 00:08:14,294
language or, you know,

239
00:08:14,294 --> 00:08:16,294
confirmed this permit

240
00:08:17,498 --> 00:08:17,899
revision that fgd

241
00:08:17,899 --> 00:08:19,332
revisions are not

242
00:08:19,332 --> 00:08:21,332
applicable because fgd

243
00:08:22,436 --> 00:08:24,672
blowdown can be discharged

244
00:08:24,672 --> 00:08:25,306
to uic wells?

245
00:08:25,306 --> 00:08:27,541
>> MR. Stryker: I don't

246
00:08:27,541 --> 00:08:28,750
know whether epa has

247
00:08:28,750 --> 00:08:29,310
agreed with it or not in

248
00:08:29,310 --> 00:08:29,844
florida.

249
00:08:29,844 --> 00:08:31,110
Florida MS. Wessling has

250
00:08:31,110 --> 00:08:32,146
jurisdiction over the

251
00:08:32,146 --> 00:08:34,146
program.

252
00:08:35,820 --> 00:08:37,685
It is not require epa's

253
00:08:37,685 --> 00:08:38,251
approval.

254
00:08:38,251 --> 00:08:39,953
Epa would have opportunity

255
00:08:39,953 --> 00:08:41,555
to review and comment on

256
00:08:41,555 --> 00:08:44,555
the draft permit, which I

257
00:08:44,925 --> 00:08:45,426
believe --

258
00:08:45,426 --> 00:08:47,528
>> this permit has not

259
00:08:47,528 --> 00:08:48,129
been granted yet?

260
00:08:48,129 --> 00:08:48,362
>> MR. Stryker: that's

261
00:08:48,362 --> 00:08:49,529
correct.

262
00:08:49,529 --> 00:08:51,465
However, the epa has

263
00:08:51,465 --> 00:08:53,865
reviewed and uic permit

264
00:08:55,690 --> 00:08:57,400
has been issued.

265
00:08:57,400 --> 00:08:59,400
Uic permit doesn't

266
00:08:59,572 --> 00:09:00,740
specifically state that

267
00:09:00,740 --> 00:09:02,474
fgd blowdown water can

268
00:09:02,843 --> 00:09:05,243
beat injection -- injected

269
00:09:06,347 --> 00:09:08,747
into the groundwater at

270
00:09:09,450 --> 00:09:11,450
big bend.

271
00:09:12,320 --> 00:09:13,754
>> has teco confirmed the

272
00:09:13,754 --> 00:09:15,754
accuracy of this

273
00:09:19,660 --> 00:09:21,660
contention within the

274
00:09:23,397 --> 00:09:25,797
permit with epa --

275
00:09:27,340 --> 00:09:29,434
>> MR. Stryker: dep has

276
00:09:30,905 --> 00:09:33,305
primacy over this program.

277
00:09:33,874 --> 00:09:34,408
>> is possible teco will

278
00:09:34,408 --> 00:09:35,876
not be able to get around

279
00:09:35,876 --> 00:09:37,277
fgd by injecting

280
00:09:37,277 --> 00:09:37,478
wastewater into uic wells,

281
00:09:37,478 --> 00:09:39,478
right?

282
00:09:40,548 --> 00:09:40,981
>> MR. Stryker: no, as I

283
00:09:40,981 --> 00:09:42,981
mission before, the

284
00:09:43,717 --> 00:09:46,117
permitting agency that has

285
00:09:50,357 --> 00:09:51,325
permitting of this is dep

286
00:09:51,325 --> 00:09:53,325
of florida.

287
00:09:54,695 --> 00:09:55,262
Elg are not applicable to

288
00:09:55,262 --> 00:09:57,662
big bend because injection

289
00:09:59,500 --> 00:10:00,368
controls are not --

290
00:10:00,368 --> 00:10:02,368
>> objection.

291
00:10:03,737 --> 00:10:04,371
Asked and answered.

292
00:10:04,371 --> 00:10:06,771
>> CHAIRMAN La Rosa: it

293
00:10:10,544 --> 00:10:12,544
has been.

294
00:10:15,316 --> 00:10:16,417
>> could you please turn

295
00:10:16,417 --> 00:10:19,417
to cl exhibit to cl

296
00:10:20,287 --> 00:10:23,287
exhibit 121 in page c3 to

297
00:10:32,990 --> 00:10:34,990
3580?

298
00:10:35,736 --> 00:10:38,639
Epa estimated the cost of

299
00:10:38,639 --> 00:10:39,390
elg compliance due to

300
00:10:39,390 --> 00:10:41,390
dealing with fgd

301
00:10:43,409 --> 00:10:43,878
wastewater at big bend is

302
00:10:43,878 --> 00:10:45,112
about 129 million in

303
00:10:45,112 --> 00:10:45,513
capital cost and 9 million

304
00:10:45,513 --> 00:10:46,413
in operating and

305
00:10:46,413 --> 00:10:48,582
maintenance cost, is that

306
00:10:48,582 --> 00:10:49,249
right?

307
00:10:49,249 --> 00:10:50,350
>> MR. Stryker: I'm going

308
00:10:50,350 --> 00:10:50,918
to take your word for it

309
00:10:50,918 --> 00:10:51,518
because there's no way I'm

310
00:10:51,518 --> 00:10:53,518
reading that.

311
00:10:55,122 --> 00:10:55,488
>> have you seen this

312
00:10:55,488 --> 00:10:56,123
document before?

313
00:10:56,123 --> 00:10:56,590
>> MR. Stryker: if it's

314
00:10:56,590 --> 00:10:58,910
the same as the

315
00:10:58,910 --> 00:10:59,760
spreadsheet during the

316
00:10:59,760 --> 00:11:02,760
deposition, I saw it then.

317
00:11:03,764 --> 00:11:04,310
>> are you aware of -- at

318
00:11:04,310 --> 00:11:06,310
big bend?

319
00:11:08,101 --> 00:11:10,501
>> MR. Stryker: I am.

320
00:11:12,806 --> 00:11:15,206
>> and, MR. Stryker, when

321
00:11:16,644 --> 00:11:17,511
do elg wastewater rules go

322
00:11:17,511 --> 00:11:19,511
into effect?

323
00:11:21,480 --> 00:11:22,883
>> MR. Stryker: I believe

324
00:11:22,883 --> 00:11:24,883
this year.

325
00:11:25,190 --> 00:11:26,687
>> can you please refer to

326
00:11:26,687 --> 00:11:29,687
cl exhibit refer to cl

327
00:11:43,270 --> 00:11:43,737
exhibit 798 page f-6 192?

328
00:11:43,737 --> 00:11:46,106
Have you seen the cpa

329
00:11:46,106 --> 00:11:47,107
document before, MR.

330
00:11:47,107 --> 00:11:48,475
Stryker?

331
00:11:48,475 --> 00:11:49,877
>> MR. Stryker: I saw it

332
00:11:49,877 --> 00:11:51,445
recently when you guys

333
00:11:51,445 --> 00:11:52,412
submitted it as a hearing

334
00:11:52,412 --> 00:11:53,981
exhibit.

335
00:11:53,981 --> 00:11:57,150
I have not seen it before

336
00:11:57,150 --> 00:11:57,818
that.

337
00:11:57,818 --> 00:12:00,818
>> would you accept it was

338
00:12:03,123 --> 00:12:05,123
published along with 2024

339
00:12:05,192 --> 00:12:05,458
elg guidelines in APRIL of

340
00:12:05,458 --> 00:12:06,600
this year?

341
00:12:06,600 --> 00:12:06,292
>> MR. Stryker: if you

342
00:12:06,292 --> 00:12:07,328
say so.

343
00:12:07,328 --> 00:12:10,130
I have no way to know its

344
00:12:10,130 --> 00:12:12,130
source and authenticity.

345
00:12:15,269 --> 00:12:15,802
>> okay.

346
00:12:15,802 --> 00:12:15,969
could you turn to page 4

347
00:12:15,969 --> 00:12:16,336
--

348
00:12:16,336 --> 00:12:16,903
>> MR. CHAIRMAN?

349
00:12:16,903 --> 00:12:18,238
Object on the bigness that

350
00:12:18,238 --> 00:12:18,771
the witness just said he

351
00:12:18,771 --> 00:12:19,306
doesn't know what this is

352
00:12:19,306 --> 00:12:20,707
and there's no foundation

353
00:12:20,707 --> 00:12:22,409
to what it is or accuracy.

354
00:12:22,409 --> 00:12:24,344
>> CHAIRMAN La Rosa: can

355
00:12:24,344 --> 00:12:24,845
you give more explanation

356
00:12:24,845 --> 00:12:26,412
of what the exhibit is?

357
00:12:26,412 --> 00:12:28,412
>> MR. CHAIRMAN, this

358
00:12:29,783 --> 00:12:30,316
exhibit is a document

359
00:12:30,316 --> 00:12:31,285
summons submitted to the

360
00:12:31,285 --> 00:12:33,520
federal register.

361
00:12:33,520 --> 00:12:34,888
Is a compliance cost

362
00:12:34,888 --> 00:12:36,888
document associated with

363
00:12:39,793 --> 00:12:40,327
the elg rule of which MR.

364
00:12:40,327 --> 00:12:41,728
Stryker is apparently the

365
00:12:41,728 --> 00:12:42,363
expert witness.

366
00:12:42,363 --> 00:12:43,970
>> CHAIRMAN La Rosa: can

367
00:12:43,970 --> 00:12:45,970
the witness clarify

368
00:12:45,365 --> 00:12:45,799
whether they are familiar

369
00:12:45,799 --> 00:12:46,399
with this document?

370
00:12:46,399 --> 00:12:46,766
>> MR. Stryker: excuse

371
00:12:46,766 --> 00:12:47,601
me?

372
00:12:47,601 --> 00:12:49,536
>> CHAIRMAN La Rosa: can

373
00:12:49,536 --> 00:12:50,370
you clarify whether you

374
00:12:50,370 --> 00:12:51,338
are familiar with this

375
00:12:51,338 --> 00:12:51,972
document?

376
00:12:51,972 --> 00:12:53,307
>> MR. Stryker: I am not

377
00:12:53,307 --> 00:12:53,973
familiar.

378
00:12:53,973 --> 00:12:56,373
>> CHAIRMAN La Rosa: then

379
00:13:32,145 --> 00:13:33,447
sustained.

380
00:13:33,447 --> 00:13:35,847
>> could you please turn

381
00:13:36,416 --> 00:13:38,816
to exhibit to exhibit 795

382
00:13:40,154 --> 00:13:42,522
in the cl page f-6 120?

383
00:13:42,522 --> 00:13:46,122
Which is the big bend uic

384
00:13:56,770 --> 00:13:57,337
permit.

385
00:13:57,337 --> 00:14:00,337
Are you familiar with this

386
00:14:00,674 --> 00:14:01,275
document, -- one?

387
00:14:01,275 --> 00:14:01,441
>> MR. Stryker: yes, I

388
00:14:01,441 --> 00:14:02,750
am.

389
00:14:02,750 --> 00:14:03,310
>> this is permit for the

390
00:14:03,310 --> 00:14:05,110
two water injection wells

391
00:14:05,110 --> 00:14:08,110
that teco built at big

392
00:14:08,915 --> 00:14:09,516
bend four, correct?

393
00:14:09,516 --> 00:14:09,749
>> MR. Stryker: that's

394
00:14:09,749 --> 00:14:11,385
correct.

395
00:14:11,385 --> 00:14:12,920
>> and I believe that

396
00:14:12,920 --> 00:14:13,286
these were built in 2023,

397
00:14:13,286 --> 00:14:15,286
is that correct?

398
00:14:16,757 --> 00:14:17,223
>> MR. Stryker: they went

399
00:14:17,223 --> 00:14:17,791
into service in 2023.

400
00:14:17,791 --> 00:14:19,192
They were constructed over

401
00:14:19,192 --> 00:14:22,792
a period of making it a

402
00:14:22,929 --> 00:14:23,597
year or so.

403
00:14:23,597 --> 00:14:25,265
>> this permit was granted

404
00:14:25,265 --> 00:14:26,330
by the florida department

405
00:14:26,330 --> 00:14:28,330
of environmental

406
00:14:28,101 --> 00:14:28,702
protection, correct?

407
00:14:28,702 --> 00:14:28,935
>> MR. Stryker: that's

408
00:14:28,935 --> 00:14:30,935
correct.

409
00:14:32,940 --> 00:14:35,940
>> if you turn to page 3

410
00:14:40,681 --> 00:14:42,682
of this permit, f-6 122.

411
00:14:42,682 --> 00:14:45,820
States the injection wells

412
00:14:46,620 --> 00:14:47,154
will also be permitted to

413
00:14:47,154 --> 00:14:49,154
receive bluegrass diesel

414
00:14:50,223 --> 00:14:50,690
authorization or fgd

415
00:14:50,690 --> 00:14:52,690
wastewater from tampa

416
00:14:52,859 --> 00:14:53,393
electric big bend station

417
00:14:53,393 --> 00:14:55,128
after department approval

418
00:14:55,128 --> 00:14:58,310
of the analysis of the fgd

419
00:14:58,310 --> 00:14:59,599
waste treaty.

420
00:14:59,599 --> 00:15:00,990
Do you see that?

421
00:15:00,990 --> 00:15:01,100
It's the middle of the

422
00:15:01,100 --> 00:15:03,401
bottom paragraph on this

423
00:15:04,371 --> 00:15:04,938
page?

424
00:15:04,938 --> 00:15:07,338
>> MR. Stryker: I do.

425
00:15:07,541 --> 00:15:07,974
>> has teco received this

426
00:15:07,974 --> 00:15:09,910
department approval?

427
00:15:09,910 --> 00:15:12,310
>> MR. Stryker: yes, we

428
00:15:13,313 --> 00:15:14,648
have.

429
00:15:14,648 --> 00:15:15,382
>> and winded teco receive

430
00:15:15,382 --> 00:15:17,382
that?

431
00:15:18,351 --> 00:15:18,618
>> MR. Stryker: was

432
00:15:18,618 --> 00:15:19,920
recently.

433
00:15:19,920 --> 00:15:21,288
However, that recent

434
00:15:21,288 --> 00:15:24,288
approval was only to allow

435
00:15:24,358 --> 00:15:24,825
direct ingestion of fgd

436
00:15:24,825 --> 00:15:26,260
wastewater since the

437
00:15:26,260 --> 00:15:28,426
initial we were permitted

438
00:15:29,796 --> 00:15:32,196
to discharge the fgd

439
00:15:32,298 --> 00:15:34,267
wastewater into the well

440
00:15:34,267 --> 00:15:37,267
as part of -- recycled

441
00:15:41,107 --> 00:15:41,642
water system.

442
00:15:41,642 --> 00:15:44,420
The approval we recently

443
00:15:46,513 --> 00:15:48,913
received from the eep

444
00:15:50,350 --> 00:15:50,884
since day one of our

445
00:15:50,884 --> 00:15:51,284
operation of the wells we

446
00:15:51,284 --> 00:15:52,685
have been able to

447
00:15:52,685 --> 00:15:55,850
discharge that same water

448
00:15:56,957 --> 00:15:57,524
into the wells because it

449
00:15:57,524 --> 00:16:00,524
was mixed into other waste

450
00:16:01,762 --> 00:16:03,762
streams.

451
00:16:05,132 --> 00:16:08,132
>> can you turn to page 6

452
00:16:28,155 --> 00:16:28,655
of this document, f-6 125?

453
00:16:28,655 --> 00:16:29,550
Here the permit states

454
00:16:29,550 --> 00:16:29,790
injection of fgd

455
00:16:29,790 --> 00:16:31,790
wastewater is authorized

456
00:16:37,731 --> 00:16:38,298
after department approval.

457
00:16:38,298 --> 00:16:38,765
The perimeter table MAY be

458
00:16:38,765 --> 00:16:41,165
amended based on the

459
00:16:41,334 --> 00:16:41,835
constituents detected in

460
00:16:41,835 --> 00:16:42,202
the fgd or other waste

461
00:16:42,202 --> 00:16:42,736
stream analysis.

462
00:16:42,736 --> 00:16:42,936
Do you see where it says

463
00:16:42,936 --> 00:16:44,936
that?

464
00:16:47,307 --> 00:16:48,508
>> MR. Stryker: I do.

465
00:16:48,508 --> 00:16:50,710
>> was the perimeter table

466
00:16:50,710 --> 00:16:51,311
amended?

467
00:16:51,311 --> 00:16:51,745
>> MR. Stryker: no, it

468
00:16:51,745 --> 00:16:53,745
was not.

469
00:17:06,590 --> 00:17:07,460
>> department approval?

470
00:17:07,460 --> 00:17:09,860
When does teco anticipate

471
00:17:10,964 --> 00:17:13,364
getting epa approval with

472
00:17:15,367 --> 00:17:16,536
regards to the elg?

473
00:17:16,536 --> 00:17:16,803
>> MR. Stryker: epa

474
00:17:16,803 --> 00:17:17,300
approval?

475
00:17:17,300 --> 00:17:19,300
Never.

476
00:17:19,772 --> 00:17:20,407
>> why do you say that?

477
00:17:20,407 --> 00:17:20,974
>> MR. Stryker: because

478
00:17:20,974 --> 00:17:22,542
it's not a requirement to

479
00:17:22,542 --> 00:17:23,910
do it in the state of

480
00:17:23,910 --> 00:17:25,645
florida.

481
00:17:25,645 --> 00:17:27,800
>> it's not a requirement

482
00:17:27,800 --> 00:17:30,680
in the state of florida to

483
00:17:30,917 --> 00:17:34,321
get an ea -- eap approval?

484
00:17:34,321 --> 00:17:36,321
>> environmental

485
00:17:38,525 --> 00:17:40,293
protection agency has --

486
00:17:40,293 --> 00:17:42,696
in the state of florida.

487
00:17:42,696 --> 00:17:43,229
>> MR. Stryker, I have a

488
00:17:43,229 --> 00:17:45,629
few questions about teco

489
00:17:45,665 --> 00:17:48,650
is summer and winter

490
00:17:50,503 --> 00:17:50,937
reserve margins.

491
00:17:50,937 --> 00:17:51,471
Should I ask these

492
00:17:51,471 --> 00:17:52,472
questions or should they

493
00:17:52,472 --> 00:17:52,705
be reserved for witness

494
00:17:52,705 --> 00:17:54,474
aponte?

495
00:17:54,474 --> 00:17:56,874
>> MR. Stryker: those are

496
00:17:57,110 --> 00:17:58,678
questions better for

497
00:17:58,678 --> 00:18:00,346
witness aponte.

498
00:18:00,346 --> 00:18:02,746
>> could you please refer

499
00:18:04,451 --> 00:18:04,884
to your testimony page 7?

500
00:18:04,884 --> 00:18:07,284
Your I think direct

501
00:18:15,495 --> 00:18:17,495
testimony.

502
00:18:19,265 --> 00:18:22,265
And the master page number

503
00:18:22,902 --> 00:18:23,436
is d is d255.

504
00:18:23,436 --> 00:18:23,603
I'm so sorry, that might

505
00:18:23,603 --> 00:18:25,603
be.

506
00:18:31,111 --> 00:18:33,111
[Indiscernible]

507
00:18:33,780 --> 00:18:34,347
>> MR. Stryker: okay.

508
00:18:34,347 --> 00:18:37,347
You state that in addition

509
00:18:37,383 --> 00:18:37,884
with the passage of the

510
00:18:37,884 --> 00:18:38,384
inflation act, federal

511
00:18:38,384 --> 00:18:39,619
government is providing

512
00:18:39,619 --> 00:18:41,454
tax incentives that

513
00:18:41,454 --> 00:18:41,621
benefit customers

514
00:18:41,621 --> 00:18:42,550
, the

515
00:18:42,550 --> 00:18:43,890
solar projects the

516
00:18:43,890 --> 00:18:45,890
customers would not

517
00:18:47,193 --> 00:18:47,627
receive the benefits of

518
00:18:47,627 --> 00:18:48,495
the additional tax

519
00:18:48,495 --> 00:18:48,694
incentives until a later

520
00:18:48,694 --> 00:18:50,694
time.

521
00:18:53,400 --> 00:18:54,000
Do you see that?

522
00:18:54,000 --> 00:18:54,167
>> MR. Stryker: yes, I

523
00:18:54,167 --> 00:18:56,200
do.

524
00:18:56,200 --> 00:18:56,336
It's actually on page 8.

525
00:18:56,336 --> 00:18:57,137
>> you go on.

526
00:18:57,137 --> 00:18:59,537
These cost increases and

527
00:19:00,773 --> 00:19:01,341
additional tax credits

528
00:19:01,341 --> 00:19:03,143
were included in the solar

529
00:19:03,143 --> 00:19:05,143
projects, cost-effective

530
00:19:05,512 --> 00:19:07,714
still provide net savings

531
00:19:07,714 --> 00:19:08,213
to our customers.

532
00:19:08,213 --> 00:19:10,316
I understand that teco

533
00:19:10,316 --> 00:19:12,316
incorporated tax credits

534
00:19:12,685 --> 00:19:14,120
into the cost analyses

535
00:19:14,120 --> 00:19:15,355
while electing to pursue

536
00:19:15,355 --> 00:19:17,755
solar projects, is that

537
00:19:18,158 --> 00:19:18,758
right?

538
00:19:18,758 --> 00:19:20,292
>> MR. Stryker: that's

539
00:19:20,292 --> 00:19:21,961
correct.

540
00:19:21,961 --> 00:19:24,961
>> can you please refer to

541
00:19:27,933 --> 00:19:28,401
teco response for fl psc

542
00:19:28,401 --> 00:19:30,401
exhibit 114, which is

543
00:19:32,338 --> 00:19:32,872
teco's response to sierra

544
00:19:32,872 --> 00:19:34,872
club's 50th interrogatory

545
00:19:53,292 --> 00:19:53,760
master page c32 c323261?

546
00:19:53,760 --> 00:19:54,293
the company has board

547
00:19:54,293 --> 00:19:54,794
approved plans to install

548
00:19:54,794 --> 00:19:57,163
an additional 350 mw of

549
00:19:57,163 --> 00:19:57,730
solar from 27-2028 and an

550
00:19:57,730 --> 00:20:00,130
additional 755 mw of solar

551
00:20:02,768 --> 00:20:04,504
from 2029-2033, right?

552
00:20:04,504 --> 00:20:06,904
Tend to clarify, belong

553
00:20:08,441 --> 00:20:08,908
document beyond 2028 the

554
00:20:08,908 --> 00:20:09,475
plans are preliminary

555
00:20:09,475 --> 00:20:10,343
based on current your site

556
00:20:10,343 --> 00:20:12,343
plan.

557
00:20:15,481 --> 00:20:16,916
>> great.

558
00:20:16,916 --> 00:20:19,916
And then could you please

559
00:20:21,554 --> 00:20:24,554
turn on the same exhibit

560
00:20:36,469 --> 00:20:38,869
page c 32 page c 30 23266.

561
00:20:40,730 --> 00:20:40,640
The company has board

562
00:20:40,640 --> 00:20:41,106
approved plans through the

563
00:20:41,106 --> 00:20:42,975
tenure site plan to

564
00:20:42,975 --> 00:20:44,975
install an additional 70

565
00:20:45,979 --> 00:20:48,379
mw storage project in

566
00:20:48,581 --> 00:20:49,215
2028, correct?

567
00:20:49,215 --> 00:20:50,349
>> MR. Stryker: that is

568
00:20:50,349 --> 00:20:51,584
correct.

569
00:20:51,584 --> 00:20:53,353
>> why is teco not

570
00:20:53,353 --> 00:20:56,353
bringing on more than one

571
00:20:57,900 --> 00:20:57,490
storage project in a six

572
00:20:57,490 --> 00:20:58,691
year period from

573
00:20:58,691 --> 00:21:00,691
2027-2023?

574
00:21:01,361 --> 00:21:01,894
>> MR. Stryker: our basic

575
00:21:01,894 --> 00:21:02,528
storage plan is based on

576
00:21:02,528 --> 00:21:04,864
when we have a need as

577
00:21:04,864 --> 00:21:07,264
based on winter reserve

578
00:21:07,567 --> 00:21:08,701
margin falling below 20%.

579
00:21:08,701 --> 00:21:12,301
We will likely as we move

580
00:21:13,740 --> 00:21:14,307
on evaluate whether it

581
00:21:14,307 --> 00:21:14,874
benefits customers further

582
00:21:14,874 --> 00:21:17,610
to have a criminal storage

583
00:21:17,610 --> 00:21:19,211
above and beyond that.

584
00:21:19,211 --> 00:21:20,513
The only need we have as

585
00:21:20,513 --> 00:21:22,181
far as additional capacity

586
00:21:22,181 --> 00:21:24,830
is not until the winter of

587
00:21:24,830 --> 00:21:26,830
2028.

588
00:21:28,721 --> 00:21:29,222
>> could teco add

589
00:21:29,222 --> 00:21:29,688
additional projects to

590
00:21:29,688 --> 00:21:31,688
ensure mega wattages

591
00:21:32,992 --> 00:21:34,794
impaired with stored while

592
00:21:34,794 --> 00:21:37,194
retiring other assets like

593
00:21:38,498 --> 00:21:39,650
we went for polk one?

594
00:21:39,650 --> 00:21:40,233
>> MR. Stryker: that

595
00:21:40,233 --> 00:21:41,533
would be a lot of storage

596
00:21:41,533 --> 00:21:45,104
and I doubt we can get it

597
00:21:45,104 --> 00:21:47,504
added in that timeframe.

598
00:21:50,410 --> 00:21:50,910
>> but does teco need all

599
00:21:50,910 --> 00:21:53,946
of big bend four in its

600
00:21:53,946 --> 00:21:55,810
capacity?

601
00:21:55,810 --> 00:21:55,247
>> MR. Stryker: yes, we

602
00:21:55,247 --> 00:21:57,247
do.

603
00:22:00,552 --> 00:22:01,870
>> 100% of the capacity of

604
00:22:01,870 --> 00:22:01,421
big bend four to meet its

605
00:22:01,421 --> 00:22:03,421
winter margin?

606
00:22:04,557 --> 00:22:04,991
>> objection.

607
00:22:04,991 --> 00:22:05,625
Asked and answered.

608
00:22:05,625 --> 00:22:06,192
>> CHAIRMAN La Rosa: I'm

609
00:22:06,192 --> 00:22:06,659
going to allow the

610
00:22:06,659 --> 00:22:08,659
question to continue

611
00:22:13,399 --> 00:22:14,490
because I think you're

612
00:22:14,490 --> 00:22:14,581
trying to get something

613
00:22:14,581 --> 00:22:14,733
specific.

614
00:22:14,733 --> 00:22:15,267
>> MR. Stryker: as I

615
00:22:15,267 --> 00:22:15,801
mentioned, this is being

616
00:22:15,801 --> 00:22:16,368
built or proposed because

617
00:22:16,368 --> 00:22:17,403
we will have a shortage in

618
00:22:17,403 --> 00:22:20,403
the reserve margin in that

619
00:22:23,242 --> 00:22:23,776
timeframe.

620
00:22:23,776 --> 00:22:25,110
So by default that means

621
00:22:25,110 --> 00:22:25,611
we need the capacity we

622
00:22:25,611 --> 00:22:27,947
already have because we

623
00:22:27,947 --> 00:22:28,447
are going to need more

624
00:22:28,447 --> 00:22:28,647
than what we currently

625
00:22:28,647 --> 00:22:30,647
have.

626
00:22:32,518 --> 00:22:33,850
Further details of that

627
00:22:33,850 --> 00:22:35,485
analysis would be deferred

628
00:22:36,389 --> 00:22:37,230
to witness aponte, though.

629
00:22:37,230 --> 00:22:37,523
>> because you said that,

630
00:22:37,523 --> 00:22:39,580
could we please look at

631
00:22:39,580 --> 00:22:39,592
exhibit

632
00:22:39,592 --> 00:22:40,910
>> because you said that,

633
00:22:40,910 --> 00:22:43,910
could we please look at

634
00:22:45,498 --> 00:22:46,666
exhibit 120 c 32 3577?

635
00:22:46,666 --> 00:22:49,666
And could you please zoom

636
00:23:03,883 --> 00:23:05,751
in on the last row?

637
00:23:05,751 --> 00:23:06,919
MR. Stryker, as you can

638
00:23:06,919 --> 00:23:09,319
see here, this document

639
00:23:10,823 --> 00:23:11,324
shows this is teco's

640
00:23:11,324 --> 00:23:13,724
response to sierra club

641
00:23:17,463 --> 00:23:17,630
interrogatory

642
00:23:17,630 --> 00:23:18,164
.

643
00:23:18,164 --> 00:23:19,799
It shows that teco's, it

644
00:23:19,799 --> 00:23:20,298
shows teco's winter and

645
00:23:20,298 --> 00:23:21,967
summer reserve margins,

646
00:23:21,967 --> 00:23:24,937
the first column for each

647
00:23:24,937 --> 00:23:25,303
year shows the winter

648
00:23:25,303 --> 00:23:26,706
reserve margin.

649
00:23:26,706 --> 00:23:29,106
Second shows the summer

650
00:23:31,310 --> 00:23:32,578
margin.

651
00:23:32,578 --> 00:23:35,214
Going out to 2033, at no

652
00:23:35,214 --> 00:23:38,214
point does teco is reserve

653
00:23:39,850 --> 00:23:41,850
margin dip below 21%.

654
00:23:41,153 --> 00:23:42,688
So my question is how

655
00:23:42,688 --> 00:23:45,880
could you possibly need

656
00:23:46,859 --> 00:23:47,994
100% of polk one and big

657
00:23:47,994 --> 00:23:50,994
bend four to meet reserve

658
00:23:51,697 --> 00:23:52,231
margin when there's a

659
00:23:52,231 --> 00:23:52,898
surplus of reserve margin?

660
00:23:52,898 --> 00:23:55,267
>> MR. Stryker: there's a

661
00:23:55,267 --> 00:23:55,735
serve -- surplus because

662
00:23:55,735 --> 00:23:58,404
when you look at the

663
00:23:58,404 --> 00:24:01,404
bottom two roles we --

664
00:24:01,540 --> 00:24:03,709
maintain and keep from

665
00:24:03,709 --> 00:24:05,709
falling below.

666
00:24:09,810 --> 00:24:09,548
The second row is the

667
00:24:09,548 --> 00:24:10,480
battery we were just

668
00:24:10,480 --> 00:24:10,449
talking about and below

669
00:24:10,449 --> 00:24:10,883
that is future of

670
00:24:10,883 --> 00:24:11,383
combustion turbine.

671
00:24:11,383 --> 00:24:13,383
Without those future

672
00:24:14,753 --> 00:24:17,880
projects it would fall

673
00:24:17,880 --> 00:24:19,880
below 28% requirement.

674
00:24:22,940 --> 00:24:24,940
>> okay.

675
00:24:25,498 --> 00:24:26,766
That 20%, 21% reserve

676
00:24:26,766 --> 00:24:28,968
margin assumes polk one

677
00:24:28,968 --> 00:24:31,968
and big bend four are

678
00:24:37,109 --> 00:24:37,743
online, right?

679
00:24:37,743 --> 00:24:37,976
>> MR. Stryker: that is

680
00:24:37,976 --> 00:24:38,644
correct.

681
00:24:38,644 --> 00:24:39,145
>> in order to get back up

682
00:24:39,145 --> 00:24:39,678
to 21%, you would need

683
00:24:39,678 --> 00:24:42,780
100% of capacity of big

684
00:24:43,949 --> 00:24:44,116
bend four and polk one,

685
00:24:44,116 --> 00:24:44,750
no?

686
00:24:44,750 --> 00:24:46,752
>> MR. Stryker: I can't

687
00:24:46,752 --> 00:24:49,722
do the math on the fly,

688
00:24:49,722 --> 00:24:50,222
but pretty close to it.

689
00:24:50,222 --> 00:24:50,689
>> that's all my

690
00:24:50,689 --> 00:24:52,689
questions.

691
00:24:55,694 --> 00:24:56,262
Thank you.

692
00:24:56,262 --> 00:24:57,129
>> CHAIRMAN La Rosa:

693
00:24:57,129 --> 00:24:59,129
thank you.

694
00:24:59,565 --> 00:25:01,565
Florida retail federation.

695
00:25:02,134 --> 00:25:04,534
>> good morning, -- one.

696
00:25:06,806 --> 00:25:07,405
how are you?

697
00:25:07,405 --> 00:25:07,706
>> MR. Stryker: great,

698
00:25:07,706 --> 00:25:09,706
how are you?

699
00:25:12,711 --> 00:25:14,880
>> I have a very brief

700
00:25:14,880 --> 00:25:17,280
cross for you regarding

701
00:25:18,217 --> 00:25:18,751
your company's plans and

702
00:25:18,751 --> 00:25:20,886
consideration of what you

703
00:25:20,886 --> 00:25:22,887
are calling carbon capture

704
00:25:22,887 --> 00:25:23,322
and storage.

705
00:25:23,322 --> 00:25:25,157
I've gotten used to

706
00:25:25,157 --> 00:25:27,557
calling it carbon capture

707
00:25:29,280 --> 00:25:29,527
and sql station, but

708
00:25:29,527 --> 00:25:29,727
that's the same thing,

709
00:25:29,727 --> 00:25:30,396
right?

710
00:25:30,396 --> 00:25:33,396
>> MR. Stryker: it is the

711
00:25:34,980 --> 00:25:36,980
same thing.

712
00:25:37,536 --> 00:25:38,370
>> my basic question I

713
00:25:38,370 --> 00:25:40,437
think is pretty simple.

714
00:25:42,908 --> 00:25:43,750
What guarantees from

715
00:25:43,750 --> 00:25:43,509
, what

716
00:25:43,509 --> 00:25:45,509
guarantees does the

717
00:25:48,514 --> 00:25:49,470
company expect to have

718
00:25:49,470 --> 00:25:50,282
that co2 is going to stay

719
00:25:50,282 --> 00:25:51,850
where you put?

720
00:25:51,850 --> 00:25:54,250
>> the main, I wouldn't

721
00:25:55,821 --> 00:25:56,355
call it a guarantee, but

722
00:25:56,355 --> 00:25:59,355
the main assurance is the

723
00:25:59,925 --> 00:26:00,459
class vi usc program,

724
00:26:00,459 --> 00:26:02,859
which is administered by

725
00:26:03,762 --> 00:26:04,229
the epa.

726
00:26:04,229 --> 00:26:04,797
It's a very rigorous

727
00:26:04,797 --> 00:26:05,864
permitting program to both

728
00:26:05,864 --> 00:26:07,864
monitor the design,

729
00:26:08,366 --> 00:26:10,366
construction, and

730
00:26:12,304 --> 00:26:12,738
operation of the wells.

731
00:26:12,738 --> 00:26:14,506
's apartment we are

732
00:26:14,506 --> 00:26:17,900
working with the epa on.

733
00:26:17,900 --> 00:26:17,909
These plans are pretty far

734
00:26:17,909 --> 00:26:20,779
out in the future, but

735
00:26:20,779 --> 00:26:21,800
that is the main method of

736
00:26:21,800 --> 00:26:23,800
compliance.

737
00:26:23,810 --> 00:26:24,550
There's also a 20-30 year

738
00:26:24,550 --> 00:26:26,950
period even after you

739
00:26:28,720 --> 00:26:29,210
would cease injection of

740
00:26:29,210 --> 00:26:30,389
the ground.

741
00:26:30,389 --> 00:26:31,590
The company would have the

742
00:26:31,590 --> 00:26:32,758
obligation to monitor the

743
00:26:32,758 --> 00:26:35,727
status of those wells and

744
00:26:35,727 --> 00:26:37,328
make sure there's no new

745
00:26:37,328 --> 00:26:37,964
effects.

746
00:26:37,964 --> 00:26:39,964
>> MR. Scheffel Wright:

747
00:26:40,232 --> 00:26:43,232
what would happen if a

748
00:26:43,568 --> 00:26:44,360
well or start to leak co2

749
00:26:44,360 --> 00:26:46,436
back into the ambient

750
00:26:51,343 --> 00:26:51,944
atmosphere?

751
00:26:51,944 --> 00:26:53,944
>> MR. Stryker: really

752
00:26:55,714 --> 00:26:56,215
nothing other than he

753
00:26:56,215 --> 00:26:56,749
would've lost what you

754
00:26:56,749 --> 00:26:57,216
were trying to accomplish

755
00:26:57,216 --> 00:26:59,184
in the first place.

756
00:26:59,184 --> 00:26:59,585
Is not hazardous to health

757
00:26:59,585 --> 00:27:01,585
unless in higher

758
00:27:01,887 --> 00:27:03,887
concentrations it would

759
00:27:07,458 --> 00:27:09,128
disperse pretty rapidly.

760
00:27:09,128 --> 00:27:10,763
Currently, as we spoke

761
00:27:10,763 --> 00:27:12,431
about before there is not

762
00:27:12,431 --> 00:27:16,310
a mandate to do any sort

763
00:27:16,935 --> 00:27:17,902
of -- project.

764
00:27:17,902 --> 00:27:20,302
Mainly we're looking at

765
00:27:20,806 --> 00:27:21,373
css because we believe it

766
00:27:21,373 --> 00:27:23,108
prudent not to because the

767
00:27:23,108 --> 00:27:25,108
potential economic

768
00:27:26,211 --> 00:27:27,790
benefits to customers via

769
00:27:27,790 --> 00:27:27,513
tax credits, but also the

770
00:27:27,513 --> 00:27:28,147
significant federal

771
00:27:28,147 --> 00:27:30,547
funding we have been

772
00:27:31,717 --> 00:27:32,350
awarded.

773
00:27:32,350 --> 00:27:33,218
>> MR. Scheffel Wright:

774
00:27:33,218 --> 00:27:34,620
wouldn't you expect that

775
00:27:34,620 --> 00:27:36,550
the potential for epa

776
00:27:36,550 --> 00:27:38,550
enforcement would be

777
00:27:40,793 --> 00:27:41,426
equivalent to a mandate?

778
00:27:41,426 --> 00:27:42,326
>> MR. Stryker: I would,

779
00:27:42,326 --> 00:27:45,326
but I just don't know

780
00:27:46,531 --> 00:27:47,990
which rule they would be

781
00:27:47,990 --> 00:27:47,632
enforcing under because if

782
00:27:47,632 --> 00:27:50,632
there's not a rule saying

783
00:27:51,836 --> 00:27:52,504
you have to do this.

784
00:27:52,504 --> 00:27:53,400
>> MR. Scheffel Wright: I

785
00:27:53,400 --> 00:27:53,505
understand that, and I

786
00:27:53,505 --> 00:27:55,774
think we all understand

787
00:27:55,774 --> 00:27:56,207
this is a future scenario.

788
00:27:56,207 --> 00:27:56,708
My question is what

789
00:27:56,708 --> 00:27:59,108
happens with that work.

790
00:27:59,378 --> 00:27:59,878
>> MR. Stryker: I think

791
00:27:59,878 --> 00:28:00,379
the biggest exposure in

792
00:28:00,379 --> 00:28:01,480
all honesty is the call

793
00:28:01,480 --> 00:28:02,647
back revision of the tax

794
00:28:02,647 --> 00:28:04,316
credit if you do not keep

795
00:28:04,316 --> 00:28:06,316
it sequestered.

796
00:28:08,200 --> 00:28:10,956
the tax credit, you have

797
00:28:10,956 --> 00:28:11,457
to give it back.

798
00:28:11,457 --> 00:28:12,924
I think it's less of an

799
00:28:12,924 --> 00:28:14,924
environmental issue than

800
00:28:15,160 --> 00:28:15,794
in my mind.

801
00:28:15,794 --> 00:28:16,662
>> MR. Scheffel Wright:

802
00:28:16,662 --> 00:28:18,662
thanks very much.

803
00:28:19,498 --> 00:28:20,980
That's all I have.

804
00:28:20,980 --> 00:28:20,265
>> MR. Stryker: thank

805
00:28:20,265 --> 00:28:22,265
you.

806
00:28:28,140 --> 00:28:28,774
Walmart?

807
00:28:28,774 --> 00:28:29,241
>> MS. Eaton: thank you.

808
00:28:29,241 --> 00:28:29,675
I do have a couple of

809
00:28:29,675 --> 00:28:30,142
follow-up questions.

810
00:28:30,142 --> 00:28:32,542
We do appreciate your

811
00:28:33,745 --> 00:28:34,279
commitment to adding clean

812
00:28:34,279 --> 00:28:34,813
energy to your grade and

813
00:28:34,813 --> 00:28:35,246
generation fleet and have

814
00:28:35,246 --> 00:28:37,646
a cook of questions

815
00:28:38,716 --> 00:28:40,510
related to collaboration

816
00:28:40,510 --> 00:28:41,520
with customers in that

817
00:28:41,520 --> 00:28:42,921
regard.

818
00:28:42,921 --> 00:28:44,156
Were you here yesterday

819
00:28:44,156 --> 00:28:45,524
when MRS. Sparkman was

820
00:28:45,524 --> 00:28:47,524
testifying?

821
00:28:50,863 --> 00:28:51,363
>> MS. Eaton: I was not

822
00:28:51,363 --> 00:28:51,563
present in the hearing

823
00:28:51,563 --> 00:28:52,164
room.

824
00:28:52,164 --> 00:28:52,730
>> MS. Eaton: are you

825
00:28:52,730 --> 00:28:55,130
familiar with the optional

826
00:28:56,268 --> 00:28:56,767
customer programs she was

827
00:28:56,767 --> 00:28:56,968
developing and talking

828
00:28:56,968 --> 00:28:57,636
about?

829
00:28:57,636 --> 00:28:57,936
>> MR. Stryker: at a very

830
00:28:57,936 --> 00:28:58,570
high level.

831
00:28:58,570 --> 00:28:59,338
>> MS. Eaton: I'm just

832
00:28:59,338 --> 00:29:01,273
wondering if your team

833
00:29:01,273 --> 00:29:03,673
collaborated with her team

834
00:29:04,309 --> 00:29:06,309
ingathering information

835
00:29:07,345 --> 00:29:07,913
from your commercial and

836
00:29:07,913 --> 00:29:09,913
industrial customers about

837
00:29:12,884 --> 00:29:13,451
their sustainability and

838
00:29:13,451 --> 00:29:14,119
renewable energy goals and

839
00:29:14,119 --> 00:29:14,619
how programs could

840
00:29:14,619 --> 00:29:16,619
ultimately be developed

841
00:29:17,722 --> 00:29:20,122
that help tampa electric

842
00:29:21,590 --> 00:29:21,460
and all -- excuse me, and

843
00:29:21,460 --> 00:29:23,460
all the customers.

844
00:29:23,996 --> 00:29:24,529
>> MR. Stryker: there are

845
00:29:24,529 --> 00:29:25,964
a few members for my team

846
00:29:25,964 --> 00:29:27,964
involved.

847
00:29:30,768 --> 00:29:31,103
Her team as the lead face

848
00:29:31,103 --> 00:29:31,637
on customers.

849
00:29:31,637 --> 00:29:32,204
My team has technological

850
00:29:32,204 --> 00:29:32,671
input to the equipment and

851
00:29:32,671 --> 00:29:33,739
design of potential

852
00:29:33,739 --> 00:29:34,706
projects.

853
00:29:34,706 --> 00:29:36,706
>> MS. Eaton: sure.

854
00:29:39,378 --> 00:29:39,845
At some point your team

855
00:29:39,845 --> 00:29:42,245
would get involved in

856
00:29:42,347 --> 00:29:42,914
order to provide the

857
00:29:42,914 --> 00:29:44,549
technical insight into how

858
00:29:44,549 --> 00:29:45,500
to develop those programs.

859
00:29:45,500 --> 00:29:48,500
The other thing that I

860
00:29:49,870 --> 00:29:49,521
didn't hear you mention,

861
00:29:49,521 --> 00:29:51,921
and perhaps this is

862
00:29:52,557 --> 00:29:53,616
another witness, what is

863
00:29:53,616 --> 00:29:56,616
tempos plans to do with

864
00:29:58,663 --> 00:29:59,164
the renewable energy

865
00:29:59,164 --> 00:29:59,698
credits with these new

866
00:29:59,698 --> 00:30:02,980
solar energy and battery

867
00:30:03,902 --> 00:30:04,536
storage units?

868
00:30:04,536 --> 00:30:05,360
>> MR. Stryker: I don't

869
00:30:05,360 --> 00:30:07,360
believe it's anybody's

870
00:30:09,340 --> 00:30:11,109
testimony.

871
00:30:11,109 --> 00:30:11,576
I know we are currently

872
00:30:11,576 --> 00:30:12,143
selling the renewable

873
00:30:12,143 --> 00:30:12,611
energy credits and hundred

874
00:30:12,611 --> 00:30:15,110
percent flow back to

875
00:30:15,480 --> 00:30:17,880
customers and fuel because

876
00:30:21,586 --> 00:30:23,288
, witness heisey can

877
00:30:23,288 --> 00:30:23,855
elaborate more.

878
00:30:23,855 --> 00:30:24,122
>> CHAIRMAN La Rosa:

879
00:30:24,122 --> 00:30:24,322
thank you.

880
00:30:24,322 --> 00:30:25,856
Staff?

881
00:30:25,856 --> 00:30:28,256
>> Staff: staff has just

882
00:30:34,633 --> 00:30:35,100
a couple of questions.

883
00:30:35,100 --> 00:30:35,634
Good morning, -- one.

884
00:30:35,634 --> 00:30:36,167
I would like to ask you a

885
00:30:36,167 --> 00:30:36,668
couple of brief questions

886
00:30:36,668 --> 00:30:37,168
about the 98.4 million

887
00:30:37,168 --> 00:30:37,736
from the department of

888
00:30:37,736 --> 00:30:39,370
energy that you discussed

889
00:30:39,370 --> 00:30:39,838
in your direct testimony.

890
00:30:39,838 --> 00:30:40,370
Are you familiar with

891
00:30:40,370 --> 00:30:42,370
that?

892
00:30:42,740 --> 00:30:42,707
>> I am.

893
00:30:42,707 --> 00:30:45,107
>> Staff: what was that

894
00:30:46,770 --> 00:30:46,678
funding for?

895
00:30:46,678 --> 00:30:47,112
>> MR. Stryker: it was

896
00:30:47,112 --> 00:30:47,479
for three different

897
00:30:47,479 --> 00:30:47,979
funding orders.

898
00:30:47,979 --> 00:30:49,347
One of them was a front

899
00:30:49,347 --> 00:30:51,747
end engineering and design

900
00:30:52,551 --> 00:30:52,984
study to evaluate carbon

901
00:30:52,984 --> 00:30:54,953
capture storage or

902
00:30:54,953 --> 00:30:56,953
sequestration technology

903
00:30:58,757 --> 00:30:59,124
in our polk unit two

904
00:30:59,124 --> 00:31:01,124
combined cycle.

905
00:31:03,995 --> 00:31:04,329
That was approximately $5

906
00:31:04,329 --> 00:31:06,329
million award.

907
00:31:06,364 --> 00:31:09,364
The second award was to

908
00:31:13,705 --> 00:31:14,272
build upon on that study

909
00:31:14,272 --> 00:31:14,739
and take the feed study to

910
00:31:14,739 --> 00:31:15,273
the next level, which

911
00:31:15,273 --> 00:31:15,707
would include evaluating

912
00:31:15,707 --> 00:31:17,275
the storage and

913
00:31:17,275 --> 00:31:19,275
transportation component

914
00:31:20,278 --> 00:31:22,278
of the project.

915
00:31:23,140 --> 00:31:23,447
Including developing

916
00:31:23,447 --> 00:31:23,949
permit application.

917
00:31:23,949 --> 00:31:26,349
It's really taking the

918
00:31:30,322 --> 00:31:30,521
engineering to the next

919
00:31:30,521 --> 00:31:30,988
level.

920
00:31:30,988 --> 00:31:31,222
There was another $5

921
00:31:31,222 --> 00:31:31,756
million.

922
00:31:31,756 --> 00:31:32,257
The biggest award in the

923
00:31:32,257 --> 00:31:34,657
$88 million as part of

924
00:31:35,926 --> 00:31:36,461
what's called the carbon

925
00:31:36,461 --> 00:31:38,229
safe program and that is

926
00:31:38,229 --> 00:31:38,529
to do with detailed

927
00:31:38,529 --> 00:31:40,529
geological

928
00:31:40,731 --> 00:31:42,990
characterization including

929
00:31:42,990 --> 00:31:45,990
drilling up to two wells

930
00:31:49,674 --> 00:31:50,242
and 3d seismic survey.

931
00:31:50,242 --> 00:31:50,775
>> Staff: could that

932
00:31:50,775 --> 00:31:51,309
funding has been used for

933
00:31:51,309 --> 00:31:53,144
something besides carbon

934
00:31:53,144 --> 00:31:53,445
capture and storage

935
00:31:53,445 --> 00:31:55,790
evaluation?

936
00:31:55,790 --> 00:31:57,479
>> MR. Stryker: no, it

937
00:31:58,482 --> 00:31:59,117
cannot.

938
00:31:59,117 --> 00:31:59,651
>> Staff: is teco using

939
00:31:59,651 --> 00:32:00,185
1/3 party -- who is that

940
00:32:00,185 --> 00:32:00,851
contractor?

941
00:32:00,851 --> 00:32:01,719
>> MR. Stryker: there's a

942
00:32:01,719 --> 00:32:03,719
couple of them.

943
00:32:05,890 --> 00:32:05,590
Sergeant lending is our

944
00:32:05,590 --> 00:32:06,957
engineering consultant

945
00:32:06,957 --> 00:32:07,491
doing the engineering.

946
00:32:07,491 --> 00:32:10,491
what we call the balance

947
00:32:13,297 --> 00:32:15,297
of planned engineering.

948
00:32:17,602 --> 00:32:19,504
-- seven clean energy and

949
00:32:19,504 --> 00:32:19,971
ari or advanced resources

950
00:32:19,971 --> 00:32:21,971
internationalism are

951
00:32:23,974 --> 00:32:24,608
geological consultant.

952
00:32:24,608 --> 00:32:24,809
>> Staff: thank you very

953
00:32:24,809 --> 00:32:26,809
much.

954
00:32:30,481 --> 00:32:30,882
Those are all the

955
00:32:30,882 --> 00:32:31,448
questions I have.

956
00:32:31,448 --> 00:32:31,716
>> CHAIRMAN La Rosa:

957
00:32:31,716 --> 00:32:32,150
thank you.

958
00:32:32,150 --> 00:32:32,417
Commissioners, any

959
00:32:32,417 --> 00:32:34,417
questions?

960
00:32:40,910 --> 00:32:40,759
Commissioner graham?

961
00:32:40,759 --> 00:32:41,326
>> Commissioner Graham: I

962
00:32:41,326 --> 00:32:42,861
am a very serious question

963
00:32:42,861 --> 00:32:43,361
for you.

964
00:32:43,361 --> 00:32:45,761
Who is responsible for

965
00:32:46,965 --> 00:32:47,332
naming these solar plants?

966
00:32:47,332 --> 00:32:49,332
Bullfrog creek,

967
00:32:50,167 --> 00:32:50,835
cottonmouth, I mean.

968
00:32:50,835 --> 00:32:52,170
>> MR. Stryker: I wish it

969
00:32:52,170 --> 00:32:52,537
wasn't me.

970
00:32:52,537 --> 00:32:53,671
It's kind of a

971
00:32:53,671 --> 00:32:55,671
collaborative effort.

972
00:32:58,543 --> 00:32:58,977
It's funny, a lot of those

973
00:32:58,977 --> 00:32:59,477
names have changed

974
00:32:59,477 --> 00:33:00,110
multiple times, but we

975
00:33:00,110 --> 00:33:03,611
tend to find a water body

976
00:33:04,716 --> 00:33:05,116
or geological feature and

977
00:33:05,116 --> 00:33:07,180
try to name them.

978
00:33:07,180 --> 00:33:07,451
There actually is a

979
00:33:07,451 --> 00:33:08,586
bullfrog creek and

980
00:33:08,586 --> 00:33:09,220
cottonmouth branch.

981
00:33:09,220 --> 00:33:09,487
>> Commissioner Graham:

982
00:33:09,487 --> 00:33:10,540
thank you.

983
00:33:10,540 --> 00:33:11,289
>> CHAIRMAN La Rosa:

984
00:33:11,289 --> 00:33:13,289
commissioners, any other

985
00:33:16,270 --> 00:33:16,594
questions?

986
00:33:16,594 --> 00:33:16,995
Seeing none, we're back to

987
00:33:16,995 --> 00:33:18,797
teco for redirect.

988
00:33:18,797 --> 00:33:21,197
>> MR. Stryker, you recall

989
00:33:24,168 --> 00:33:24,636
questions about the ccs

990
00:33:24,636 --> 00:33:24,836
project yesterday and

991
00:33:24,836 --> 00:33:25,403
today.

992
00:33:25,403 --> 00:33:27,538
>> MR. Stryker: I do.

993
00:33:27,538 --> 00:33:27,872
>> is teco requesting --

994
00:33:27,872 --> 00:33:29,872
in this case?

995
00:33:33,277 --> 00:33:33,845
>> MR. Stryker: no, as i

996
00:33:33,845 --> 00:33:34,345
mentioned before, the only

997
00:33:34,345 --> 00:33:37,345
request in this case is

998
00:33:39,684 --> 00:33:39,918
our cost year of the doe

999
00:33:39,918 --> 00:33:40,518
awards.

1000
00:33:40,518 --> 00:33:41,850
>> de recall a line of

1001
00:33:41,850 --> 00:33:42,153
questioning yesterday when

1002
00:33:42,153 --> 00:33:45,153
there is a current limit

1003
00:33:46,191 --> 00:33:46,357
of omissions for polk unit

1004
00:33:46,357 --> 00:33:47,625
two?

1005
00:33:47,625 --> 00:33:50,250
>> MR. Stryker: I do.

1006
00:33:50,600 --> 00:33:51,830
>> if there is not an

1007
00:33:51,830 --> 00:33:53,310
emissions limit, why are

1008
00:33:53,310 --> 00:33:53,198
you proceeding with this

1009
00:33:53,198 --> 00:33:55,198
now?

1010
00:33:57,335 --> 00:33:57,902
>> MR. Stryker: one is

1011
00:33:57,902 --> 00:33:58,436
the credibility of funding

1012
00:33:58,436 --> 00:33:59,737
that MAY not be available

1013
00:33:59,737 --> 00:34:02,941
in the future if and when

1014
00:34:02,941 --> 00:34:04,542
there becomes a mandate.

1015
00:34:04,542 --> 00:34:06,211
The other reason is, as I

1016
00:34:06,211 --> 00:34:08,611
mentioned, you heard in

1017
00:34:09,914 --> 00:34:10,447
witness collins testimony

1018
00:34:10,447 --> 00:34:12,847
we are constantly looking

1019
00:34:15,286 --> 00:34:15,753
for ways it can benefit

1020
00:34:15,753 --> 00:34:16,286
the customer and the

1021
00:34:16,286 --> 00:34:16,755
affordability concern and

1022
00:34:16,755 --> 00:34:18,556
the magnitude of the

1023
00:34:18,556 --> 00:34:19,357
taxpayers associated,

1024
00:34:19,357 --> 00:34:21,292
we're talking $3 billion

1025
00:34:21,292 --> 00:34:23,128
in tax credits over the

1026
00:34:23,128 --> 00:34:23,561
life of the project.

1027
00:34:23,561 --> 00:34:24,962
We feel it would be

1028
00:34:24,962 --> 00:34:27,962
imprudent for us to not

1029
00:34:30,335 --> 00:34:30,702
evaluate the potential of

1030
00:34:30,702 --> 00:34:31,302
such a project.

1031
00:34:31,302 --> 00:34:31,870
>> no further questions.

1032
00:34:31,870 --> 00:34:32,700
>> CHAIRMAN La Rosa:

1033
00:34:32,700 --> 00:34:33,505
great.

1034
00:34:33,505 --> 00:34:35,505
Thank you.

1035
00:34:36,241 --> 00:34:36,741
Let's start with moving

1036
00:34:36,741 --> 00:34:39,141
some exhibits into the

1037
00:34:41,178 --> 00:34:41,646
record.

1038
00:34:41,646 --> 00:34:41,913
Teco, do you have any

1039
00:34:41,913 --> 00:34:42,547
exhibits?

1040
00:34:42,547 --> 00:34:44,947
>> yes, we move exhibits

1041
00:34:47,218 --> 00:34:47,451
19 and 143 into the

1042
00:34:47,451 --> 00:34:48,860
record.

1043
00:34:48,860 --> 00:34:48,319
>> CHAIRMAN La Rosa: 19

1044
00:34:48,319 --> 00:34:48,820
and 143.

1045
00:34:48,820 --> 00:34:51,220
Any objections to those?

1046
00:34:52,991 --> 00:34:53,458
see no objections, see

1047
00:34:53,458 --> 00:34:55,858
them entered into the

1048
00:34:57,556 --> 00:34:57,695
record.

1049
00:34:57,695 --> 00:34:57,797
Do any parties have any

1050
00:34:57,797 --> 00:34:57,892
exhibits?

1051
00:34:57,892 --> 00:34:59,230
Start with opc.

1052
00:34:59,230 --> 00:34:59,730
>> things, MR. Chair.

1053
00:34:59,730 --> 00:35:01,132
Opc would move into the

1054
00:35:01,132 --> 00:35:03,132
record hearing exhibits

1055
00:35:05,102 --> 00:35:05,736
408, 300, and 457, please.

1056
00:35:05,736 --> 00:35:06,437
>> CHAIRMAN La Rosa: any

1057
00:35:06,437 --> 00:35:08,437
objections to those

1058
00:35:08,506 --> 00:35:09,600
exhibits?

1059
00:35:09,600 --> 00:35:11,406
Seeing none, show them

1060
00:35:17,715 --> 00:35:17,915
entered into the record.

1061
00:35:17,915 --> 00:35:18,516
Lulac?

1062
00:35:18,516 --> 00:35:19,500
>> thank you, MR. Chair.

1063
00:35:19,500 --> 00:35:19,817
Lulac would move hearing

1064
00:35:19,817 --> 00:35:21,817
exhibits 616, 646, 677,

1065
00:35:22,820 --> 00:35:23,721
678, and 711 into the

1066
00:35:23,721 --> 00:35:25,356
record.

1067
00:35:25,356 --> 00:35:27,756
>> CHAIRMAN La Rosa: any

1068
00:35:28,910 --> 00:35:29,694
thoughts or concerns?

1069
00:35:29,694 --> 00:35:30,327
>> no objections.

1070
00:35:30,327 --> 00:35:32,727
>> CHAIRMAN La Rosa: no

1071
00:35:33,131 --> 00:35:33,698
objections.

1072
00:35:33,698 --> 00:35:33,931
Show them entered into the

1073
00:35:33,931 --> 00:35:35,931
record.

1074
00:35:38,903 --> 00:35:39,470
>> sierra club would like

1075
00:35:39,470 --> 00:35:41,470
to introduce exhibits 799,

1076
00:35:42,740 --> 00:35:44,740
714, 121, 795, and 120

1077
00:35:46,377 --> 00:35:46,878
into the record.

1078
00:35:46,878 --> 00:35:47,512
>> no objections.

1079
00:35:47,512 --> 00:35:49,912
>> CHAIRMAN La Rosa: no

1080
00:35:50,715 --> 00:35:51,282
objections.

1081
00:35:51,282 --> 00:35:51,516
Show them entered into the

1082
00:35:51,516 --> 00:35:51,983
record.

1083
00:35:51,983 --> 00:35:53,170
Any other intervening

1084
00:35:53,170 --> 00:35:55,119
parties have exhibits to

1085
00:35:55,119 --> 00:35:55,620
enter into the record?

1086
00:35:55,620 --> 00:35:58,620
Seeing none, I think we

1087
00:35:58,856 --> 00:36:02,456
can go ahead and move on.

1088
00:36:02,903 --> 00:36:05,303
MR. Stryker, you are

1089
00:36:08,566 --> 00:36:09,133
excused.

1090
00:36:09,133 --> 00:36:09,534
Thank you for your witness

1091
00:36:09,534 --> 00:36:09,801
testimonies today.

1092
00:36:09,801 --> 00:36:10,334
All right.

1093
00:36:10,334 --> 00:36:10,568
I will throw it back over

1094
00:36:10,568 --> 00:36:11,680
to teco.

1095
00:36:11,680 --> 00:36:11,402
You can introduce your

1096
00:36:11,402 --> 00:36:11,602
next witness.

1097
00:36:11,602 --> 00:36:12,703
Okay.

1098
00:36:12,703 --> 00:36:14,905
MR. CHAIRMAN, before we do

1099
00:36:14,905 --> 00:36:16,874
that if you don't mind I

1100
00:36:16,874 --> 00:36:19,874
did a little lawyer map

1101
00:36:23,781 --> 00:36:24,215
and it looks like we've

1102
00:36:24,215 --> 00:36:24,715
got about 14 tampa

1103
00:36:24,715 --> 00:36:25,116
electric witnesses left

1104
00:36:25,116 --> 00:36:26,984
and 13 intervener

1105
00:36:26,984 --> 00:36:28,984
witnesses.

1106
00:36:30,880 --> 00:36:30,521
We talked about it on the

1107
00:36:30,521 --> 00:36:32,521
table electric side.

1108
00:36:37,327 --> 00:36:38,996
I talked to MR.

1109
00:36:38,996 --> 00:36:39,263
Trierweiler and MR.

1110
00:36:39,263 --> 00:36:41,263
Rehwinkel.

1111
00:36:44,768 --> 00:36:45,202
Tampa talk about we

1112
00:36:45,202 --> 00:36:45,736
probably would not

1113
00:36:45,736 --> 00:36:46,300
cross-examine intervener

1114
00:36:46,300 --> 00:36:48,300
witnesses.

1115
00:36:49,173 --> 00:36:49,573
We are part -- prepared to

1116
00:36:49,573 --> 00:36:51,973
say we would not

1117
00:36:52,577 --> 00:36:53,440
cross-examine any

1118
00:36:53,440 --> 00:36:54,211
intervener witnesses

1119
00:36:54,211 --> 00:36:55,579
and/or staff witnesses and

1120
00:36:55,579 --> 00:36:57,181
we are perfectly happy to

1121
00:36:57,181 --> 00:36:58,816
have them insert their

1122
00:36:58,816 --> 00:37:00,500
testimony into the record

1123
00:37:00,500 --> 00:37:03,500
as though red and the

1124
00:37:03,754 --> 00:37:05,323
excused without appearing.

1125
00:37:05,323 --> 00:37:07,425
I think public counsel

1126
00:37:07,425 --> 00:37:07,958
historically has liked to

1127
00:37:07,958 --> 00:37:09,794
have their witnesses make

1128
00:37:09,794 --> 00:37:11,729
a summary and they can

1129
00:37:11,729 --> 00:37:12,296
speak for themselves, but

1130
00:37:12,296 --> 00:37:15,296
we are perfectly happy for

1131
00:37:16,670 --> 00:37:16,566
them all to just be

1132
00:37:16,566 --> 00:37:17,680
entered into the record

1133
00:37:17,680 --> 00:37:18,903
without any summary or

1134
00:37:18,903 --> 00:37:20,705
anything.

1135
00:37:20,705 --> 00:37:22,573
We also talked a little

1136
00:37:22,573 --> 00:37:24,542
bit, there's been

1137
00:37:24,542 --> 00:37:26,542
discussion about outside

1138
00:37:26,810 --> 00:37:27,678
witnesses experts, trying

1139
00:37:27,678 --> 00:37:30,678
to get them all done

1140
00:37:31,148 --> 00:37:31,616
tomorrow.

1141
00:37:31,616 --> 00:37:32,750
We are fine with that.

1142
00:37:32,750 --> 00:37:33,250
I have also understood

1143
00:37:33,250 --> 00:37:35,152
from MR. Rehwinkel that

1144
00:37:35,152 --> 00:37:37,210
maybe they are going to do

1145
00:37:37,210 --> 00:37:38,122
a little bit of work and

1146
00:37:38,122 --> 00:37:41,722
see if they can figure out

1147
00:37:42,393 --> 00:37:42,893
how to trim

1148
00:37:42,893 --> 00:37:43,427
cross-examination, too,

1149
00:37:43,427 --> 00:37:45,290
but we are working on the

1150
00:37:45,290 --> 00:37:45,563
schedule and for planning

1151
00:37:45,563 --> 00:37:46,263
purposes wanted everyone

1152
00:37:46,263 --> 00:37:48,663
to know that tampa

1153
00:37:50,534 --> 00:37:51,200
electric is fine with all

1154
00:37:51,200 --> 00:37:52,102
the outside experts,

1155
00:37:52,102 --> 00:37:54,102
out-of-town witnesses

1156
00:37:55,720 --> 00:37:56,730
appearing tomorrow, we

1157
00:37:56,730 --> 00:37:57,807
would like hours to do

1158
00:37:57,807 --> 00:37:58,108
that, too, if we can and

1159
00:37:58,108 --> 00:38:00,108
will not be

1160
00:38:00,210 --> 00:38:00,645
cross-examining the

1161
00:38:00,645 --> 00:38:01,512
intervener or staff

1162
00:38:01,512 --> 00:38:02,790
witnesses.

1163
00:38:02,790 --> 00:38:03,647
>> CHAIRMAN La Rosa:

1164
00:38:03,647 --> 00:38:04,181
thank you, and I

1165
00:38:04,181 --> 00:38:05,716
appreciate the discussion

1166
00:38:05,716 --> 00:38:07,718
back and forth to help us

1167
00:38:07,718 --> 00:38:08,819
move along.

1168
00:38:08,819 --> 00:38:10,521
I'm going to consult with

1169
00:38:10,521 --> 00:38:12,156
my staff just really

1170
00:38:12,156 --> 00:38:13,924
quickly to see if there's

1171
00:38:13,924 --> 00:38:15,325
anything that we can maybe

1172
00:38:15,325 --> 00:38:17,261
move to expedite things.

1173
00:38:17,261 --> 00:38:18,729
So if you MAY be just give

1174
00:38:18,729 --> 00:38:19,196
me 2 and a half minutes

1175
00:38:19,196 --> 00:38:22,196
and I will come right

1176
00:39:07,644 --> 00:39:09,644
back.

1177
00:42:38,255 --> 00:42:38,455
>> CHAIRMAN La Rosa: all

1178
00:42:38,455 --> 00:42:40,455
right.

1179
00:42:43,930 --> 00:42:43,260
I think we can jump back

1180
00:42:43,260 --> 00:42:43,760
and.

1181
00:42:43,760 --> 00:42:43,960
Got what I needed from

1182
00:42:43,960 --> 00:42:44,494
that.

1183
00:42:44,494 --> 00:42:44,995
Certainly appreciate the

1184
00:42:44,995 --> 00:42:46,995
parties working through

1185
00:42:47,640 --> 00:42:48,432
things and to continue

1186
00:42:48,432 --> 00:42:50,432
working on things.

1187
00:42:50,433 --> 00:42:52,433
Thank you guys.

1188
00:42:53,403 --> 00:42:57,300
Let's move back to teco to

1189
00:42:57,740 --> 00:42:57,307
introduce their next

1190
00:42:57,307 --> 00:42:59,307
witness.

1191
00:42:59,743 --> 00:43:01,743
>> tampa electric calls

1192
00:43:19,696 --> 00:43:20,329
jose aponte, please.

1193
00:43:20,329 --> 00:43:20,831
>> CHAIRMAN La Rosa: MR.

1194
00:43:20,831 --> 00:43:21,798
Aponte, before you sit

1195
00:43:21,798 --> 00:43:24,798
down, I don't believe you

1196
00:43:26,436 --> 00:43:26,703
have been administered the

1197
00:43:26,703 --> 00:43:27,237
oath yet.

1198
00:43:27,237 --> 00:43:28,338
Do you mind stay standing

1199
00:43:28,338 --> 00:43:28,839
and raise your right hand.

1200
00:43:28,839 --> 00:43:31,274
Do you swear and affirm

1201
00:43:31,274 --> 00:43:31,808
the testimony you are

1202
00:43:31,808 --> 00:43:32,476
about to give will be the

1203
00:43:32,476 --> 00:43:34,876
truth, the whole truth,

1204
00:43:35,712 --> 00:43:35,979
and nothing but the truth?

1205
00:43:35,979 --> 00:43:37,314
Thank you.

1206
00:43:37,314 --> 00:43:37,814
Have a seat, settle in,

1207
00:43:37,814 --> 00:43:41,414
and will give you a few

1208
00:43:51,628 --> 00:43:54,280
seconds to get situated.

1209
00:43:55,980 --> 00:43:57,498
It's yours when you're

1210
00:44:00,270 --> 00:44:02,270
ready.

1211
00:44:03,720 --> 00:44:03,640
>> MR. Wahlen: would you

1212
00:44:03,640 --> 00:44:04,341
please state your name for

1213
00:44:04,341 --> 00:44:05,542
the record?

1214
00:44:05,542 --> 00:44:06,876
>> MR. Aponte: jose

1215
00:44:06,876 --> 00:44:08,444
aponte.

1216
00:44:08,444 --> 00:44:09,646
>> MR. Wahlen: and who is

1217
00:44:09,646 --> 00:44:12,460
your current employer and

1218
00:44:14,351 --> 00:44:14,918
business address?

1219
00:44:14,918 --> 00:44:15,452
>> MR. Aponte: table

1220
00:44:15,452 --> 00:44:16,653
electric company business

1221
00:44:16,653 --> 00:44:17,120
is 702 north franklin st.

1222
00:44:17,120 --> 00:44:17,653
>> MR. Aponte: table

1223
00:44:17,653 --> 00:44:18,221
electric company business

1224
00:44:18,221 --> 00:44:19,189
is 702 north franklin st.,

1225
00:44:19,189 --> 00:44:19,723
tampa, fl.

1226
00:44:19,723 --> 00:44:20,257
The limb did you prepare

1227
00:44:20,257 --> 00:44:23,126
cause to be filed in this

1228
00:44:23,126 --> 00:44:24,962
docket APRIL 22, 2024,

1229
00:44:24,962 --> 00:44:26,962
prepared direct testimony

1230
00:44:30,166 --> 00:44:30,700
consisting of 38 pages?

1231
00:44:30,700 --> 00:44:31,301
>> MR. Aponte: yes.

1232
00:44:31,301 --> 00:44:33,701
>> MR. Wahlen: did you

1233
00:44:35,339 --> 00:44:35,872
also prepare cause to be

1234
00:44:35,872 --> 00:44:36,440
filed prepare a rebuttal

1235
00:44:36,440 --> 00:44:38,440
testimony consisting of 15

1236
00:44:39,609 --> 00:44:40,143
pages?

1237
00:44:40,143 --> 00:44:40,743
>> MR. Aponte: yes.

1238
00:44:40,743 --> 00:44:41,210
>> MR. Wahlen: do you

1239
00:44:41,210 --> 00:44:43,610
have any additions or

1240
00:44:46,149 --> 00:44:46,583
corrections to your direct

1241
00:44:46,583 --> 00:44:47,217
rebuttal testimony?

1242
00:44:47,217 --> 00:44:47,884
>> MR. Aponte: I do not.

1243
00:44:47,884 --> 00:44:49,586
>> MR. Wahlen: if I would

1244
00:44:49,586 --> 00:44:50,200
ask you questions prepared

1245
00:44:50,200 --> 00:44:50,554
in your direct and

1246
00:44:50,554 --> 00:44:52,554
rebuttal testimony, with

1247
00:44:54,758 --> 00:44:55,392
those answers be the same?

1248
00:44:55,392 --> 00:44:55,592
>> MR. Aponte: yes, they

1249
00:44:55,592 --> 00:44:56,593
would.

1250
00:44:56,593 --> 00:44:58,593
>> MR. Wahlen: tampa

1251
00:44:59,196 --> 00:45:01,596
electric request it be

1252
00:45:01,865 --> 00:45:04,265
inserted into the record

1253
00:45:05,969 --> 00:45:06,503
as though red.

1254
00:45:06,503 --> 00:45:07,537
MR. Aponte, did you also

1255
00:45:07,537 --> 00:45:10,507
prepare cause to be filed

1256
00:45:10,507 --> 00:45:11,600
with your direct testimony

1257
00:45:11,600 --> 00:45:11,407
exhibit marked j a-one

1258
00:45:11,407 --> 00:45:13,407
consisting of 22

1259
00:45:15,779 --> 00:45:16,313
documents?

1260
00:45:16,313 --> 00:45:18,313
>> MR. Aponte: yes.

1261
00:45:19,483 --> 00:45:21,684
>> MR. Wahlen: did you

1262
00:45:21,684 --> 00:45:22,151
prepare cause to be filed

1263
00:45:22,151 --> 00:45:22,586
exhibit marked j a to

1264
00:45:22,586 --> 00:45:22,853
consisting of three

1265
00:45:22,853 --> 00:45:23,386
documents?

1266
00:45:23,386 --> 00:45:25,386
>> MR. Aponte: yes.

1267
00:45:27,890 --> 00:45:27,624
>> MR. Wahlen: MR.

1268
00:45:27,624 --> 00:45:28,157
CHAIRMAN, for the record

1269
00:45:28,157 --> 00:45:28,625
we will note exhibits ja

1270
00:45:28,625 --> 00:45:29,250
one and two have been

1271
00:45:29,250 --> 00:45:31,250
identified in the

1272
00:45:31,728 --> 00:45:33,728
comprehensive exhibit list

1273
00:45:33,897 --> 00:45:34,464
as exhibits 20 and 144.

1274
00:45:34,464 --> 00:45:34,664
>> CHAIRMAN La Rosa:

1275
00:45:34,664 --> 00:45:36,199
okay.

1276
00:45:36,199 --> 00:45:36,600
>> MR. Wahlen: MR.

1277
00:45:36,600 --> 00:45:38,600
Aponte, we please

1278
00:45:39,936 --> 00:45:42,336
summarize your direct and

1279
00:45:42,672 --> 00:45:43,240
rebuttal testimony.

1280
00:45:43,240 --> 00:45:43,840
>> MR. Aponte: good

1281
00:45:43,840 --> 00:45:45,840
morning, commissioners.

1282
00:45:49,746 --> 00:45:50,213
My name is MR. Aponte.

1283
00:45:50,213 --> 00:45:50,680
As you are aware, the

1284
00:45:50,680 --> 00:45:52,680
company is proposing

1285
00:45:53,516 --> 00:45:54,490
several resource additions

1286
00:45:54,490 --> 00:45:56,119
to its general portfolio

1287
00:45:56,119 --> 00:45:59,119
in order to satisfy our

1288
00:45:59,489 --> 00:45:59,889
reserve margin needs and

1289
00:45:59,889 --> 00:46:00,156
affordability for

1290
00:46:00,156 --> 00:46:01,224
customers.

1291
00:46:01,224 --> 00:46:02,125
My direct testimony

1292
00:46:02,125 --> 00:46:04,125
demonstrates that the

1293
00:46:04,127 --> 00:46:06,527
projects in the proposed

1294
00:46:06,830 --> 00:46:08,830
portfolio consisting of

1295
00:46:16,720 --> 00:46:16,573
this tampa resilience polk

1296
00:46:16,573 --> 00:46:17,107
one flexibility, future

1297
00:46:17,107 --> 00:46:17,540
energy storage and future

1298
00:46:17,540 --> 00:46:19,540
energy projects are

1299
00:46:22,979 --> 00:46:23,380
cost-effective, they are

1300
00:46:23,380 --> 00:46:23,813
prudent, promote

1301
00:46:23,813 --> 00:46:24,915
efficiency and fuel

1302
00:46:24,915 --> 00:46:27,315
diversity, and enhance the

1303
00:46:29,319 --> 00:46:29,819
reliability and resilience

1304
00:46:29,819 --> 00:46:31,488
of the company's system.

1305
00:46:31,488 --> 00:46:31,955
Together, these projects

1306
00:46:31,955 --> 00:46:33,657
are expected to save

1307
00:46:33,657 --> 00:46:35,657
customers about $1.2

1308
00:46:36,759 --> 00:46:39,159
billion in fuel costs.

1309
00:46:40,130 --> 00:46:41,831
And over $490 million in

1310
00:46:41,831 --> 00:46:43,831
cumulative present value

1311
00:46:44,868 --> 00:46:46,868
revenue requirements.

1312
00:46:47,270 --> 00:46:49,270
My rebuttal testimony

1313
00:46:50,440 --> 00:46:51,908
serves several purposes.

1314
00:46:51,908 --> 00:46:53,908
It refused criticism

1315
00:47:03,153 --> 00:47:03,720
raised by fipa and lulac.

1316
00:47:03,720 --> 00:47:04,187
It addresses comments from

1317
00:47:04,187 --> 00:47:06,587
sierra club about the

1318
00:47:07,323 --> 00:47:07,857
economics of converting

1319
00:47:07,857 --> 00:47:11,457
polk unit one to a single

1320
00:47:19,669 --> 00:47:20,203
cycle unit and responds to

1321
00:47:20,203 --> 00:47:22,380
fipug's -- this concludes

1322
00:47:22,380 --> 00:47:22,305
my summary.

1323
00:47:22,305 --> 00:47:24,305
Thank you.

1324
00:47:25,410 --> 00:47:27,441
>> MR. Wahlen: MR. Aponte

1325
00:47:28,545 --> 00:47:28,945
is available for

1326
00:47:28,945 --> 00:47:29,512
cross-examination.

1327
00:47:29,512 --> 00:47:29,779
>> CHAIRMAN La Rosa:

1328
00:47:29,779 --> 00:47:31,381
thank you.

1329
00:47:31,381 --> 00:47:33,781
Opc, you are recognized.

1330
00:47:34,317 --> 00:47:34,850
>> good morning.

1331
00:47:34,850 --> 00:47:38,321
Can I ask you to turn to

1332
00:47:38,321 --> 00:47:38,587
page 6 of your direct

1333
00:47:38,587 --> 00:47:40,587
testimony?

1334
00:47:51,267 --> 00:47:51,801
25302.

1335
00:47:51,801 --> 00:47:53,801
>> MR. Aponte: yes.

1336
00:47:55,438 --> 00:47:57,307
>> on page 6 starting on

1337
00:47:57,307 --> 00:47:57,841
line 13, then you say the

1338
00:47:57,841 --> 00:48:00,241
purpose of your testimony

1339
00:48:00,443 --> 00:48:01,900
is to do the

1340
00:48:01,900 --> 00:48:02,645
cost-effectiveness test to

1341
00:48:02,645 --> 00:48:04,847
support teco's request to

1342
00:48:04,847 --> 00:48:06,847
include the multiple

1343
00:48:07,283 --> 00:48:07,817
generic projects, correct?

1344
00:48:07,817 --> 00:48:09,251
>> MR. Aponte: yes.

1345
00:48:09,251 --> 00:48:09,819
>> okay.

1346
00:48:09,819 --> 00:48:13,223
and then if you move on to

1347
00:48:13,223 --> 00:48:15,623
page 7 of your testimony,

1348
00:48:16,910 --> 00:48:18,491
starting at line 1 you

1349
00:48:21,763 --> 00:48:24,763
start to say that your

1350
00:48:26,350 --> 00:48:27,937
testimony shows from a cpv

1351
00:48:27,937 --> 00:48:30,337
rr basis the company's

1352
00:48:31,140 --> 00:48:31,574
resource plan is

1353
00:48:31,574 --> 00:48:31,807
favorable, is that

1354
00:48:31,807 --> 00:48:32,842
correct?

1355
00:48:32,842 --> 00:48:34,842
>> MR. Aponte: yes.

1356
00:48:35,110 --> 00:48:37,110
>> okay.

1357
00:48:37,847 --> 00:48:40,247
What does cpvrr mean?

1358
00:48:40,884 --> 00:48:41,351
>> MR. Aponte:

1359
00:48:41,351 --> 00:48:41,683
communicative present

1360
00:48:41,683 --> 00:48:42,618
value revenue

1361
00:48:42,618 --> 00:48:44,618
requirements.

1362
00:48:45,255 --> 00:48:45,788
>> okay.

1363
00:48:45,788 --> 00:48:48,788
Would you agree that the

1364
00:48:50,960 --> 00:48:51,527
-- five is intended to

1365
00:48:51,527 --> 00:48:52,610
compare the alternative of

1366
00:48:52,610 --> 00:48:53,562
the proposed unit and its

1367
00:48:53,562 --> 00:48:55,865
revenue requirement to the

1368
00:48:55,865 --> 00:48:56,432
next alternative unit?

1369
00:48:56,432 --> 00:48:58,432
>> MR. Aponte: yes,

1370
00:48:58,902 --> 00:48:59,235
that's correct.

1371
00:48:59,235 --> 00:48:59,769
>> okay.

1372
00:48:59,769 --> 00:49:02,105
And you're the person who

1373
00:49:02,105 --> 00:49:02,605
developed the economic

1374
00:49:02,605 --> 00:49:04,605
evaluations and support

1375
00:49:05,742 --> 00:49:06,142
for the companies solar

1376
00:49:06,142 --> 00:49:08,142
projects, correct?

1377
00:49:11,800 --> 00:49:11,748
>> MR. Aponte: correct.

1378
00:49:11,748 --> 00:49:12,282
>> would you agree that in

1379
00:49:12,282 --> 00:49:12,682
your economic evaluations

1380
00:49:12,682 --> 00:49:13,916
for the new solar

1381
00:49:13,916 --> 00:49:15,418
resources, you used a 35

1382
00:49:15,418 --> 00:49:18,418
year service life for the

1383
00:49:21,324 --> 00:49:21,858
solar?

1384
00:49:21,858 --> 00:49:22,525
>> MR. Aponte: yes.

1385
00:49:22,525 --> 00:49:25,525
>> would you also agree if

1386
00:49:27,263 --> 00:49:27,797
you use ash longer or

1387
00:49:27,797 --> 00:49:28,530
shorter service life the

1388
00:49:28,530 --> 00:49:29,650
economic evaluation and

1389
00:49:29,650 --> 00:49:29,899
present value benefit or

1390
00:49:29,899 --> 00:49:32,299
harm of adding the

1391
00:49:32,302 --> 00:49:34,702
resource compared to the

1392
00:49:35,271 --> 00:49:35,905
base rate?

1393
00:49:35,905 --> 00:49:37,730
>> MR. Aponte: it would

1394
00:49:37,730 --> 00:49:39,730
change it.

1395
00:49:39,709 --> 00:49:40,276
>> and isn't it true if

1396
00:49:40,276 --> 00:49:41,844
you used a shorter service

1397
00:49:41,844 --> 00:49:42,578
life, it would reduce the

1398
00:49:42,578 --> 00:49:44,978
economic benefit of the

1399
00:49:48,250 --> 00:49:50,250
solar resources?

1400
00:49:50,753 --> 00:49:51,220
>> MR. Aponte: subject to

1401
00:49:51,220 --> 00:49:53,620
check, I believe the

1402
00:49:56,626 --> 00:49:56,959
change will be

1403
00:49:56,959 --> 00:49:57,626
insignificant.

1404
00:49:57,626 --> 00:49:59,896
>> but you would agree

1405
00:49:59,896 --> 00:50:01,430
that it would lessen the

1406
00:50:01,430 --> 00:50:03,430
economic benefit?

1407
00:50:06,669 --> 00:50:07,337
However slightly.

1408
00:50:07,337 --> 00:50:08,104
>> MR. Aponte: not having

1409
00:50:08,104 --> 00:50:09,939
done it, I would have to

1410
00:50:09,939 --> 00:50:11,400
say it's just a small

1411
00:50:11,400 --> 00:50:12,709
change.

1412
00:50:12,709 --> 00:50:14,430
I don't know which way it

1413
00:50:14,430 --> 00:50:15,478
would go.

1414
00:50:15,478 --> 00:50:17,478
>> okay.

1415
00:50:18,781 --> 00:50:19,314
If the solar project is

1416
00:50:19,314 --> 00:50:19,782
delayed or never billed,

1417
00:50:19,782 --> 00:50:22,182
that would reduce the

1418
00:50:22,385 --> 00:50:22,885
economic benefit of the

1419
00:50:22,885 --> 00:50:24,885
solar resource itself,

1420
00:50:26,822 --> 00:50:28,822
correct?

1421
00:50:29,859 --> 00:50:31,859
>> MR. Aponte: yes.

1422
00:50:33,429 --> 00:50:37,290
>> I would ask to look at

1423
00:50:38,434 --> 00:50:40,434
opc five.

1424
00:50:42,672 --> 00:50:43,840
And as soon as that is up,

1425
00:50:43,840 --> 00:50:45,840
there we go.

1426
00:50:49,645 --> 00:50:52,645
Do you see that workpaper?

1427
00:50:53,683 --> 00:50:54,160
>> MR. Aponte: yes.

1428
00:50:54,160 --> 00:50:56,160
>> okay.

1429
00:50:57,860 --> 00:50:59,655
Is this your analysis for

1430
00:50:59,655 --> 00:51:01,657
the solar farm project?

1431
00:51:01,657 --> 00:51:03,657
>> MR. Aponte: yes.

1432
00:51:07,163 --> 00:51:07,663
>> looking at the bottom

1433
00:51:07,663 --> 00:51:08,164
there's a note there, I

1434
00:51:08,164 --> 00:51:08,698
know it's difficult to

1435
00:51:08,698 --> 00:51:09,980
read and would be easier

1436
00:51:09,980 --> 00:51:11,980
from your laptop.

1437
00:51:11,868 --> 00:51:12,101
It says 2053 contains and

1438
00:51:12,101 --> 00:51:14,101
affects.

1439
00:51:15,238 --> 00:51:16,172
Does this mean the -- five

1440
00:51:16,172 --> 00:51:18,572
analysis was done for 30

1441
00:51:21,677 --> 00:51:22,311
years or three 2053?

1442
00:51:22,311 --> 00:51:22,778
>> MR. Aponte: what that

1443
00:51:22,778 --> 00:51:23,312
means is in order to

1444
00:51:23,312 --> 00:51:25,712
capture the full revenue

1445
00:51:27,282 --> 00:51:29,510
requirements for assets

1446
00:51:29,510 --> 00:51:30,119
that go in service later

1447
00:51:30,119 --> 00:51:33,119
in the time horizon, we

1448
00:51:34,757 --> 00:51:35,291
have to extend the

1449
00:51:35,291 --> 00:51:36,759
calculations past 2053 to

1450
00:51:36,759 --> 00:51:38,494
capture their full revenue

1451
00:51:38,494 --> 00:51:40,494
requirement components of

1452
00:51:42,665 --> 00:51:43,332
future assets.

1453
00:51:43,332 --> 00:51:43,799
>> okay.

1454
00:51:43,799 --> 00:51:44,433
Is a correct that the

1455
00:51:44,433 --> 00:51:47,433
company does not have any

1456
00:51:49,472 --> 00:51:50,500
specific plans to retire

1457
00:51:50,500 --> 00:51:50,506
its solar resources prior

1458
00:51:50,506 --> 00:51:52,708
to the 35 year service

1459
00:51:52,708 --> 00:51:55,108
life reflected in the

1460
00:51:56,645 --> 00:51:57,179
economic evaluations?

1461
00:51:57,179 --> 00:51:59,179
>> MR. Aponte: yes.

1462
00:52:01,490 --> 00:52:01,951
>> and would you agree

1463
00:52:01,951 --> 00:52:05,551
that in the near term, and

1464
00:52:06,255 --> 00:52:06,622
this is a slightly

1465
00:52:06,622 --> 00:52:07,857
different take.

1466
00:52:07,857 --> 00:52:09,725
Artificial intelligence

1467
00:52:09,725 --> 00:52:11,427
holds the possibility of

1468
00:52:11,427 --> 00:52:13,427
lowering operating costs

1469
00:52:13,663 --> 00:52:14,196
of and extending the lives

1470
00:52:14,196 --> 00:52:16,596
of your solar generation

1471
00:52:17,466 --> 00:52:18,134
facilities, if you know.

1472
00:52:18,134 --> 00:52:19,235
>> MR. Aponte: sorry, you

1473
00:52:19,235 --> 00:52:21,235
said artificial

1474
00:52:22,838 --> 00:52:24,838
intelligence?

1475
00:52:26,809 --> 00:52:28,611
>> mm-hmm.

1476
00:52:28,611 --> 00:52:31,611
>> MR. Aponte: I hope it

1477
00:52:31,681 --> 00:52:32,114
will.

1478
00:52:32,114 --> 00:52:35,114
I'm not sure it is.

1479
00:52:35,684 --> 00:52:37,153
>> I would ask you look at

1480
00:52:37,153 --> 00:52:39,210
opc 1, and this should be

1481
00:52:39,210 --> 00:52:39,889
a copy of the 10 year site

1482
00:52:39,889 --> 00:52:41,889
plan.

1483
00:52:44,493 --> 00:52:44,760
Are you familiar with this

1484
00:52:44,760 --> 00:52:45,326
document?

1485
00:52:45,326 --> 00:52:46,362
The company's 10 year site

1486
00:52:46,362 --> 00:52:48,130
plan?

1487
00:52:48,130 --> 00:52:50,660
>> MR. Aponte: yes, I am.

1488
00:52:50,660 --> 00:52:52,680
>> I think that's just the

1489
00:52:52,680 --> 00:52:53,302
coversheet, but if you

1490
00:52:53,302 --> 00:52:55,271
move down to page -- I'm

1491
00:52:55,271 --> 00:52:56,906
sorry, there it is.

1492
00:52:56,906 --> 00:52:58,774
Two pages you can see the

1493
00:52:58,774 --> 00:53:00,443
cover page for the 10 year

1494
00:53:00,443 --> 00:53:02,111
site plan.

1495
00:53:02,111 --> 00:53:04,111
>> MR. Aponte: yes.

1496
00:53:04,146 --> 00:53:07,746
>> then I would ask to go

1497
00:53:07,983 --> 00:53:10,519
to page 80 f21-80, which

1498
00:53:10,519 --> 00:53:13,456
is page 78 of this 10 year

1499
00:53:13,456 --> 00:53:14,689
site plan.

1500
00:53:14,689 --> 00:53:16,826
And once we get there, I

1501
00:53:16,826 --> 00:53:18,293
was going to ask you to

1502
00:53:18,293 --> 00:53:21,893
take a look at this, which

1503
00:53:24,633 --> 00:53:26,633
is the

1504
00:53:27,169 --> 00:53:29,569
, I believe it is

1505
00:53:29,972 --> 00:53:31,474
the english creek 10 year

1506
00:53:31,474 --> 00:53:32,641
site plan.

1507
00:53:32,641 --> 00:53:35,643
And if you can look down

1508
00:53:35,643 --> 00:53:36,745
at the bottom of this

1509
00:53:36,745 --> 00:53:39,145
portion of the document

1510
00:53:41,984 --> 00:53:44,220
and under line 13, I

1511
00:53:44,220 --> 00:53:45,654
believe it says that the

1512
00:53:45,654 --> 00:53:48,654
service life or the book

1513
00:53:49,925 --> 00:53:50,259
life here is 35 years, is

1514
00:53:50,259 --> 00:53:51,460
that correct?

1515
00:53:51,460 --> 00:53:52,895
>> MR. Aponte: yes.

1516
00:53:52,895 --> 00:53:53,429
>> okay.

1517
00:53:53,429 --> 00:53:57,629
And then if we go to the

1518
00:53:57,966 --> 00:53:58,501
next page, which is

1519
00:53:58,501 --> 00:53:59,567
another project, this is

1520
00:53:59,567 --> 00:54:01,567
the bullfrog creek

1521
00:54:03,272 --> 00:54:03,872
project, right?

1522
00:54:03,872 --> 00:54:04,390
>> MR. Aponte: yes, it

1523
00:54:04,390 --> 00:54:06,390
is.

1524
00:54:08,911 --> 00:54:09,478
>> okay.

1525
00:54:09,478 --> 00:54:10,120
And if you go down to that

1526
00:54:10,120 --> 00:54:11,180
same line, 13, and go to

1527
00:54:11,180 --> 00:54:12,247
book life years, it also

1528
00:54:12,247 --> 00:54:14,490
says 35 years, correct?

1529
00:54:14,490 --> 00:54:16,490
>> MR. Aponte: yes.

1530
00:54:16,652 --> 00:54:18,652
>> okay.

1531
00:54:20,356 --> 00:54:21,356
Let me take you back to

1532
00:54:21,356 --> 00:54:22,624
your testimony at page 13

1533
00:54:22,624 --> 00:54:24,226
,

1534
00:54:24,226 --> 00:54:28,630
and if you can let me know

1535
00:54:28,630 --> 00:54:29,465
when you get there.

1536
00:54:29,465 --> 00:54:31,865
>> MR. Aponte: I'm there.

1537
00:54:32,668 --> 00:54:33,168
>> okay.

1538
00:54:33,168 --> 00:54:34,536
I'm going to give it a

1539
00:54:34,536 --> 00:54:35,838
second for these guys to

1540
00:54:35,838 --> 00:54:37,838
also get there.

1541
00:54:42,578 --> 00:54:43,450
Starting at line 7 of your

1542
00:54:43,450 --> 00:54:44,120
testimony, you start

1543
00:54:44,120 --> 00:54:46,412
talking about the south

1544
00:54:46,582 --> 00:54:48,582
tampa resiliency project,

1545
00:54:48,884 --> 00:54:50,884
correct?

1546
00:54:53,288 --> 00:54:53,956
>> MR. Aponte: yes.

1547
00:54:53,956 --> 00:54:56,956
>> and you are adding four

1548
00:54:58,726 --> 00:54:59,195
reciprocating engines with

1549
00:54:59,195 --> 00:55:01,595
capacity of 71 mw on

1550
00:55:03,198 --> 00:55:03,532
macdill air force base, is

1551
00:55:03,532 --> 00:55:04,133
that correct?

1552
00:55:04,133 --> 00:55:04,366
>> MR. Aponte: that is

1553
00:55:04,366 --> 00:55:04,934
correct.

1554
00:55:04,934 --> 00:55:06,135
>> and if you go down

1555
00:55:06,135 --> 00:55:09,135
further on the line to

1556
00:55:09,572 --> 00:55:11,940
page 23 here, you through

1557
00:55:11,940 --> 00:55:15,540
the top of the next page,

1558
00:55:17,379 --> 00:55:17,913
you say in exchange for

1559
00:55:17,913 --> 00:55:19,448
access to the base side,

1560
00:55:19,448 --> 00:55:20,683
teco is getting an added

1561
00:55:20,683 --> 00:55:23,830
added level of resiliency,

1562
00:55:24,686 --> 00:55:25,221
is that correct?

1563
00:55:25,221 --> 00:55:26,422
>> MR. Aponte: yes.

1564
00:55:26,422 --> 00:55:29,422
>> am I correct that by

1565
00:55:29,491 --> 00:55:31,493
adding the resilience you

1566
00:55:31,493 --> 00:55:31,927
MAY not south tampa

1567
00:55:31,927 --> 00:55:32,995
resiliency project

1568
00:55:32,995 --> 00:55:34,163
generation is located in

1569
00:55:34,163 --> 00:55:36,980
the middle of a dense load

1570
00:55:36,980 --> 00:55:36,698
center?

1571
00:55:36,698 --> 00:55:37,466
>> MR. Aponte: yes, it

1572
00:55:37,466 --> 00:55:39,466
is.

1573
00:55:40,302 --> 00:55:40,836
>> okay.

1574
00:55:40,836 --> 00:55:42,104
And would you agree that

1575
00:55:42,104 --> 00:55:45,104
adding -- or would you

1576
00:55:45,507 --> 00:55:46,410
agree that this would

1577
00:55:46,410 --> 00:55:48,410
provide essential backup

1578
00:55:49,311 --> 00:55:50,790
power for the base in case

1579
00:55:50,790 --> 00:55:50,612
of emergency?

1580
00:55:50,612 --> 00:55:52,348
>> MR. Aponte: yes.

1581
00:55:52,348 --> 00:55:53,810
>> would you also agree

1582
00:55:53,810 --> 00:55:56,810
that you did not include

1583
00:55:56,585 --> 00:55:58,985
any government funding in

1584
00:55:59,880 --> 00:56:00,255
your -- five analysis?

1585
00:56:00,255 --> 00:56:03,255
>> MR. Aponte: I did not.

1586
00:56:04,693 --> 00:56:07,930
>> going to page 17 of

1587
00:56:13,350 --> 00:56:15,350
your testimony, starting

1588
00:56:23,378 --> 00:56:23,845
at line 14, you say the --

1589
00:56:23,845 --> 00:56:24,747
five differential was

1590
00:56:24,747 --> 00:56:25,781
favorable for customers by

1591
00:56:25,781 --> 00:56:27,781
only 10 million without

1592
00:56:29,852 --> 00:56:30,850
the omissions, is that

1593
00:56:30,850 --> 00:56:31,353
correct?

1594
00:56:31,353 --> 00:56:33,550
>> MR. Aponte: yes.

1595
00:56:33,550 --> 00:56:35,455
>> you would agree that

1596
00:56:35,958 --> 00:56:36,391
the cpvrr would've been

1597
00:56:36,391 --> 00:56:38,391
more favorable for

1598
00:56:38,460 --> 00:56:40,280
customers if governmental

1599
00:56:40,280 --> 00:56:42,428
monetary funding had been

1600
00:56:42,998 --> 00:56:44,933
sought?

1601
00:56:44,933 --> 00:56:46,933
>> MR. Aponte: not

1602
00:56:46,969 --> 00:56:49,369
knowing what type of

1603
00:56:49,638 --> 00:56:51,638
funding is good.

1604
00:56:51,940 --> 00:56:55,540
I don't know any type of

1605
00:56:55,911 --> 00:56:56,244
funding.

1606
00:56:56,244 --> 00:56:58,244
>> okay.

1607
00:57:01,616 --> 00:57:02,184
If we go on to page 18 of

1608
00:57:02,184 --> 00:57:03,385
your testimony, looking at

1609
00:57:03,385 --> 00:57:05,785
line 5, you start talking

1610
00:57:08,623 --> 00:57:10,292
about the future energy

1611
00:57:10,292 --> 00:57:11,660
storage projects, which is

1612
00:57:11,660 --> 00:57:14,660
the same thing as utility

1613
00:57:15,230 --> 00:57:15,464
scale battery storage,

1614
00:57:15,464 --> 00:57:16,899
correct?

1615
00:57:16,899 --> 00:57:18,899
>> MR. Aponte: yes.

1616
00:57:19,201 --> 00:57:22,201
>> at this time, is teco

1617
00:57:25,600 --> 00:57:25,541
planning four battery

1618
00:57:25,541 --> 00:57:27,541
storage projects in 2025?

1619
00:57:35,116 --> 00:57:35,651
Those would be over mabel,

1620
00:57:35,651 --> 00:57:35,883
wamama, and south tampa,

1621
00:57:35,883 --> 00:57:36,418
correct?

1622
00:57:36,418 --> 00:57:37,190
>> MR. Aponte: yes.

1623
00:57:37,190 --> 00:57:39,419
>> and south tampa has

1624
00:57:39,488 --> 00:57:41,888
been delayed to DECEMBER,

1625
00:57:43,558 --> 00:57:44,580
2025.

1626
00:57:44,580 --> 00:57:44,626
Is that still the case?

1627
00:57:44,626 --> 00:57:45,259
>> MR. Aponte: yes,

1628
00:57:45,259 --> 00:57:47,620
that's my understanding.

1629
00:57:47,620 --> 00:57:49,620
>> okay.

1630
00:57:49,598 --> 00:57:53,198
Going to the top of page

1631
00:57:53,702 --> 00:57:56,102
25 of this document, or

1632
00:57:59,641 --> 00:58:02,410
I'm sorry, 24, you discuss

1633
00:58:03,545 --> 00:58:03,778
the future solar projects,

1634
00:58:03,778 --> 00:58:05,778
correct?

1635
00:58:07,115 --> 00:58:08,850
>> MR. Aponte: yes.

1636
00:58:08,850 --> 00:58:11,953
>> and if you go over to

1637
00:58:11,953 --> 00:58:14,953
the next page on page 25

1638
00:58:17,592 --> 00:58:17,926
starting at line 22 if

1639
00:58:17,926 --> 00:58:19,940
you're there,

1640
00:58:19,940 --> 00:58:21,663
>> MR. Aponte: yes, I am.

1641
00:58:21,663 --> 00:58:22,197
>> you can see that you

1642
00:58:22,197 --> 00:58:25,197
are also starting to talk

1643
00:58:25,400 --> 00:58:27,800
about the company's plans

1644
00:58:28,870 --> 00:58:31,270
to build future solar.

1645
00:58:33,442 --> 00:58:35,443
Do you see that?

1646
00:58:35,443 --> 00:58:37,843
>> MR. Aponte: I do.

1647
00:58:41,983 --> 00:58:42,517
>> and on that line, you

1648
00:58:42,517 --> 00:58:43,510
say the company plans to

1649
00:58:43,510 --> 00:58:43,585
build 448.7 million mw of

1650
00:58:43,585 --> 00:58:44,853
additional solar scale pv

1651
00:58:44,853 --> 00:58:46,822
projects across its

1652
00:58:46,822 --> 00:58:49,222
service territory by the

1653
00:58:49,591 --> 00:58:49,825
end of 2026, is that

1654
00:58:49,825 --> 00:58:51,825
correct?

1655
00:58:52,527 --> 00:58:54,527
>> MR. Aponte: yes.

1656
00:58:56,698 --> 00:58:57,232
>> and mi correct these

1657
00:58:57,232 --> 00:58:59,232
projects are cottonmouth,

1658
00:59:03,672 --> 00:59:03,905
big for booster and

1659
00:59:03,905 --> 00:59:05,730
wamama?

1660
00:59:05,730 --> 00:59:07,730
>> MR. Aponte: yes.

1661
00:59:07,876 --> 00:59:08,410
>> okay.

1662
00:59:08,410 --> 00:59:11,410
Would you agree that you

1663
00:59:11,980 --> 00:59:14,616
have a total of 97.5 mw of

1664
00:59:14,616 --> 00:59:16,510
solar put in place by the

1665
00:59:16,510 --> 00:59:17,452
end of 2024?

1666
00:59:17,452 --> 00:59:18,887
>> MR. Aponte: yes.

1667
00:59:18,887 --> 00:59:20,887
>> okay.

1668
00:59:22,624 --> 00:59:23,910
And those would consist of

1669
00:59:23,910 --> 00:59:23,858
the english creek and

1670
00:59:23,858 --> 00:59:25,858
bullfrog creek project

1671
00:59:26,940 --> 00:59:26,328
,

1672
00:59:26,328 --> 00:59:26,962
correct?

1673
00:59:26,962 --> 00:59:27,495
>> MR. Aponte: yes, that

1674
00:59:27,495 --> 00:59:28,964
is correct.

1675
00:59:28,964 --> 00:59:32,564
>> if you can go to page

1676
00:59:33,668 --> 00:59:34,669
26 of your testimony, you

1677
00:59:34,669 --> 00:59:37,669
say that 140 mw of future

1678
00:59:37,872 --> 00:59:39,341
solar will be put in place

1679
00:59:39,341 --> 00:59:42,310
by the end of 2025, is

1680
00:59:42,310 --> 00:59:42,843
that correct?

1681
00:59:42,843 --> 00:59:44,843
>> MR. Aponte: yes.

1682
00:59:48,950 --> 00:59:49,483
>> those projects are --

1683
00:59:49,483 --> 00:59:50,885
and cottonmouth projects,

1684
00:59:50,885 --> 00:59:51,419
yes?

1685
00:59:51,419 --> 00:59:53,419
>> MR. Aponte: yes.

1686
00:59:54,256 --> 00:59:56,224
>> moving on further into

1687
00:59:56,224 --> 00:59:58,590
your testimony, you say

1688
00:59:58,590 --> 00:59:59,962
you have 240 mw of future

1689
00:59:59,962 --> 01:00:02,297
solar that will be put

1690
01:00:02,297 --> 01:00:04,432
into the place by the end

1691
01:00:04,432 --> 01:00:06,101
of 2026, correct?

1692
01:00:06,101 --> 01:00:07,636
>> MR. Aponte: yes.

1693
01:00:07,636 --> 01:00:10,360
>> those projects are the

1694
01:00:10,839 --> 01:00:13,239
remaining ones, big four,

1695
01:00:15,760 --> 01:00:15,677
booster, and wamama?

1696
01:00:15,677 --> 01:00:17,677
>> MR. Aponte: that's

1697
01:00:18,279 --> 01:00:19,514
correct.

1698
01:00:19,514 --> 01:00:23,114
>> if we can look at page

1699
01:00:23,718 --> 01:00:26,118
58 for bait stamp 70 of

1700
01:00:26,555 --> 01:00:29,291
the 10 year site plan that

1701
01:00:29,291 --> 01:00:31,291
is f272.

1702
01:00:32,600 --> 01:00:35,660
Soon as we get there we'll

1703
01:00:41,436 --> 01:00:43,772
take a look at that.

1704
01:00:43,772 --> 01:00:45,707
And yeah, I think 72 I

1705
01:00:45,707 --> 01:00:47,275
think master sheet

1706
01:00:47,275 --> 01:00:49,275
.

1707
01:00:49,277 --> 01:00:51,146
Okay.

1708
01:00:51,146 --> 01:00:54,746
And I know it's not right

1709
01:00:56,830 --> 01:00:58,830
side out.

1710
01:00:58,686 --> 01:00:59,220
You can see that this

1711
01:00:59,220 --> 01:01:01,620
shows the current summer

1712
01:01:03,625 --> 01:01:06,250
margin reserve for tampa

1713
01:01:09,697 --> 01:01:11,697
electric, correct?

1714
01:01:14,469 --> 01:01:16,371
>> MR. Aponte: yes.

1715
01:01:16,371 --> 01:01:16,838
>> it MAY be easier to

1716
01:01:16,838 --> 01:01:18,440
look up on the screen

1717
01:01:18,440 --> 01:01:19,641
because it has the correct

1718
01:01:19,641 --> 01:01:21,142
orientation.

1719
01:01:21,142 --> 01:01:23,542
Can you see that?

1720
01:01:30,418 --> 01:01:31,686
And can you see -- do you

1721
01:01:31,686 --> 01:01:32,220
have a better view?

1722
01:01:32,220 --> 01:01:35,900
Let me know when you got

1723
01:01:35,900 --> 01:01:35,623
it in a good orientation

1724
01:01:35,623 --> 01:01:39,823
for you to take a look at

1725
01:01:56,244 --> 01:01:58,244
it.

1726
01:01:59,247 --> 01:02:01,247
>> MR. Aponte: okay.

1727
01:02:02,650 --> 01:02:05,500
>> this shows the southern

1728
01:02:08,723 --> 01:02:11,123
reserve in 2026 and 29% in

1729
01:02:15,960 --> 01:02:15,630
2027, is that correct?

1730
01:02:15,630 --> 01:02:17,980
>> MR. Aponte: yes.

1731
01:02:17,980 --> 01:02:19,634
>> I'm going to ask you to

1732
01:02:19,634 --> 01:02:23,234
scroll to the next page of

1733
01:02:24,272 --> 01:02:24,806
this exhibit I believe

1734
01:02:24,806 --> 01:02:26,600
should be -- I'm sorry, f

1735
01:02:26,600 --> 01:02:28,406
73, which should be the

1736
01:02:30,378 --> 01:02:30,912
next page.

1737
01:02:30,912 --> 01:02:32,800
We MAY still have similar

1738
01:02:32,800 --> 01:02:32,480
orientation issues.

1739
01:02:32,480 --> 01:02:34,880
When you get that

1740
01:02:37,251 --> 01:02:39,651
oriented, let me know.

1741
01:02:39,687 --> 01:02:42,657
And this page should show

1742
01:02:42,657 --> 01:02:42,923
the winter reserve margin

1743
01:02:42,923 --> 01:02:44,458
for teco.

1744
01:02:44,458 --> 01:02:45,860
>> MR. Aponte: yes.

1745
01:02:45,860 --> 01:02:47,628
>> okay.

1746
01:02:47,628 --> 01:02:50,698
can you see over into the

1747
01:02:50,698 --> 01:02:53,698
last column where it says

1748
01:02:54,680 --> 01:02:56,680
there's a 23% reserve

1749
01:02:57,538 --> 01:02:59,538
margin in 2025, 23% in

1750
01:03:00,474 --> 01:03:02,420
2026, and 22% in 2027?

1751
01:03:02,420 --> 01:03:04,420
>> MR. Aponte: yes.

1752
01:03:07,882 --> 01:03:08,349
>> okay, and that's

1753
01:03:08,349 --> 01:03:08,550
correct as far as you

1754
01:03:08,550 --> 01:03:09,830
know?

1755
01:03:09,830 --> 01:03:09,683
>> MR. Aponte: yes.

1756
01:03:09,683 --> 01:03:10,718
>> would you agree that

1757
01:03:10,718 --> 01:03:13,118
solar does not contribute

1758
01:03:15,356 --> 01:03:15,957
to winter reserve margin?

1759
01:03:15,957 --> 01:03:16,190
>> MR. Aponte: that's

1760
01:03:16,190 --> 01:03:17,725
correct.

1761
01:03:17,725 --> 01:03:18,293
>> and would you agree

1762
01:03:18,293 --> 01:03:18,960
that right now there is no

1763
01:03:18,960 --> 01:03:20,960
carbon emission cost

1764
01:03:21,863 --> 01:03:23,863
imposed the federal

1765
01:03:23,865 --> 01:03:24,980
government or state of

1766
01:03:24,980 --> 01:03:24,966
florida?

1767
01:03:24,966 --> 01:03:26,701
Has that changed as of

1768
01:03:26,701 --> 01:03:27,302
today?

1769
01:03:27,302 --> 01:03:29,702
>> MR. Aponte: it has

1770
01:03:30,738 --> 01:03:31,339
not.

1771
01:03:31,339 --> 01:03:32,400
>> and would you agree

1772
01:03:32,400 --> 01:03:34,440
that the companies reserve

1773
01:03:34,775 --> 01:03:37,175
margin is above 20% for

1774
01:03:41,282 --> 01:03:41,816
both winter and summer

1775
01:03:41,816 --> 01:03:43,816
reserve margins from 2025

1776
01:03:49,590 --> 01:03:50,224
through 2027?

1777
01:03:50,224 --> 01:03:50,891
>> MR. Aponte: they are.

1778
01:03:50,891 --> 01:03:51,359
>> and is not correct that

1779
01:03:51,359 --> 01:03:51,926
the solar generation

1780
01:03:51,926 --> 01:03:54,926
projects are not needed to

1781
01:04:02,200 --> 01:04:02,570
meet the companies solar

1782
01:04:02,570 --> 01:04:02,770
peak needs in 2025 through

1783
01:04:02,770 --> 01:04:03,371
2027?

1784
01:04:03,371 --> 01:04:03,671
>> MR. Aponte: did you

1785
01:04:03,671 --> 01:04:04,380
say summer?

1786
01:04:04,380 --> 01:04:04,605
>> summer.

1787
01:04:04,605 --> 01:04:05,139
>> MR. Aponte: they

1788
01:04:05,139 --> 01:04:07,539
contribute to the summer

1789
01:04:07,842 --> 01:04:08,176
reserve margin, but a

1790
01:04:08,176 --> 01:04:10,176
small percent.

1791
01:04:10,845 --> 01:04:12,845
>> okay.

1792
01:04:14,582 --> 01:04:15,116
Would also be correct it

1793
01:04:15,116 --> 01:04:15,583
is not needed to meet the

1794
01:04:15,583 --> 01:04:17,583
company's winter peak

1795
01:04:17,719 --> 01:04:18,686
demand needs in 2025

1796
01:04:18,686 --> 01:04:20,686
through 2027?

1797
01:04:20,855 --> 01:04:22,890
>> MR. Aponte: yes.

1798
01:04:22,890 --> 01:04:24,890
>> okay.

1799
01:04:25,359 --> 01:04:25,926
I would like to call your

1800
01:04:25,926 --> 01:04:28,326
attention to your rebuttal

1801
01:04:29,430 --> 01:04:30,598
testimony page 7, and then

1802
01:04:30,598 --> 01:04:33,670
when you get there we will

1803
01:04:33,670 --> 01:04:35,467
be looking at lines 10

1804
01:04:45,790 --> 01:04:47,790
through 12.

1805
01:04:49,500 --> 01:04:49,140
Let me know

1806
01:04:49,140 --> 01:04:51,520
.

1807
01:04:51,520 --> 01:04:52,686
>> MR. Aponte: I'm there.

1808
01:04:52,686 --> 01:04:54,686
>> okay.

1809
01:04:55,423 --> 01:04:55,990
And looking at that

1810
01:04:55,990 --> 01:04:57,324
portion of your testimony,

1811
01:04:57,324 --> 01:04:57,825
you say the company

1812
01:04:57,825 --> 01:04:59,825
performed a sensitivity

1813
01:05:01,762 --> 01:05:02,697
analysis incorporating a

1814
01:05:02,697 --> 01:05:04,697
0.4% degradation per year

1815
01:05:06,868 --> 01:05:07,401
until the end of the

1816
01:05:07,401 --> 01:05:09,801
project's useful life for

1817
01:05:11,939 --> 01:05:12,306
the future solar projects,

1818
01:05:12,306 --> 01:05:12,940
is that correct?

1819
01:05:12,940 --> 01:05:13,241
>> MR. Aponte: yes, that

1820
01:05:13,241 --> 01:05:15,410
is correct.

1821
01:05:15,410 --> 01:05:15,610
>> and you used a 35 year

1822
01:05:15,610 --> 01:05:17,545
life for the solar in this

1823
01:05:17,545 --> 01:05:19,945
analysis, is that correct?

1824
01:05:20,140 --> 01:05:20,180
>> MR. Aponte: yes, I

1825
01:05:20,180 --> 01:05:21,649
did.

1826
01:05:21,649 --> 01:05:23,649
>> okay.

1827
01:05:24,485 --> 01:05:25,520
Thank you very much.

1828
01:05:25,520 --> 01:05:25,319
>> CHAIRMAN La Rosa:

1829
01:05:25,319 --> 01:05:27,288
thank you.

1830
01:05:27,288 --> 01:05:28,456
Florida rising and lulac.

1831
01:05:28,456 --> 01:05:30,456
>> thank you.

1832
01:05:34,128 --> 01:05:36,528
Good morning, MR. Aponte.

1833
01:05:37,865 --> 01:05:42,650
If we can go to f3.3-5838,

1834
01:05:47,708 --> 01:05:49,708
fll 177.

1835
01:05:50,645 --> 01:05:51,179
As MR. Christiansen just

1836
01:05:51,179 --> 01:05:53,748
ended out, I believe you

1837
01:05:53,748 --> 01:05:56,148
just said that solar

1838
01:05:56,918 --> 01:05:58,918
contributes zero points

1839
01:06:00,688 --> 01:06:01,221
the winter reserve margin

1840
01:06:01,221 --> 01:06:03,190
and that's because solar

1841
01:06:03,190 --> 01:06:04,292
has a zero assumed

1842
01:06:04,292 --> 01:06:06,692
capacity value during the

1843
01:06:08,895 --> 01:06:09,497
time of the winter peak.

1844
01:06:09,497 --> 01:06:09,730
>> MR. Aponte: that's

1845
01:06:09,730 --> 01:06:11,320
correct.

1846
01:06:11,320 --> 01:06:13,432
>> this chart here in

1847
01:06:15,703 --> 01:06:18,103
exhibit fll-177 is the

1848
01:06:18,939 --> 01:06:21,339
summer capacity value for

1849
01:06:22,909 --> 01:06:23,344
the solar plant that are

1850
01:06:23,344 --> 01:06:25,744
issued at this case?

1851
01:06:26,800 --> 01:06:28,800
>> MR. Aponte: yes.

1852
01:06:28,248 --> 01:06:30,648
>> so way four includes

1853
01:06:31,419 --> 01:06:32,686
the booster and wamama

1854
01:06:32,686 --> 01:06:34,686
solar booster project?

1855
01:06:34,688 --> 01:06:36,157
>> MR. Aponte: yes.

1856
01:06:36,157 --> 01:06:38,557
>> those are planned to

1857
01:06:42,196 --> 01:06:42,429
come into start generating

1858
01:06:42,429 --> 01:06:43,300
in 2027?

1859
01:06:43,300 --> 01:06:43,264
>> MR. Aponte: that's

1860
01:06:43,264 --> 01:06:43,931
correct.

1861
01:06:43,931 --> 01:06:44,365
>> so that will be part of

1862
01:06:44,365 --> 01:06:46,365
the subsequent year

1863
01:06:49,937 --> 01:06:50,471
adjustment?

1864
01:06:50,471 --> 01:06:51,720
>> MR. Aponte: yes.

1865
01:06:51,720 --> 01:06:51,572
>> they are assumed to

1866
01:06:51,572 --> 01:06:52,606
have a summer capacity

1867
01:06:52,606 --> 01:06:53,400
volume of one point

1868
01:06:53,400 --> 01:06:53,641
>> MR. Aponte: yes.

1869
01:06:53,641 --> 01:06:54,141
>> they are assumed to

1870
01:06:54,141 --> 01:06:54,508
have a summer capacity

1871
01:06:54,508 --> 01:06:55,343
volume of 1.5%?

1872
01:06:55,343 --> 01:06:55,809
>> MR. Aponte: they do.

1873
01:06:55,809 --> 01:06:56,477
>> why is that?

1874
01:06:56,477 --> 01:06:57,778
>> MR. Aponte: the reason

1875
01:06:57,778 --> 01:07:00,414
for that is the more solar

1876
01:07:00,414 --> 01:07:03,451
you add the effect on the

1877
01:07:03,451 --> 01:07:06,451
system peak is that it

1878
01:07:06,821 --> 01:07:07,922
moves the system peak to a

1879
01:07:07,922 --> 01:07:10,922
later time in the day.

1880
01:07:13,928 --> 01:07:14,462
The net between the load

1881
01:07:14,462 --> 01:07:15,620
minus the output of solar

1882
01:07:15,620 --> 01:07:16,864
is what we call net peak.

1883
01:07:16,864 --> 01:07:19,864
The more solar you add,

1884
01:07:19,966 --> 01:07:21,268
the later that net peak is

1885
01:07:21,268 --> 01:07:23,771
going to occur during the

1886
01:07:23,771 --> 01:07:26,771
day when the solar is

1887
01:07:29,276 --> 01:07:30,144
producing less output.

1888
01:07:30,144 --> 01:07:31,645
>> and if I can now direct

1889
01:07:31,645 --> 01:07:34,645
your attention to what has

1890
01:07:39,200 --> 01:07:39,520
been admitted on the cel,

1891
01:07:39,520 --> 01:07:42,520
this is master number c

1892
01:07:57,504 --> 01:07:57,972
32-1577.

1893
01:07:57,972 --> 01:07:59,106
Do you recognize this

1894
01:07:59,106 --> 01:08:01,106
document?

1895
01:08:03,410 --> 01:08:03,911
>> MR. Aponte: I do.

1896
01:08:03,911 --> 01:08:04,512
>> and what is it?

1897
01:08:04,512 --> 01:08:05,450
>> MR. Aponte: it is a

1898
01:08:05,450 --> 01:08:06,413
spreadsheet that we used

1899
01:08:06,413 --> 01:08:08,413
to calculate reserve

1900
01:08:08,916 --> 01:08:09,550
margins.

1901
01:08:09,550 --> 01:08:11,550
>> those diminished solar

1902
01:08:14,789 --> 01:08:15,289
reserve firm capacity --

1903
01:08:15,289 --> 01:08:17,689
>> MR. Aponte: if you

1904
01:08:23,964 --> 01:08:24,565
mean capacity values, yes.

1905
01:08:24,565 --> 01:08:25,131
>> for example, wamama

1906
01:08:25,131 --> 01:08:26,200
three has a capacity of --

1907
01:08:26,200 --> 01:08:27,368
but has a summer firm

1908
01:08:27,368 --> 01:08:27,601
capacity on this chart of

1909
01:08:27,601 --> 01:08:28,202
1.1 mw?

1910
01:08:28,202 --> 01:08:30,202
>> MR. Aponte: that's

1911
01:08:39,180 --> 01:08:39,780
correct.

1912
01:08:39,780 --> 01:08:40,181
>> would be fair to say

1913
01:08:40,181 --> 01:08:40,681
for the period of

1914
01:08:40,681 --> 01:08:41,215
2025-2027, in order to

1915
01:08:41,215 --> 01:08:41,982
maintain 20% would be the

1916
01:08:41,982 --> 01:08:42,516
winter reserve margin we

1917
01:08:42,516 --> 01:08:44,652
should be looking at the

1918
01:08:44,652 --> 01:08:47,520
could be driving plant

1919
01:08:47,154 --> 01:08:47,755
additions into the system?

1920
01:08:47,755 --> 01:08:50,124
>> MR. Aponte: can you

1921
01:08:50,124 --> 01:08:52,124
please repeat that

1922
01:08:53,327 --> 01:08:53,661
question?

1923
01:08:53,661 --> 01:08:54,228
>> sure.

1924
01:08:54,228 --> 01:08:54,628
In other words, the summer

1925
01:08:54,628 --> 01:08:55,663
reserve margin as

1926
01:08:55,663 --> 01:08:57,231
reflected in this chart

1927
01:08:57,231 --> 01:08:59,631
for 2025-2027 is higher

1928
01:08:59,867 --> 01:09:01,902
than the winter reserve

1929
01:09:01,902 --> 01:09:02,436
margin?

1930
01:09:02,436 --> 01:09:04,436
>> MR. Aponte: yes.

1931
01:09:05,720 --> 01:09:07,472
>> so any plant additions,

1932
01:09:07,875 --> 01:09:09,109
for reserve margin

1933
01:09:09,109 --> 01:09:11,509
purposes to meet that 20%

1934
01:09:12,713 --> 01:09:13,147
we should be looking at

1935
01:09:13,147 --> 01:09:13,380
that winter reserve

1936
01:09:13,380 --> 01:09:14,480
margin?

1937
01:09:14,480 --> 01:09:16,448
>> MR. Aponte: we are.

1938
01:09:18,418 --> 01:09:18,952
>> and solar plants are

1939
01:09:18,952 --> 01:09:20,321
assumed to not contribute

1940
01:09:20,321 --> 01:09:22,321
to that?

1941
01:09:26,560 --> 01:09:27,161
>> MR. Aponte: correct.

1942
01:09:27,161 --> 01:09:27,661
>> so the solar plants

1943
01:09:27,661 --> 01:09:28,128
that are being added to

1944
01:09:28,128 --> 01:09:28,529
the system or for the

1945
01:09:28,529 --> 01:09:29,620
energy value that

1946
01:09:29,620 --> 01:09:30,197
translates into economic

1947
01:09:30,197 --> 01:09:31,465
benefits for teco and its

1948
01:09:31,465 --> 01:09:33,465
customers?

1949
01:09:35,802 --> 01:09:36,337
>> MR. Aponte: yes, a big

1950
01:09:36,337 --> 01:09:37,705
portion of the benefit is

1951
01:09:37,705 --> 01:09:40,105
reduction of fuel costs.

1952
01:09:41,542 --> 01:09:41,975
>> so the solar is not

1953
01:09:41,975 --> 01:09:43,110
being added for its

1954
01:09:43,110 --> 01:09:45,110
capacity value?

1955
01:09:48,115 --> 01:09:50,115
>> MR. Aponte: correct.

1956
01:09:50,451 --> 01:09:52,190
>> you're not aware of any

1957
01:09:52,190 --> 01:09:52,553
recent analysis by teco

1958
01:09:52,553 --> 01:09:55,553
showing that if you went

1959
01:09:55,823 --> 01:09:57,823
below 20% reserve margin

1960
01:09:59,926 --> 01:10:01,926
that rolling blackouts

1961
01:10:02,529 --> 01:10:02,730
would be more likely to

1962
01:10:02,730 --> 01:10:03,330
occur?

1963
01:10:03,330 --> 01:10:04,980
>> MR. Aponte: I'm not

1964
01:10:04,980 --> 01:10:04,298
aware of any analysis like

1965
01:10:04,298 --> 01:10:06,298
that.

1966
01:10:09,870 --> 01:10:10,403
>> if I connect direct

1967
01:10:10,403 --> 01:10:12,803
your attention to master

1968
01:10:21,482 --> 01:10:23,482
page f 3.1-2651.

1969
01:10:23,717 --> 01:10:26,717
You are the sponsor of

1970
01:10:30,900 --> 01:10:30,624
this interrogatory?

1971
01:10:30,624 --> 01:10:31,959
>> MR. Aponte: yes.

1972
01:10:31,959 --> 01:10:34,728
>> and so teco does not

1973
01:10:34,728 --> 01:10:37,128
conduct loss of load

1974
01:10:37,765 --> 01:10:38,432
probability studies?

1975
01:10:38,432 --> 01:10:38,632
>> MR. Aponte: not at the

1976
01:10:38,632 --> 01:10:40,632
time.

1977
01:10:43,437 --> 01:10:43,837
>> what is a loss of load

1978
01:10:43,837 --> 01:10:44,471
probability study?

1979
01:10:44,471 --> 01:10:46,390
>> MR. Aponte: a loss of

1980
01:10:46,390 --> 01:10:46,573
load would indicate if the

1981
01:10:46,573 --> 01:10:47,441
portfolio, it's a measure

1982
01:10:47,441 --> 01:10:50,441
of the reliability of the

1983
01:10:50,577 --> 01:10:51,511
portfolio and it's trying

1984
01:10:51,511 --> 01:10:53,911
to determine the chances

1985
01:10:54,314 --> 01:10:56,714
of not meeting load.

1986
01:10:57,283 --> 01:10:57,818
The industry standard

1987
01:10:57,818 --> 01:11:01,418
seems to be one day in 10

1988
01:11:01,688 --> 01:11:03,688
years.

1989
01:11:03,924 --> 01:11:04,358
>> switching topics now,

1990
01:11:04,358 --> 01:11:07,358
you did a series of

1991
01:11:12,699 --> 01:11:13,233
cost-effective analyses in

1992
01:11:13,233 --> 01:11:13,767
connection with this case?

1993
01:11:13,767 --> 01:11:14,368
>> MR. Aponte: yes.

1994
01:11:14,368 --> 01:11:14,902
>> and if we can go to

1995
01:11:14,902 --> 01:11:15,869
what has been admitted as

1996
01:11:15,869 --> 01:11:18,269
staff exhibit 159 master e

1997
01:11:31,840 --> 01:11:32,685
master e1965.

1998
01:11:32,685 --> 01:11:35,880
This is a copy of the

1999
01:11:35,880 --> 01:11:35,422
financial inputs that you

2000
01:11:35,422 --> 01:11:36,857
used in your

2001
01:11:36,857 --> 01:11:38,592
cost-effective analyses

2002
01:11:38,592 --> 01:11:41,592
that were included in your

2003
01:11:42,930 --> 01:11:43,530
study?

2004
01:11:43,530 --> 01:11:45,530
>> MR. Aponte: yes.

2005
01:11:49,336 --> 01:11:49,736
>> you assumed a 10.2 %

2006
01:11:49,736 --> 01:11:50,303
return on equity?

2007
01:11:50,303 --> 01:11:50,970
>> MR. Aponte: I did.

2008
01:11:50,970 --> 01:11:53,707
>> if the return on equity

2009
01:11:53,707 --> 01:11:56,107
was approved it would

2010
01:11:58,612 --> 01:11:59,245
impact your analyses?

2011
01:11:59,245 --> 01:11:59,846
>> MR. Aponte: it would.

2012
01:11:59,846 --> 01:12:01,615
>> that would create a

2013
01:12:01,615 --> 01:12:01,915
different than the revenue

2014
01:12:01,915 --> 01:12:02,549
requirement?

2015
01:12:02,549 --> 01:12:04,949
>> MR. Aponte: it would

2016
01:12:07,921 --> 01:12:08,337
create a different revenue

2017
01:12:08,337 --> 01:12:08,789
requirement.

2018
01:12:08,789 --> 01:12:09,289
The only thing I would add

2019
01:12:09,289 --> 01:12:09,756
to that is when we are

2020
01:12:09,756 --> 01:12:11,625
doing cost-effective

2021
01:12:11,625 --> 01:12:12,125
analysis we are looking at

2022
01:12:12,125 --> 01:12:14,525
doing reference case as

2023
01:12:15,161 --> 01:12:15,596
well as a change case and

2024
01:12:15,596 --> 01:12:17,596
when the financial

2025
01:12:19,990 --> 01:12:21,990
assumptions change, they

2026
01:12:22,102 --> 01:12:22,536
have to be changed on both

2027
01:12:22,536 --> 01:12:24,137
and I'm saying that

2028
01:12:24,137 --> 01:12:26,537
because we expect the

2029
01:12:32,546 --> 01:12:34,114
changes to the results to

2030
01:12:34,114 --> 01:12:36,514
be not that material.

2031
01:12:36,817 --> 01:12:38,652
>> if I can direct your

2032
01:12:38,652 --> 01:12:41,520
attention to e your

2033
01:12:53,467 --> 01:12:55,467
attention to e2088.

2034
01:12:55,835 --> 01:12:59,435
This shows a copy of the

2035
01:13:02,175 --> 01:13:02,576
fuel price that was used

2036
01:13:02,576 --> 01:13:03,109
in the right case?

2037
01:13:03,109 --> 01:13:05,109
>> MR. Aponte: yes.

2038
01:13:07,681 --> 01:13:08,181
>> included in your

2039
01:13:08,181 --> 01:13:08,782
cost-effective analysis?

2040
01:13:08,782 --> 01:13:09,449
>> MR. Aponte: correct.

2041
01:13:09,449 --> 01:13:11,618
>> it does show escalating

2042
01:13:11,618 --> 01:13:13,618
gas prices?

2043
01:13:18,725 --> 01:13:21,125
>> MR. Aponte: it does.

2044
01:13:26,833 --> 01:13:27,334
>> the south tampa

2045
01:13:27,334 --> 01:13:27,901
resiliency project is a

2046
01:13:27,901 --> 01:13:28,435
series of reciprocating --

2047
01:13:28,435 --> 01:13:28,635
on the macdill air force

2048
01:13:28,635 --> 01:13:29,169
base?

2049
01:13:29,169 --> 01:13:29,836
>> MR. Aponte: yes.

2050
01:13:29,836 --> 01:13:32,236
>> it will provide backup

2051
01:13:33,473 --> 01:13:33,740
-- in case of an

2052
01:13:33,740 --> 01:13:34,341
emergency?

2053
01:13:34,341 --> 01:13:34,908
>> MR. Aponte: in the

2054
01:13:34,908 --> 01:13:37,908
case of an emergency, yes.

2055
01:13:38,612 --> 01:13:39,790
>> besides the land, the

2056
01:13:39,790 --> 01:13:39,646
us government is not

2057
01:13:39,646 --> 01:13:41,646
providing any contribution

2058
01:13:44,384 --> 01:13:44,918
to the us --

2059
01:13:44,918 --> 01:13:45,251
>> MR. Aponte: not that

2060
01:13:45,251 --> 01:13:46,953
I'm aware of.

2061
01:13:46,953 --> 01:13:49,953
>> if I can direct your

2062
01:13:51,858 --> 01:13:54,858
attention to f ll master

2063
01:14:13,146 --> 01:14:13,580
page f 3.3-5305.

2064
01:14:13,580 --> 01:14:14,714
This is one of your

2065
01:14:14,714 --> 01:14:16,810
documents?

2066
01:14:16,810 --> 01:14:18,810
>> MR. Aponte: yes.

2067
01:14:19,786 --> 01:14:20,153
>> and it includes the

2068
01:14:20,153 --> 01:14:21,888
reserve margin

2069
01:14:21,888 --> 01:14:22,922
calculations for the

2070
01:14:22,922 --> 01:14:25,910
winter with and without

2071
01:14:25,910 --> 01:14:26,359
the south tampa resiliency

2072
01:14:26,359 --> 01:14:28,359
project?

2073
01:14:40,600 --> 01:14:40,574
>> MR. Aponte: yes.

2074
01:14:40,574 --> 01:14:41,107
>> then if I connect

2075
01:14:41,107 --> 01:14:43,507
direct your attention to

2076
01:14:45,478 --> 01:14:47,478
exhibit fll 127 master

2077
01:15:10,837 --> 01:15:11,504
page f 3.2-3894.

2078
01:15:11,504 --> 01:15:13,390
>> MR. Aponte: I'm sorry,

2079
01:15:13,390 --> 01:15:14,107
MAY I have a clarification

2080
01:15:14,107 --> 01:15:16,507
on the previous exhibit?

2081
01:15:19,179 --> 01:15:22,779
>> we can go back to that

2082
01:15:31,724 --> 01:15:31,924
was master page f 3.3-505.

2083
01:15:31,924 --> 01:15:33,924
3.3 b

2084
01:15:36,329 --> 01:15:38,298
5305.

2085
01:15:38,298 --> 01:15:39,532
>> MR. Aponte: thank you.

2086
01:15:39,532 --> 01:15:41,932
When this exhibit was

2087
01:15:47,307 --> 01:15:48,675
developed and reflect with

2088
01:15:48,675 --> 01:15:51,750
and without the specific

2089
01:15:51,344 --> 01:15:53,380
project, I just wanted to

2090
01:15:53,380 --> 01:15:55,380
clarify the remaining

2091
01:15:57,883 --> 01:16:00,283
expansion plan has been

2092
01:16:02,188 --> 01:16:02,555
tailored to meet reserve

2093
01:16:02,555 --> 01:16:04,555
margin of 20%.

2094
01:16:05,492 --> 01:16:06,893
So this does not reflect

2095
01:16:06,893 --> 01:16:08,940
pulling the project out

2096
01:16:08,940 --> 01:16:10,494
and leaving a reserve

2097
01:16:12,599 --> 01:16:14,267
margin gap.

2098
01:16:14,267 --> 01:16:15,701
>> I'm sorry, could you

2099
01:16:15,701 --> 01:16:17,137
say that again?

2100
01:16:17,137 --> 01:16:18,471
>> MR. Aponte: yes.

2101
01:16:18,471 --> 01:16:20,606
For example, if I take

2102
01:16:20,606 --> 01:16:23,600
away all the proposed

2103
01:16:23,242 --> 01:16:25,879
projects that we have, we

2104
01:16:25,879 --> 01:16:27,879
would fall under 20%

2105
01:16:29,816 --> 01:16:30,500
reserve margin ready

2106
01:16:30,500 --> 01:16:31,584
quickly.

2107
01:16:31,584 --> 01:16:32,919
And to satisfy that

2108
01:16:32,919 --> 01:16:35,919
reserve margin, if we were

2109
01:16:35,921 --> 01:16:39,521
to not do the projects, we

2110
01:16:39,925 --> 01:16:40,359
would have to add capacity

2111
01:16:40,359 --> 01:16:42,759
in a different way.

2112
01:16:42,962 --> 01:16:43,496
Perhaps it's the next best

2113
01:16:43,496 --> 01:16:45,896
condition, which could be

2114
01:16:45,932 --> 01:16:47,100
a ct.

2115
01:16:47,100 --> 01:16:49,402
What I'm trying to say is

2116
01:16:49,402 --> 01:16:51,738
when we took away the

2117
01:16:51,738 --> 01:16:54,138
south tampa project, for

2118
01:16:56,476 --> 01:16:56,943
example, in this chart and

2119
01:16:56,943 --> 01:16:58,311
it created a reserve

2120
01:16:58,311 --> 01:17:00,547
margin need, we filled it

2121
01:17:00,547 --> 01:17:02,547
with another resource.

2122
01:17:03,682 --> 01:17:04,170
>> and I think we're going

2123
01:17:04,170 --> 01:17:04,417
to get there.

2124
01:17:04,417 --> 01:17:07,220
We have a lot of

2125
01:17:07,220 --> 01:17:07,653
documents, MR. Aponte.

2126
01:17:07,653 --> 01:17:08,860
I think what you're

2127
01:17:08,860 --> 01:17:09,589
referring to is the

2128
01:17:09,589 --> 01:17:11,491
documents that show the

2129
01:17:11,491 --> 01:17:13,927
base case and the change

2130
01:17:13,927 --> 01:17:16,327
case with each individual

2131
01:17:19,980 --> 01:17:19,632
projects and those base

2132
01:17:19,632 --> 01:17:22,320
cases has placeholder ct

2133
01:17:24,270 --> 01:17:24,771
for teco to meet its

2134
01:17:24,771 --> 01:17:24,971
reserve margin, is that

2135
01:17:24,971 --> 01:17:25,572
right?

2136
01:17:25,572 --> 01:17:27,972
>> MR. Aponte: that is

2137
01:17:29,575 --> 01:17:30,109
correct.

2138
01:17:30,109 --> 01:17:30,610
>> this would be in

2139
01:17:30,610 --> 01:17:32,912
reference to those base

2140
01:17:32,912 --> 01:17:34,912
cases?

2141
01:17:40,887 --> 01:17:41,521
>> MR. Aponte: yes.

2142
01:17:41,521 --> 01:17:42,210
>> if we can go back now

2143
01:17:42,210 --> 01:17:43,289
to master page f 3.2 b

2144
01:17:43,289 --> 01:17:46,289
3894, this is going to be

2145
01:18:04,710 --> 01:18:06,710
fll 127.

2146
01:18:07,800 --> 01:18:08,581
and this document provides

2147
01:18:08,581 --> 01:18:10,683
the detail of that base

2148
01:18:10,683 --> 01:18:13,830
case without the south

2149
01:18:19,792 --> 01:18:21,792
tampa resiliency project?

2150
01:18:22,610 --> 01:18:24,461
>> MR. Aponte: I believe

2151
01:18:25,832 --> 01:18:27,333
so.

2152
01:18:27,333 --> 01:18:29,680
>> and you would agree

2153
01:18:29,680 --> 01:18:31,468
there's no summer reserve

2154
01:18:32,538 --> 01:18:33,139
margin issue?

2155
01:18:33,139 --> 01:18:35,139
>> MR. Aponte: that's

2156
01:18:35,308 --> 01:18:37,308
correct.

2157
01:18:37,343 --> 01:18:39,712
>> and it does show on the

2158
01:18:39,712 --> 01:18:42,712
next page for the winter

2159
01:18:43,650 --> 01:18:46,650
it does show a 20% reserve

2160
01:18:49,889 --> 01:18:52,889
margin for the winter of

2161
01:18:53,826 --> 01:18:55,360
2026?

2162
01:18:55,360 --> 01:18:57,830
>> MR. Aponte: yes, I see

2163
01:18:57,830 --> 01:18:58,464
that.

2164
01:18:58,464 --> 01:19:00,233
>> and it does not show a

2165
01:19:00,233 --> 01:19:02,233
winter reserve margin

2166
01:19:02,769 --> 01:19:03,436
before then?

2167
01:19:03,436 --> 01:19:04,770
>> MR. Aponte: not before

2168
01:19:04,770 --> 01:19:06,770
then.

2169
01:19:07,206 --> 01:19:07,673
>> would you agree it

2170
01:19:07,673 --> 01:19:10,730
would be for economic

2171
01:19:10,309 --> 01:19:10,543
reasons, not capacity

2172
01:19:10,543 --> 01:19:12,543
reasons?

2173
01:19:16,149 --> 01:19:18,149
>> MR. Aponte: yes.

2174
01:19:19,552 --> 01:19:20,860
>> if I can now go to

2175
01:19:20,860 --> 01:19:23,860
fll-128, this is going to

2176
01:19:41,741 --> 01:19:42,308
be master page f.2-3897.

2177
01:19:42,308 --> 01:19:43,609
And so this document would

2178
01:19:43,609 --> 01:19:44,744
provide additional detail

2179
01:19:44,744 --> 01:19:46,244
regarding the reserve

2180
01:19:46,244 --> 01:19:48,644
margins with the south

2181
01:19:51,417 --> 01:19:53,417
tampa resiliency project.

2182
01:19:54,520 --> 01:19:55,555
>> MR. Aponte: I'm going

2183
01:19:55,555 --> 01:19:57,623
to go with that because I

2184
01:19:57,623 --> 01:19:59,959
don't see a title on the

2185
01:19:59,959 --> 01:20:00,593
page.

2186
01:20:00,593 --> 01:20:02,829
>> we can go through the

2187
01:20:02,829 --> 01:20:04,362
bait stamped number and

2188
01:20:04,362 --> 01:20:04,963
establish the trail.

2189
01:20:04,963 --> 01:20:05,731
>> MR. Aponte: that's

2190
01:20:05,731 --> 01:20:07,500
okay.

2191
01:20:07,500 --> 01:20:09,900
We can move on.

2192
01:20:10,100 --> 01:20:11,637
>> and this document,

2193
01:20:11,637 --> 01:20:13,339
again, if I represent to

2194
01:20:13,339 --> 01:20:16,939
you is would be the south

2195
01:20:17,510 --> 01:20:17,944
tampa resiliency change

2196
01:20:17,944 --> 01:20:18,377
case, it would only

2197
01:20:18,377 --> 01:20:20,377
include the reserve

2198
01:20:22,715 --> 01:20:25,115
margins over the next

2199
01:20:26,719 --> 01:20:27,253
document that we're going

2200
01:20:27,253 --> 01:20:27,954
to get to, which would be

2201
01:20:27,954 --> 01:20:30,122
the south tampa resiliency

2202
01:20:30,122 --> 01:20:30,623
project case that you use

2203
01:20:30,623 --> 01:20:32,623
in your cost-effective

2204
01:20:33,426 --> 01:20:33,993
analysis.

2205
01:20:33,993 --> 01:20:35,993
>> MR. Aponte: okay.

2206
01:20:36,695 --> 01:20:37,129
>> so it does not include

2207
01:20:37,129 --> 01:20:39,529
all of the storage

2208
01:20:42,735 --> 01:20:42,969
projects after the --

2209
01:20:42,969 --> 01:20:44,270
project?

2210
01:20:44,270 --> 01:20:46,270
>> MR. Aponte: that's

2211
01:20:46,706 --> 01:20:48,706
correct.

2212
01:20:49,542 --> 01:20:51,277
>> this shows it would be

2213
01:20:51,277 --> 01:20:53,512
down to a 20% reserve

2214
01:20:53,512 --> 01:20:56,382
margin for the winter of

2215
01:20:56,382 --> 01:20:57,160
2027?

2216
01:20:57,160 --> 01:20:58,184
>> MR. Aponte: yes, that

2217
01:20:58,184 --> 01:20:58,818
is correct.

2218
01:20:58,818 --> 01:21:00,186
>> maybe I should've done

2219
01:21:00,186 --> 01:21:02,588
this in a different order,

2220
01:21:02,588 --> 01:21:06,188
but what let's now go to

2221
01:21:20,339 --> 01:21:21,574
master page f 3.2-3900.

2222
01:21:21,574 --> 01:21:23,309
And so this document shows

2223
01:21:23,309 --> 01:21:25,711
the base case and south

2224
01:21:25,711 --> 01:21:27,711
tampa resiliency project

2225
01:21:28,800 --> 01:21:31,800
change case used for your

2226
01:21:33,119 --> 01:21:35,119
cost-effective analysis?

2227
01:21:37,156 --> 01:21:38,257
>> MR. Aponte: yes.

2228
01:21:38,257 --> 01:21:41,257
>> so it does not include

2229
01:21:41,460 --> 01:21:41,960
any of the solar

2230
01:21:41,960 --> 01:21:44,130
subsequent to the dover

2231
01:21:44,130 --> 01:21:44,630
battery project in either

2232
01:21:44,630 --> 01:21:45,231
case, although teco is

2233
01:21:45,231 --> 01:21:46,732
moot landing to move

2234
01:21:46,732 --> 01:21:48,732
forward with those

2235
01:21:49,735 --> 01:21:50,336
projects?

2236
01:21:50,336 --> 01:21:52,736
>> MR. Aponte: that is

2237
01:21:54,240 --> 01:21:54,840
correct.

2238
01:21:54,840 --> 01:21:56,475
>> even for the change

2239
01:21:56,475 --> 01:21:59,780
case, it still shows a

2240
01:21:59,780 --> 01:22:01,478
need for the ct

2241
01:22:02,214 --> 01:22:02,747
?

2242
01:22:02,747 --> 01:22:04,747
>> MR. Aponte: yes.

2243
01:22:08,220 --> 01:22:10,689
>> and it does include the

2244
01:22:10,689 --> 01:22:13,890
polk one simple cycle

2245
01:22:13,159 --> 01:22:15,159
conversion project, is

2246
01:22:16,395 --> 01:22:16,996
that right?

2247
01:22:16,996 --> 01:22:18,697
>> MR. Aponte: it does.

2248
01:22:18,697 --> 01:22:20,299
>> we will discuss the

2249
01:22:20,299 --> 01:22:22,299
project more in-depth

2250
01:22:23,135 --> 01:22:25,535
later, but that actually

2251
01:22:28,307 --> 01:22:28,599
increases the depth of

2252
01:22:28,599 --> 01:22:29,141
that?

2253
01:22:29,141 --> 01:22:29,308
>> MR. Aponte: slightly,

2254
01:22:29,308 --> 01:22:31,308
yes.

2255
01:22:34,546 --> 01:22:35,790
>> if I can next direct

2256
01:22:35,790 --> 01:22:36,140
your attention to fll-233

2257
01:22:36,140 --> 01:22:36,549
master page f 3.2-388

2258
01:22:36,549 --> 01:22:37,150
direct your attention to

2259
01:22:37,150 --> 01:22:39,415
fll-233 master page f

2260
01:22:53,565 --> 01:22:55,565
3.2-3883.

2261
01:22:58,536 --> 01:22:59,104
And this shows your

2262
01:22:59,104 --> 01:23:01,104
cost-effectiveness results

2263
01:23:01,339 --> 01:23:01,774
for the south tampa

2264
01:23:01,774 --> 01:23:03,774
resiliency project?

2265
01:23:06,545 --> 01:23:08,545
>> MR. Aponte: yes.

2266
01:23:12,251 --> 01:23:12,618
>> and some basic

2267
01:23:12,618 --> 01:23:13,118
questions here.

2268
01:23:13,118 --> 01:23:13,485
If it's in parentheses,

2269
01:23:13,485 --> 01:23:14,220
that's savings.

2270
01:23:14,220 --> 01:23:14,753
If it's not in

2271
01:23:14,753 --> 01:23:16,753
parentheses, that's base

2272
01:23:22,127 --> 01:23:24,127
cost.

2273
01:23:26,498 --> 01:23:26,999
The biggest savings come

2274
01:23:26,999 --> 01:23:29,399
from system fuel, right?

2275
01:23:30,335 --> 01:23:32,471
And it is directed with

2276
01:23:32,471 --> 01:23:33,405
energy fuel, not -- this

2277
01:23:33,405 --> 01:23:35,240
project would not have

2278
01:23:35,240 --> 01:23:37,640
been found to be

2279
01:23:39,545 --> 01:23:40,145
cost-effective.

2280
01:23:40,145 --> 01:23:41,130
>> MR. Aponte: that's

2281
01:23:41,130 --> 01:23:43,130
correct.

2282
01:23:44,116 --> 01:23:47,116
>> if I can next direct

2283
01:23:49,722 --> 01:23:50,389
your attention to master

2284
01:23:50,389 --> 01:23:52,389
page if 3.2-3901.

2285
01:24:07,973 --> 01:24:09,973
This is fll-29.

2286
01:24:11,210 --> 01:24:12,878
And just want to direct

2287
01:24:12,878 --> 01:24:14,880
your attention to the

2288
01:24:14,880 --> 01:24:17,750
bottom of the page there's

2289
01:24:17,750 --> 01:24:19,750
a note.

2290
01:24:23,188 --> 01:24:23,655
It says the south tampa

2291
01:24:23,655 --> 01:24:25,655
resiliency project is

2292
01:24:26,958 --> 01:24:27,426
constrained to 37.6 mw

2293
01:24:27,426 --> 01:24:29,426
until summer of 2026.

2294
01:24:31,463 --> 01:24:32,131
Is that right?

2295
01:24:32,131 --> 01:24:32,331
>> MR. Aponte: yes, I see

2296
01:24:32,331 --> 01:24:32,798
that.

2297
01:24:32,798 --> 01:24:34,600
>> is that your

2298
01:24:34,600 --> 01:24:34,800
understanding that that's

2299
01:24:34,800 --> 01:24:35,601
true?

2300
01:24:35,601 --> 01:24:38,100
>> MR. Aponte: that is

2301
01:24:40,439 --> 01:24:43,439
true that analysis was --

2302
01:24:44,343 --> 01:24:46,743
we MAY have some

2303
01:24:50,481 --> 01:24:51,116
accelerating on that date.

2304
01:24:51,116 --> 01:24:51,617
>> one of the benefits of

2305
01:24:51,617 --> 01:24:52,117
the project for teco's

2306
01:24:52,117 --> 01:24:54,517
customers was to avoid

2307
01:24:59,424 --> 01:24:59,725
transmissions upgrades, is

2308
01:24:59,725 --> 01:25:00,258
that right?

2309
01:25:00,258 --> 01:25:00,859
>> MR. Aponte: yes.

2310
01:25:00,859 --> 01:25:01,326
>> if I can direct your

2311
01:25:01,326 --> 01:25:03,326
attention to fll-247

2312
01:25:05,831 --> 01:25:06,131
master page f 3.4 -- I'm

2313
01:25:06,131 --> 01:25:08,131
sorry, yes.

2314
01:25:25,551 --> 01:25:27,352
F 3.4-19921.

2315
01:25:27,352 --> 01:25:28,686
This is an earlier draft

2316
01:25:28,686 --> 01:25:30,686
of the cost-effectiveness

2317
01:25:31,790 --> 01:25:34,190
analysis for the south

2318
01:25:37,196 --> 01:25:39,196
tampa resiliency project.

2319
01:25:39,798 --> 01:25:41,798
>> MR. Aponte: yes.

2320
01:25:42,167 --> 01:25:44,503
>> and it shows an

2321
01:25:44,503 --> 01:25:46,503
estimate of approximately

2322
01:25:46,939 --> 01:25:48,939
$5.5 million in savings

2323
01:25:52,945 --> 01:25:53,278
and avoided transmission

2324
01:25:53,278 --> 01:25:53,879
is a benefit.

2325
01:25:53,879 --> 01:25:54,213
>> MR. Aponte: that's

2326
01:25:54,213 --> 01:25:54,847
correct, yes.

2327
01:25:54,847 --> 01:25:55,314
>> it also shows the cost

2328
01:25:55,314 --> 01:25:56,181
for the facility are

2329
01:25:56,181 --> 01:25:58,181
estimated to be 8.2

2330
01:26:02,187 --> 01:26:02,720
million.

2331
01:26:02,720 --> 01:26:04,890
>> MR. Aponte: yes.

2332
01:26:04,890 --> 01:26:06,890
>> sold those interdiction

2333
01:26:07,920 --> 01:26:07,559
costs are higher than the

2334
01:26:07,559 --> 01:26:09,361
avoided transmission

2335
01:26:09,361 --> 01:26:09,995
costs?

2336
01:26:09,995 --> 01:26:12,395
>> MR. Aponte: yes, they

2337
01:26:22,206 --> 01:26:23,809
are.

2338
01:26:23,809 --> 01:26:25,809
>> all right.

2339
01:26:33,918 --> 01:26:34,386
If I could go back to

2340
01:26:34,386 --> 01:26:36,688
master page c32-3577.

2341
01:26:36,688 --> 01:26:39,880
This is admitted exhibit

2342
01:26:46,798 --> 01:26:48,798
320.

2343
01:26:50,836 --> 01:26:51,303
This document contains all

2344
01:26:51,303 --> 01:26:53,703
of the generation and

2345
01:26:54,305 --> 01:26:56,705
storage projects that teco

2346
01:26:56,841 --> 01:26:59,241
has proposed through this

2347
01:27:23,535 --> 01:27:25,535
rate case?

2348
01:27:26,905 --> 01:27:29,305
>> MR. Aponte: I'm there.

2349
01:27:32,477 --> 01:27:32,944
>> this document contains

2350
01:27:32,944 --> 01:27:33,412
all of the stroller,

2351
01:27:33,412 --> 01:27:33,945
battery storage, and

2352
01:27:33,945 --> 01:27:35,945
generation projects that

2353
01:27:36,815 --> 01:27:38,583
teco has in this case?

2354
01:27:38,583 --> 01:27:40,585
>> MR. Aponte: it does.

2355
01:27:40,585 --> 01:27:42,154
>> if you go to winter of

2356
01:27:42,154 --> 01:27:44,154
2027, south tampa

2357
01:27:48,827 --> 01:27:49,194
resiliency has 75 mw of

2358
01:27:49,194 --> 01:27:51,620
capacity that's

2359
01:27:51,620 --> 01:27:53,620
contributing to that

2360
01:27:53,331 --> 01:27:55,331
winter reserve margin?

2361
01:28:00,605 --> 01:28:01,239
>> MR. Aponte: yes.

2362
01:28:01,239 --> 01:28:02,574
>> if you deduct that 75

2363
01:28:02,574 --> 01:28:04,842
mw, you would still have

2364
01:28:04,842 --> 01:28:07,212
that margin in 2027, would

2365
01:28:07,212 --> 01:28:09,212
you?

2366
01:28:14,119 --> 01:28:14,619
>> MR. Aponte: we MAY in

2367
01:28:14,619 --> 01:28:15,200
that year, we MAY fall

2368
01:28:15,200 --> 01:28:15,620
shorter than that.

2369
01:28:15,620 --> 01:28:16,188
>> you would agree that

2370
01:28:16,188 --> 01:28:18,588
through 2027 you would be

2371
01:28:20,225 --> 01:28:20,758
okay?

2372
01:28:20,758 --> 01:28:21,359
>> MR. Aponte: yes.

2373
01:28:21,359 --> 01:28:24,359
>> if I can next direct

2374
01:28:31,103 --> 01:28:31,670
your attention to fll-131.

2375
01:28:31,670 --> 01:28:35,270
This is going to be master

2376
01:28:52,958 --> 01:28:54,958
page f 3.2-3908.

2377
01:28:56,928 --> 01:28:57,495
This document would

2378
01:28:57,495 --> 01:29:00,131
include the big four solar

2379
01:29:00,131 --> 01:29:02,901
base case and change case?

2380
01:29:02,901 --> 01:29:04,901
>> MR. Aponte: okay.

2381
01:29:06,504 --> 01:29:07,380
>> and you would agree

2382
01:29:07,380 --> 01:29:09,438
that the reserve margins

2383
01:29:11,410 --> 01:29:14,641
on here are -- well, even

2384
01:29:19,117 --> 01:29:19,717
through 2027 are both 20%?

2385
01:29:19,717 --> 01:29:19,883
>> MR. Aponte: winter,

2386
01:29:19,883 --> 01:29:20,485
yes.

2387
01:29:20,485 --> 01:29:21,190
>> as comparison to the

2388
01:29:21,190 --> 01:29:24,190
base case and change case

2389
01:29:26,791 --> 01:29:27,359
we were looking at with

2390
01:29:27,359 --> 01:29:27,892
the south tampa resiliency

2391
01:29:27,892 --> 01:29:28,359
projects, the shows other

2392
01:29:28,359 --> 01:29:29,494
projects lingered on,

2393
01:29:29,494 --> 01:29:31,730
which is the energy

2394
01:29:31,730 --> 01:29:32,263
storage subsequent to the

2395
01:29:32,263 --> 01:29:34,663
dover energy project and

2396
01:29:34,833 --> 01:29:37,233
other solar projects that

2397
01:29:38,937 --> 01:29:39,537
come before this.

2398
01:29:39,537 --> 01:29:41,537
>> MR. Aponte: that's

2399
01:29:48,346 --> 01:29:49,130
correct.

2400
01:29:49,130 --> 01:29:50,815
>> and just for comparison

2401
01:29:50,815 --> 01:29:53,815
purposes, keep in mind the

2402
01:29:54,452 --> 01:29:54,986
summer reserve margin here

2403
01:29:54,986 --> 01:29:57,986
for 2027, and if we could

2404
01:30:03,940 --> 01:30:03,661
next go to fll-145, this

2405
01:30:03,661 --> 01:30:07,261
is going to be master page

2406
01:30:09,000 --> 01:30:09,534
f 3.2-3964.

2407
01:30:09,534 --> 01:30:09,734
Before we -- sorry, real

2408
01:30:09,734 --> 01:30:11,102
quick.

2409
01:30:11,102 --> 01:30:14,102
This does not show the

2410
01:30:19,344 --> 01:30:19,978
wamama three project?

2411
01:30:19,978 --> 01:30:20,578
>> MR. Aponte: it is not.

2412
01:30:20,578 --> 01:30:23,578
>> now let's go to that

2413
01:30:44,502 --> 01:30:46,203
master f 3.2-3964.

2414
01:30:46,203 --> 01:30:48,603
This document includes the

2415
01:30:48,807 --> 01:30:50,141
wamama change case and

2416
01:30:50,141 --> 01:30:52,141
base case?

2417
01:30:53,545 --> 01:30:55,545
>> MR. Aponte: yes.

2418
01:30:55,679 --> 01:30:56,814
>> and the reserve margin

2419
01:30:56,814 --> 01:30:58,917
is not all that different

2420
01:30:58,917 --> 01:30:59,918
from what we were looking

2421
01:30:59,918 --> 01:31:01,918
at before?

2422
01:31:06,791 --> 01:31:08,791
>> MR. Aponte: yes.

2423
01:31:12,997 --> 01:31:13,231
>> if we can next go to

2424
01:31:13,231 --> 01:31:13,798
fll-122.

2425
01:31:13,798 --> 01:31:17,398
This is going to be master

2426
01:31:33,718 --> 01:31:34,510
page f 3.2-3875.

2427
01:31:34,510 --> 01:31:35,319
This is your

2428
01:31:35,319 --> 01:31:37,319
cost-effective analysis

2429
01:31:38,823 --> 01:31:39,923
for the polk unit one

2430
01:31:39,923 --> 01:31:41,325
flexibility project, which

2431
01:31:41,325 --> 01:31:43,725
is the simple cycle

2432
01:31:43,928 --> 01:31:45,928
conversion project?

2433
01:31:49,334 --> 01:31:51,334
>> MR. Aponte: yes.

2434
01:31:51,836 --> 01:31:54,236
>> and this project found

2435
01:31:57,141 --> 01:31:59,541
savings or has savings

2436
01:32:00,178 --> 01:32:00,645
from the polk one project

2437
01:32:00,645 --> 01:32:03,450
upgrade and polk one

2438
01:32:05,550 --> 01:32:05,783
sustaining capital and

2439
01:32:05,783 --> 01:32:06,317
feeling?

2440
01:32:06,317 --> 01:32:06,985
>> MR. Aponte: yes.

2441
01:32:06,985 --> 01:32:08,318
>> so you would agree that

2442
01:32:08,318 --> 01:32:09,687
those savings are coming

2443
01:32:09,687 --> 01:32:10,121
from some kind of capital

2444
01:32:10,121 --> 01:32:11,890
investment teco is

2445
01:32:11,890 --> 01:32:14,890
assuming would need to be

2446
01:32:20,765 --> 01:32:21,299
made at polk unit one to

2447
01:32:21,299 --> 01:32:21,866
keep polk unit one as it

2448
01:32:21,866 --> 01:32:22,100
is without the flexibility

2449
01:32:22,100 --> 01:32:22,733
project?

2450
01:32:22,733 --> 01:32:23,340
>> MR. Aponte: yes, that

2451
01:32:23,340 --> 01:32:24,636
is correct.

2452
01:32:24,636 --> 01:32:25,202
>> and this is not a

2453
01:32:25,202 --> 01:32:28,202
project to add capacity to

2454
01:32:31,342 --> 01:32:31,976
the system?

2455
01:32:31,976 --> 01:32:32,610
>> MR. Aponte: it is not.

2456
01:32:32,610 --> 01:32:33,110
>> in fact, the expected

2457
01:32:33,110 --> 01:32:33,645
output of the converted

2458
01:32:33,645 --> 01:32:35,546
unit is about 20 mw less

2459
01:32:35,546 --> 01:32:36,147
than the converted cycle?

2460
01:32:36,147 --> 01:32:38,147
>> MR. Aponte: that's

2461
01:32:39,150 --> 01:32:40,451
correct.

2462
01:32:40,451 --> 01:32:43,451
>> if I can next direct

2463
01:32:45,723 --> 01:32:48,123
your attention to fll-92

2464
01:33:10,748 --> 01:33:11,115
master page f 3.1-2895.

2465
01:33:11,115 --> 01:33:11,616
Do you see that

2466
01:33:11,616 --> 01:33:11,949
interrogatory answer in

2467
01:33:11,949 --> 01:33:12,516
front of you?

2468
01:33:12,516 --> 01:33:13,184
>> MR. Aponte: I do.

2469
01:33:13,184 --> 01:33:14,352
>> this actually shows the

2470
01:33:14,352 --> 01:33:14,885
cost of that polk one

2471
01:33:14,885 --> 01:33:17,285
upgrade without the polk

2472
01:33:18,221 --> 01:33:18,856
one flexibility project.

2473
01:33:18,856 --> 01:33:20,391
>> MR. Aponte: I believe

2474
01:33:20,391 --> 01:33:20,992
so, yes.

2475
01:33:20,992 --> 01:33:23,992
>> so this will be the

2476
01:33:24,161 --> 01:33:25,563
cost necessary to maintain

2477
01:33:25,563 --> 01:33:27,799
polk one as is?

2478
01:33:27,799 --> 01:33:28,398
>> that's correct.

2479
01:33:28,398 --> 01:33:30,798
>> would you agree the

2480
01:33:30,835 --> 01:33:33,235
biggest cost is capital

2481
01:33:35,439 --> 01:33:36,107
for the steam turbine?

2482
01:33:36,107 --> 01:33:39,107
>> MR. Aponte: yes, I see

2483
01:33:44,820 --> 01:33:46,820
that.

2484
01:33:48,518 --> 01:33:49,860
>> and the next biggest

2485
01:33:49,860 --> 01:33:49,620
cost would be for the heat

2486
01:33:49,620 --> 01:33:51,620
recovery steam generator?

2487
01:33:54,592 --> 01:33:56,592
>> MR. Aponte: yes.

2488
01:33:57,428 --> 01:34:00,428
>> if I can next direct

2489
01:34:01,699 --> 01:34:02,267
your attention to fll 124.

2490
01:34:02,267 --> 01:34:05,867
This is going to be master

2491
01:34:16,380 --> 01:34:18,380
page f 3.2-3885.

2492
01:34:19,584 --> 01:34:22,584
And so this document shows

2493
01:34:22,987 --> 01:34:24,288
the reserve margins in the

2494
01:34:24,288 --> 01:34:26,688
fgd one flexibility base

2495
01:34:31,862 --> 01:34:32,397
case.

2496
01:34:32,397 --> 01:34:33,300
>> MR. Aponte: yes.

2497
01:34:33,300 --> 01:34:34,498
>> the base case for that

2498
01:34:34,498 --> 01:34:36,498
is flexibility project

2499
01:34:38,535 --> 01:34:41,535
does not move forward and

2500
01:34:44,809 --> 01:34:45,409
polk one stays as is?

2501
01:34:45,409 --> 01:34:45,643
>> MR. Aponte: that's

2502
01:34:45,643 --> 01:34:46,611
correct.

2503
01:34:46,611 --> 01:34:47,345
>> if I can next direct

2504
01:34:47,345 --> 01:34:50,345
your attention to fll --

2505
01:35:03,794 --> 01:35:04,295
master page 3888.

2506
01:35:04,295 --> 01:35:06,297
And this document shows

2507
01:35:06,297 --> 01:35:08,165
the reserve margins in the

2508
01:35:08,165 --> 01:35:08,633
fgd one flexibility case

2509
01:35:08,633 --> 01:35:11,330
as the project moves

2510
01:35:11,801 --> 01:35:12,336
forward.

2511
01:35:12,336 --> 01:35:14,336
>> MR. Aponte: yes.

2512
01:35:14,639 --> 01:35:15,172
>> and as alluded to

2513
01:35:15,172 --> 01:35:17,572
earlier, you would agree

2514
01:35:18,276 --> 01:35:18,776
the total installed form

2515
01:35:18,776 --> 01:35:20,344
capacity as compared to

2516
01:35:20,344 --> 01:35:23,344
the document we were just

2517
01:35:25,149 --> 01:35:25,416
looking at those down

2518
01:35:25,416 --> 01:35:25,950
slightly?

2519
01:35:25,950 --> 01:35:26,550
>> MR. Aponte: yes.

2520
01:35:26,550 --> 01:35:27,118
>> you would agree that

2521
01:35:27,118 --> 01:35:29,518
the summer reserve margins

2522
01:35:29,754 --> 01:35:32,154
are still well below 20%?

2523
01:35:32,790 --> 01:35:35,190
>> MR. Aponte: they are.

2524
01:35:38,610 --> 01:35:38,529
>> if we can next go to

2525
01:35:38,529 --> 01:35:40,929
fll-126 master page f

2526
01:35:50,741 --> 01:35:52,741
3.2-3891.

2527
01:35:53,777 --> 01:35:54,312
And this document shows

2528
01:35:54,312 --> 01:35:56,712
the polk one flexibility

2529
01:35:57,581 --> 01:36:01,181
base case and the polk one

2530
01:36:04,321 --> 01:36:06,321
flexibility change case.

2531
01:36:08,759 --> 01:36:10,759
>> MR. Aponte: yes.

2532
01:36:11,561 --> 01:36:13,961
>> and the fgd one

2533
01:36:14,664 --> 01:36:15,166
flexibility base case does

2534
01:36:15,166 --> 01:36:18,166
not include any of the

2535
01:36:19,360 --> 01:36:19,470
other projects at issue in

2536
01:36:19,470 --> 01:36:21,470
this case, correct?

2537
01:36:21,738 --> 01:36:22,839
Other than the dover

2538
01:36:22,839 --> 01:36:24,839
energy storage capacity

2539
01:36:27,177 --> 01:36:29,177
project going in 2024?

2540
01:36:31,615 --> 01:36:31,982
>> MR. Aponte: yes, in

2541
01:36:31,982 --> 01:36:32,516
this particular

2542
01:36:32,516 --> 01:36:33,150
illustration it does not.

2543
01:36:33,150 --> 01:36:35,753
>> it is not include the

2544
01:36:35,753 --> 01:36:36,187
-- it does not show any

2545
01:36:36,187 --> 01:36:38,187
need for additional

2546
01:36:40,458 --> 01:36:40,991
generation until 2027?

2547
01:36:40,991 --> 01:36:41,625
>> MR. Aponte: yes.

2548
01:36:41,625 --> 01:36:42,593
>> and that's going to be

2549
01:36:42,593 --> 01:36:44,993
based on the 20% reserve

2550
01:36:46,397 --> 01:36:46,931
margin for winter?

2551
01:36:46,931 --> 01:36:48,931
>> MR. Aponte: yes.

2552
01:36:54,238 --> 01:36:54,772
>> if I can next direct

2553
01:36:54,772 --> 01:36:57,772
your attention to f ll-97

2554
01:37:09,919 --> 01:37:12,319
master page f 3.1-3000.

2555
01:37:12,823 --> 01:37:13,323
You conducted a

2556
01:37:13,323 --> 01:37:13,858
cost-effective analysis

2557
01:37:13,858 --> 01:37:16,258
looking at the potential

2558
01:37:18,395 --> 01:37:18,996
to retire polk unit one?

2559
01:37:18,996 --> 01:37:21,396
>> MR. Aponte: yes, we

2560
01:37:21,432 --> 01:37:21,932
did.

2561
01:37:21,932 --> 01:37:22,332
>> and found such

2562
01:37:22,332 --> 01:37:23,300
retirement to be

2563
01:37:23,300 --> 01:37:23,434
cost-effective

2564
01:37:23,434 --> 01:37:25,434
?

2565
01:37:29,807 --> 01:37:30,241
>> MR. Aponte: did.

2566
01:37:30,241 --> 01:37:30,774
>> thank you.

2567
01:37:30,774 --> 01:37:31,108
That's all my questions,

2568
01:37:31,108 --> 01:37:31,675
MR. CHAIRMAN.

2569
01:37:31,675 --> 01:37:31,942
>> CHAIRMAN La Rosa:

2570
01:37:31,942 --> 01:37:33,942
thank you.

2571
01:37:37,248 --> 01:37:37,748
Next up is fipug.

2572
01:37:37,748 --> 01:37:38,549
>> thank you, MR.

2573
01:37:38,549 --> 01:37:40,549
CHAIRMAN.

2574
01:37:41,918 --> 01:37:42,486
Good morning.

2575
01:37:42,486 --> 01:37:44,486
>> MR. Aponte: good

2576
01:37:45,222 --> 01:37:45,756
morning.

2577
01:37:45,756 --> 01:37:46,256
>> I had a question

2578
01:37:46,256 --> 01:37:48,458
yesterday for your vice

2579
01:37:48,458 --> 01:37:48,959
PRESIDENT Of operations

2580
01:37:48,959 --> 01:37:51,862
with respect to how you

2581
01:37:51,862 --> 01:37:52,262
determine the need for

2582
01:37:52,262 --> 01:37:52,863
future facilities.

2583
01:37:52,863 --> 01:37:56,463
I believe he asked me to

2584
01:37:57,568 --> 01:37:58,680
ask you that question and

2585
01:37:58,680 --> 01:37:59,690
you are responsible for

2586
01:37:59,690 --> 01:38:01,469
future facilities, is that

2587
01:38:03,640 --> 01:38:04,174
right?

2588
01:38:04,174 --> 01:38:04,808
>> MR. Aponte: yes.

2589
01:38:04,808 --> 01:38:05,709
>> MR. Moyle: how do you

2590
01:38:05,709 --> 01:38:08,709
determine the need for the

2591
01:38:09,679 --> 01:38:10,470
solar plants that you are

2592
01:38:10,470 --> 01:38:10,648
putting in now?

2593
01:38:10,648 --> 01:38:13,648
You were asked a question

2594
01:38:18,721 --> 01:38:19,256
about an economic need

2595
01:38:19,256 --> 01:38:19,556
versus a physical reserve

2596
01:38:19,556 --> 01:38:20,240
margin need.

2597
01:38:20,240 --> 01:38:20,591
Explain how you would

2598
01:38:20,591 --> 01:38:22,626
determine the need for the

2599
01:38:22,626 --> 01:38:23,930
solar plants that you are

2600
01:38:23,930 --> 01:38:24,595
seeking recovery for,

2601
01:38:24,595 --> 01:38:25,195
please.

2602
01:38:25,195 --> 01:38:25,962
>> MR. Aponte: yes, of

2603
01:38:25,962 --> 01:38:27,962
course.

2604
01:38:28,332 --> 01:38:29,933
There are two basic

2605
01:38:29,933 --> 01:38:32,933
components of need or a

2606
01:38:35,906 --> 01:38:36,173
criteria for adding new

2607
01:38:36,173 --> 01:38:36,707
resources.

2608
01:38:36,707 --> 01:38:37,174
In the example of solar,

2609
01:38:37,174 --> 01:38:39,174
that is affordability.

2610
01:38:40,944 --> 01:38:43,180
It is an economic need,

2611
01:38:43,180 --> 01:38:45,580
adding the solar lowers

2612
01:38:48,385 --> 01:38:48,852
the cpvrr for customers

2613
01:38:48,852 --> 01:38:49,219
compared to not doing

2614
01:38:49,219 --> 01:38:50,287
those projects.

2615
01:38:50,287 --> 01:38:53,287
The second criteria is the

2616
01:38:58,295 --> 01:38:58,729
20% reserve margin.

2617
01:38:58,729 --> 01:38:59,129
We are required to

2618
01:38:59,129 --> 01:38:59,596
maintain 20%.

2619
01:38:59,596 --> 01:39:00,970
In the case of tampa

2620
01:39:00,970 --> 01:39:02,497
electric, it's a winter

2621
01:39:06,503 --> 01:39:07,137
reserve margin.

2622
01:39:07,137 --> 01:39:07,671
>> MR. Moyle: is part of

2623
01:39:07,671 --> 01:39:10,710
your analysis, if you're

2624
01:39:10,874 --> 01:39:11,441
looking and you have a 20%

2625
01:39:11,441 --> 01:39:11,975
reserve margin and there's

2626
01:39:11,975 --> 01:39:14,375
an economic benefit with

2627
01:39:17,548 --> 01:39:18,810
silver, when you keep

2628
01:39:18,810 --> 01:39:18,549
adding solar to take you

2629
01:39:18,549 --> 01:39:19,160
above 25 to go to 30?

2630
01:39:19,160 --> 01:39:19,482
Is there a hard line

2631
01:39:19,482 --> 01:39:21,882
anywhere stop on the

2632
01:39:22,252 --> 01:39:24,252
reserve margin?

2633
01:39:24,755 --> 01:39:27,155
>> MR. Aponte: well, with

2634
01:39:27,424 --> 01:39:29,893
solar, as I described very

2635
01:39:29,893 --> 01:39:32,293
briefly earlier, there's a

2636
01:39:34,765 --> 01:39:35,332
point where solar loses in

2637
01:39:35,332 --> 01:39:37,234
a capacity value, which in

2638
01:39:37,234 --> 01:39:38,335
this case will be in the

2639
01:39:38,335 --> 01:39:39,870
summer.

2640
01:39:39,870 --> 01:39:41,105
At some point, solar

2641
01:39:41,105 --> 01:39:43,505
doesn't really move the

2642
01:39:45,342 --> 01:39:45,809
needle in any way in terms

2643
01:39:45,809 --> 01:39:48,209
of reserve margin for

2644
01:39:49,580 --> 01:39:51,980
either winter or summer.

2645
01:39:52,182 --> 01:39:52,816
And we believe that is a

2646
01:39:52,816 --> 01:39:54,384
proper way to look at it

2647
01:39:54,384 --> 01:39:56,587
because if we don't do

2648
01:39:56,587 --> 01:39:58,587
that adjustment, solar

2649
01:39:59,322 --> 01:40:01,322
would artificially inflate

2650
01:40:03,861 --> 01:40:06,261
reserve margins and that's

2651
01:40:06,697 --> 01:40:07,264
just not a good

2652
01:40:07,264 --> 01:40:09,664
reliability metric to have

2653
01:40:11,100 --> 01:40:11,668
high reserve for solar.

2654
01:40:11,668 --> 01:40:12,503
That's why that adjustment

2655
01:40:12,503 --> 01:40:14,903
is necessary for the

2656
01:40:16,673 --> 01:40:17,341
summer.

2657
01:40:17,341 --> 01:40:17,875
>> MR. Moyle: I think you

2658
01:40:17,875 --> 01:40:18,408
answered a question where

2659
01:40:18,408 --> 01:40:21,408
you said there's no value

2660
01:40:22,120 --> 01:40:24,181
added to the winter.

2661
01:40:24,181 --> 01:40:26,383
There's a very small

2662
01:40:26,383 --> 01:40:27,551
benefit added to the

2663
01:40:27,551 --> 01:40:28,852
summer.

2664
01:40:28,852 --> 01:40:31,252
It was 1.5%, is that

2665
01:40:32,560 --> 01:40:32,656
right?

2666
01:40:32,656 --> 01:40:32,890
>> MR. Aponte: that's

2667
01:40:32,890 --> 01:40:33,790
correct.

2668
01:40:33,790 --> 01:40:34,324
That would be the last

2669
01:40:34,324 --> 01:40:37,324
couple of projects we are

2670
01:40:37,327 --> 01:40:39,620
presenting would have 1.5%

2671
01:40:39,620 --> 01:40:41,131
capacity value to the

2672
01:40:41,131 --> 01:40:43,131
summer.

2673
01:40:46,360 --> 01:40:46,603
>> MR. Moyle: and when

2674
01:40:46,603 --> 01:40:47,700
you say that 1.5% capacity

2675
01:40:47,700 --> 01:40:49,470
value to the summer,

2676
01:40:49,740 --> 01:40:49,940
explain exactly what that

2677
01:40:49,940 --> 01:40:50,807
means.

2678
01:40:50,807 --> 01:40:53,207
That doesn't mean you're

2679
01:40:59,490 --> 01:40:59,583
at 18.5 and it gets you

2680
01:40:59,583 --> 01:41:00,830
1.5, so you're at 20%, so

2681
01:41:00,830 --> 01:41:00,450
you're good on reserve

2682
01:41:00,450 --> 01:41:02,450
margin, does it?

2683
01:41:05,289 --> 01:41:07,457
>> MR. Aponte: no, it

2684
01:41:07,457 --> 01:41:07,991
does not mean that.

2685
01:41:07,991 --> 01:41:08,492
What that means is out of

2686
01:41:08,492 --> 01:41:08,958
the name plate capacity

2687
01:41:08,958 --> 01:41:09,493
out of solar going on

2688
01:41:09,493 --> 01:41:11,893
doing calculation for the

2689
01:41:13,130 --> 01:41:13,597
reserve margin on any

2690
01:41:13,597 --> 01:41:14,498
given year, I'm only

2691
01:41:14,498 --> 01:41:16,498
counting 1.5% of its

2692
01:41:17,133 --> 01:41:18,368
nameplate to contribute

2693
01:41:18,368 --> 01:41:20,768
towards reserve margin in

2694
01:41:23,707 --> 01:41:24,341
the summer in that year.

2695
01:41:24,341 --> 01:41:26,309
>> MR. Moyle: so what's

2696
01:41:26,309 --> 01:41:28,378
the math on that assuming

2697
01:41:28,378 --> 01:41:30,378
75 mw?

2698
01:41:31,448 --> 01:41:33,848
>> MR. Aponte: like one,

2699
01:41:37,220 --> 01:41:37,888
2 mw.

2700
01:41:37,888 --> 01:41:38,521
>> MR. Moyle: do you have

2701
01:41:38,521 --> 01:41:40,521
operational familiarity

2702
01:41:41,580 --> 01:41:42,826
with how your solar

2703
01:41:42,826 --> 01:41:44,826
utility skills solar

2704
01:41:45,961 --> 01:41:47,563
works?

2705
01:41:47,563 --> 01:41:49,563
>> MR. Aponte: yes.

2706
01:41:51,000 --> 01:41:51,668
Somewhat, yes.

2707
01:41:51,668 --> 01:41:52,201
>> MR. Moyle: there was a

2708
01:41:52,201 --> 01:41:54,601
discussion about if the

2709
01:41:59,276 --> 01:41:59,776
sun is not shining it can

2710
01:41:59,776 --> 01:42:00,100
degrade the solar unit

2711
01:42:00,100 --> 01:42:00,477
output.

2712
01:42:00,477 --> 01:42:02,477
Obviously, that makes

2713
01:42:02,611 --> 01:42:03,460
sense at night.

2714
01:42:03,460 --> 01:42:03,613
But in a discussion

2715
01:42:03,613 --> 01:42:06,130
yesterday with MR. Stryker

2716
01:42:07,500 --> 01:42:07,483
you said there's

2717
01:42:07,483 --> 01:42:07,985
variability on that.

2718
01:42:07,985 --> 01:42:09,186
Can the variability go

2719
01:42:09,186 --> 01:42:10,554
higher as well?

2720
01:42:10,554 --> 01:42:12,521
He was talking about it

2721
01:42:12,521 --> 01:42:13,923
going lower, but can I go

2722
01:42:13,923 --> 01:42:15,923
higher as well

2723
01:42:16,760 --> 01:42:18,561
operationally?

2724
01:42:18,561 --> 01:42:20,561
>> MR. Aponte: yes.

2725
01:42:23,660 --> 01:42:23,467
The variability of solar

2726
01:42:23,467 --> 01:42:24,000
can go both ways.

2727
01:42:24,000 --> 01:42:25,635
At any given hour, solar

2728
01:42:25,635 --> 01:42:29,235
could move a little bit up

2729
01:42:29,606 --> 01:42:30,173
or down.

2730
01:42:30,173 --> 01:42:32,750
>> MR. Moyle: and if

2731
01:42:32,750 --> 01:42:32,542
you're designing your

2732
01:42:32,542 --> 01:42:34,542
solar fields, utility

2733
01:42:36,460 --> 01:42:38,446
skills solar fields at

2734
01:42:39,810 --> 01:42:39,683
71.5, is that right?

2735
01:42:39,683 --> 01:42:39,916
>> MR. Aponte: that is

2736
01:42:39,916 --> 01:42:40,584
correct.

2737
01:42:40,584 --> 01:42:41,317
>> MR. Moyle: can go over

2738
01:42:41,317 --> 01:42:42,986
that on an ideal day for

2739
01:42:42,986 --> 01:42:43,587
solar?

2740
01:42:43,587 --> 01:42:45,822
>> MR. Aponte: no, it

2741
01:42:45,822 --> 01:42:46,322
cannot.

2742
01:42:46,322 --> 01:42:49,322
That is governed by the

2743
01:42:52,662 --> 01:42:53,296
converters.

2744
01:42:53,296 --> 01:42:54,231
>> MR. Moyle: inverter,

2745
01:42:54,231 --> 01:42:54,797
is that like a governor

2746
01:42:54,797 --> 01:42:55,365
that won't let it go about

2747
01:42:55,365 --> 01:42:57,365
that?

2748
01:42:59,350 --> 01:42:59,436
Have you heard of a

2749
01:42:59,436 --> 01:43:01,238
governor on a car?

2750
01:43:01,238 --> 01:43:03,238
>> MR. Aponte: yeah,

2751
01:43:07,978 --> 01:43:09,978
something like that.

2752
01:43:12,782 --> 01:43:13,282
>> MR. Moyle: on page 27

2753
01:43:13,282 --> 01:43:15,682
of your testimony, line

2754
01:43:18,488 --> 01:43:20,523
12, I mean, you run

2755
01:43:20,523 --> 01:43:22,523
cost-effective analysis on

2756
01:43:23,159 --> 01:43:24,794
all of these solar

2757
01:43:24,794 --> 01:43:26,794
projects, correct?

2758
01:43:26,830 --> 01:43:27,430
>> MR. Aponte: yes.

2759
01:43:27,430 --> 01:43:28,732
>> MR. Moyle: you said

2760
01:43:28,732 --> 01:43:30,732
one was not

2761
01:43:32,269 --> 01:43:32,669
cost-effective, yes?

2762
01:43:32,669 --> 01:43:33,236
Which one is that?

2763
01:43:33,236 --> 01:43:35,236
>> MR. Aponte: it's

2764
01:43:43,460 --> 01:43:43,713
english creek.

2765
01:43:43,713 --> 01:43:45,782
>> but you're asking it to

2766
01:43:45,782 --> 01:43:46,316
be approved even though

2767
01:43:46,316 --> 01:43:47,217
it's not cost-effective,

2768
01:43:47,217 --> 01:43:47,817
right?

2769
01:43:47,817 --> 01:43:49,352
>> MR. Aponte: that is

2770
01:43:49,352 --> 01:43:51,352
correct.

2771
01:43:51,855 --> 01:43:52,321
Although, there has been a

2772
01:43:52,321 --> 01:43:54,721
couple of changes to

2773
01:43:55,758 --> 01:43:55,992
inputs that have recently

2774
01:43:55,992 --> 01:43:57,760
happen.

2775
01:43:57,760 --> 01:44:00,160
For example, the increase

2776
01:44:00,864 --> 01:44:03,864
of the ptc from 27.5-$30

2777
01:44:04,400 --> 01:44:04,934
per megawatt hour.

2778
01:44:04,934 --> 01:44:06,569
We also filed a midcourse

2779
01:44:06,569 --> 01:44:08,237
correction forecast

2780
01:44:08,237 --> 01:44:10,637
several months ago as

2781
01:44:11,708 --> 01:44:12,275
another input change and I

2782
01:44:12,275 --> 01:44:14,577
believe that both of those

2783
01:44:14,577 --> 01:44:16,577
combined make english

2784
01:44:20,617 --> 01:44:21,217
creek the small benefit.

2785
01:44:21,217 --> 01:44:23,587
>> MR. Moyle: but you

2786
01:44:23,587 --> 01:44:25,987
haven't done an analysis

2787
01:44:26,389 --> 01:44:29,389
or have a document or

2788
01:44:30,393 --> 01:44:30,927
anything that suggests

2789
01:44:30,927 --> 01:44:31,160
that's the case, is that

2790
01:44:31,160 --> 01:44:31,761
correct?

2791
01:44:31,761 --> 01:44:31,995
>> MR. Aponte: that's

2792
01:44:31,995 --> 01:44:32,529
correct.

2793
01:44:32,529 --> 01:44:33,630
We believe it's going to

2794
01:44:33,630 --> 01:44:35,630
become a cost-effective

2795
01:44:44,808 --> 01:44:45,475
project.

2796
01:44:45,475 --> 01:44:47,210
>> MR. Moyle: MR. Collins

2797
01:44:47,210 --> 01:44:50,147
indicated that you did not

2798
01:44:50,147 --> 01:44:53,147
use a carbon ater with

2799
01:44:53,549 --> 01:44:55,949
respect to your analysis

2800
01:44:56,190 --> 01:44:57,387
of a cost-effectiveness of

2801
01:44:57,387 --> 01:44:59,255
solar projects.

2802
01:44:59,255 --> 01:45:02,255
Wasn't he half right when

2803
01:45:03,193 --> 01:45:05,193
he said that?

2804
01:45:05,628 --> 01:45:06,129
>> MR. Aponte: MR.

2805
01:45:06,129 --> 01:45:06,763
Collins was absolutely

2806
01:45:06,763 --> 01:45:07,630
correct.

2807
01:45:07,630 --> 01:45:09,630
I did not.

2808
01:45:12,869 --> 01:45:13,370
>> MR. Moyle: duly noted.

2809
01:45:13,370 --> 01:45:13,536
Let me come at it this

2810
01:45:13,536 --> 01:45:14,370
way.

2811
01:45:14,370 --> 01:45:15,405
Didn't you do an analysis

2812
01:45:15,405 --> 01:45:17,405
of your cost-effectiveness

2813
01:45:20,843 --> 01:45:22,178
assuming a carbon cost in

2814
01:45:22,178 --> 01:45:25,778
one way and then also not

2815
01:45:27,617 --> 01:45:28,184
assuming a carbon cost?

2816
01:45:28,184 --> 01:45:28,551
>> MR. Aponte: yes,

2817
01:45:28,551 --> 01:45:29,953
that's correct.

2818
01:45:29,953 --> 01:45:32,953
We did it both ways,

2819
01:45:33,189 --> 01:45:34,190
although the company's

2820
01:45:34,190 --> 01:45:36,190
criteria for determining

2821
01:45:36,292 --> 01:45:38,692
to move forward with

2822
01:45:39,396 --> 01:45:41,396
cost-effective projects

2823
01:45:43,132 --> 01:45:45,532
excludes all benefits from

2824
01:45:45,969 --> 01:45:48,369
the reduction of co2.

2825
01:45:49,339 --> 01:45:49,873
Exhibits show it to show

2826
01:45:49,873 --> 01:45:51,440
how much more benefit we

2827
01:45:51,440 --> 01:45:53,576
could potentially get in

2828
01:45:53,576 --> 01:45:56,576
the event that a carbon

2829
01:45:56,645 --> 01:45:58,515
tax becomes a mandate, but

2830
01:45:58,515 --> 01:45:59,150
the criteria for the

2831
01:45:59,150 --> 01:46:00,183
company to move forward

2832
01:46:00,183 --> 01:46:02,180
with cost-effective

2833
01:46:02,180 --> 01:46:04,180
projects excludes the

2834
01:46:05,555 --> 01:46:06,189
benefit of co2.

2835
01:46:06,189 --> 01:46:06,521
>> MR. Moyle: let's just

2836
01:46:06,521 --> 01:46:08,521
reference one.

2837
01:46:08,691 --> 01:46:11,691
The last exhibit in your

2838
01:46:16,533 --> 01:46:18,533
direct testimony.

2839
01:46:22,572 --> 01:46:23,720
It's on page 63.

2840
01:46:23,720 --> 01:46:25,720
Document number 22 page

2841
01:46:25,308 --> 01:46:27,308
101 of your direct

2842
01:46:42,692 --> 01:46:44,692
testimony.

2843
01:46:44,894 --> 01:46:47,294
>> MR. Aponte: I am

2844
01:47:10,153 --> 01:47:12,153
there.

2845
01:47:13,556 --> 01:47:14,557
>> MR. Moyle: I believe

2846
01:47:14,557 --> 01:47:16,492
-- okay, it's up there.

2847
01:47:16,492 --> 01:47:19,492
The name of this project

2848
01:47:19,562 --> 01:47:20,163
is, what?

2849
01:47:20,163 --> 01:47:22,163
>> MR. Aponte: wamama

2850
01:47:22,699 --> 01:47:23,333
three.

2851
01:47:23,333 --> 01:47:25,567
>> MR. Moyle: if you go

2852
01:47:25,567 --> 01:47:29,167
down so we can scroll down

2853
01:47:29,405 --> 01:47:32,405
to the co2 emissions cost.

2854
01:47:35,345 --> 01:47:36,120
>> MR. Aponte: yes.

2855
01:47:36,120 --> 01:47:36,546
>> CHAIRMAN La Rosa: that

2856
01:47:36,546 --> 01:47:36,979
figure, how did you come

2857
01:47:36,979 --> 01:47:37,613
up with that figure?

2858
01:47:37,613 --> 01:47:38,214
>> MR. Aponte: some time

2859
01:47:38,214 --> 01:47:41,214
ago we went out and

2860
01:47:42,685 --> 01:47:44,554
purchased a report from an

2861
01:47:44,554 --> 01:47:46,554
outside consultant that

2862
01:47:46,589 --> 01:47:48,524
based on their research

2863
01:47:48,524 --> 01:47:50,524
and their analysis

2864
01:47:52,562 --> 01:47:54,962
assigned a specific value

2865
01:47:56,933 --> 01:47:58,768
to a cost per ton of co2.

2866
01:47:58,768 --> 01:48:00,736
For our region.

2867
01:48:00,736 --> 01:48:03,136
So basically using that

2868
01:48:04,140 --> 01:48:05,775
value multiplied by the

2869
01:48:05,775 --> 01:48:08,775
amount of tons that the

2870
01:48:14,617 --> 01:48:15,151
solar project would reduce

2871
01:48:15,151 --> 01:48:15,518
on our system, that turns

2872
01:48:15,518 --> 01:48:17,518
into a benefit.

2873
01:48:18,821 --> 01:48:19,321
The amount of tons reduced

2874
01:48:19,321 --> 01:48:19,956
by the cost of each ton

2875
01:48:19,956 --> 01:48:22,225
that would've cost us if

2876
01:48:22,225 --> 01:48:25,225
there was a carbon tax,

2877
01:48:29,699 --> 01:48:29,932
that is what that cost

2878
01:48:29,932 --> 01:48:31,533
benefit.

2879
01:48:31,533 --> 01:48:33,933
The consultant's name was

2880
01:48:34,303 --> 01:48:36,303
called icf.

2881
01:48:38,307 --> 01:48:38,741
>> MR. Moyle: what did

2882
01:48:38,741 --> 01:48:39,308
the report conclude?

2883
01:48:39,308 --> 01:48:39,708
When you read it, what was

2884
01:48:39,708 --> 01:48:41,708
the rationale and

2885
01:48:41,777 --> 01:48:43,613
reasoning as to why a

2886
01:48:43,613 --> 01:48:45,548
carbon cost was projected

2887
01:48:45,548 --> 01:48:47,948
to be in place

2888
01:48:48,651 --> 01:48:49,552
particularly at a point in

2889
01:48:49,552 --> 01:48:52,155
time that it would affect

2890
01:48:52,155 --> 01:48:55,155
the solar units that you

2891
01:48:56,826 --> 01:48:57,426
are moving forward with.

2892
01:48:57,426 --> 01:48:59,826
>> MR. Aponte: like I

2893
01:49:01,474 --> 01:49:02,498
said, the report is a year

2894
01:49:02,498 --> 01:49:02,932
or two old and the report

2895
01:49:02,932 --> 01:49:04,660
looked at the macro

2896
01:49:04,660 --> 01:49:06,660
economics everything going

2897
01:49:10,239 --> 01:49:13,239
on with any type of

2898
01:49:15,143 --> 01:49:16,450
proposals for regulations,

2899
01:49:16,450 --> 01:49:18,450
emission regulations.

2900
01:49:19,281 --> 01:49:22,281
It looks at the region.

2901
01:49:22,752 --> 01:49:25,752
It looked at many factors

2902
01:49:25,788 --> 01:49:26,956
to come up with that.

2903
01:49:26,956 --> 01:49:29,726
>> MR. Moyle: and did his

2904
01:49:29,726 --> 01:49:30,493
report assume it would be

2905
01:49:30,493 --> 01:49:32,493
government action that

2906
01:49:35,564 --> 01:49:37,990
would impose a fee or tax

2907
01:49:37,990 --> 01:49:39,000
on carbon?

2908
01:49:39,000 --> 01:49:39,869
>> MR. Aponte: at the

2909
01:49:39,869 --> 01:49:42,672
time of that report, I

2910
01:49:42,672 --> 01:49:44,473
believe that it did assume

2911
01:49:44,473 --> 01:49:46,275
government action at a

2912
01:49:46,275 --> 01:49:48,675
certain year in the

2913
01:49:49,211 --> 01:49:51,211
future.

2914
01:49:52,810 --> 01:49:55,618
Like I said, the report is

2915
01:49:55,618 --> 01:49:58,618
a couple of years old.

2916
01:49:58,920 --> 01:49:59,455
>> MR. Moyle: did you, in

2917
01:49:59,455 --> 01:49:59,855
preparing your testimony,

2918
01:49:59,855 --> 01:50:02,255
did you check the

2919
01:50:02,258 --> 01:50:04,658
conclusion there might be

2920
01:50:05,328 --> 01:50:05,695
a tax on carbon imposed by

2921
01:50:05,695 --> 01:50:07,695
the government?

2922
01:50:09,310 --> 01:50:09,565
Did you check it with any

2923
01:50:09,565 --> 01:50:10,660
legislative people at the

2924
01:50:10,660 --> 01:50:13,660
state people and say I

2925
01:50:13,202 --> 01:50:14,870
think florida is going to

2926
01:50:14,870 --> 01:50:17,639
be putting a carbon tax in

2927
01:50:17,639 --> 01:50:18,174
place anytime soon?

2928
01:50:18,174 --> 01:50:19,375
>> MR. Aponte: not

2929
01:50:19,375 --> 01:50:19,841
outside the company, but

2930
01:50:19,841 --> 01:50:22,110
we recognize that the

2931
01:50:22,110 --> 01:50:24,780
moment there is no plan to

2932
01:50:24,780 --> 01:50:26,381
assign a carbon tax.

2933
01:50:26,381 --> 01:50:28,217
>> MR. Moyle: what about

2934
01:50:28,217 --> 01:50:28,817
within the company?

2935
01:50:28,817 --> 01:50:30,820
>> MR. Aponte: yes, we

2936
01:50:30,820 --> 01:50:32,321
recognize our immediate

2937
01:50:32,321 --> 01:50:35,257
plan to assign a carbon

2938
01:50:35,257 --> 01:50:35,791
tax.

2939
01:50:35,791 --> 01:50:36,291
>> MR. Moyle: same

2940
01:50:36,291 --> 01:50:38,691
question with regard to

2941
01:50:39,361 --> 01:50:41,361
federal legislative

2942
01:50:42,631 --> 01:50:43,165
actions you have.

2943
01:50:43,165 --> 01:50:44,990
>> MR. Wahlen: MR.

2944
01:50:44,990 --> 01:50:46,990
CHAIRMAN, this is

2945
01:50:46,402 --> 01:50:47,169
fascinating to me, of

2946
01:50:47,169 --> 01:50:49,569
course, but the testimony

2947
01:50:53,842 --> 01:50:54,376
is the company is not

2948
01:50:54,376 --> 01:50:54,910
relying on carbon ater to

2949
01:50:54,910 --> 01:50:55,711
prove cost-effectiveness.

2950
01:50:55,711 --> 01:50:57,747
I really don't know that

2951
01:50:57,747 --> 01:51:00,747
this is adding a lot.

2952
01:51:02,752 --> 01:51:04,787
If MR. Moyle wants to

2953
01:51:04,787 --> 01:51:07,220
continue, he can, but --

2954
01:51:07,220 --> 01:51:07,522
>> CHAIRMAN La Rosa: I

2955
01:51:07,522 --> 01:51:09,922
think the question has

2956
01:51:11,594 --> 01:51:12,160
been answered.

2957
01:51:12,160 --> 01:51:12,628
>> MR. Moyle: I was

2958
01:51:12,628 --> 01:51:14,628
trying to understand.

2959
01:51:15,310 --> 01:51:15,597
He said he did report.

2960
01:51:15,597 --> 01:51:17,666
I was trying to understand

2961
01:51:17,666 --> 01:51:17,900
the rationale for the

2962
01:51:17,900 --> 01:51:19,900
report.

2963
01:51:20,102 --> 01:51:20,436
They got exhibits that are

2964
01:51:20,436 --> 01:51:22,436
showing this.

2965
01:51:24,600 --> 01:51:24,507
They are saying they are

2966
01:51:24,507 --> 01:51:24,974
not relying on it, but

2967
01:51:24,974 --> 01:51:25,541
they done it and are

2968
01:51:25,541 --> 01:51:28,541
putting it in front of

2969
01:51:28,611 --> 01:51:29,111
you, but I think I've

2970
01:51:29,111 --> 01:51:30,980
exhausted that line of

2971
01:51:30,980 --> 01:51:31,547
questioning.

2972
01:51:31,547 --> 01:51:31,747
>> CHAIRMAN La Rosa:

2973
01:51:31,747 --> 01:51:33,747
okay.

2974
01:51:44,927 --> 01:51:45,528
Thank you.

2975
01:51:45,528 --> 01:51:47,928
>> MR. Moyle: you also

2976
01:51:51,534 --> 01:51:52,670
are projected savings

2977
01:51:52,670 --> 01:51:52,535
unprotected fuel savings

2978
01:51:52,535 --> 01:51:53,235
and you had to use a

2979
01:51:53,235 --> 01:51:54,837
forecast of what natural

2980
01:51:54,837 --> 01:51:57,206
gas prices would be going

2981
01:51:57,206 --> 01:51:59,606
forward, is that right?

2982
01:52:00,175 --> 01:52:01,777
>> MR. Aponte: yes.

2983
01:52:01,777 --> 01:52:02,311
>> MR. Moyle: the prices

2984
01:52:02,311 --> 01:52:04,790
that you used are higher

2985
01:52:04,790 --> 01:52:07,790
than the henry hub natural

2986
01:52:07,248 --> 01:52:09,648
gas price futures that

2987
01:52:16,625 --> 01:52:16,859
come from imex, is that

2988
01:52:16,859 --> 01:52:17,426
correct?

2989
01:52:17,426 --> 01:52:19,426
>> MR. Aponte: yes,

2990
01:52:19,561 --> 01:52:20,960
because we have databases

2991
01:52:20,960 --> 01:52:23,960
to get the fuel delivered

2992
01:52:31,974 --> 01:52:32,608
to our region.

2993
01:52:32,608 --> 01:52:33,375
>> MR. Moyle: I have no

2994
01:52:33,375 --> 01:52:33,942
further questions.

2995
01:52:33,942 --> 01:52:35,942
>> CHAIRMAN La Rosa:

2996
01:52:37,146 --> 01:52:37,413
thank you.

2997
01:52:37,413 --> 01:52:37,579
All right.

2998
01:52:37,579 --> 01:52:39,579
Fea?

2999
01:52:41,984 --> 01:52:42,484
>> fea has no questions.

3000
01:52:42,484 --> 01:52:43,485
Thank you, commissioner.

3001
01:52:43,485 --> 01:52:45,485
>> CHAIRMAN La Rosa:

3002
01:52:45,554 --> 01:52:45,854
thank you.

3003
01:52:45,854 --> 01:52:47,389
Sierra club?

3004
01:52:47,389 --> 01:52:47,656
>> yes, we have some

3005
01:52:47,656 --> 01:52:49,656
questions.

3006
01:52:50,558 --> 01:52:51,126
Good morning, MR. Aponte.

3007
01:52:51,126 --> 01:52:51,359
>> MR. Aponte: good

3008
01:52:51,359 --> 01:52:52,928
morning.

3009
01:52:52,928 --> 01:52:55,328
>> you state in your

3010
01:52:58,167 --> 01:52:58,700
testimony that the polk

3011
01:52:58,700 --> 01:52:59,101
one project will cost $85

3012
01:52:59,101 --> 01:53:01,101
million, correct?

3013
01:53:02,604 --> 01:53:03,238
>> MR. Aponte: yes.

3014
01:53:03,238 --> 01:53:03,739
>> can you please pull up

3015
01:53:03,739 --> 01:53:04,206
sierra club exhibit 17,

3016
01:53:04,206 --> 01:53:04,739
which is psc exhibit

3017
01:53:04,739 --> 01:53:05,240
>> can you please pull up

3018
01:53:05,240 --> 01:53:05,741
sierra club exhibit 17,

3019
01:53:05,741 --> 01:53:08,141
which is psc exhibit 84

3020
01:53:09,745 --> 01:53:11,113
page f-6 360?

3021
01:53:11,113 --> 01:53:14,713
And let me know when you

3022
01:53:25,160 --> 01:53:25,794
have that in front of you.

3023
01:53:25,794 --> 01:53:28,794
>> MR. Aponte: I see it.

3024
01:53:29,164 --> 01:53:29,431
>>

3025
01:53:29,431 --> 01:53:29,965
>> thanks.

3026
01:53:29,965 --> 01:53:32,965
When looking at the cost

3027
01:53:35,137 --> 01:53:35,671
with polk one cost

3028
01:53:35,671 --> 01:53:38,671
flexibly, we can see and

3029
01:53:40,275 --> 01:53:40,776
$90.1 million cost for the

3030
01:53:40,776 --> 01:53:41,143
conversion of polk one.

3031
01:53:41,143 --> 01:53:41,777
Do you see that?

3032
01:53:41,777 --> 01:53:44,713
>> MR. Aponte: I see it.

3033
01:53:44,713 --> 01:53:45,247
>> possible total cost of

3034
01:53:45,247 --> 01:53:47,349
the polk one flexibility

3035
01:53:47,349 --> 01:53:49,585
project is higher than

3036
01:53:49,585 --> 01:53:51,585
81.5 million?

3037
01:53:52,520 --> 01:53:54,920
>> MR. Aponte: what the

3038
01:53:56,925 --> 01:53:57,426
90.1 million represents is

3039
01:53:57,426 --> 01:53:57,826
the cost after we have

3040
01:53:57,826 --> 01:53:58,359
gone through the

3041
01:53:58,359 --> 01:53:59,628
calculation of adding the

3042
01:53:59,628 --> 01:54:01,429
revenue requirement for

3043
01:54:01,429 --> 01:54:03,232
that capital.

3044
01:54:03,232 --> 01:54:04,900
So the mpv of the revenue

3045
01:54:04,900 --> 01:54:06,900
requirement of that

3046
01:54:09,838 --> 01:54:10,380
capital becomes 90.1.

3047
01:54:10,380 --> 01:54:10,606
Seem

3048
01:54:10,606 --> 01:54:11,740
>> so which cost is passed

3049
01:54:11,740 --> 01:54:14,140
on to ratepayers, the 80.5

3050
01:54:15,760 --> 01:54:17,760
or this higher 90.1?

3051
01:54:17,613 --> 01:54:18,460
>> MR. Aponte: the 90.1.

3052
01:54:18,460 --> 01:54:20,460
>> all right.

3053
01:54:20,782 --> 01:54:22,782
Thank you.

3054
01:54:25,754 --> 01:54:26,288
Looking again at sierra

3055
01:54:26,288 --> 01:54:29,288
club the same exhibit on

3056
01:54:30,492 --> 01:54:30,926
page f-6 353, the tab,

3057
01:54:30,926 --> 01:54:32,594
this is a tab that

3058
01:54:32,594 --> 01:54:33,610
considers a scenario

3059
01:54:33,610 --> 01:54:34,897
without the polk one

3060
01:54:34,897 --> 01:54:36,897
flexibility project.

3061
01:54:37,866 --> 01:54:38,367
Thank you.

3062
01:54:38,367 --> 01:54:39,635
This also projects high

3063
01:54:39,635 --> 01:54:42,350
cost for maintaining the

3064
01:54:44,706 --> 01:54:45,239
unit as is, right?

3065
01:54:45,239 --> 01:54:45,807
>> MR. Aponte: yes.

3066
01:54:45,807 --> 01:54:47,900
>> including a $130.9

3067
01:54:47,900 --> 01:54:49,900
million project upgrade

3068
01:54:49,678 --> 01:54:50,211
cost, right?

3069
01:54:50,211 --> 01:54:52,211
>> MR. Aponte: yes.

3070
01:54:53,415 --> 01:54:53,748
>> when without upgrade

3071
01:54:53,748 --> 01:54:55,748
need to occur?

3072
01:54:59,921 --> 01:55:00,255
>> MR. Aponte: in 2025.

3073
01:55:00,255 --> 01:55:00,822
>> okay.

3074
01:55:00,822 --> 01:55:04,422
If polk one were to retire

3075
01:55:05,327 --> 01:55:05,861
in 2021, teco would avoid

3076
01:55:05,861 --> 01:55:06,361
incurring this roughly 1

3077
01:55:06,361 --> 01:55:06,961
$31 million cost, right?

3078
01:55:06,961 --> 01:55:08,764
>> MR. Aponte: if that

3079
01:55:08,764 --> 01:55:11,164
unit retires in 2025, it

3080
01:55:14,503 --> 01:55:15,370
will be replaced with the

3081
01:55:15,370 --> 01:55:15,704
same -- it would need to

3082
01:55:15,704 --> 01:55:16,171
be replaced with the same

3083
01:55:16,171 --> 01:55:18,571
amount of capacity to

3084
01:55:20,776 --> 01:55:21,310
retain reserve margin, so

3085
01:55:21,310 --> 01:55:22,677
I believe that the amount

3086
01:55:22,677 --> 01:55:25,347
of money would be higher

3087
01:55:25,347 --> 01:55:27,347
than that.

3088
01:55:28,583 --> 01:55:30,185
>> okay.

3089
01:55:30,185 --> 01:55:32,754
That feeds right into my

3090
01:55:32,754 --> 01:55:32,921
next question, so thank

3091
01:55:32,921 --> 01:55:34,589
you.

3092
01:55:34,589 --> 01:55:37,192
Teco is not performed a

3093
01:55:37,192 --> 01:55:37,659
retirement analysis for

3094
01:55:37,659 --> 01:55:39,659
polk one since 2022,

3095
01:55:42,431 --> 01:55:43,980
correct?

3096
01:55:43,980 --> 01:55:45,980
>> MR. Aponte: retirement

3097
01:55:45,600 --> 01:55:48,000
analysis for polk one

3098
01:55:48,636 --> 01:55:49,171
since 2022?

3099
01:55:49,171 --> 01:55:50,405
I know we have looked at

3100
01:55:50,405 --> 01:55:50,939
it several times.

3101
01:55:50,939 --> 01:55:53,875
Our most recent one might

3102
01:55:53,875 --> 01:55:55,875
be 2023.

3103
01:55:57,645 --> 01:55:58,113
>> 2023.

3104
01:55:58,113 --> 01:55:58,713
Is that in the record?

3105
01:55:58,713 --> 01:56:00,480
>> MR. Aponte: yes, it

3106
01:56:00,480 --> 01:56:02,480
is.

3107
01:56:02,184 --> 01:56:04,653
>> so was that the same

3108
01:56:04,653 --> 01:56:07,530
retirement analysis I had

3109
01:56:10,492 --> 01:56:11,930
asked witness -- about?

3110
01:56:11,930 --> 01:56:12,560
>> MR. Aponte: that's

3111
01:56:12,560 --> 01:56:14,560
correct.

3112
01:56:16,310 --> 01:56:16,531
>> but this study did not

3113
01:56:16,531 --> 01:56:17,320
consider any retirement

3114
01:56:17,320 --> 01:56:19,320
years apart from 2028,

3115
01:56:24,720 --> 01:56:24,673
right?

3116
01:56:24,673 --> 01:56:24,839
>> MR. Aponte: it did

3117
01:56:24,839 --> 01:56:25,474
not.

3118
01:56:25,474 --> 01:56:26,700
>> so when assessing the

3119
01:56:26,700 --> 01:56:26,508
cost of retiring polk one

3120
01:56:26,508 --> 01:56:28,908
versus keeping the unit

3121
01:56:29,440 --> 01:56:29,578
operational, teco did not

3122
01:56:29,578 --> 01:56:30,770
consider a scenario that

3123
01:56:30,770 --> 01:56:31,346
replaces polk one with

3124
01:56:31,346 --> 01:56:33,746
renewable energy or energy

3125
01:56:38,530 --> 01:56:38,653
storage, right?

3126
01:56:38,653 --> 01:56:38,820
>> MR. Aponte: we did

3127
01:56:38,820 --> 01:56:39,387
not.

3128
01:56:39,387 --> 01:56:39,955
>> in performing this

3129
01:56:39,955 --> 01:56:42,290
retirement study, teco did

3130
01:56:42,290 --> 01:56:42,858
not consider the cost of

3131
01:56:42,858 --> 01:56:43,425
acquiring renewable energy

3132
01:56:43,425 --> 01:56:44,792
such as storage through an

3133
01:56:44,792 --> 01:56:47,192
open source rfp process,

3134
01:56:47,996 --> 01:56:48,530
did it?

3135
01:56:48,530 --> 01:56:49,640
>> MR. Aponte: for

3136
01:56:49,640 --> 01:56:51,464
purposes of the analysis,

3137
01:56:52,200 --> 01:56:52,734
no.

3138
01:56:52,734 --> 01:56:55,134
>> but teco is not

3139
01:56:57,205 --> 01:56:57,372
planning on offering -- is

3140
01:56:57,372 --> 01:56:59,372
it?

3141
01:57:00,800 --> 01:57:02,676
>> MR. Aponte: I am not

3142
01:57:02,676 --> 01:57:05,676
the project expert, but we

3143
01:57:07,449 --> 01:57:09,849
have a competitive buying

3144
01:57:11,552 --> 01:57:11,886
methodology.

3145
01:57:11,886 --> 01:57:12,354
>> okay.

3146
01:57:12,354 --> 01:57:14,354
does that methodology

3147
01:57:15,756 --> 01:57:16,257
include an open source rfp

3148
01:57:16,257 --> 01:57:18,257
where participants can

3149
01:57:20,161 --> 01:57:20,795
bid?

3150
01:57:20,795 --> 01:57:23,164
>> MR. Aponte: I believe

3151
01:57:23,164 --> 01:57:23,698
it does.

3152
01:57:23,698 --> 01:57:26,698
I'm not the right person

3153
01:57:26,968 --> 01:57:27,302
to answer that.

3154
01:57:27,302 --> 01:57:28,937
>> okay.

3155
01:57:28,937 --> 01:57:29,371
I guess put differently

3156
01:57:29,371 --> 01:57:31,771
maybe this is more

3157
01:57:31,939 --> 01:57:33,939
helpful.

3158
01:57:34,241 --> 01:57:36,641
Teco is planning on

3159
01:57:39,614 --> 01:57:39,981
building its storage

3160
01:57:39,981 --> 01:57:40,515
itself, correct?

3161
01:57:40,515 --> 01:57:41,116
>> MR. Aponte: yes.

3162
01:57:41,116 --> 01:57:42,350
>> would you agree the

3163
01:57:42,350 --> 01:57:42,817
economics of building

3164
01:57:42,817 --> 01:57:44,817
storage are changing

3165
01:57:45,200 --> 01:57:45,654
rapidly?

3166
01:57:45,654 --> 01:57:47,789
>> MR. Aponte: yes, they

3167
01:57:47,789 --> 01:57:48,390
are changing.

3168
01:57:48,390 --> 01:57:50,191
>> for example, do you

3169
01:57:50,191 --> 01:57:52,159
anticipate the inflation

3170
01:57:52,159 --> 01:57:54,559
reduction act credits are

3171
01:57:56,464 --> 01:57:56,965
driving down the cost of

3172
01:57:56,965 --> 01:57:58,965
battery storage further?

3173
01:58:00,835 --> 01:58:01,402
>> MR. Aponte: yes, I do.

3174
01:58:01,402 --> 01:58:01,970
>> can you guarantee

3175
01:58:01,970 --> 01:58:04,970
holding an open source rfp

3176
01:58:05,540 --> 01:58:06,107
would not result in energy

3177
01:58:06,107 --> 01:58:09,107
storage then if teco build

3178
01:58:09,911 --> 01:58:10,512
its own energy storage?

3179
01:58:10,512 --> 01:58:11,780
>> MR. Aponte: I'm not

3180
01:58:11,780 --> 01:58:14,780
the right person to answer

3181
01:58:16,184 --> 01:58:16,517
that.

3182
01:58:16,517 --> 01:58:18,517
>> okay.

3183
01:58:19,387 --> 01:58:22,987
And who would be the right

3184
01:58:23,444 --> 01:58:23,594
witness in this case to

3185
01:58:23,594 --> 01:58:25,594
answer that?

3186
01:58:26,560 --> 01:58:26,795
>> that would be witness

3187
01:58:26,795 --> 01:58:28,663
stryker.

3188
01:58:28,663 --> 01:58:30,663
>> witness stryker

3189
01:58:31,432 --> 01:58:32,367
directed much of his

3190
01:58:32,367 --> 01:58:34,367
questions to you.

3191
01:58:36,938 --> 01:58:37,339
Did teco consider the cost

3192
01:58:37,339 --> 01:58:39,441
of the polk -- I

3193
01:58:39,441 --> 01:58:41,441
apologize, from 2023.

3194
01:58:41,709 --> 01:58:43,979
Did teco consider the cost

3195
01:58:43,979 --> 01:58:46,680
of the polk one project in

3196
01:58:46,680 --> 01:58:47,349
that study?

3197
01:58:47,349 --> 01:58:47,782
>> MR. Aponte: I'm sorry,

3198
01:58:47,782 --> 01:58:50,182
can you repeat the

3199
01:58:50,251 --> 01:58:50,885
question?

3200
01:58:50,885 --> 01:58:51,944
>> yes, I have the wrong

3201
01:58:51,944 --> 01:58:52,420
year.

3202
01:58:52,420 --> 01:58:54,289
Turning back to the 2023

3203
01:58:54,289 --> 01:58:56,689
polk one retirement study,

3204
01:58:57,124 --> 01:58:59,194
did teco consider the cost

3205
01:58:59,194 --> 01:59:01,594
of the diversity project

3206
01:59:02,196 --> 01:59:02,730
in conducting this study?

3207
01:59:02,730 --> 01:59:03,998
>> MR. Aponte: my

3208
01:59:03,998 --> 01:59:05,300
understanding is those two

3209
01:59:05,300 --> 01:59:06,801
projects are not

3210
01:59:06,801 --> 01:59:08,370
connected.

3211
01:59:08,370 --> 01:59:10,370
>> okay.

3212
01:59:13,341 --> 01:59:13,474
So did teco consider

3213
01:59:13,474 --> 01:59:13,883
, I

3214
01:59:13,883 --> 01:59:15,777
guess I will ask

3215
01:59:15,777 --> 01:59:16,244
differently.

3216
01:59:16,244 --> 01:59:18,644
Did teco consider the

3217
01:59:22,584 --> 01:59:25,584
costs of the teco --

3218
01:59:29,424 --> 01:59:30,580
>> MR. Aponte: no.

3219
01:59:30,580 --> 01:59:32,458
>> did teco consider the

3220
01:59:32,559 --> 01:59:34,729
cost of the polk one

3221
01:59:34,729 --> 01:59:36,729
flexibility process

3222
01:59:39,901 --> 01:59:40,502
?

3223
01:59:40,502 --> 01:59:40,935
>> MR. Aponte: ask me

3224
01:59:40,935 --> 01:59:42,300
that one more time,

3225
01:59:42,300 --> 01:59:42,436
please.

3226
01:59:42,436 --> 01:59:42,971
>> no problem.

3227
01:59:42,971 --> 01:59:44,971
>> MR. Aponte: in

3228
01:59:45,907 --> 01:59:47,907
conducting that retirement

3229
01:59:48,410 --> 01:59:50,441
study, did teco consider

3230
01:59:52,346 --> 01:59:55,946
the cost of the polk one

3231
02:00:04,558 --> 02:00:05,192
flexibility project?

3232
02:00:05,192 --> 02:00:05,727
>> MR. Aponte: in order

3233
02:00:05,727 --> 02:00:06,127
to do a complete analysis

3234
02:00:06,127 --> 02:00:06,661
for the polk one

3235
02:00:06,661 --> 02:00:08,620
flexibility, we looked at

3236
02:00:08,620 --> 02:00:08,963
a retirement analysis in

3237
02:00:08,963 --> 02:00:10,963
2028, yes.

3238
02:00:11,199 --> 02:00:13,599
That was one sensitivity

3239
02:00:13,968 --> 02:00:15,968
we did.

3240
02:00:16,604 --> 02:00:18,604
>> in performing the 2023

3241
02:00:19,340 --> 02:00:21,276
study, did teco factor in

3242
02:00:21,276 --> 02:00:23,276
compliance costs?

3243
02:00:24,412 --> 02:00:25,979
>> MR. Aponte: no, we did

3244
02:00:25,979 --> 02:00:26,314
not.

3245
02:00:26,314 --> 02:00:28,314
>> okay.

3246
02:00:29,830 --> 02:00:29,584
teco did not consider cost

3247
02:00:29,584 --> 02:00:30,117
of rules that were not

3248
02:00:30,117 --> 02:00:32,117
finalized after 2023 such

3249
02:00:34,956 --> 02:00:35,355
as the 2024 greenhouse gas

3250
02:00:35,355 --> 02:00:36,560
standards, right?

3251
02:00:36,560 --> 02:00:37,792
>> MR. Aponte: no, not on

3252
02:00:37,792 --> 02:00:39,792
that analysis.

3253
02:00:43,197 --> 02:00:43,731
>> so in your rebuttal

3254
02:00:43,731 --> 02:00:44,966
testimony on page 13, you

3255
02:00:44,966 --> 02:00:47,966
stated that if polk unit

3256
02:00:56,945 --> 02:00:57,477
one were to return to ijcc

3257
02:00:57,477 --> 02:00:57,912
-- would you still agree

3258
02:00:57,912 --> 02:00:58,513
with that statement?

3259
02:00:58,513 --> 02:00:59,130
>> MR. Aponte: can you

3260
02:00:59,130 --> 02:01:01,413
please point to me?

3261
02:01:04,418 --> 02:01:04,885
>> absolutely.

3262
02:01:04,885 --> 02:01:05,387
This is your rebuttal

3263
02:01:05,387 --> 02:01:07,322
testimony -- apologies,

3264
02:01:07,322 --> 02:01:09,722
that is actually witness

3265
02:01:10,757 --> 02:01:11,158
aldazabal's rebuttal, so

3266
02:01:11,158 --> 02:01:13,558
that is a mistake.

3267
02:01:17,998 --> 02:01:18,432
This is about polk unit

3268
02:01:18,432 --> 02:01:18,967
one and retirement.

3269
02:01:18,967 --> 02:01:19,467
I'm going to ask you this

3270
02:01:19,467 --> 02:01:20,568
question and if you are

3271
02:01:20,568 --> 02:01:22,968
unfamiliar, let me know.

3272
02:01:24,973 --> 02:01:25,473
But it's on witness

3273
02:01:25,473 --> 02:01:27,473
aldazabal's rebuttal on

3274
02:01:29,643 --> 02:01:30,211
page 13 line 20 --

3275
02:01:30,211 --> 02:01:30,778
>> MR. Wahlen: excuse me,

3276
02:01:30,778 --> 02:01:32,647
it sounds like she's about

3277
02:01:32,647 --> 02:01:35,470
to cross examine MR.

3278
02:01:35,716 --> 02:01:35,984
Aponte on MR. Aldazabal's

3279
02:01:35,984 --> 02:01:36,651
testimony.

3280
02:01:36,651 --> 02:01:39,510
>> CHAIRMAN La Rosa: can

3281
02:01:40,520 --> 02:01:40,955
we get clarification on

3282
02:01:40,955 --> 02:01:41,990
where you're going?

3283
02:01:41,990 --> 02:01:43,424
>> absolutely and that was

3284
02:01:43,424 --> 02:01:43,958
my mistake.

3285
02:01:43,958 --> 02:01:47,495
I'm just going to ask the

3286
02:01:47,495 --> 02:01:48,620
witness a question that

3287
02:01:48,620 --> 02:01:48,596
relates to this retirement

3288
02:01:48,596 --> 02:01:49,564
analysis.

3289
02:01:49,564 --> 02:01:51,964
It's just one statement

3290
02:01:52,934 --> 02:01:53,468
that was in witness

3291
02:01:53,468 --> 02:01:55,468
aldazabal's rebuttal, but

3292
02:01:56,304 --> 02:01:59,904
it relates to -- if this

3293
02:02:01,909 --> 02:02:02,410
witness is unfamiliar, MR.

3294
02:02:02,410 --> 02:02:02,610
Aponte can just let me

3295
02:02:02,610 --> 02:02:04,112
know.

3296
02:02:04,112 --> 02:02:04,312
>> CHAIRMAN La Rosa: go

3297
02:02:04,312 --> 02:02:06,312
ahead.

3298
02:02:07,280 --> 02:02:07,749
>> thank you.

3299
02:02:07,749 --> 02:02:08,449
So this is on witness

3300
02:02:08,449 --> 02:02:10,449
aldazabal's testimony on

3301
02:02:13,488 --> 02:02:13,988
page 13 lines 20-22.

3302
02:02:13,988 --> 02:02:17,588
And I can read it aloud

3303
02:02:17,759 --> 02:02:18,259
and you can let me know if

3304
02:02:18,259 --> 02:02:19,327
you're unfamiliar with

3305
02:02:19,327 --> 02:02:19,660
this topic.

3306
02:02:19,660 --> 02:02:20,261
Is that okay?

3307
02:02:20,261 --> 02:02:21,229
>> MR. Aponte: that's

3308
02:02:21,229 --> 02:02:21,662
okay.

3309
02:02:21,662 --> 02:02:23,662
>> thank you.

3310
02:02:23,698 --> 02:02:24,165
So MR. Aldazabal stated if

3311
02:02:24,165 --> 02:02:27,165
polk unit one were to

3312
02:02:32,730 --> 02:02:32,640
return to ijcc operation

3313
02:02:32,640 --> 02:02:33,141
but retire before 2032, it

3314
02:02:33,141 --> 02:02:33,574
would not be subject to

3315
02:02:33,574 --> 02:02:35,574
any greenhouse gas

3316
02:02:36,310 --> 02:02:36,844
emission standards.

3317
02:02:36,844 --> 02:02:37,110
Does that sound right to

3318
02:02:37,110 --> 02:02:37,645
you?

3319
02:02:37,645 --> 02:02:40,645
>> MR. Aponte: I am very

3320
02:02:43,250 --> 02:02:43,684
unfamiliar with that.

3321
02:02:43,684 --> 02:02:43,952
Any greenhouse gas

3322
02:02:43,952 --> 02:02:44,285
standards.

3323
02:02:44,285 --> 02:02:44,585
>> okay.

3324
02:02:44,585 --> 02:02:46,585
That's fine.

3325
02:02:46,754 --> 02:02:49,156
So then I will move on.

3326
02:02:49,156 --> 02:02:51,156
Okay.

3327
02:03:03,771 --> 02:03:04,305
So okay.

3328
02:03:04,305 --> 02:03:04,772
You are familiar with the

3329
02:03:04,772 --> 02:03:05,600
term reserve margin,

3330
02:03:05,600 --> 02:03:05,640
correct?

3331
02:03:05,640 --> 02:03:06,307
>> MR. Aponte: yes, I am.

3332
02:03:06,307 --> 02:03:06,874
>> can you briefly explain

3333
02:03:06,874 --> 02:03:07,375
how reserve margin impacts

3334
02:03:07,375 --> 02:03:09,375
and electric utilities

3335
02:03:10,444 --> 02:03:11,450
generation mix?

3336
02:03:11,450 --> 02:03:13,445
>> MR. Aponte: can you

3337
02:03:16,150 --> 02:03:16,651
repeat that question?

3338
02:03:16,651 --> 02:03:18,651
>> yes, of course.

3339
02:03:20,695 --> 02:03:20,818
Can you please briefly

3340
02:03:20,818 --> 02:03:20,909
explain how utilities

3341
02:03:20,909 --> 02:03:23,309
reserve margin impacts its

3342
02:03:23,891 --> 02:03:24,458
generation mix?

3343
02:03:24,458 --> 02:03:26,458
>> MR. Aponte: well,

3344
02:03:29,831 --> 02:03:30,397
planning reserve margin

3345
02:03:30,397 --> 02:03:30,797
and generation mix are two

3346
02:03:30,797 --> 02:03:31,332
different things.

3347
02:03:31,332 --> 02:03:33,732
We can satisfy reserve

3348
02:03:33,867 --> 02:03:36,267
margin in many different

3349
02:03:36,637 --> 02:03:38,380
ways very different

3350
02:03:38,380 --> 02:03:40,380
generation mixes.

3351
02:03:41,750 --> 02:03:41,409
I'm not sure I'm following

3352
02:03:41,409 --> 02:03:43,409
your question.

3353
02:03:46,981 --> 02:03:47,481
>> okay.

3354
02:03:47,481 --> 02:03:47,715
I think that answer is

3355
02:03:47,715 --> 02:03:48,249
helpful.

3356
02:03:48,249 --> 02:03:50,649
The higher reserve margin

3357
02:03:52,296 --> 02:03:52,522
makes it more difficult to

3358
02:03:52,522 --> 02:03:54,922
retire a generation asset,

3359
02:03:55,220 --> 02:03:55,623
all else equal, right?

3360
02:03:55,623 --> 02:03:56,357
>> MR. Aponte: higher

3361
02:03:56,357 --> 02:03:58,757
reserve margins make it

3362
02:03:59,759 --> 02:03:59,994
more difficult to retire

3363
02:03:59,994 --> 02:04:01,994
margins?

3364
02:04:02,330 --> 02:04:05,330
No, I don't agree with

3365
02:04:07,267 --> 02:04:07,901
that.

3366
02:04:07,901 --> 02:04:08,402
>> generally compared to

3367
02:04:08,402 --> 02:04:10,802
having a lower reserve

3368
02:04:16,677 --> 02:04:17,345
margin, is that right?

3369
02:04:17,345 --> 02:04:17,744
>> MR. Aponte: they don't

3370
02:04:17,744 --> 02:04:20,144
have to be online.

3371
02:04:24,485 --> 02:04:24,985
Every margin is based on

3372
02:04:24,985 --> 02:04:25,318
reserve store capacity.

3373
02:04:25,318 --> 02:04:25,819
>> okay.

3374
02:04:25,819 --> 02:04:28,219
It generally requires a

3375
02:04:28,855 --> 02:04:29,389
higher degree as opposed

3376
02:04:29,389 --> 02:04:31,789
to lower reserve margin,

3377
02:04:32,793 --> 02:04:33,360
right?

3378
02:04:33,360 --> 02:04:35,360
>> MR. Aponte: yes,

3379
02:04:41,402 --> 02:04:42,350
that's right.

3380
02:04:42,350 --> 02:04:42,403
>> when resources can be

3381
02:04:42,403 --> 02:04:42,703
retired without

3382
02:04:42,703 --> 02:04:43,304
replacement?

3383
02:04:43,304 --> 02:04:43,804
>> MR. Aponte: at this

3384
02:04:43,804 --> 02:04:46,804
moment, yes, we are a

3385
02:04:47,241 --> 02:04:47,574
winter need to.

3386
02:04:47,574 --> 02:04:49,574
>> okay.

3387
02:04:54,582 --> 02:04:55,820
Can you please turn to

3388
02:04:55,820 --> 02:04:57,820
florida psc exhibit 120

3389
02:05:06,260 --> 02:05:07,561
page c3 2-1577?

3390
02:05:07,561 --> 02:05:09,830
And we MAY need to zoom in

3391
02:05:09,830 --> 02:05:10,330
if possible.

3392
02:05:10,330 --> 02:05:12,466
I'm just looking at the

3393
02:05:12,466 --> 02:05:14,466
last row.

3394
02:05:16,511 --> 02:05:16,632
In the last row, can you

3395
02:05:16,632 --> 02:05:16,836
see that teco is winter

3396
02:05:16,836 --> 02:05:18,836
reserve margins for

3397
02:05:23,770 --> 02:05:25,770
2024-2027 are 30%, 23%,

3398
02:05:26,247 --> 02:05:27,800
23%, and 22%?

3399
02:05:27,800 --> 02:05:29,800
>> MR. Wahlen: MR.

3400
02:05:30,751 --> 02:05:31,318
CHAIRMAN, I think we have

3401
02:05:31,318 --> 02:05:34,288
been through this ground a

3402
02:05:34,288 --> 02:05:34,755
few times now.

3403
02:05:34,755 --> 02:05:36,755
>> it was asked.

3404
02:05:37,291 --> 02:05:37,725
I was trying to lay down a

3405
02:05:37,725 --> 02:05:38,259
foundation, but if

3406
02:05:38,259 --> 02:05:39,760
everyone is familiar with

3407
02:05:39,760 --> 02:05:43,360
it, I can ask my next

3408
02:05:43,764 --> 02:05:43,964
question.

3409
02:05:43,964 --> 02:05:45,964
Okay.

3410
02:05:48,220 --> 02:05:50,220
Focusing on this 30%

3411
02:05:50,704 --> 02:05:51,238
number for a second, would

3412
02:05:51,238 --> 02:05:51,772
you agree it's unusual to

3413
02:05:51,772 --> 02:05:51,972
have a reserve margin the

3414
02:05:51,972 --> 02:05:53,340
high.

3415
02:05:53,340 --> 02:05:55,340
>> MR. Aponte: no.

3416
02:05:56,377 --> 02:05:56,910
It's not unusual.

3417
02:05:56,910 --> 02:05:59,910
The reason that number is

3418
02:06:00,470 --> 02:06:00,848
that hi, I believe we, for

3419
02:06:00,848 --> 02:06:02,848
reliability purposes,

3420
02:06:04,351 --> 02:06:06,351
purchased some short-term

3421
02:06:06,587 --> 02:06:07,822
dpa's.

3422
02:06:07,822 --> 02:06:10,222
For like I said,

3423
02:06:15,329 --> 02:06:15,696
reliability on the energy

3424
02:06:15,696 --> 02:06:16,163
and fuel supply.

3425
02:06:16,163 --> 02:06:16,664
That's just temporary.

3426
02:06:16,664 --> 02:06:17,464
That's why you see that

3427
02:06:17,464 --> 02:06:19,967
bump up and you stated get

3428
02:06:19,967 --> 02:06:22,836
back down to 23% the next

3429
02:06:22,836 --> 02:06:23,170
year.

3430
02:06:23,170 --> 02:06:25,170
>> okay.

3431
02:06:28,608 --> 02:06:29,143
Teco is operating on an

3432
02:06:29,143 --> 02:06:29,376
assumption of 23% margin,

3433
02:06:29,376 --> 02:06:31,376
correct?

3434
02:06:31,478 --> 02:06:32,120
>> MR. Aponte: 20%.

3435
02:06:32,120 --> 02:06:34,412
>> it has far more

3436
02:06:35,215 --> 02:06:37,615
capacity than that for,

3437
02:06:38,586 --> 02:06:39,220
right?

3438
02:06:39,220 --> 02:06:39,753
>> MR. Wahlen: that has

3439
02:06:39,753 --> 02:06:40,187
been covered two or three

3440
02:06:40,187 --> 02:06:40,788
times, MR. CHAIRMAN.

3441
02:06:40,788 --> 02:06:41,221
>> CHAIRMAN La Rosa: I

3442
02:06:41,221 --> 02:06:43,221
would agree.

3443
02:06:43,224 --> 02:06:44,958
>> okay.

3444
02:06:44,958 --> 02:06:46,260
I will just ask one more

3445
02:06:46,260 --> 02:06:47,594
reserve margin question

3446
02:06:47,594 --> 02:06:48,562
and then I can move on if

3447
02:06:48,562 --> 02:06:50,197
that's fine.

3448
02:06:50,197 --> 02:06:51,364
That I believe hasn't been

3449
02:06:51,364 --> 02:06:53,364
asked.

3450
02:06:55,636 --> 02:06:58,360
So a 30% reserve margin

3451
02:06:59,573 --> 02:07:01,208
compared to say a 50% --

3452
02:07:01,208 --> 02:07:02,409
>> MR. Wahlen: asked and

3453
02:07:02,409 --> 02:07:03,777
answered.

3454
02:07:03,777 --> 02:07:05,379
>> okay.

3455
02:07:05,379 --> 02:07:07,614
I will move on to another

3456
02:07:07,614 --> 02:07:08,748
topic and we are close to

3457
02:07:08,748 --> 02:07:10,250
the end of these

3458
02:07:10,250 --> 02:07:12,250
questions.

3459
02:07:12,419 --> 02:07:15,419
Teco is planning to add

3460
02:07:20,940 --> 02:07:20,527
nearly 500 mw of new solar

3461
02:07:20,527 --> 02:07:21,280
across its service

3462
02:07:21,280 --> 02:07:21,361
territory by the end of

3463
02:07:21,361 --> 02:07:21,829
2026, correct?

3464
02:07:21,829 --> 02:07:22,329
>> MR. Aponte:

3465
02:07:22,329 --> 02:07:24,729
>> you would agree that

3466
02:07:25,332 --> 02:07:25,566
solar has no fuel cost,

3467
02:07:25,566 --> 02:07:25,966
correct?

3468
02:07:25,966 --> 02:07:27,966
>> correct.

3469
02:07:29,603 --> 02:07:30,700
>> you added that this

3470
02:07:30,700 --> 02:07:30,571
would save customers

3471
02:07:30,571 --> 02:07:32,571
nearly $800 million in

3472
02:07:34,942 --> 02:07:35,475
fuel costs over the

3473
02:07:35,475 --> 02:07:35,709
lifetime of the projects,

3474
02:07:35,709 --> 02:07:36,310
correct?

3475
02:07:36,310 --> 02:07:37,244
>> MR. Aponte: correct.

3476
02:07:37,244 --> 02:07:37,711
>> solar plants tend to

3477
02:07:37,711 --> 02:07:39,279
have lower operation

3478
02:07:39,279 --> 02:07:40,647
admittance costs than

3479
02:07:40,647 --> 02:07:42,647
fossil plants, yes?

3480
02:07:43,160 --> 02:07:45,416
>> MR. Aponte: they do.

3481
02:07:45,718 --> 02:07:46,220
>> teco is solar will

3482
02:07:46,220 --> 02:07:48,620
reduce costs and price

3483
02:07:49,723 --> 02:07:49,923
volatility for ratepayers,

3484
02:07:49,923 --> 02:07:50,491
right?

3485
02:07:50,491 --> 02:07:52,491
>> MR. Aponte: yes,

3486
02:07:53,930 --> 02:07:53,694
absolute.

3487
02:07:53,694 --> 02:07:56,940
>> you would agree that

3488
02:07:57,737 --> 02:07:59,199
solar generators conserve

3489
02:07:59,199 --> 02:07:59,600
more water than fossil

3490
02:07:59,600 --> 02:08:00,200
generators, right?

3491
02:08:00,200 --> 02:08:00,501
>> MR. Aponte: yes, I

3492
02:08:00,501 --> 02:08:02,501
would agree.

3493
02:08:05,139 --> 02:08:05,605
>> solar will supply 18%

3494
02:08:05,605 --> 02:08:05,939
of the energy on its

3495
02:08:05,939 --> 02:08:06,606
system, right?

3496
02:08:06,606 --> 02:08:09,600
>> MR. Aponte: subject to

3497
02:08:09,710 --> 02:08:10,440
checks, the year, yes.

3498
02:08:10,440 --> 02:08:12,440
>> okay.

3499
02:08:12,780 --> 02:08:13,247
And this will increase

3500
02:08:13,247 --> 02:08:15,148
teco fuel diversity,

3501
02:08:15,148 --> 02:08:15,749
right?

3502
02:08:15,749 --> 02:08:17,749
>> MR. Aponte: correct.

3503
02:08:18,886 --> 02:08:19,353
>> results will fuel

3504
02:08:19,353 --> 02:08:19,719
diversity from energy

3505
02:08:19,719 --> 02:08:21,255
storage, right?

3506
02:08:21,255 --> 02:08:21,822
>> MR. Aponte: some.

3507
02:08:21,822 --> 02:08:23,323
>> as well as energy

3508
02:08:23,323 --> 02:08:25,323
efficiency and demand

3509
02:08:26,660 --> 02:08:27,261
measures?

3510
02:08:27,261 --> 02:08:29,661
>> MR. Aponte: I'm not

3511
02:08:30,864 --> 02:08:31,197
sure about that when.

3512
02:08:31,197 --> 02:08:31,632
>> okay.

3513
02:08:31,632 --> 02:08:32,990
But a number of the

3514
02:08:32,990 --> 02:08:32,599
sources of energy can

3515
02:08:32,599 --> 02:08:34,999
hedge against high gas

3516
02:08:36,737 --> 02:08:37,171
prices, correct?

3517
02:08:37,171 --> 02:08:39,171
>> absolutely.

3518
02:08:39,339 --> 02:08:41,441
>> teco is planning on

3519
02:08:41,441 --> 02:08:41,775
bringing four new storage

3520
02:08:41,775 --> 02:08:43,775
units, right?

3521
02:08:45,712 --> 02:08:46,380
>> MR. Aponte: yes.

3522
02:08:46,380 --> 02:08:46,847
>> but teco is planning on

3523
02:08:46,847 --> 02:08:49,116
bringing only one new

3524
02:08:49,116 --> 02:08:51,151
storage project, a 70 mw

3525
02:08:51,151 --> 02:08:51,618
project, coming online in

3526
02:08:51,618 --> 02:08:54,180
2028 in the six year

3527
02:08:54,454 --> 02:08:56,454
period from 2027-2033,

3528
02:08:56,723 --> 02:08:57,824
right?

3529
02:08:57,824 --> 02:08:59,824
>> MR. Aponte: that's

3530
02:09:00,293 --> 02:09:01,395
what we are reflecting

3531
02:09:01,395 --> 02:09:03,395
now.

3532
02:09:05,833 --> 02:09:06,399
We have an degraded

3533
02:09:06,399 --> 02:09:08,769
resource plan process that

3534
02:09:08,769 --> 02:09:09,336
we execute every year as

3535
02:09:09,336 --> 02:09:10,837
part of the development of

3536
02:09:10,837 --> 02:09:11,371
the 10 year site plan.

3537
02:09:11,371 --> 02:09:14,371
We are always looking for

3538
02:09:16,577 --> 02:09:17,760
ways to optimize the

3539
02:09:17,760 --> 02:09:17,477
portfolio in ways that

3540
02:09:17,477 --> 02:09:19,477
creates value to

3541
02:09:19,913 --> 02:09:21,913
customers, affordability,

3542
02:09:24,785 --> 02:09:25,285
we look for reliability of

3543
02:09:25,285 --> 02:09:25,719
the system, we look for

3544
02:09:25,719 --> 02:09:26,220
many criteria, many

3545
02:09:26,220 --> 02:09:28,620
objectives, and to the

3546
02:09:28,722 --> 02:09:31,722
extent that we find more

3547
02:09:34,160 --> 02:09:34,727
battery storage is

3548
02:09:34,727 --> 02:09:35,162
cost-effective, it creates

3549
02:09:35,162 --> 02:09:37,162
value for customers.

3550
02:09:37,597 --> 02:09:38,832
It adds reliability and

3551
02:09:38,832 --> 02:09:39,333
resiliency to the system

3552
02:09:39,333 --> 02:09:40,400
we would consider doing

3553
02:09:40,400 --> 02:09:42,400
that.

3554
02:09:45,272 --> 02:09:45,606
It could change.

3555
02:09:45,606 --> 02:09:46,730
>> okay.

3556
02:09:46,730 --> 02:09:47,808
There's no technical

3557
02:09:47,808 --> 02:09:50,808
barrier from teco -- and

3558
02:09:51,477 --> 02:09:52,120
as teco brings on energy

3559
02:09:52,120 --> 02:09:52,813
storage, that storage can

3560
02:09:52,813 --> 02:09:55,213
be paired with teco's

3561
02:09:57,751 --> 02:09:57,985
existing solar units,

3562
02:09:57,985 --> 02:09:58,652
correct?

3563
02:09:58,652 --> 02:09:59,987
>> MR. Aponte: I'm sorry,

3564
02:09:59,987 --> 02:10:01,987
repeat that question.

3565
02:10:03,523 --> 02:10:06,523
>> as -- that storage can

3566
02:10:07,270 --> 02:10:09,427
be compared with solar

3567
02:10:17,236 --> 02:10:17,871
generation, right?

3568
02:10:17,871 --> 02:10:18,405
>> MR. Aponte: it could,

3569
02:10:18,405 --> 02:10:18,905
but we are finding it is

3570
02:10:18,905 --> 02:10:20,905
most cost-effective to

3571
02:10:21,707 --> 02:10:22,275
connect it to the grid and

3572
02:10:22,275 --> 02:10:22,809
optimize charging so it is

3573
02:10:22,809 --> 02:10:25,145
the most economic way of

3574
02:10:25,145 --> 02:10:27,847
charging might not be from

3575
02:10:27,847 --> 02:10:30,247
solar at this point.

3576
02:10:31,170 --> 02:10:31,484
>> do you know how many of

3577
02:10:31,484 --> 02:10:31,985
the storage projects

3578
02:10:31,985 --> 02:10:34,385
coming online or paired

3579
02:10:36,890 --> 02:10:36,356
with existing storage

3580
02:10:36,356 --> 02:10:36,990
projects?

3581
02:10:36,990 --> 02:10:37,457
>> MR. Aponte: the ones

3582
02:10:37,457 --> 02:10:39,857
coming online are all

3583
02:10:44,131 --> 02:10:44,498
connected with the grid.

3584
02:10:44,498 --> 02:10:44,997
>> thanks.

3585
02:10:44,997 --> 02:10:45,565
When storage is paired

3586
02:10:45,565 --> 02:10:47,670
with solar or optimized to

3587
02:10:47,670 --> 02:10:49,467
connect to the grid,

3588
02:10:53,774 --> 02:10:54,341
energy storage can saul's

3589
02:10:54,341 --> 02:10:54,841
power that is -- return it

3590
02:10:54,841 --> 02:10:55,275
to the grid at times of

3591
02:10:55,275 --> 02:10:56,143
peak demand, right?

3592
02:10:56,143 --> 02:10:59,143
>> MR. Aponte: a code if

3593
02:11:05,185 --> 02:11:05,619
that is the lowest-cost

3594
02:11:05,619 --> 02:11:05,952
way to dispatch it.

3595
02:11:05,952 --> 02:11:06,186
>> okay.

3596
02:11:06,186 --> 02:11:06,753
thanks.

3597
02:11:06,753 --> 02:11:07,254
The capacity of new energy

3598
02:11:07,254 --> 02:11:09,254
storage units is 100%,

3599
02:11:09,722 --> 02:11:10,256
right?

3600
02:11:10,256 --> 02:11:12,256
>> MR. Aponte: yes.

3601
02:11:12,358 --> 02:11:14,758
For the proposed projects,

3602
02:11:15,729 --> 02:11:16,329
it is.

3603
02:11:16,329 --> 02:11:16,897
>> this means they are

3604
02:11:16,897 --> 02:11:19,297
assumed to provide 100% of

3605
02:11:21,700 --> 02:11:22,269
capacity at times of peak

3606
02:11:22,269 --> 02:11:22,469
demand on teco the system,

3607
02:11:22,469 --> 02:11:24,469
right?

3608
02:11:25,839 --> 02:11:26,173
>> MR. Aponte: yes.

3609
02:11:26,173 --> 02:11:28,173
>> okay.

3610
02:11:31,478 --> 02:11:32,110
So if teco brings say more

3611
02:11:32,110 --> 02:11:35,110
than one storage unit in

3612
02:11:36,549 --> 02:11:37,500
the period from 2027-2023,

3613
02:11:37,500 --> 02:11:37,550
would you predict that

3614
02:11:37,550 --> 02:11:37,984
storage unit would also

3615
02:11:37,984 --> 02:11:39,984
have a 100% storage

3616
02:11:41,488 --> 02:11:43,488
capacity credit?

3617
02:11:44,324 --> 02:11:44,891
>> MR. Aponte: we need to

3618
02:11:44,891 --> 02:11:47,127
be studied, but I can tell

3619
02:11:47,127 --> 02:11:47,760
you the capacity of

3620
02:11:47,760 --> 02:11:47,961
storage at some point

3621
02:11:47,961 --> 02:11:49,961
, we

3622
02:11:54,334 --> 02:11:54,867
are not there yet.

3623
02:11:54,867 --> 02:11:55,368
It will start to decline

3624
02:11:55,368 --> 02:11:55,835
also, not as drastic as

3625
02:11:55,835 --> 02:11:56,680
earlier, but it will

3626
02:11:56,680 --> 02:11:58,680
decline.

3627
02:11:58,204 --> 02:12:00,204
Effective load carrying

3628
02:12:01,641 --> 02:12:01,974
incapability.

3629
02:12:01,974 --> 02:12:03,410
>> okay.

3630
02:12:03,410 --> 02:12:05,810
Teco measures credits for

3631
02:12:09,883 --> 02:12:10,416
solar at tons of peak load

3632
02:12:10,416 --> 02:12:10,917
as ranging from about 56%

3633
02:12:10,917 --> 02:12:12,718
in the summer to lower

3634
02:12:12,718 --> 02:12:14,920
around maybe one or lower

3635
02:12:14,920 --> 02:12:17,920
percent in the winter, is

3636
02:12:21,428 --> 02:12:22,280
that right?

3637
02:12:22,280 --> 02:12:23,863
>> MR. Aponte: that's

3638
02:12:23,863 --> 02:12:24,497
right.

3639
02:12:24,497 --> 02:12:25,798
>> but the energy storage

3640
02:12:25,798 --> 02:12:27,867
would be higher than this,

3641
02:12:27,867 --> 02:12:29,269
right?

3642
02:12:29,269 --> 02:12:32,370
>> MR. Aponte: I think it

3643
02:12:32,370 --> 02:12:35,370
will still be the same.

3644
02:12:35,408 --> 02:12:37,808
You just have batteries.

3645
02:12:37,844 --> 02:12:40,844
Also on the grid as

3646
02:12:44,117 --> 02:12:44,450
another asset.

3647
02:12:44,450 --> 02:12:45,180
>> okay.

3648
02:12:45,180 --> 02:12:47,120
But if, for example, there

3649
02:12:47,120 --> 02:12:50,120
were a storage unit that

3650
02:12:50,657 --> 02:12:51,190
repaired with a solar

3651
02:12:51,190 --> 02:12:53,590
unit, the capacity would

3652
02:12:53,827 --> 02:12:54,461
be higher, right?

3653
02:12:54,461 --> 02:12:55,228
>> MR. Aponte: again, it

3654
02:12:55,228 --> 02:12:57,228
depends.

3655
02:12:57,364 --> 02:12:58,640
If the portfolio was

3656
02:12:58,640 --> 02:13:01,640
asking for a solar plus

3657
02:13:01,968 --> 02:13:04,368
storage asset as one,

3658
02:13:05,838 --> 02:13:06,406
together it would create a

3659
02:13:06,406 --> 02:13:07,574
higher capacity value, but

3660
02:13:07,574 --> 02:13:09,709
those are not the type of

3661
02:13:09,709 --> 02:13:12,109
projects we are looking

3662
02:13:12,212 --> 02:13:12,545
for at this time.

3663
02:13:12,545 --> 02:13:13,413
>> okay.

3664
02:13:13,413 --> 02:13:15,413
Thanks.

3665
02:13:17,916 --> 02:13:18,451
Can you please look at

3666
02:13:18,451 --> 02:13:20,851
your direct testimony on

3667
02:13:28,694 --> 02:13:30,694
page 31?

3668
02:13:32,365 --> 02:13:35,965
And just let me know when

3669
02:13:43,675 --> 02:13:44,310
you're ready.

3670
02:13:44,310 --> 02:13:44,744
>> MR. Aponte: I'm there.

3671
02:13:44,744 --> 02:13:45,278
>> thank you.

3672
02:13:45,278 --> 02:13:45,812
Can you please read lines

3673
02:13:45,812 --> 02:13:46,278
1 through I believe it's

3674
02:13:46,278 --> 02:13:47,380
12 starting at public

3675
02:13:47,380 --> 02:13:49,380
policy considerations and

3676
02:13:57,624 --> 02:13:58,224
ending at possibility?

3677
02:13:58,224 --> 02:13:58,658
>> MR. Aponte: can you

3678
02:13:58,658 --> 02:13:58,892
point to me the row

3679
02:13:58,892 --> 02:13:59,225
number?

3680
02:13:59,225 --> 02:13:59,659
>> yes.

3681
02:13:59,659 --> 02:14:02,590
It begins on line 1

3682
02:14:03,696 --> 02:14:04,264
actually on that page.

3683
02:14:04,264 --> 02:14:04,931
>> MR. Aponte: okay.

3684
02:14:04,931 --> 02:14:07,500
>> I believe it is on page

3685
02:14:07,500 --> 02:14:07,834
31 and it begins with

3686
02:14:07,834 --> 02:14:09,168
public policy

3687
02:14:09,168 --> 02:14:11,168
considerations.

3688
02:14:14,174 --> 02:14:14,707
Actually, looks like it

3689
02:14:14,707 --> 02:14:15,341
does start on page 3 -- I

3690
02:14:15,341 --> 02:14:17,741
mean line 3. And then

3691
02:14:23,816 --> 02:14:24,117
extending to rule out that

3692
02:14:24,117 --> 02:14:24,651
possibility.

3693
02:14:24,651 --> 02:14:26,651
Spirit yes, public-policy

3694
02:14:29,122 --> 02:14:29,656
consideration expectations

3695
02:14:29,656 --> 02:14:30,123
in the united states and

3696
02:14:30,123 --> 02:14:30,623
around the world are

3697
02:14:30,623 --> 02:14:32,623
trending against carbon

3698
02:14:32,759 --> 02:14:33,226
emissions and in favor of

3699
02:14:33,226 --> 02:14:35,280
renewable energy like

3700
02:14:35,280 --> 02:14:36,796
solar innovation.

3701
02:14:36,796 --> 02:14:39,796
It is difficult to predict

3702
02:14:43,635 --> 02:14:44,871
when a carbon tax or fuel

3703
02:14:44,871 --> 02:14:45,237
will be imposed.

3704
02:14:45,237 --> 02:14:45,772
>> thanks.

3705
02:14:45,772 --> 02:14:46,306
You would agree that it's

3706
02:14:46,306 --> 02:14:46,873
possible new environment

3707
02:14:46,873 --> 02:14:49,273
or regulation could impose

3708
02:14:50,676 --> 02:14:52,676
limits on carbon

3709
02:14:58,818 --> 02:14:59,352
emissions, right?

3710
02:14:59,352 --> 02:14:59,619
>> MR. Aponte: is

3711
02:14:59,619 --> 02:15:00,253
possible.

3712
02:15:00,253 --> 02:15:00,820
>> emissions from carbon

3713
02:15:00,820 --> 02:15:01,200
are more intense than gas,

3714
02:15:01,200 --> 02:15:01,554
right?

3715
02:15:01,554 --> 02:15:02,121
>> MR. Aponte: yes.

3716
02:15:02,121 --> 02:15:02,589
>> gas is more carbon

3717
02:15:02,589 --> 02:15:02,789
intensive them solar,

3718
02:15:02,789 --> 02:15:04,789
right?

3719
02:15:04,791 --> 02:15:06,791
>> MR. Aponte: yes.

3720
02:15:07,927 --> 02:15:08,494
>> if -- deciding on its

3721
02:15:08,494 --> 02:15:10,894
generation mix, this would

3722
02:15:12,832 --> 02:15:13,366
make fossil fuel plants

3723
02:15:13,366 --> 02:15:15,435
more extensive than they

3724
02:15:15,435 --> 02:15:15,968
otherwise would be, right?

3725
02:15:15,968 --> 02:15:17,968
>> MR. Wahlen: MR.

3726
02:15:18,171 --> 02:15:21,171
CHAIRMAN, I think we have

3727
02:15:22,642 --> 02:15:23,209
been very clear that we

3728
02:15:23,209 --> 02:15:23,543
don't consider the cost of

3729
02:15:23,543 --> 02:15:24,611
carbon in our

3730
02:15:24,611 --> 02:15:26,611
cost-effectiveness and we

3731
02:15:34,554 --> 02:15:34,887
or maybe on the second lap

3732
02:15:34,887 --> 02:15:35,521
of this topic.

3733
02:15:35,521 --> 02:15:36,220
>> CHAIRMAN La Rosa: it

3734
02:15:36,220 --> 02:15:36,222
is certainly a similar

3735
02:15:36,222 --> 02:15:36,555
topic.

3736
02:15:36,555 --> 02:15:36,990
Let's do this.

3737
02:15:36,990 --> 02:15:37,523
It is 10:20 almost.

3738
02:15:37,523 --> 02:15:38,910
Let's take a quick break

3739
02:15:38,910 --> 02:15:38,524
for 10 minutes and then we

3740
02:15:38,524 --> 02:15:38,825
will jump back into

3741
02:15:38,825 --> 02:15:40,627
questioning.

3742
02:15:40,627 --> 02:15:42,895
>> actually, I have two

3743
02:15:42,895 --> 02:15:43,463
more questions.

3744
02:15:43,463 --> 02:15:43,896
>> CHAIRMAN La Rosa:

3745
02:15:43,896 --> 02:15:46,296
let's go with those.

3746
02:15:46,598 --> 02:15:48,701
>> is it fine if I just

3747
02:15:48,701 --> 02:15:49,335
re-ask that question?

3748
02:15:49,335 --> 02:15:51,735
>> CHAIRMAN La Rosa: is

3749
02:15:54,606 --> 02:15:54,941
it a question you just

3750
02:15:54,941 --> 02:15:55,308
asked before?

3751
02:15:55,308 --> 02:15:55,941
>> it is.

3752
02:15:55,941 --> 02:15:58,341
>> CHAIRMAN La Rosa: we

3753
02:15:59,990 --> 02:16:00,127
have talked about that

3754
02:16:00,127 --> 02:16:00,232
subject.

3755
02:16:00,232 --> 02:16:00,352
I think the question was

3756
02:16:00,352 --> 02:16:00,452
more related to policy.

3757
02:16:00,452 --> 02:16:02,852
If there's a direct

3758
02:16:09,188 --> 02:16:09,522
question in there, yes, I

3759
02:16:09,522 --> 02:16:10,230
will allow it.

3760
02:16:10,230 --> 02:16:10,556
I don't want to keep on

3761
02:16:10,556 --> 02:16:10,790
skirting around the same

3762
02:16:10,790 --> 02:16:11,124
subject.

3763
02:16:11,124 --> 02:16:11,524
>> okay.

3764
02:16:11,524 --> 02:16:11,991
That makes sense.

3765
02:16:11,991 --> 02:16:12,525
I will ask this last

3766
02:16:12,525 --> 02:16:13,250
question and just make it

3767
02:16:13,250 --> 02:16:15,294
one question, if that's

3768
02:16:15,294 --> 02:16:15,828
okay.

3769
02:16:15,828 --> 02:16:16,362
If teco were to consider

3770
02:16:16,362 --> 02:16:18,762
avoiding carbon cost and

3771
02:16:23,769 --> 02:16:24,237
deciding on its generation

3772
02:16:24,237 --> 02:16:24,671
mix, this would make

3773
02:16:24,671 --> 02:16:25,204
fossil fuel plants

3774
02:16:25,204 --> 02:16:25,738
relatively more expensive

3775
02:16:25,738 --> 02:16:26,205
and renewables relatively

3776
02:16:26,205 --> 02:16:26,539
more cost-effective,

3777
02:16:26,539 --> 02:16:27,240
right?

3778
02:16:27,240 --> 02:16:27,673
>> MR. Aponte: sorry, you

3779
02:16:27,673 --> 02:16:28,374
said that very fast.

3780
02:16:28,374 --> 02:16:30,374
>> I know.

3781
02:16:32,311 --> 02:16:32,779
Apologies.

3782
02:16:32,779 --> 02:16:33,120
I will say that more

3783
02:16:33,120 --> 02:16:33,846
slowly.

3784
02:16:33,846 --> 02:16:36,846
If teco were to consider

3785
02:16:42,255 --> 02:16:42,822
avoiding carbon cost and

3786
02:16:42,822 --> 02:16:43,289
deciding on its generation

3787
02:16:43,289 --> 02:16:43,723
mix, that would make

3788
02:16:43,723 --> 02:16:44,257
fossil fuel plants

3789
02:16:44,257 --> 02:16:44,791
relatively more expensive

3790
02:16:44,791 --> 02:16:45,258
and renewables relatively

3791
02:16:45,258 --> 02:16:47,258
more cost-effective,

3792
02:16:48,194 --> 02:16:50,194
right?

3793
02:16:51,998 --> 02:16:52,365
>> MR. Aponte: will make

3794
02:16:52,365 --> 02:16:54,365
renewables more

3795
02:16:56,502 --> 02:16:56,936
cost-effective, yes?

3796
02:16:56,936 --> 02:16:57,403
>> thank you.

3797
02:16:57,403 --> 02:16:57,970
No further questions.

3798
02:16:57,970 --> 02:16:58,236
>> CHAIRMAN La Rosa:

3799
02:16:58,236 --> 02:16:59,772
thank you.

3800
02:16:59,772 --> 02:17:02,772
Let's go ahead and jump

3801
02:17:03,420 --> 02:17:03,576
into a 10 minute break.

3802
02:17:03,576 --> 02:17:04,610
We will reconvene here at

3803
02:17:04,610 --> 02:17:06,610
10:30.

3804
02:17:21,560 --> 02:17:23,560
Thank you.

3805
02:18:43,750 --> 02:18:45,750
[Break]

3806
02:30:10,610 --> 02:30:10,261
>> CHAIRMAN La Rosa: all

3807
02:30:10,261 --> 02:30:11,195
right.

3808
02:30:11,195 --> 02:30:12,663
I think we can go ahead

3809
02:30:12,663 --> 02:30:16,263
and jump back in our seats

3810
02:30:20,605 --> 02:30:22,605
and get rolling.

3811
02:30:23,908 --> 02:30:24,442
So where we left off was

3812
02:30:24,442 --> 02:30:26,842
sierra club just finished

3813
02:30:27,311 --> 02:30:29,711
up with questions for

3814
02:30:30,581 --> 02:30:31,480
witness aponte.

3815
02:30:31,480 --> 02:30:34,480
I will go to florida

3816
02:30:37,210 --> 02:30:37,522
retail federation.

3817
02:30:37,522 --> 02:30:38,423
>> thank you, MR.

3818
02:30:38,423 --> 02:30:40,423
CHAIRMAN.

3819
02:30:40,458 --> 02:30:44,580
I don't have any cross for

3820
02:30:45,620 --> 02:30:45,630
MR. Aponte.

3821
02:30:45,630 --> 02:30:45,897
>> CHAIRMAN La Rosa:

3822
02:30:45,897 --> 02:30:46,130
thank you.

3823
02:30:46,130 --> 02:30:47,665
Walmart?

3824
02:30:47,665 --> 02:30:50,665
>> I don't have any cross.

3825
02:30:53,537 --> 02:30:54,105
Thank you.

3826
02:30:54,105 --> 02:30:54,372
>> CHAIRMAN La Rosa:

3827
02:30:54,372 --> 02:30:54,572
thank you.

3828
02:30:54,572 --> 02:30:55,206
Staff?

3829
02:30:55,206 --> 02:30:55,773
>> Staff: staff does not

3830
02:30:55,773 --> 02:30:56,700
have any questions for MR.

3831
02:30:56,700 --> 02:30:56,274
Aponte.

3832
02:30:56,274 --> 02:30:56,840
Thank you.

3833
02:30:56,840 --> 02:30:58,840
>> CHAIRMAN La Rosa:

3834
02:31:00,244 --> 02:31:00,812
seeing no questions, teco,

3835
02:31:00,812 --> 02:31:01,770
I threw it back to you for

3836
02:31:01,770 --> 02:31:03,770
redirect.

3837
02:31:05,817 --> 02:31:06,350
>> MR. Wahlen: thank you.

3838
02:31:06,350 --> 02:31:09,350
MR. Aponte, you are asked

3839
02:31:10,788 --> 02:31:11,355
about the solar project

3840
02:31:11,355 --> 02:31:11,789
and you indicated with the

3841
02:31:11,789 --> 02:31:12,890
increase in the tax

3842
02:31:12,890 --> 02:31:14,890
credit, the

3843
02:31:14,925 --> 02:31:15,159
cost-effectiveness was

3844
02:31:15,159 --> 02:31:17,159
better.

3845
02:31:20,264 --> 02:31:20,798
Do you are member that?

3846
02:31:20,798 --> 02:31:22,798
>> MR. Aponte: yes.

3847
02:31:23,768 --> 02:31:24,302
>> I was going to object

3848
02:31:24,302 --> 02:31:27,302
on asked and answered for

3849
02:31:30,207 --> 02:31:32,109
my friend, MR. Wahlen.

3850
02:31:32,109 --> 02:31:33,978
>> CHAIRMAN La Rosa: I'm

3851
02:31:33,978 --> 02:31:36,378
sure he appreciates that.

3852
02:31:39,650 --> 02:31:40,251
Go ahead, continue.

3853
02:31:40,251 --> 02:31:40,717
>> MR. Wahlen: if you

3854
02:31:40,717 --> 02:31:43,117
apply the higher tax

3855
02:31:44,288 --> 02:31:44,855
credits all the projects

3856
02:31:44,855 --> 02:31:45,289
you are imposing, with the

3857
02:31:45,289 --> 02:31:47,289
cost-effectiveness

3858
02:31:52,196 --> 02:31:52,763
improve?

3859
02:31:52,763 --> 02:31:53,640
>> MR. Aponte: yes,

3860
02:31:53,640 --> 02:31:53,698
absolutely.

3861
02:31:53,698 --> 02:31:54,131
>> MR. Wahlen: thank you.

3862
02:31:54,131 --> 02:31:54,665
You are asked some

3863
02:31:54,665 --> 02:31:55,199
questions about the south

3864
02:31:55,199 --> 02:31:55,699
tampa resiliency project

3865
02:31:55,699 --> 02:31:57,201
by the office of public

3866
02:31:57,201 --> 02:32:00,201
counsel and they asked you

3867
02:32:01,372 --> 02:32:01,906
the question, well, if the

3868
02:32:01,906 --> 02:32:02,439
government had paid money

3869
02:32:02,439 --> 02:32:04,839
toward the project, would

3870
02:32:08,780 --> 02:32:08,512
have improved?

3871
02:32:08,512 --> 02:32:09,180
Do your member that?

3872
02:32:09,180 --> 02:32:11,482
>> MR. Aponte: I remember

3873
02:32:11,482 --> 02:32:12,149
that.

3874
02:32:12,149 --> 02:32:13,183
>> MR. Wahlen: company is

3875
02:32:13,183 --> 02:32:13,651
getting the land from that

3876
02:32:13,651 --> 02:32:15,452
project for no cost,

3877
02:32:15,452 --> 02:32:17,452
correct?

3878
02:32:18,990 --> 02:32:19,223
>> MR. Aponte: that's

3879
02:32:19,223 --> 02:32:19,824
correct.

3880
02:32:19,824 --> 02:32:20,391
>> MR. Wahlen: if the

3881
02:32:20,391 --> 02:32:20,858
company had to buy land or

3882
02:32:20,858 --> 02:32:22,526
lease land from that

3883
02:32:22,526 --> 02:32:24,862
project, it would hurt the

3884
02:32:24,862 --> 02:32:25,162
cost-effectiveness,

3885
02:32:25,162 --> 02:32:27,162
wouldn't it?

3886
02:32:29,166 --> 02:32:29,667
>> MR. Aponte: yes, it

3887
02:32:29,667 --> 02:32:32,670
would be very expensive

3888
02:32:34,171 --> 02:32:34,805
almost impossible to get.

3889
02:32:34,805 --> 02:32:35,306
>> MR. Wahlen: the fact

3890
02:32:35,306 --> 02:32:35,573
that there's free land

3891
02:32:35,573 --> 02:32:36,540
helps the

3892
02:32:36,540 --> 02:32:38,540
cost-effectiveness of the

3893
02:32:38,876 --> 02:32:39,543
project, correct?

3894
02:32:39,543 --> 02:32:42,543
>> MR. Aponte: it helps a

3895
02:32:44,615 --> 02:32:45,182
lot.

3896
02:32:45,182 --> 02:32:45,449
>> MR. Wahlen: okay.

3897
02:32:45,449 --> 02:32:45,983
Thank you.

3898
02:32:45,983 --> 02:32:47,510
You are asked a question

3899
02:32:47,510 --> 02:32:47,285
about the winter reserve

3900
02:32:47,285 --> 02:32:47,684
margin.

3901
02:32:47,684 --> 02:32:49,520
When the company

3902
02:32:49,520 --> 02:32:50,540
calculates its winter

3903
02:32:50,540 --> 02:32:52,454
reserve margin, does the

3904
02:32:59,630 --> 02:33:00,131
company assume a

3905
02:33:00,131 --> 02:33:00,664
particular temperature?

3906
02:33:00,664 --> 02:33:01,310
>> MR. Aponte: yes.

3907
02:33:01,310 --> 02:33:01,232
That's correct.

3908
02:33:01,232 --> 02:33:01,865
We do.

3909
02:33:01,865 --> 02:33:04,101
>> MR. Wahlen: and what

3910
02:33:04,101 --> 02:33:04,669
is that temperature?

3911
02:33:04,669 --> 02:33:07,690
>> MR. Aponte: it is

3912
02:33:10,207 --> 02:33:10,841
30b0f.

3913
02:33:10,841 --> 02:33:11,342
>> MR. Wahlen: does the

3914
02:33:11,342 --> 02:33:11,609
company do temperature

3915
02:33:11,609 --> 02:33:12,276
analysis?

3916
02:33:12,276 --> 02:33:12,910
>> MR. Aponte: yes.

3917
02:33:12,910 --> 02:33:15,310
>> MR. Wahlen: could we

3918
02:33:15,479 --> 02:33:18,479
call up master document f

3919
02:33:20,785 --> 02:33:22,785
2.1-74, please?

3920
02:33:34,598 --> 02:33:35,833
Part of cel 226.

3921
02:33:35,833 --> 02:33:38,833
Is that the reserve margin

3922
02:33:45,109 --> 02:33:45,609
that you were sensitivity

3923
02:33:45,609 --> 02:33:45,776
that you were referring

3924
02:33:45,776 --> 02:33:46,377
to?

3925
02:33:46,377 --> 02:33:46,543
>> MR. Aponte: yes, it

3926
02:33:46,543 --> 02:33:47,111
is.

3927
02:33:47,111 --> 02:33:47,578
>> MR. Wahlen: what

3928
02:33:47,578 --> 02:33:49,578
temperature does this

3929
02:33:54,852 --> 02:33:55,190
assume?

3930
02:33:55,190 --> 02:33:55,486
The

3931
02:33:55,486 --> 02:33:56,860
>> MR. Aponte: 29b0.

3932
02:33:56,860 --> 02:33:56,587
>> MR. Wahlen: if the

3933
02:33:56,587 --> 02:33:57,121
temperature is 29b0 as

3934
02:33:57,121 --> 02:33:57,655
opposed to 31, what does

3935
02:33:57,655 --> 02:34:00,550
the winter reserve margin

3936
02:34:02,293 --> 02:34:02,926
look like in 2025?

3937
02:34:02,926 --> 02:34:03,427
>> MR. Aponte: well, it

3938
02:34:03,427 --> 02:34:04,280
drops significantly to

3939
02:34:04,280 --> 02:34:04,662
17%.

3940
02:34:04,662 --> 02:34:07,620
>> MR. Aponte: and that

3941
02:34:11,234 --> 02:34:11,802
is below the 20%, right?

3942
02:34:11,802 --> 02:34:12,200
>> MR. Aponte: it is

3943
02:34:12,200 --> 02:34:12,603
below.

3944
02:34:12,603 --> 02:34:14,838
>> MR. Wahlen: do you

3945
02:34:14,838 --> 02:34:15,339
recall whether replacing

3946
02:34:15,339 --> 02:34:17,739
the company solid fuel

3947
02:34:18,776 --> 02:34:19,310
assets -- you were asked

3948
02:34:19,310 --> 02:34:20,878
about whether the company

3949
02:34:20,878 --> 02:34:21,378
did an analysis about

3950
02:34:21,378 --> 02:34:23,378
replacing the company's

3951
02:34:24,514 --> 02:34:25,490
solid fuel assets with

3952
02:34:25,490 --> 02:34:27,449
solar and battery storage?

3953
02:34:27,751 --> 02:34:27,985
>> MR. Aponte: yes, I

3954
02:34:27,985 --> 02:34:28,619
recall.

3955
02:34:28,619 --> 02:34:31,190
>> MR. Wahlen: would it

3956
02:34:35,659 --> 02:34:36,193
be possible to

3957
02:34:36,193 --> 02:34:36,727
cost-effectively replace

3958
02:34:36,727 --> 02:34:39,127
the company's solid fuel

3959
02:34:39,296 --> 02:34:39,796
capacity generating

3960
02:34:39,796 --> 02:34:40,164
capacity with solar and

3961
02:34:40,164 --> 02:34:41,232
energy storage?

3962
02:34:41,232 --> 02:34:43,232
>> MR. Aponte: possible.

3963
02:34:52,176 --> 02:34:52,610
I mean, it would be

3964
02:34:52,610 --> 02:34:53,243
extremely expensive.

3965
02:34:53,243 --> 02:34:53,643
>> MR. Wahlen: would it

3966
02:34:53,643 --> 02:34:55,445
be cost-effective?

3967
02:34:55,445 --> 02:34:57,845
>> MR. Wahlen: solid fuel

3968
02:34:58,181 --> 02:35:00,581
units have the capability

3969
02:35:02,219 --> 02:35:03,353
of running 24/7

3970
02:35:03,353 --> 02:35:03,553
around-the-clock for

3971
02:35:03,553 --> 02:35:05,553
weeks.

3972
02:35:07,958 --> 02:35:09,392
In the event that fuel is

3973
02:35:09,392 --> 02:35:12,392
economic fuel or in the

3974
02:35:14,297 --> 02:35:14,798
event we have a disruption

3975
02:35:14,798 --> 02:35:17,198
with natural gas, those

3976
02:35:17,901 --> 02:35:18,268
units can run for extended

3977
02:35:18,268 --> 02:35:19,436
amounts of time.

3978
02:35:19,436 --> 02:35:22,436
To replace them with solar

3979
02:35:22,806 --> 02:35:25,206
and battery storage would

3980
02:35:27,744 --> 02:35:28,112
require a lot of solar and

3981
02:35:28,112 --> 02:35:28,612
battery storage.

3982
02:35:28,612 --> 02:35:31,120
Doing some mental math

3983
02:35:32,950 --> 02:35:33,316
here, it's going to not be

3984
02:35:33,316 --> 02:35:33,784
cost-effective.

3985
02:35:33,784 --> 02:35:36,687
It's going to be very

3986
02:35:36,687 --> 02:35:37,254
expensive.

3987
02:35:37,254 --> 02:35:39,254
>> MR. Wahlen: okay.

3988
02:35:41,291 --> 02:35:41,859
Thank you.

3989
02:35:41,859 --> 02:35:42,393
MR. Bradley marshall asked

3990
02:35:42,393 --> 02:35:44,793
you about your retirement

3991
02:35:51,301 --> 02:35:51,768
analysis for polk one.

3992
02:35:51,768 --> 02:35:52,336
Do you remember that?

3993
02:35:52,336 --> 02:35:53,300
>> MR. Aponte: I do.

3994
02:35:53,300 --> 02:35:53,504
>> MR. Wahlen: did you do

3995
02:35:53,504 --> 02:35:54,710
an analysis that showed

3996
02:35:54,710 --> 02:35:54,571
the compared retirement of

3997
02:35:54,571 --> 02:35:57,571
polk one to the simple

3998
02:35:59,760 --> 02:35:59,243
cycle conversion of polk

3999
02:35:59,243 --> 02:36:01,770
one?

4000
02:36:01,770 --> 02:36:03,770
>> MR. Aponte: yes.

4001
02:36:04,140 --> 02:36:04,348
>> MR. Wahlen: and which

4002
02:36:04,348 --> 02:36:06,348
was the most

4003
02:36:06,716 --> 02:36:07,384
cost-effective?

4004
02:36:07,384 --> 02:36:09,784
>> MR. Aponte: the status

4005
02:36:11,955 --> 02:36:12,355
quo option was the most

4006
02:36:12,355 --> 02:36:14,190
expensive option.

4007
02:36:14,190 --> 02:36:14,591
Retiring it in 2028 was a

4008
02:36:14,591 --> 02:36:16,326
slight benefit to

4009
02:36:16,326 --> 02:36:18,326
customers, but converting

4010
02:36:21,397 --> 02:36:21,732
the unit to simple cycle

4011
02:36:21,732 --> 02:36:23,732
was the most

4012
02:36:28,372 --> 02:36:28,939
cost-effective option.

4013
02:36:28,939 --> 02:36:29,373
>> MR. Wahlen: okay.

4014
02:36:29,373 --> 02:36:29,639
One last series of

4015
02:36:29,639 --> 02:36:31,639
questions.

4016
02:36:31,775 --> 02:36:32,275
There was talk about

4017
02:36:32,275 --> 02:36:34,675
reserve margin and its

4018
02:36:37,281 --> 02:36:37,548
role in the company's

4019
02:36:37,548 --> 02:36:38,810
planning.

4020
02:36:38,810 --> 02:36:40,810
Any generation additions

4021
02:36:40,250 --> 02:36:40,784
you are talking about

4022
02:36:40,784 --> 02:36:43,184
being proposed solely to

4023
02:36:43,887 --> 02:36:45,887
meet reserve margin

4024
02:36:48,258 --> 02:36:50,258
requirements?

4025
02:36:51,194 --> 02:36:51,728
>> MR. Aponte: well, as I

4026
02:36:51,728 --> 02:36:54,128
said earlier, the reserve

4027
02:36:56,433 --> 02:36:56,700
minimum is a minimum 20%

4028
02:36:56,700 --> 02:36:57,467
criteria.

4029
02:36:57,467 --> 02:37:00,971
To the extent we can add

4030
02:37:00,971 --> 02:37:01,405
assets that enhance value

4031
02:37:01,405 --> 02:37:02,840
to the customer or

4032
02:37:02,840 --> 02:37:03,600
affordability

4033
02:37:03,600 --> 02:37:05,600
, fuel

4034
02:37:06,743 --> 02:37:09,143
savings to the customer,

4035
02:37:10,147 --> 02:37:12,547
fuel price mitigation, we

4036
02:37:12,983 --> 02:37:13,516
would be comfortable with

4037
02:37:13,516 --> 02:37:15,916
being slightly above the

4038
02:37:16,453 --> 02:37:18,689
20% because of the added

4039
02:37:18,689 --> 02:37:19,220
benefit that it brings to

4040
02:37:19,220 --> 02:37:21,220
the customer.

4041
02:37:23,260 --> 02:37:23,827
So not all the proposed

4042
02:37:23,827 --> 02:37:26,227
additions are strictly due

4043
02:37:27,970 --> 02:37:27,631
to reserve margin

4044
02:37:27,631 --> 02:37:29,631
requirement contribution.

4045
02:37:34,571 --> 02:37:35,400
Many of them are just

4046
02:37:35,400 --> 02:37:35,271
additional value to

4047
02:37:35,271 --> 02:37:35,739
customer.

4048
02:37:35,739 --> 02:37:36,206
I mentioned the $1.2

4049
02:37:36,206 --> 02:37:37,841
billion of fuel cost

4050
02:37:37,841 --> 02:37:38,108
benefit over the

4051
02:37:38,108 --> 02:37:39,977
portfolio.

4052
02:37:39,977 --> 02:37:42,977
Part of that benefit comes

4053
02:37:45,849 --> 02:37:46,315
from an asset that MAY not

4054
02:37:46,315 --> 02:37:46,750
contribute to reserve

4055
02:37:46,750 --> 02:37:47,251
margin, but it's of

4056
02:37:47,251 --> 02:37:49,651
economic benefit to the

4057
02:37:52,623 --> 02:37:53,257
customer to do so.

4058
02:37:53,257 --> 02:37:54,424
>> MR. Wahlen: thank you

4059
02:37:54,424 --> 02:37:54,924
very much.

4060
02:37:54,924 --> 02:37:55,492
Those are my questions.

4061
02:37:55,492 --> 02:37:55,759
>> CHAIRMAN La Rosa:

4062
02:37:55,759 --> 02:37:56,930
thank you.

4063
02:37:56,930 --> 02:37:57,661
Now, let's --

4064
02:37:57,661 --> 02:37:59,661
>> commissioner?

4065
02:38:01,631 --> 02:38:02,165
This is patty christensen.

4066
02:38:02,165 --> 02:38:02,633
-- one has to question in

4067
02:38:02,633 --> 02:38:04,633
redirect regarding a

4068
02:38:06,136 --> 02:38:06,703
comment I made during my

4069
02:38:06,703 --> 02:38:09,439
cross, but he went further

4070
02:38:09,439 --> 02:38:09,907
afield, I think, of the

4071
02:38:09,907 --> 02:38:11,308
topic that I covered.

4072
02:38:11,308 --> 02:38:13,276
He asked about the use of

4073
02:38:13,276 --> 02:38:16,276
the land for the south

4074
02:38:17,347 --> 02:38:17,914
tampa resiliency project,

4075
02:38:17,914 --> 02:38:19,216
but I think there needs to

4076
02:38:19,216 --> 02:38:19,749
be some additional

4077
02:38:19,749 --> 02:38:22,149
information that needs to

4078
02:38:23,520 --> 02:38:24,540
be good out in cross and I

4079
02:38:24,540 --> 02:38:25,880
have just a few follow-up

4080
02:38:25,880 --> 02:38:27,880
questions.

4081
02:38:29,526 --> 02:38:30,270
>> CHAIRMAN La Rosa: let

4082
02:38:30,270 --> 02:38:30,227
me go to my advisors on

4083
02:38:30,227 --> 02:38:30,661
this.

4084
02:38:30,661 --> 02:38:32,661
It's not typically

4085
02:38:40,470 --> 02:38:41,710
something I prefer to do.

4086
02:38:41,710 --> 02:38:43,206
>> maybe we should hear

4087
02:38:43,206 --> 02:38:44,273
from -- one first, MR.

4088
02:38:44,273 --> 02:38:44,841
CHAIRMAN?

4089
02:38:44,841 --> 02:38:46,543
>> CHAIRMAN La Rosa:

4090
02:38:46,543 --> 02:38:47,177
let's do that.

4091
02:38:47,177 --> 02:38:47,711
>> MR. Wahlen: I didn't

4092
02:38:47,711 --> 02:38:49,413
think I was going beyond

4093
02:38:49,413 --> 02:38:50,614
the scope of her

4094
02:38:50,614 --> 02:38:52,382
cross-examination.

4095
02:38:52,382 --> 02:38:55,382
If I did, it was

4096
02:38:55,886 --> 02:38:57,220
inadvertent.

4097
02:38:57,220 --> 02:38:59,220
>> MR. CHAIRMAN,

4098
02:39:02,259 --> 02:39:02,659
unfortunately, I wasn't

4099
02:39:02,659 --> 02:39:03,600
here at the time.

4100
02:39:03,600 --> 02:39:04,928
It's within your

4101
02:39:04,928 --> 02:39:05,462
prerogative.

4102
02:39:05,462 --> 02:39:08,462
MR. Wahlen is supposed to

4103
02:39:11,134 --> 02:39:11,701
stay within the scope of

4104
02:39:11,701 --> 02:39:12,135
the cross-examination that

4105
02:39:12,135 --> 02:39:12,669
is conducted by the

4106
02:39:12,669 --> 02:39:15,669
parties and I wasn't here

4107
02:39:16,707 --> 02:39:17,240
and I don't have an

4108
02:39:17,240 --> 02:39:17,673
opinion on that, so it's

4109
02:39:17,673 --> 02:39:18,875
really within your

4110
02:39:18,875 --> 02:39:19,409
prerogative whether you

4111
02:39:19,409 --> 02:39:21,144
think it's appropriate or

4112
02:39:21,144 --> 02:39:24,214
not, but I can say it is

4113
02:39:24,214 --> 02:39:24,747
highly irregular in our

4114
02:39:24,747 --> 02:39:27,147
practice to have further

4115
02:39:28,118 --> 02:39:28,585
cross-examination after a

4116
02:39:28,585 --> 02:39:30,985
party has taken their

4117
02:39:31,540 --> 02:39:31,655
turn.

4118
02:39:31,655 --> 02:39:33,890
>> commissioner, I can

4119
02:39:33,890 --> 02:39:33,724
pose the question to ask.

4120
02:39:33,724 --> 02:39:36,124
>> CHAIRMAN La Rosa: go

4121
02:39:37,160 --> 02:39:37,761
ahead and propose it.

4122
02:39:37,761 --> 02:39:38,328
>> MS. Christensen: my

4123
02:39:38,328 --> 02:39:41,197
question would be how long

4124
02:39:41,197 --> 02:39:43,133
does teco have use of the

4125
02:39:43,133 --> 02:39:44,668
federal land for the south

4126
02:39:44,668 --> 02:39:44,901
florida tampa resiliency

4127
02:39:44,901 --> 02:39:46,901
project?

4128
02:39:48,805 --> 02:39:49,372
30 or 35 years?

4129
02:39:49,372 --> 02:39:49,840
>> CHAIRMAN La Rosa:

4130
02:39:49,840 --> 02:39:50,140
before you answer the

4131
02:39:50,140 --> 02:39:51,207
question --

4132
02:39:51,207 --> 02:39:51,407
>> MR. Wahlen: that's

4133
02:39:51,407 --> 02:39:53,407
fine.

4134
02:39:54,978 --> 02:39:55,311
She can ask that.

4135
02:39:55,311 --> 02:39:55,946
I don't mind.

4136
02:39:55,946 --> 02:39:56,146
>> CHAIRMAN La Rosa: go

4137
02:39:56,146 --> 02:39:56,513
ahead.

4138
02:39:56,513 --> 02:39:58,513
You MAY answer.

4139
02:39:58,615 --> 02:39:59,820
>> MR. Aponte: yes, I

4140
02:39:59,820 --> 02:40:01,820
believe it's 30 or 35

4141
02:40:02,919 --> 02:40:03,586
years.

4142
02:40:03,586 --> 02:40:03,753
>> MS. Christensen: thank

4143
02:40:03,753 --> 02:40:04,321
you.

4144
02:40:04,321 --> 02:40:04,588
>> CHAIRMAN La Rosa:

4145
02:40:04,588 --> 02:40:06,588
thank you.

4146
02:40:10,590 --> 02:40:10,427
let's now move exhibits

4147
02:40:10,427 --> 02:40:10,894
into the record.

4148
02:40:10,894 --> 02:40:11,528
Let's start with teco.

4149
02:40:11,528 --> 02:40:11,995
>> MR. Wahlen: thank you.

4150
02:40:11,995 --> 02:40:13,995
Tampa electric moves

4151
02:40:16,299 --> 02:40:16,600
exhibits 20 and 144 into

4152
02:40:16,600 --> 02:40:17,233
the record.

4153
02:40:17,233 --> 02:40:17,733
>> CHAIRMAN La Rosa: are

4154
02:40:17,733 --> 02:40:17,934
there any objections to

4155
02:40:17,934 --> 02:40:19,934
that?

4156
02:40:25,342 --> 02:40:25,842
Seeing none, show them

4157
02:40:25,842 --> 02:40:26,900
entered into the record.

4158
02:40:26,900 --> 02:40:27,610
Opc?

4159
02:40:27,610 --> 02:40:28,144
>> I would move to 30 and

4160
02:40:28,144 --> 02:40:31,144
I believe 226, but it MAY

4161
02:40:36,786 --> 02:40:36,952
have already been moved

4162
02:40:36,952 --> 02:40:37,587
in.

4163
02:40:37,587 --> 02:40:38,354
>> CHAIRMAN La Rosa: any

4164
02:40:38,354 --> 02:40:38,622
objections to those

4165
02:40:38,622 --> 02:40:39,155
exhibits?

4166
02:40:39,155 --> 02:40:39,422
>> MR. Wahlen: no

4167
02:40:39,422 --> 02:40:39,990
objection.

4168
02:40:39,990 --> 02:40:40,190
>> CHAIRMAN La Rosa:

4169
02:40:40,190 --> 02:40:40,757
okay.

4170
02:40:40,757 --> 02:40:40,991
Show them entered into the

4171
02:40:40,991 --> 02:40:41,191
record.

4172
02:40:41,191 --> 02:40:41,790
Lulac?

4173
02:40:41,790 --> 02:40:42,459
>> we have a list here.

4174
02:40:42,459 --> 02:40:44,593
>> CHAIRMAN La Rosa: just

4175
02:40:44,593 --> 02:40:45,128
read them slowly so

4176
02:40:45,128 --> 02:40:47,528
everyone else can digest.

4177
02:40:49,599 --> 02:40:51,599
>> exhibits 545, 552, 557,

4178
02:41:00,911 --> 02:41:02,911
582, through 589, 591,

4179
02:41:10,987 --> 02:41:11,521
605, 633, 637, and 707.

4180
02:41:11,521 --> 02:41:11,788
>> MR. Wahlen: no

4181
02:41:11,788 --> 02:41:12,422
objection.

4182
02:41:12,422 --> 02:41:12,722
>> CHAIRMAN La Rosa: no

4183
02:41:12,722 --> 02:41:12,988
objections.

4184
02:41:12,988 --> 02:41:14,988
Thank you.

4185
02:41:15,858 --> 02:41:16,920
Show them entered into the

4186
02:41:16,920 --> 02:41:16,393
record.

4187
02:41:16,393 --> 02:41:18,228
Sierra club.

4188
02:41:18,228 --> 02:41:18,694
>> sierra club moves

4189
02:41:18,694 --> 02:41:20,694
exhibit 804 into the

4190
02:41:22,499 --> 02:41:23,330
record.

4191
02:41:23,330 --> 02:41:23,300
>> MR. Wahlen: no

4192
02:41:23,300 --> 02:41:23,867
objection.

4193
02:41:23,867 --> 02:41:24,367
>> CHAIRMAN La Rosa:

4194
02:41:24,367 --> 02:41:24,868
seeing none, show them

4195
02:41:24,868 --> 02:41:26,770
entered into the record.

4196
02:41:26,770 --> 02:41:28,770
any other exhibits?

4197
02:41:32,442 --> 02:41:32,809
Seeing none, MR. Aponte,

4198
02:41:32,809 --> 02:41:33,476
you are excused.

4199
02:41:33,476 --> 02:41:35,876
>> MR. Aponte: thank you,

4200
02:41:39,415 --> 02:41:39,749
commissioners.

4201
02:41:39,749 --> 02:41:40,315
Appreciate it.

4202
02:41:40,315 --> 02:41:42,315
>> CHAIRMAN La Rosa:

4203
02:41:42,318 --> 02:41:42,852
thank you.

4204
02:41:42,852 --> 02:41:43,860
I will throw it back over

4205
02:41:43,860 --> 02:41:43,653
to teco.

4206
02:41:43,653 --> 02:41:44,200
In fact, before I do that,

4207
02:41:44,200 --> 02:41:44,420
let me do some

4208
02:41:44,420 --> 02:41:45,210
housekeeping here.

4209
02:41:45,210 --> 02:41:45,221
Still planning to break at

4210
02:41:45,221 --> 02:41:46,723
12:00.

4211
02:41:46,723 --> 02:41:49,723
I know there's still some

4212
02:41:51,193 --> 02:41:51,461
questions on some of the

4213
02:41:51,461 --> 02:41:51,961
witnesses.

4214
02:41:51,961 --> 02:41:54,264
I have course encourage

4215
02:41:54,264 --> 02:41:54,764
that.

4216
02:41:54,764 --> 02:41:55,332
What I would like to do

4217
02:41:55,332 --> 02:41:57,567
this afternoon, later this

4218
02:41:57,567 --> 02:41:59,335
afternoon is at 6:00 until

4219
02:41:59,335 --> 02:42:02,335
6:30 is have kind of a

4220
02:42:07,444 --> 02:42:07,911
brief dinner break and

4221
02:42:07,911 --> 02:42:08,211
then we will continue

4222
02:42:08,211 --> 02:42:08,711
after that.

4223
02:42:08,711 --> 02:42:11,111
So after the 6:30 hour

4224
02:42:11,347 --> 02:42:13,347
until 9:00 or so.

4225
02:42:15,885 --> 02:42:16,419
Just to make sure we all

4226
02:42:16,419 --> 02:42:16,753
have an understanding of

4227
02:42:16,753 --> 02:42:17,887
the schedule.

4228
02:42:17,887 --> 02:42:18,455
Is somewhat early now, but

4229
02:42:18,455 --> 02:42:19,489
just want to give you guys

4230
02:42:19,489 --> 02:42:21,557
a heads up anyone who's

4231
02:42:21,557 --> 02:42:24,557
got to make plans or

4232
02:42:28,298 --> 02:42:28,831
thoughts.

4233
02:42:28,831 --> 02:42:29,265
Hopefully give you enough

4234
02:42:29,265 --> 02:42:29,565
time to do anything

4235
02:42:29,565 --> 02:42:31,565
additional.

4236
02:42:38,708 --> 02:42:39,750
Again, still planning to

4237
02:42:39,750 --> 02:42:39,609
break at 12:00.

4238
02:42:39,609 --> 02:42:40,430
Teco, let's go ahead and

4239
02:42:40,430 --> 02:42:40,276
introduce your next

4240
02:42:40,276 --> 02:42:40,777
witness.

4241
02:42:40,777 --> 02:42:41,440
>> thank you, MR.

4242
02:42:41,440 --> 02:42:41,611
CHAIRMAN.

4243
02:42:41,611 --> 02:42:44,110
Tampa electric calls chip

4244
02:42:45,615 --> 02:42:47,615
whitworth.

4245
02:42:49,719 --> 02:42:50,152
>> CHAIRMAN La Rosa: mr.

4246
02:42:50,152 --> 02:42:50,620
whitworth, I do not

4247
02:42:50,620 --> 02:42:53,200
believe you have been

4248
02:42:55,325 --> 02:42:55,792
administered the oath.

4249
02:42:55,792 --> 02:42:56,292
Do you mind standing?

4250
02:42:56,292 --> 02:42:56,760
Do you swear and affirm

4251
02:42:56,760 --> 02:42:57,293
the testimony you are

4252
02:42:57,293 --> 02:43:00,893
about to give will be the

4253
02:43:02,632 --> 02:43:03,165
truth, the whole truth,

4254
02:43:03,165 --> 02:43:03,766
and nothing but the truth?

4255
02:43:03,766 --> 02:43:04,334
>> MR. Whitworth: I do.

4256
02:43:04,334 --> 02:43:04,601
>> CHAIRMAN La Rosa:

4257
02:43:04,601 --> 02:43:05,135
thank you.

4258
02:43:05,135 --> 02:43:05,601
Have a seat, get settled

4259
02:43:05,601 --> 02:43:08,601
in, we'll give you a

4260
02:43:20,817 --> 02:43:22,352
second to get organized.

4261
02:43:22,352 --> 02:43:22,585
Teco, we are ready when

4262
02:43:22,585 --> 02:43:24,287
you are.

4263
02:43:24,287 --> 02:43:26,255
>> thank you, MR.

4264
02:43:26,255 --> 02:43:28,255
CHAIRMAN.

4265
02:43:28,657 --> 02:43:29,259
Good morning, transacting.

4266
02:43:29,259 --> 02:43:29,492
>> MR. Whitworth: good

4267
02:43:29,492 --> 02:43:31,492
morning.

4268
02:43:33,696 --> 02:43:34,197
>> can you please state

4269
02:43:34,197 --> 02:43:34,430
your full name for the

4270
02:43:34,430 --> 02:43:34,998
record?

4271
02:43:34,998 --> 02:43:35,198
>> MR. Whitworth: --

4272
02:43:35,198 --> 02:43:37,198
seven.

4273
02:43:38,668 --> 02:43:38,902
>> were just sworn,

4274
02:43:38,902 --> 02:43:39,535
correct?

4275
02:43:39,535 --> 02:43:40,360
>> MR. Whitworth: I was.

4276
02:43:40,360 --> 02:43:41,400
Tampa electric company

4277
02:43:41,400 --> 02:43:43,400
business address is 702

4278
02:43:53,282 --> 02:43:53,850
north franklin st. Is 702

4279
02:43:53,850 --> 02:43:54,170
north franklin st., tampa,

4280
02:43:54,170 --> 02:43:54,617
fl.

4281
02:43:54,617 --> 02:43:55,118
>> did you prepare plan

4282
02:43:55,118 --> 02:43:55,617
cause to be filed APRIL

4283
02:43:55,617 --> 02:43:56,185
22, 2024 prepare direct

4284
02:43:56,185 --> 02:43:56,386
testimony consisting of --

4285
02:43:56,386 --> 02:43:57,190
pages?

4286
02:43:57,190 --> 02:43:57,654
>> MR. Whitworth: I did.

4287
02:43:57,654 --> 02:44:00,654
>> and did you prepare in

4288
02:44:02,725 --> 02:44:03,293
cause prepare rebuttal

4289
02:44:03,293 --> 02:44:03,493
testimony consisting of 15

4290
02:44:03,493 --> 02:44:04,127
pages?

4291
02:44:04,127 --> 02:44:04,661
>> MR. Whitworth: I did.

4292
02:44:04,661 --> 02:44:05,193
>> do you have any

4293
02:44:05,193 --> 02:44:07,193
additional questions to

4294
02:44:09,499 --> 02:44:09,766
your prepared rebuttal

4295
02:44:09,766 --> 02:44:10,366
testimony?

4296
02:44:10,366 --> 02:44:10,533
>> MR. Whitworth: I do

4297
02:44:10,533 --> 02:44:11,100
not.

4298
02:44:11,100 --> 02:44:11,668
>> if I would ask you

4299
02:44:11,668 --> 02:44:14,680
questions compared in your

4300
02:44:17,400 --> 02:44:17,440
direct and -- would your

4301
02:44:17,440 --> 02:44:18,400
interest the same?

4302
02:44:18,400 --> 02:44:18,241
>> MR. Whitworth: they

4303
02:44:18,241 --> 02:44:18,874
would.

4304
02:44:18,874 --> 02:44:19,409
>> tampa electric request

4305
02:44:19,409 --> 02:44:21,809
the prepared and rebuttal

4306
02:44:45,335 --> 02:44:45,902
testimony of transacting

4307
02:44:45,902 --> 02:44:46,202
the insert into the record

4308
02:44:46,202 --> 02:44:46,703
as the red.

4309
02:44:46,703 --> 02:44:47,203
Did you also prepare in

4310
02:44:47,203 --> 02:44:47,670
cause to be filed with

4311
02:44:47,670 --> 02:44:48,137
your direct testimony

4312
02:44:48,137 --> 02:44:48,571
exhibit marked cw-one

4313
02:44:48,571 --> 02:44:48,838
consisting of eight

4314
02:44:48,838 --> 02:44:49,472
documents?

4315
02:44:49,472 --> 02:44:50,730
>> MR. Whitworth: I did.

4316
02:44:50,730 --> 02:44:50,606
>> did you also prepare

4317
02:44:50,606 --> 02:44:51,140
cause to be filed exhibit

4318
02:44:51,140 --> 02:44:51,574
marked cw-two consisting

4319
02:44:51,574 --> 02:44:52,208
of three documents?

4320
02:44:52,208 --> 02:44:52,809
>> MR. Whitworth: I did.

4321
02:44:52,809 --> 02:44:53,309
>> MR. CHAIRMAN, tampa

4322
02:44:53,309 --> 02:44:53,810
electric would note for

4323
02:44:53,810 --> 02:44:54,310
the record that exhibit

4324
02:44:54,310 --> 02:44:54,811
cw-one and cw-two have

4325
02:44:54,811 --> 02:44:55,378
been identified on the

4326
02:44:55,378 --> 02:44:55,878
comprehensive exhibit list

4327
02:44:55,878 --> 02:44:56,445
as exhibits 21 and 145.

4328
02:44:56,445 --> 02:44:56,646
>> CHAIRMAN La Rosa:

4329
02:44:56,646 --> 02:44:57,280
okay.

4330
02:44:57,280 --> 02:44:57,814
>> MR. Whitworth, and to

4331
02:44:57,814 --> 02:44:58,247
prepare a summary of your

4332
02:44:58,247 --> 02:44:58,513
direct and rebuttal

4333
02:44:58,513 --> 02:44:59,148
testimony?

4334
02:44:59,148 --> 02:45:01,484
>> MR. Whitworth: I did.

4335
02:45:01,484 --> 02:45:01,851
>> would you please give

4336
02:45:01,851 --> 02:45:02,451
that testimony?

4337
02:45:02,451 --> 02:45:02,952
>> MR. Whitworth: good

4338
02:45:02,952 --> 02:45:03,486
morning, commissioners.

4339
02:45:03,486 --> 02:45:05,486
My direct testimony

4340
02:45:06,723 --> 02:45:07,156
describes my companies

4341
02:45:07,156 --> 02:45:07,690
just vision system,

4342
02:45:07,690 --> 02:45:08,156
however system has grown

4343
02:45:08,156 --> 02:45:10,556
and changed since the

4344
02:45:11,494 --> 02:45:12,280
company's last base rate

4345
02:45:12,280 --> 02:45:12,528
case, our customers have

4346
02:45:12,528 --> 02:45:14,528
benefited from improved

4347
02:45:16,265 --> 02:45:16,766
blue sky and extreme

4348
02:45:16,766 --> 02:45:17,300
weather reliability and

4349
02:45:17,300 --> 02:45:17,800
white capital investments

4350
02:45:17,800 --> 02:45:20,269
in the tnd system since

4351
02:45:20,269 --> 02:45:21,571
the last rate cases were

4352
02:45:21,571 --> 02:45:22,171
necessary and prudent.

4353
02:45:22,171 --> 02:45:24,171
Are direct testimony

4354
02:45:27,844 --> 02:45:28,377
explains -- in our

4355
02:45:28,377 --> 02:45:30,377
transmission distribution

4356
02:45:31,147 --> 02:45:32,115
substation expansion and

4357
02:45:32,115 --> 02:45:32,548
upgrades that are needed

4358
02:45:32,548 --> 02:45:34,548
to support customer

4359
02:45:37,753 --> 02:45:38,121
growth, maintain and

4360
02:45:38,121 --> 02:45:38,654
improve system

4361
02:45:38,654 --> 02:45:39,188
reliability, improve grid

4362
02:45:39,188 --> 02:45:40,956
resiliency, replace aging

4363
02:45:40,956 --> 02:45:41,491
infrastructure, improve

4364
02:45:41,491 --> 02:45:43,491
our customers experience,

4365
02:45:44,727 --> 02:45:45,940
and meet our governmental

4366
02:45:45,940 --> 02:45:45,395
and regulatory

4367
02:45:45,395 --> 02:45:47,395
commitments.

4368
02:45:50,433 --> 02:45:50,933
Lastly, my direct

4369
02:45:50,933 --> 02:45:51,434
testimony describes how

4370
02:45:51,434 --> 02:45:53,434
tampa electric proposed

4371
02:46:09,752 --> 02:46:10,219
t&d and capital budgets

4372
02:46:10,219 --> 02:46:10,787
represent a strategic

4373
02:46:10,787 --> 02:46:11,353
approach that will provide

4374
02:46:11,353 --> 02:46:11,821
a modern grade to meet our

4375
02:46:11,821 --> 02:46:12,321
customers increasing

4376
02:46:12,321 --> 02:46:12,889
expectations, and after

4377
02:46:12,889 --> 02:46:13,422
growing demand, and ensure

4378
02:46:13,422 --> 02:46:13,923
a grid that will be safe,

4379
02:46:13,923 --> 02:46:14,490
resilient, secure, and

4380
02:46:14,490 --> 02:46:14,690
reliable for many years to

4381
02:46:14,690 --> 02:46:15,157
come.

4382
02:46:15,157 --> 02:46:15,691
My rebuttal testimony

4383
02:46:15,691 --> 02:46:16,225
addresses two main issues

4384
02:46:16,225 --> 02:46:16,659
raised by the office of

4385
02:46:16,659 --> 02:46:17,192
public counsel' is

4386
02:46:17,192 --> 02:46:17,693
testimony related to the

4387
02:46:17,693 --> 02:46:19,693
companies spare medium

4388
02:46:20,262 --> 02:46:20,796
power transformer

4389
02:46:20,796 --> 02:46:21,129
inventory and accounting

4390
02:46:21,129 --> 02:46:23,129
for spp work.

4391
02:46:25,300 --> 02:46:25,801
First, our rebuttal

4392
02:46:25,801 --> 02:46:26,335
testimony explained the

4393
02:46:26,335 --> 02:46:26,769
company's reasonable and

4394
02:46:26,769 --> 02:46:28,769
prudent process for

4395
02:46:29,205 --> 02:46:29,605
maintaining inventory.

4396
02:46:29,605 --> 02:46:31,605
tampa electric it

4397
02:46:35,111 --> 02:46:35,645
currently has four

4398
02:46:35,645 --> 02:46:36,112
transformers in stock and

4399
02:46:36,112 --> 02:46:36,646
the office of public

4400
02:46:36,646 --> 02:46:37,113
counsel has requested the

4401
02:46:37,113 --> 02:46:39,113
company reduce medium

4402
02:46:42,251 --> 02:46:42,652
power transformer

4403
02:46:42,652 --> 02:46:43,152
inventory by four.

4404
02:46:43,152 --> 02:46:45,552
I recommend the company

4405
02:46:50,260 --> 02:46:50,492
make no adjustment since

4406
02:46:50,492 --> 02:46:50,992
lead times for medium

4407
02:46:50,992 --> 02:46:51,560
power transformers are

4408
02:46:51,560 --> 02:46:53,560
approximately 1.5-2 years,

4409
02:46:55,131 --> 02:46:55,598
they are an essential

4410
02:46:55,598 --> 02:46:56,980
piece of equipment to

4411
02:46:56,980 --> 02:46:56,599
serve our customers and

4412
02:46:56,599 --> 02:46:57,499
needed to keep up with

4413
02:46:57,499 --> 02:46:57,733
energy demand and customer

4414
02:46:57,733 --> 02:46:59,733
growth.

4415
02:47:07,143 --> 02:47:07,610
Second.

4416
02:47:07,610 --> 02:47:08,177
My rebuttal testimony!

4417
02:47:08,177 --> 02:47:08,578
How opc's reclassification

4418
02:47:08,578 --> 02:47:09,111
of certain feeder

4419
02:47:09,111 --> 02:47:09,645
hardening costs from base

4420
02:47:09,645 --> 02:47:12,645
rates to the spp recovery

4421
02:47:20,890 --> 02:47:20,556
clause is inconsistent

4422
02:47:20,556 --> 02:47:20,955
with the commission's

4423
02:47:20,955 --> 02:47:21,390
order when tampa

4424
02:47:21,390 --> 02:47:21,924
electric's 2020 spp

4425
02:47:21,924 --> 02:47:22,191
settlement agreement was

4426
02:47:22,191 --> 02:47:22,725
approved.

4427
02:47:22,725 --> 02:47:23,225
That agreement, which opc

4428
02:47:23,225 --> 02:47:23,726
signed, requires tampa

4429
02:47:23,726 --> 02:47:25,461
electric to charge the

4430
02:47:25,461 --> 02:47:25,995
cost of removal for assets

4431
02:47:25,995 --> 02:47:28,995
that are being retired as

4432
02:47:29,765 --> 02:47:30,132
part of an spp project to

4433
02:47:30,132 --> 02:47:31,534
the accumulated

4434
02:47:31,534 --> 02:47:33,169
depreciation and rate

4435
02:47:33,169 --> 02:47:33,369
based used to set base

4436
02:47:33,369 --> 02:47:33,836
rates.

4437
02:47:33,836 --> 02:47:34,270
I recommend that the

4438
02:47:34,270 --> 02:47:36,270
commission make no

4439
02:47:40,242 --> 02:47:40,776
adjustments to the

4440
02:47:40,776 --> 02:47:41,310
hardening cost removal of

4441
02:47:41,310 --> 02:47:41,877
expenses since those were

4442
02:47:41,877 --> 02:47:42,578
charged properly under the

4443
02:47:42,578 --> 02:47:44,578
2022 spp agreement.

4444
02:47:46,882 --> 02:47:47,149
This concludes my summary.

4445
02:47:47,149 --> 02:47:47,783
Thank you.

4446
02:47:47,783 --> 02:47:49,218
>> we tender the witness

4447
02:47:49,218 --> 02:47:49,785
for cross-examination.

4448
02:47:49,785 --> 02:47:50,520
>> CHAIRMAN La Rosa:

4449
02:47:50,520 --> 02:47:52,520
thank you.

4450
02:47:53,422 --> 02:47:53,722
Opc, you are recognized

4451
02:47:53,722 --> 02:47:54,222
when ready.

4452
02:47:54,222 --> 02:47:56,222
>> good morning,

4453
02:48:00,496 --> 02:48:00,896
commissioners.

4454
02:48:00,896 --> 02:48:01,163
Good morning, MR.

4455
02:48:01,163 --> 02:48:01,697
Whitworth.

4456
02:48:01,697 --> 02:48:02,230
MR. Whitworth, can I have

4457
02:48:02,230 --> 02:48:05,301
you take a look at page 2

4458
02:48:05,301 --> 02:48:05,501
of the testimony that's up

4459
02:48:05,501 --> 02:48:06,100
there?

4460
02:48:06,100 --> 02:48:06,535
In your direct, you say

4461
02:48:06,535 --> 02:48:07,690
that your duties include

4462
02:48:07,690 --> 02:48:09,469
advanced metering and for

4463
02:48:14,543 --> 02:48:15,100
structure, advanced this

4464
02:48:15,100 --> 02:48:15,510
tradition management

4465
02:48:15,510 --> 02:48:15,978
systems, line clearing

4466
02:48:15,978 --> 02:48:16,412
activities, and fleet

4467
02:48:16,412 --> 02:48:16,845
equipment, is that

4468
02:48:16,845 --> 02:48:17,480
correct?

4469
02:48:17,480 --> 02:48:19,480
>> MR. Whitworth: that's

4470
02:48:21,684 --> 02:48:22,284
correct.

4471
02:48:22,284 --> 02:48:22,785
>> and are you aware of

4472
02:48:22,785 --> 02:48:25,185
the filing your company

4473
02:48:26,210 --> 02:48:28,210
made on AUGUST 22, 2024

4474
02:48:28,123 --> 02:48:30,123
where teco revised

4475
02:48:31,693 --> 02:48:32,128
portions of the gr r

4476
02:48:32,128 --> 02:48:34,528
program that is now

4477
02:48:39,468 --> 02:48:40,102
included in this request?

4478
02:48:40,102 --> 02:48:40,636
>> MR. Whitworth: could

4479
02:48:40,636 --> 02:48:40,870
you repeat the question,

4480
02:48:40,870 --> 02:48:41,436
please?

4481
02:48:41,436 --> 02:48:41,937
>> sure to go are you

4482
02:48:41,937 --> 02:48:43,338
aware of the AUGUST 22

4483
02:48:43,338 --> 02:48:45,241
filing that was made to

4484
02:48:45,241 --> 02:48:47,209
revise the request?

4485
02:48:47,209 --> 02:48:47,376
>> MR. Whitworth: yes, I

4486
02:48:47,376 --> 02:48:49,376
am.

4487
02:48:51,460 --> 02:48:51,580
>> are you aware in that

4488
02:48:51,580 --> 02:48:54,580
filing one of the things

4489
02:48:54,716 --> 02:48:55,151
they revised were a number

4490
02:48:55,151 --> 02:48:56,418
of things that were

4491
02:48:56,418 --> 02:48:58,420
included in the gr r?

4492
02:48:58,420 --> 02:49:00,420
>> MR. Whitworth: yes,

4493
02:49:03,492 --> 02:49:04,930
I'm aware of that.

4494
02:49:04,930 --> 02:49:04,593
>> can you tell me how

4495
02:49:04,593 --> 02:49:05,560
many programs from the

4496
02:49:05,560 --> 02:49:07,560
original 40 programs that

4497
02:49:10,199 --> 02:49:10,733
you discuss in your

4498
02:49:10,733 --> 02:49:13,133
testimony on page 22 have

4499
02:49:15,470 --> 02:49:16,710
been removed?

4500
02:49:16,710 --> 02:49:16,605
>> MR. Whitworth: that

4501
02:49:16,605 --> 02:49:19,500
question is better suited

4502
02:49:20,408 --> 02:49:22,510
for witness david lukcic.

4503
02:49:22,510 --> 02:49:24,510
>> david?

4504
02:49:24,512 --> 02:49:26,512
>> yes.

4505
02:49:27,650 --> 02:49:27,917
>> me ask you this

4506
02:49:27,917 --> 02:49:28,450
question.

4507
02:49:28,450 --> 02:49:31,420
Would I be correct that

4508
02:49:31,420 --> 02:49:31,987
removing this program from

4509
02:49:31,987 --> 02:49:34,560
this request does not mean

4510
02:49:34,560 --> 02:49:34,256
these projects will not be

4511
02:49:34,256 --> 02:49:34,890
done?

4512
02:49:34,890 --> 02:49:36,890
>> MR. Whitworth: that's

4513
02:49:38,860 --> 02:49:40,860
correct.

4514
02:49:41,664 --> 02:49:42,230
>> and looking at page 22

4515
02:49:42,230 --> 02:49:43,666
of your testimony, and let

4516
02:49:43,666 --> 02:49:46,234
me know when you get

4517
02:49:46,234 --> 02:49:48,234
there.

4518
02:49:51,307 --> 02:49:51,540
Lines 15 through 17, I

4519
02:49:51,540 --> 02:49:53,540
believe.

4520
02:49:57,646 --> 02:49:57,780
Referring to

4521
02:49:57,780 --> 02:49:59,415
.

4522
02:49:59,415 --> 02:50:02,415
In that portion of your

4523
02:50:05,821 --> 02:50:06,889
testimony, you say it is

4524
02:50:06,889 --> 02:50:09,289
teco's goal to complete

4525
02:50:11,727 --> 02:50:12,261
all the projects by 2030.

4526
02:50:12,261 --> 02:50:15,261
But you would agree that

4527
02:50:16,331 --> 02:50:16,598
completion date is not a

4528
02:50:16,598 --> 02:50:17,199
firm date?

4529
02:50:17,199 --> 02:50:18,701
>> MR. Whitworth: our

4530
02:50:18,701 --> 02:50:21,701
intent is to complete the

4531
02:50:23,739 --> 02:50:24,139
entire set of our gr

4532
02:50:24,139 --> 02:50:26,139
projects by 2030.

4533
02:50:26,742 --> 02:50:27,209
I would also like to note

4534
02:50:27,209 --> 02:50:27,743
we are not asking the

4535
02:50:27,743 --> 02:50:30,143
commission to approve the

4536
02:50:32,881 --> 02:50:33,382
entire set of the gr

4537
02:50:33,382 --> 02:50:33,582
projects for this rate

4538
02:50:33,582 --> 02:50:34,116
case.

4539
02:50:34,116 --> 02:50:34,650
We are only asking you to

4540
02:50:34,650 --> 02:50:37,650
approve a subset of those

4541
02:50:38,687 --> 02:50:40,155
in 2025 stubbs had asked.

4542
02:50:40,155 --> 02:50:43,155
>> mi fair to assume that

4543
02:50:43,258 --> 02:50:45,761
you agree with my question

4544
02:50:45,761 --> 02:50:49,361
that it's not a firm date?

4545
02:50:53,402 --> 02:50:53,936
>> MR. Whitworth: we

4546
02:50:53,936 --> 02:50:54,470
intend to complete it by

4547
02:50:54,470 --> 02:50:54,970
2030 and I would refer to

4548
02:50:54,970 --> 02:50:56,505
david lukcic about the

4549
02:50:56,505 --> 02:50:56,838
specific dates.

4550
02:50:56,838 --> 02:50:58,838
>> okay.

4551
02:51:04,679 --> 02:51:05,180
On the bottom of 2022 on

4552
02:51:05,180 --> 02:51:05,747
the page, this page of

4553
02:51:05,747 --> 02:51:06,281
your testimony, your claim

4554
02:51:06,281 --> 02:51:06,815
is that aggregating these

4555
02:51:06,815 --> 02:51:08,317
projects result in more

4556
02:51:08,317 --> 02:51:10,317
efficient capital spend

4557
02:51:14,389 --> 02:51:14,723
and enhancement

4558
02:51:14,723 --> 02:51:15,189
functionality.

4559
02:51:15,189 --> 02:51:15,691
Not that all these 40

4560
02:51:15,691 --> 02:51:18,910
projects cannot be done

4561
02:51:18,260 --> 02:51:18,494
individually, is that

4562
02:51:18,494 --> 02:51:19,127
correct?

4563
02:51:19,127 --> 02:51:19,895
>> MR. Whitworth: that's

4564
02:51:19,895 --> 02:51:21,895
correct.

4565
02:51:24,266 --> 02:51:24,766
>> living on the page 24

4566
02:51:24,766 --> 02:51:26,234
of this portion of your

4567
02:51:26,234 --> 02:51:28,234
testimony.

4568
02:51:29,171 --> 02:51:32,771
You say that the gr are

4569
02:51:38,781 --> 02:51:39,314
projects are necessary to

4570
02:51:39,314 --> 02:51:39,815
replace obsolete systems

4571
02:51:39,815 --> 02:51:40,348
and equipment that have

4572
02:51:40,348 --> 02:51:40,682
reached the end of their

4573
02:51:40,682 --> 02:51:41,216
life, correct?

4574
02:51:41,216 --> 02:51:41,450
>> MR. Whitworth:

4575
02:51:41,450 --> 02:51:43,152
correct.

4576
02:51:43,152 --> 02:51:46,152
That is one component of

4577
02:51:46,354 --> 02:51:47,556
the gr auto projects.

4578
02:51:47,556 --> 02:51:48,560
>> you would agree that

4579
02:51:48,560 --> 02:51:48,490
replacing old obsolete

4580
02:51:48,490 --> 02:51:48,790
equipment is normal

4581
02:51:48,790 --> 02:51:48,990
activities

4582
02:51:48,990 --> 02:51:50,990
, correct?

4583
02:51:51,392 --> 02:51:51,927
>> MR. Whitworth: in

4584
02:51:51,927 --> 02:51:52,930
certain circumstances it

4585
02:51:52,930 --> 02:51:54,930
is.

4586
02:51:54,696 --> 02:51:55,263
In other circumstances

4587
02:51:55,263 --> 02:51:58,263
when you can replace these

4588
02:51:58,733 --> 02:52:00,936
assets in a coordinated

4589
02:52:00,936 --> 02:52:01,470
fashion, there is a way a

4590
02:52:01,470 --> 02:52:03,439
company can execute these

4591
02:52:03,439 --> 02:52:05,839
projects and save the

4592
02:52:07,776 --> 02:52:08,277
customers further capital

4593
02:52:08,277 --> 02:52:10,677
by the efficiency these

4594
02:52:11,130 --> 02:52:13,130
are executed

4595
02:52:13,882 --> 02:52:14,415
.

4596
02:52:14,415 --> 02:52:17,415
david lukcic has a great

4597
02:52:18,420 --> 02:52:18,921
deal of --

4598
02:52:18,921 --> 02:52:20,656
>> you would agree it's

4599
02:52:20,656 --> 02:52:22,656
normal activities, right?

4600
02:52:24,626 --> 02:52:24,992
>> CHAIRMAN La Rosa: it

4601
02:52:24,992 --> 02:52:26,992
has been asked.

4602
02:52:27,290 --> 02:52:30,629
>> I know I asked it, but

4603
02:52:31,533 --> 02:52:31,766
I did not get a yes or no

4604
02:52:31,766 --> 02:52:32,233
answer.

4605
02:52:32,233 --> 02:52:35,833
If I can ask that the

4606
02:52:37,873 --> 02:52:38,140
witness give me a yes or

4607
02:52:38,140 --> 02:52:38,774
no answer.

4608
02:52:38,774 --> 02:52:39,206
>> CHAIRMAN La Rosa: I'm

4609
02:52:39,206 --> 02:52:41,760
going to allow the

4610
02:52:41,760 --> 02:52:43,476
question to be asked.

4611
02:52:50,485 --> 02:52:50,652
>> I think you agree it is

4612
02:52:50,652 --> 02:52:51,186
--

4613
02:52:51,186 --> 02:52:51,720
>> MR. Whitworth: I said

4614
02:52:51,720 --> 02:52:51,920
in certain circumstances

4615
02:52:51,920 --> 02:52:52,254
it is.

4616
02:52:52,254 --> 02:52:52,721
>> okay.

4617
02:52:52,721 --> 02:52:53,655
You then say in your

4618
02:52:53,655 --> 02:52:55,655
testimony that investments

4619
02:52:56,291 --> 02:52:57,693
are to improve

4620
02:52:57,693 --> 02:52:58,226
reliability, access to

4621
02:52:58,226 --> 02:52:58,460
data

4622
02:52:58,460 --> 02:53:00,460
, correct?

4623
02:53:02,430 --> 02:53:02,931
>> MR. Whitworth: what

4624
02:53:02,931 --> 02:53:05,931
page are you on, please?

4625
02:53:06,802 --> 02:53:09,802
>> I'm on page 22 -- or

4626
02:53:10,271 --> 02:53:12,271
I'm sorry, 24.

4627
02:53:15,677 --> 02:53:16,178
And I believe we are

4628
02:53:16,178 --> 02:53:18,578
looking at your answer

4629
02:53:20,115 --> 02:53:20,648
which starts at line 4.

4630
02:53:20,648 --> 02:53:20,816
>> MR. Whitworth: excuse

4631
02:53:20,816 --> 02:53:22,500
me?

4632
02:53:22,500 --> 02:53:24,500
Which line?

4633
02:53:26,788 --> 02:53:27,322
>> line 4 if you need to

4634
02:53:27,322 --> 02:53:29,722
read through that answer,

4635
02:53:31,693 --> 02:53:32,293
that's fine.

4636
02:53:32,293 --> 02:53:34,293
>> MR. Whitworth: okay.

4637
02:53:40,680 --> 02:53:40,702
Thank you.

4638
02:53:40,702 --> 02:53:41,203
>> so would you agree in

4639
02:53:41,203 --> 02:53:41,770
your testimony you say

4640
02:53:41,770 --> 02:53:42,269
investments are to improve

4641
02:53:42,269 --> 02:53:44,269
reliability, access to

4642
02:53:50,112 --> 02:53:50,545
data, and improve -- would

4643
02:53:50,545 --> 02:53:51,790
you agree that teco

4644
02:53:51,790 --> 02:53:51,580
routinely looks for ways

4645
02:53:51,580 --> 02:53:53,980
to improve its systems

4646
02:53:54,549 --> 02:53:55,183
functions?

4647
02:53:55,183 --> 02:53:56,284
>> MR. Whitworth: we do.

4648
02:53:56,284 --> 02:53:58,152
>> okay.

4649
02:53:58,152 --> 02:54:01,152
Let's go to page 29 of

4650
02:54:07,620 --> 02:54:09,620
your testimony.

4651
02:54:11,833 --> 02:54:14,833
Looking at lines 1 and two

4652
02:54:18,907 --> 02:54:22,377
on that page, it says the

4653
02:54:22,377 --> 02:54:23,678
company plans to begin the

4654
02:54:23,678 --> 02:54:25,514
grid reliability and

4655
02:54:25,514 --> 02:54:27,514
resiliency projects in

4656
02:54:30,452 --> 02:54:32,452
2024 and conclude in 2023.

4657
02:54:36,224 --> 02:54:36,758
Did you mean to say 2030

4658
02:54:36,758 --> 02:54:37,250
and that portion of your

4659
02:54:37,250 --> 02:54:37,626
testimony?

4660
02:54:37,626 --> 02:54:39,127
>> MR. Whitworth: yes,

4661
02:54:39,127 --> 02:54:39,728
that should say 2030.

4662
02:54:39,728 --> 02:54:41,696
>> would you agree that

4663
02:54:41,696 --> 02:54:42,229
existing field devices

4664
02:54:42,229 --> 02:54:44,229
communicate through your

4665
02:54:49,404 --> 02:54:50,500
radio network currently?

4666
02:54:50,500 --> 02:54:50,172
>> MR. Whitworth: they

4667
02:54:50,172 --> 02:54:50,772
do.

4668
02:54:50,772 --> 02:54:52,840
>> and would you agree

4669
02:54:52,840 --> 02:54:55,760
that the current radio

4670
02:54:55,760 --> 02:54:57,476
scata system was installed

4671
02:54:59,847 --> 02:55:00,348
in -- and that the scata

4672
02:55:00,348 --> 02:55:02,348
system needs replacing?

4673
02:55:04,219 --> 02:55:04,452
>> MR. Whitworth: that is

4674
02:55:04,452 --> 02:55:06,452
correct.

4675
02:55:08,890 --> 02:55:09,324
>> looking at your exhibit

4676
02:55:09,324 --> 02:55:09,824
for your testimony,

4677
02:55:09,824 --> 02:55:12,224
document seven, given a

4678
02:55:28,243 --> 02:55:28,443
minute here.

4679
02:55:28,443 --> 02:55:30,443
Okay.

4680
02:55:31,512 --> 02:55:34,512
This is an exhibit that

4681
02:55:39,454 --> 02:55:39,854
shows the gr project as

4682
02:55:39,854 --> 02:55:40,488
proposed, correct?

4683
02:55:40,488 --> 02:55:40,755
>> MR. Whitworth: no, it

4684
02:55:40,755 --> 02:55:41,256
does not.

4685
02:55:41,256 --> 02:55:43,124
This is a general graph

4686
02:55:43,124 --> 02:55:43,692
that shows large buckets

4687
02:55:43,692 --> 02:55:45,493
and timeline, but does not

4688
02:55:45,493 --> 02:55:47,493
depict any in-service

4689
02:55:51,299 --> 02:55:51,633
dates.

4690
02:55:51,633 --> 02:55:52,167
>> okay.

4691
02:55:52,167 --> 02:55:54,567
It's a general indication

4692
02:56:01,876 --> 02:56:02,309
of the projects and

4693
02:56:02,309 --> 02:56:02,844
timelines, but not

4694
02:56:02,844 --> 02:56:03,780
specific in-service date,

4695
02:56:03,780 --> 02:56:03,612
correct?

4696
02:56:03,612 --> 02:56:03,844
>> MR. Whitworth:

4697
02:56:03,844 --> 02:56:04,412
correct.

4698
02:56:04,412 --> 02:56:04,746
>> part of this talks

4699
02:56:04,746 --> 02:56:05,246
about the new

4700
02:56:05,246 --> 02:56:07,246
communication platform

4701
02:56:08,283 --> 02:56:10,518
that is the plt spectrum,

4702
02:56:10,518 --> 02:56:11,186
is that correct?

4703
02:56:11,186 --> 02:56:11,653
>> MR. Whitworth: it does

4704
02:56:11,653 --> 02:56:13,653
mention that, correct.

4705
02:56:14,322 --> 02:56:17,322
>> and that is the purple

4706
02:56:22,530 --> 02:56:23,131
line, correct?

4707
02:56:23,131 --> 02:56:23,364
>> MR. Whitworth: yes,

4708
02:56:23,364 --> 02:56:23,998
correct.

4709
02:56:23,998 --> 02:56:24,566
>> and the plte spectrum

4710
02:56:24,566 --> 02:56:25,660
project, that is projected

4711
02:56:25,660 --> 02:56:25,900
to go into service in

4712
02:56:25,900 --> 02:56:27,900
2026, is that still

4713
02:56:30,138 --> 02:56:30,805
correct?

4714
02:56:30,805 --> 02:56:31,271
>> MR. Whitworth: that's

4715
02:56:31,271 --> 02:56:31,773
my understanding, but

4716
02:56:31,773 --> 02:56:32,473
witness lukcic has the

4717
02:56:32,473 --> 02:56:34,873
specifics on the plte

4718
02:56:42,950 --> 02:56:43,217
project and all the

4719
02:56:43,217 --> 02:56:43,718
projects.

4720
02:56:43,718 --> 02:56:44,185
>> let me ask the

4721
02:56:44,185 --> 02:56:44,719
questions and to the

4722
02:56:44,719 --> 02:56:45,190
extent that you know you

4723
02:56:45,190 --> 02:56:45,552
can answer.

4724
02:56:45,552 --> 02:56:46,540
Looking at the blue field

4725
02:56:46,540 --> 02:56:47,755
devices, did your items

4726
02:56:47,755 --> 02:56:50,155
that will communicate the

4727
02:56:51,693 --> 02:56:52,327
plte system, correct?

4728
02:56:52,327 --> 02:56:54,327
>> MR. Whitworth: that's

4729
02:56:56,331 --> 02:56:56,998
correct.

4730
02:56:56,998 --> 02:56:59,998
>> your plan is to modify,

4731
02:57:02,570 --> 02:57:03,400
your plan is to modify

4732
02:57:03,400 --> 02:57:03,538
existing capacitors

4733
02:57:03,538 --> 02:57:06,538
already out in the field

4734
02:57:07,909 --> 02:57:10,309
to communicate through the

4735
02:57:14,215 --> 02:57:14,883
plte system, correct?

4736
02:57:14,883 --> 02:57:15,383
>> MR. Whitworth: yes, we

4737
02:57:15,383 --> 02:57:15,917
have to modify existing

4738
02:57:15,917 --> 02:57:17,352
equipment and if there's

4739
02:57:17,352 --> 02:57:17,919
other equipment we might

4740
02:57:17,919 --> 02:57:21,222
have to modify and what we

4741
02:57:21,222 --> 02:57:21,790
install new we will have

4742
02:57:21,790 --> 02:57:22,323
the ability to communicate

4743
02:57:22,323 --> 02:57:24,723
through the solar network.

4744
02:57:26,161 --> 02:57:26,661
Again, witness lukcic can

4745
02:57:26,661 --> 02:57:29,610
provide all the details

4746
02:57:32,734 --> 02:57:33,233
around how that

4747
02:57:33,233 --> 02:57:33,768
communications network

4748
02:57:33,768 --> 02:57:34,101
will interact with these

4749
02:57:34,101 --> 02:57:36,101
field devices.

4750
02:57:38,773 --> 02:57:39,273
>> you will also replace

4751
02:57:39,273 --> 02:57:39,774
older automated lateral

4752
02:57:39,774 --> 02:57:40,908
switches and modify the

4753
02:57:40,908 --> 02:57:43,308
newer als switches to

4754
02:57:44,812 --> 02:57:46,800
enact the plte spectrum

4755
02:57:46,800 --> 02:57:48,800
system, correct?

4756
02:57:48,917 --> 02:57:49,484
That's the plan?

4757
02:57:49,484 --> 02:57:51,484
>> MR. Whitworth: if

4758
02:57:52,287 --> 02:57:52,620
necessary, yes.

4759
02:57:52,620 --> 02:57:54,620
>> okay.

4760
02:57:55,723 --> 02:57:58,123
Starting on page 36 of

4761
02:58:03,364 --> 02:58:03,830
your testimony.

4762
02:58:03,830 --> 02:58:04,332
When we get there I'm

4763
02:58:04,332 --> 02:58:07,332
going to be looking at

4764
02:58:08,336 --> 02:58:10,736
starting at line 19 and

4765
02:58:16,444 --> 02:58:17,679
through the top.

4766
02:58:17,679 --> 02:58:19,679
Okay.

4767
02:58:21,683 --> 02:58:22,250
You mention the projects

4768
02:58:22,250 --> 02:58:24,650
included in the subsequent

4769
02:58:26,720 --> 02:58:27,155
year adjustment in your

4770
02:58:27,155 --> 02:58:27,755
testimony, correct?

4771
02:58:27,755 --> 02:58:29,755
>> MR. Whitworth: I'm

4772
02:58:32,994 --> 02:58:33,294
sorry, which page and

4773
02:58:33,294 --> 02:58:33,862
which line?

4774
02:58:33,862 --> 02:58:34,362
>> looking at page 36

4775
02:58:34,362 --> 02:58:36,362
starting online 19 you

4776
02:58:42,937 --> 02:58:43,470
have a question protecting

4777
02:58:43,470 --> 02:58:44,400
capital investments in 26

4778
02:58:44,400 --> 02:58:44,572
and 27 that were going to

4779
02:58:44,572 --> 02:58:45,600
be proposed to be put into

4780
02:58:45,600 --> 02:58:45,306
the subsequent year

4781
02:58:45,306 --> 02:58:47,306
adjustments.

4782
02:58:47,408 --> 02:58:48,900
Do you see that?

4783
02:58:48,900 --> 02:58:50,409
>> MR. Whitworth: I do.

4784
02:58:51,813 --> 02:58:52,313
>> that was my question.

4785
02:58:52,313 --> 02:58:52,814
This is the portion of

4786
02:58:52,814 --> 02:58:54,814
your testimony starting

4787
02:59:07,995 --> 02:59:08,563
here and going to the next

4788
02:59:08,563 --> 02:59:09,290
page where you discuss the

4789
02:59:09,290 --> 02:59:09,564
projects that will be

4790
02:59:09,564 --> 02:59:09,931
included in the 26 and 27

4791
02:59:09,931 --> 02:59:10,398
subsequent year

4792
02:59:10,398 --> 02:59:10,999
adjustments, correct?

4793
02:59:10,999 --> 02:59:11,432
>> MR. Whitworth: no,

4794
02:59:11,432 --> 02:59:11,866
that's not correct.

4795
02:59:11,866 --> 02:59:12,232
My answer says the

4796
02:59:12,232 --> 02:59:12,667
subsequent year

4797
02:59:12,667 --> 02:59:13,134
adjustments will be

4798
02:59:13,134 --> 02:59:15,134
explained by witness

4799
02:59:22,944 --> 02:59:23,611
lukcic.

4800
02:59:23,611 --> 02:59:25,546
>> to a certain extent you

4801
02:59:25,546 --> 02:59:27,749
do include gr projects?

4802
02:59:27,749 --> 02:59:29,316
>> MR. Whitworth: yes, I

4803
02:59:29,316 --> 02:59:29,817
discussed the gr projects

4804
02:59:29,817 --> 02:59:32,217
in a strategic overall

4805
02:59:35,756 --> 02:59:36,123
level of what we plan to

4806
02:59:36,123 --> 02:59:36,624
achieve in them.

4807
02:59:36,624 --> 02:59:38,792
Specific details how we

4808
02:59:38,792 --> 02:59:39,327
plan to execute that and

4809
02:59:39,327 --> 02:59:41,727
in-service dates of those

4810
02:59:45,632 --> 02:59:45,967
are with witness lukcic.

4811
02:59:45,967 --> 02:59:46,500
>> okay.

4812
02:59:46,500 --> 02:59:49,500
Let's go back to document

4813
02:59:54,108 --> 02:59:54,308
seven.

4814
02:59:54,308 --> 02:59:55,276
Okay.

4815
02:59:55,276 --> 02:59:58,276
And you have green boxes

4816
02:59:59,113 --> 02:59:59,447
with a line for breaker

4817
02:59:59,447 --> 03:00:00,181
replacements.

4818
03:00:00,181 --> 03:00:02,183
You would agree that

4819
03:00:02,183 --> 03:00:04,183
replacement breakers, that

4820
03:00:06,187 --> 03:00:06,754
you replace breakers when

4821
03:00:06,754 --> 03:00:06,988
they are old and obsolete,

4822
03:00:06,988 --> 03:00:08,988
correct?

4823
03:00:12,600 --> 03:00:12,593
>> MR. Whitworth: not

4824
03:00:12,593 --> 03:00:13,600
necessarily when they are

4825
03:00:13,600 --> 03:00:14,862
old and obsolete, but

4826
03:00:14,862 --> 03:00:15,263
certainly when they become

4827
03:00:15,263 --> 03:00:17,263
nonfunctional and

4828
03:00:18,666 --> 03:00:19,100
nonserviceable we make an

4829
03:00:19,100 --> 03:00:21,500
attempt to do that.

4830
03:00:21,769 --> 03:00:22,269
This is referencing relays

4831
03:00:22,269 --> 03:00:24,669
that are not compatible

4832
03:00:30,912 --> 03:00:31,446
with the cellular

4833
03:00:31,446 --> 03:00:31,845
communication technology

4834
03:00:31,845 --> 03:00:32,246
and plans for our

4835
03:00:32,246 --> 03:00:32,847
modernized grade.

4836
03:00:32,847 --> 03:00:33,347
>> let me ask you this.

4837
03:00:33,347 --> 03:00:35,747
When you replace older

4838
03:00:36,830 --> 03:00:36,617
breakers for whatever the

4839
03:00:36,617 --> 03:00:37,118
reason and put them into

4840
03:00:37,118 --> 03:00:37,652
service in between rate

4841
03:00:37,652 --> 03:00:40,520
cases, that would become

4842
03:00:40,621 --> 03:00:41,956
part of rate base that's

4843
03:00:41,956 --> 03:00:43,324
covered in the next rate

4844
03:00:43,324 --> 03:00:45,324
case.

4845
03:00:49,964 --> 03:00:50,231
Without me correct to your

4846
03:00:50,231 --> 03:00:50,831
knowledge?

4847
03:00:50,831 --> 03:00:51,431
>> MR. Whitworth: yes.

4848
03:00:51,431 --> 03:00:53,831
>> looking at the green

4849
03:00:56,837 --> 03:00:57,338
line for power transformer

4850
03:00:57,338 --> 03:00:57,872
replacement, you would

4851
03:00:57,872 --> 03:00:58,372
agree that you upgrade or

4852
03:00:58,372 --> 03:00:58,806
build out transformers

4853
03:00:58,806 --> 03:00:59,272
relative to teco's

4854
03:00:59,272 --> 03:01:01,272
customer planning and

4855
03:01:06,146 --> 03:01:06,713
growth in demand, right?

4856
03:01:06,713 --> 03:01:06,913
>> MR. Whitworth: I

4857
03:01:06,913 --> 03:01:07,281
would.

4858
03:01:07,281 --> 03:01:07,748
We do overhead

4859
03:01:07,748 --> 03:01:09,748
distillation planning

4860
03:01:12,787 --> 03:01:13,540
according to a city state

4861
03:01:13,540 --> 03:01:13,688
criteria.

4862
03:01:13,688 --> 03:01:16,688
>> you would also in the

4863
03:01:19,159 --> 03:01:20,962
agree -- put it into

4864
03:01:20,962 --> 03:01:21,462
service sween rate cases

4865
03:01:21,462 --> 03:01:21,862
it becomes part of rate

4866
03:01:21,862 --> 03:01:24,262
base that is then

4867
03:01:25,599 --> 03:01:28,599
recovered in the next base

4868
03:01:30,304 --> 03:01:32,304
rate, correct?

4869
03:01:33,700 --> 03:01:35,407
>> MR. Whitworth: that is

4870
03:01:40,548 --> 03:01:42,548
correct.

4871
03:01:44,418 --> 03:01:46,200
>> let me take you to opc

4872
03:01:46,200 --> 03:01:48,420
exhibit to opc exhibit

4873
03:01:51,725 --> 03:01:53,725
145, I believe is

4874
03:01:59,500 --> 03:02:01,500
f2.27210.

4875
03:02:05,606 --> 03:02:06,741
Are you familiar with this

4876
03:02:06,741 --> 03:02:07,340
document?

4877
03:02:07,340 --> 03:02:07,942
>> MR. Whitworth: I am.

4878
03:02:07,942 --> 03:02:09,610
>> and can we have you

4879
03:02:09,610 --> 03:02:12,610
look at page 3 of this

4880
03:02:24,491 --> 03:02:26,491
document?

4881
03:02:27,695 --> 03:02:27,962
And let me know when you

4882
03:02:27,962 --> 03:02:28,562
get there.

4883
03:02:28,562 --> 03:02:30,562
>> MR. Whitworth: I'm

4884
03:02:30,698 --> 03:02:31,132
there.

4885
03:02:31,132 --> 03:02:31,632
>> wonderful.

4886
03:02:31,632 --> 03:02:33,900
And if you look at the

4887
03:02:33,900 --> 03:02:34,368
bottom of that document

4888
03:02:34,368 --> 03:02:36,768
you see project risk

4889
03:02:37,438 --> 03:02:39,438
assessment header.

4890
03:02:42,109 --> 03:02:42,443
>> MR. Whitworth: I do.

4891
03:02:42,443 --> 03:02:43,677
>> okay.

4892
03:02:43,677 --> 03:02:46,213
You would agree that the

4893
03:02:46,213 --> 03:02:48,613
third bullet down talks

4894
03:02:48,682 --> 03:02:51,682
about the risk of material

4895
03:02:52,787 --> 03:02:53,353
shortages, correct?

4896
03:02:53,353 --> 03:02:53,553
>> MR. Whitworth: it

4897
03:02:53,553 --> 03:02:54,154
does.

4898
03:02:54,154 --> 03:02:56,554
>> if you look further

4899
03:02:56,757 --> 03:02:57,224
down about the for the

4900
03:02:57,224 --> 03:02:59,624
bullet is as program

4901
03:02:59,927 --> 03:03:00,393
benefits are not achieved

4902
03:03:00,393 --> 03:03:01,962
on specific timelines.

4903
03:03:01,962 --> 03:03:02,263
Is there another risk you

4904
03:03:02,263 --> 03:03:04,263
identified?

4905
03:03:07,334 --> 03:03:07,568
>> MR. Whitworth: that is

4906
03:03:07,568 --> 03:03:08,202
correct.

4907
03:03:08,202 --> 03:03:08,769
>> and an additional risk

4908
03:03:08,769 --> 03:03:11,705
that you identified is the

4909
03:03:11,705 --> 03:03:12,239
pace of change exceeds the

4910
03:03:12,239 --> 03:03:14,239
organizations ability to

4911
03:03:15,676 --> 03:03:18,676
adapt and you called that

4912
03:03:21,248 --> 03:03:21,782
change fatigue, correct?

4913
03:03:21,782 --> 03:03:22,160
>> MR. Whitworth:

4914
03:03:22,160 --> 03:03:22,549
correct.

4915
03:03:22,549 --> 03:03:23,830
>> another risk you

4916
03:03:23,830 --> 03:03:24,510
identified related to the

4917
03:03:24,510 --> 03:03:27,510
gr are programs is the

4918
03:03:27,154 --> 03:03:27,655
cost changing on

4919
03:03:27,655 --> 03:03:29,655
ecstatically over time,

4920
03:03:29,956 --> 03:03:30,491
correct?

4921
03:03:30,491 --> 03:03:30,724
>> MR. Whitworth:

4922
03:03:30,724 --> 03:03:31,258
correct.

4923
03:03:31,258 --> 03:03:34,258
What I really like about

4924
03:03:40,670 --> 03:03:40,601
this list shows the

4925
03:03:40,601 --> 03:03:41,101
company's forethought in

4926
03:03:41,101 --> 03:03:41,635
understanding the risk

4927
03:03:41,635 --> 03:03:42,360
before we enter a capital

4928
03:03:42,360 --> 03:03:42,603
project like this.

4929
03:03:42,603 --> 03:03:42,936
Before we even started, we

4930
03:03:42,936 --> 03:03:43,470
mapped it out.

4931
03:03:43,470 --> 03:03:45,306
We communicate it to our

4932
03:03:45,306 --> 03:03:45,672
leaders, staff, and we are

4933
03:03:45,672 --> 03:03:46,106
mapping out in

4934
03:03:46,106 --> 03:03:48,106
understanding what

4935
03:03:55,616 --> 03:03:56,116
mitigation plans do we put

4936
03:03:56,116 --> 03:03:56,317
in place to avoid this

4937
03:03:56,317 --> 03:03:56,851
risk?

4938
03:03:56,851 --> 03:03:57,184
We are thinking about it

4939
03:03:57,184 --> 03:03:57,718
ahead of time.

4940
03:03:57,718 --> 03:03:58,219
This is a testament to us

4941
03:03:58,219 --> 03:03:58,819
how we achieve success.

4942
03:03:58,819 --> 03:04:00,120
>> finally, one of the

4943
03:04:00,120 --> 03:04:00,654
other risks that you

4944
03:04:00,654 --> 03:04:02,654
identified is technology

4945
03:04:07,161 --> 03:04:07,695
and standards changeover

4946
03:04:07,695 --> 03:04:08,610
program life among other

4947
03:04:08,610 --> 03:04:08,596
risks, correct?

4948
03:04:08,596 --> 03:04:08,828
>> MR. Whitworth:

4949
03:04:08,828 --> 03:04:09,463
correct.

4950
03:04:09,463 --> 03:04:11,598
>> if I can have you look

4951
03:04:11,598 --> 03:04:14,598
back on page 24 of your

4952
03:04:24,845 --> 03:04:26,146
direct testimony.

4953
03:04:26,146 --> 03:04:28,146
And specifically I'm

4954
03:04:38,859 --> 03:04:41,259
looking at line 10-14.

4955
03:04:43,530 --> 03:04:46,530
You mention in always on

4956
03:04:48,101 --> 03:04:48,468
experience.

4957
03:04:48,468 --> 03:04:49,690
Do you see that?

4958
03:04:49,690 --> 03:04:49,736
>> MR. Whitworth: I do.

4959
03:04:49,736 --> 03:04:50,270
>> are you warranting that

4960
03:04:50,270 --> 03:04:52,670
customers will never lose

4961
03:04:58,379 --> 03:04:58,812
serious -- service if the

4962
03:04:58,812 --> 03:04:59,113
chief rre is never

4963
03:04:59,113 --> 03:04:59,712
implemented?

4964
03:04:59,712 --> 03:04:59,880
>> MR. Whitworth: I am

4965
03:04:59,880 --> 03:05:00,513
not.

4966
03:05:00,513 --> 03:05:01,181
>> am I correctly believe

4967
03:05:01,181 --> 03:05:01,682
the gr projects are giving

4968
03:05:01,682 --> 03:05:03,682
the distribution system

4969
03:05:03,817 --> 03:05:05,520
the brain whereas the spp

4970
03:05:05,520 --> 03:05:07,452
or the physical aspects

4971
03:05:10,824 --> 03:05:11,491
that are being replaced?

4972
03:05:11,491 --> 03:05:11,725
>> MR. Whitworth: that is

4973
03:05:11,725 --> 03:05:12,326
correct.

4974
03:05:12,326 --> 03:05:14,228
>> and you would agree

4975
03:05:14,228 --> 03:05:14,695
that there is a --

4976
03:05:14,695 --> 03:05:16,695
component, mechanical

4977
03:05:17,498 --> 03:05:20,134
devices that are going out

4978
03:05:20,134 --> 03:05:20,801
into the field, correct?

4979
03:05:20,801 --> 03:05:23,201
>> MR. Whitworth: that is

4980
03:05:23,303 --> 03:05:23,871
correct.

4981
03:05:23,871 --> 03:05:26,271
The mechanical devices are

4982
03:05:26,807 --> 03:05:27,240
installed since the crews

4983
03:05:27,240 --> 03:05:29,640
are there, they are

4984
03:05:30,377 --> 03:05:30,878
mobilized, they are

4985
03:05:30,878 --> 03:05:31,770
already performing the

4986
03:05:31,770 --> 03:05:31,544
work.

4987
03:05:31,544 --> 03:05:32,745
It's just a matter of

4988
03:05:32,745 --> 03:05:34,514
efficiency to have them

4989
03:05:34,514 --> 03:05:36,914
installed hardware and the

4990
03:05:41,522 --> 03:05:44,522
gr are welcome and --

4991
03:05:51,431 --> 03:05:54,431
>> can you tell me what

4992
03:05:55,335 --> 03:05:55,869
frf --

4993
03:05:55,869 --> 03:05:57,137
>> MR. Whitworth: yes, I

4994
03:05:57,137 --> 03:05:58,838
would.

4995
03:05:58,838 --> 03:06:00,307
>> you mainly rely on

4996
03:06:00,307 --> 03:06:02,707
alabama power as an

4997
03:06:03,143 --> 03:06:05,143
example of utility

4998
03:06:05,245 --> 03:06:07,645
development of a private

4999
03:06:10,751 --> 03:06:11,585
lte communication network

5000
03:06:11,585 --> 03:06:11,919
and flssr technology, is

5001
03:06:11,919 --> 03:06:13,919
that correct?

5002
03:06:17,958 --> 03:06:18,391
>> MR. Whitworth: no,

5003
03:06:18,391 --> 03:06:18,925
that is not correct.

5004
03:06:18,925 --> 03:06:19,426
We have a team of people

5005
03:06:19,426 --> 03:06:19,960
and staff of people who

5006
03:06:19,960 --> 03:06:21,528
evaluate this technology.

5007
03:06:21,528 --> 03:06:21,995
It's a proven technology

5008
03:06:21,995 --> 03:06:22,529
that's been installed

5009
03:06:22,529 --> 03:06:24,929
throughout the us and

5010
03:06:30,204 --> 03:06:32,205
alabama is one example of

5011
03:06:32,205 --> 03:06:32,739
an iou nearby, but there

5012
03:06:32,739 --> 03:06:35,139
are many examples across

5013
03:06:38,445 --> 03:06:40,845
the country of this.

5014
03:06:46,854 --> 03:06:47,387
>> this is the one you

5015
03:06:47,387 --> 03:06:47,588
have the most familiarity

5016
03:06:47,588 --> 03:06:48,188
with?

5017
03:06:48,188 --> 03:06:48,689
>> MR. Whitworth: that

5018
03:06:48,689 --> 03:06:48,988
would be the company I

5019
03:06:48,988 --> 03:06:49,489
visit with.

5020
03:06:49,489 --> 03:06:51,291
>> is it true the

5021
03:06:51,291 --> 03:06:51,825
affiliate company in

5022
03:06:51,825 --> 03:06:54,225
canada nova scotia power

5023
03:06:55,462 --> 03:06:55,963
does not have a gr program

5024
03:06:55,963 --> 03:06:58,310
or private network, to

5025
03:06:58,310 --> 03:07:00,310
your knowledge?

5026
03:07:00,400 --> 03:07:00,734
>> MR. Whitworth: not to

5027
03:07:00,734 --> 03:07:02,734
my knowledge.

5028
03:07:06,272 --> 03:07:09,750
>> the gr rp is prudent,

5029
03:07:09,750 --> 03:07:11,750
correct?

5030
03:07:12,879 --> 03:07:13,413
>> MR. Whitworth: we are

5031
03:07:13,413 --> 03:07:14,781
only seeking a portion of

5032
03:07:14,781 --> 03:07:16,917
the gr are project in its

5033
03:07:16,917 --> 03:07:18,917
entirety.

5034
03:07:19,186 --> 03:07:20,420
David lukcic can speak to

5035
03:07:20,420 --> 03:07:22,420
that.

5036
03:07:27,361 --> 03:07:29,610
>> it will not go into

5037
03:07:29,610 --> 03:07:31,610
service until after 2027,

5038
03:07:32,599 --> 03:07:34,468
teco will come back in the

5039
03:07:34,468 --> 03:07:35,100
future and ask for psc

5040
03:07:35,100 --> 03:07:37,100
authorization to recover

5041
03:07:38,805 --> 03:07:39,339
those costs later?

5042
03:07:39,339 --> 03:07:39,573
>> MR. Whitworth:

5043
03:07:39,573 --> 03:07:41,374
correct.

5044
03:07:41,374 --> 03:07:41,875
Whatever is not allowed in

5045
03:07:41,875 --> 03:07:44,275
2025, that will be for

5046
03:07:48,115 --> 03:07:48,715
another rate case.

5047
03:07:48,715 --> 03:07:49,249
>> you are not seeking

5048
03:07:49,249 --> 03:07:49,916
continual progress beyond

5049
03:07:49,916 --> 03:07:53,516
what you are asking for in

5050
03:07:53,720 --> 03:07:54,254
2027, correct?

5051
03:07:54,254 --> 03:07:54,488
>> MR. Whitworth:

5052
03:07:54,488 --> 03:07:55,550
correct.

5053
03:07:55,550 --> 03:07:57,455
>> I have no further

5054
03:07:58,692 --> 03:07:58,959
questions.

5055
03:07:58,959 --> 03:07:59,526
Thank you.

5056
03:07:59,526 --> 03:07:59,793
>> CHAIRMAN La Rosa:

5057
03:07:59,793 --> 03:08:01,793
thank you.

5058
03:08:06,633 --> 03:08:07,267
Florida rising, lulac.

5059
03:08:07,267 --> 03:08:07,701
>> good after -- I think

5060
03:08:07,701 --> 03:08:08,135
it's afternoon now.

5061
03:08:08,135 --> 03:08:08,401
Good afternoon, MR.

5062
03:08:08,401 --> 03:08:09,200
Whitworth.

5063
03:08:09,200 --> 03:08:11,200
>> MR. Whitworth: good

5064
03:08:13,472 --> 03:08:13,874
morning, or afternoon.

5065
03:08:13,874 --> 03:08:15,874
Whatever you want.

5066
03:08:19,279 --> 03:08:19,646
>> I think we met during

5067
03:08:19,646 --> 03:08:20,470
the depositions.

5068
03:08:20,470 --> 03:08:20,313
I have just a few

5069
03:08:20,313 --> 03:08:20,881
questions.

5070
03:08:20,881 --> 03:08:25,810
I'm going to try not to be

5071
03:08:25,886 --> 03:08:26,453
repetitive with the

5072
03:08:26,453 --> 03:08:26,752
questions MS. Christiansen

5073
03:08:26,752 --> 03:08:28,752
just asked.

5074
03:08:34,894 --> 03:08:35,562
I will direct you to your

5075
03:08:35,562 --> 03:08:37,562
-- actually, speaking

5076
03:08:39,900 --> 03:08:40,467
generally about your

5077
03:08:40,467 --> 03:08:41,100
testimony, you did look at

5078
03:08:41,100 --> 03:08:43,401
sort of long-term trends

5079
03:08:44,271 --> 03:08:46,671
of the grid reliability

5080
03:08:47,720 --> 03:08:48,674
project.

5081
03:08:48,674 --> 03:08:50,674
>> we did, yes.

5082
03:08:51,478 --> 03:08:52,120
>> thank you.

5083
03:08:52,120 --> 03:08:55,612
I will direct you to this

5084
03:08:59,185 --> 03:09:01,585
is staff exhibit 181 staff

5085
03:09:02,121 --> 03:09:04,121
exhibit 181e4022.

5086
03:09:04,591 --> 03:09:06,260
And if we can rotate it

5087
03:09:06,260 --> 03:09:08,260
.

5088
03:09:11,264 --> 03:09:12,732
Perfect.

5089
03:09:12,732 --> 03:09:14,434
Just scrolling down to

5090
03:09:14,434 --> 03:09:16,603
where there are the key

5091
03:09:16,603 --> 03:09:19,300
bullet points or key

5092
03:09:19,390 --> 03:09:21,390
observations, the first

5093
03:09:22,275 --> 03:09:24,675
bullet point does state

5094
03:09:31,218 --> 03:09:31,750
that teco has maintained

5095
03:09:31,750 --> 03:09:32,319
second place in the state

5096
03:09:32,319 --> 03:09:32,819
in the last few years with

5097
03:09:32,819 --> 03:09:34,819
minimal reliability and

5098
03:09:35,688 --> 03:09:37,688
proactive preventability

5099
03:09:39,893 --> 03:09:40,560
maidens programs, correct?

5100
03:09:40,560 --> 03:09:40,793
>> MR. Whitworth: that is

5101
03:09:40,793 --> 03:09:42,793
correct.

5102
03:09:48,301 --> 03:09:48,735
>> now I would like to

5103
03:09:48,735 --> 03:09:49,235
direct you to your

5104
03:09:49,235 --> 03:09:49,669
testimony particularly

5105
03:09:49,669 --> 03:09:52,690
this is master page

5106
03:10:02,115 --> 03:10:02,648
c6-938.

5107
03:10:02,648 --> 03:10:06,248
If we can scroll down to

5108
03:10:06,386 --> 03:10:08,786
lines 13 and -- yeah.

5109
03:10:18,630 --> 03:10:18,265
Lines 13.

5110
03:10:18,265 --> 03:10:20,265
Sorry.

5111
03:10:27,673 --> 03:10:29,673
C6-938.

5112
03:10:32,679 --> 03:10:33,847
Okay.

5113
03:10:33,847 --> 03:10:35,847
Sorry.

5114
03:11:10,830 --> 03:11:12,830
Oh, 398.

5115
03:11:13,620 --> 03:11:13,719
My own device is

5116
03:11:13,719 --> 03:11:15,719
.

5117
03:11:17,423 --> 03:11:19,423
[Indiscernible] Generally

5118
03:11:21,728 --> 03:11:23,728
speaking, the reliability

5119
03:11:25,865 --> 03:11:28,265
project is reported to

5120
03:11:30,303 --> 03:11:30,536
benefit customers,

5121
03:11:30,536 --> 03:11:31,170
correct?

5122
03:11:31,170 --> 03:11:33,170
>> MR. Whitworth: that's

5123
03:11:34,307 --> 03:11:34,741
correct.

5124
03:11:34,741 --> 03:11:36,741
>> thank you.

5125
03:11:41,214 --> 03:11:44,814
If we can pull up fll 265,

5126
03:11:45,840 --> 03:11:47,484
which is master number

5127
03:12:00,333 --> 03:12:02,333
f3.5-4488.

5128
03:12:04,571 --> 03:12:07,440
And these are I feel like

5129
03:12:07,440 --> 03:12:10,440
I'm going to say this

5130
03:12:12,345 --> 03:12:14,345
incorrectly, the mife

5131
03:12:15,815 --> 03:12:18,215
numbers regarding the --

5132
03:12:26,526 --> 03:12:27,920
project.

5133
03:12:27,920 --> 03:12:27,593
>> MR. Whitworth: it

5134
03:12:27,593 --> 03:12:28,795
looks like based on the

5135
03:12:28,795 --> 03:12:31,795
title this is the data

5136
03:12:32,332 --> 03:12:35,932
that was used for the ice

5137
03:12:40,173 --> 03:12:40,740
calculator.

5138
03:12:40,740 --> 03:12:41,307
>> thank you so much.

5139
03:12:41,307 --> 03:12:41,841
If you look under column b

5140
03:12:41,841 --> 03:12:42,341
it shows that residential

5141
03:12:42,341 --> 03:12:44,741
customers have a total

5142
03:12:46,120 --> 03:12:46,646
benefit of 6%.

5143
03:12:46,646 --> 03:12:46,879
>> MR. Whitworth: that's

5144
03:12:46,879 --> 03:12:48,879
correct.

5145
03:12:49,348 --> 03:12:51,748
>> and 94% would be going

5146
03:12:54,854 --> 03:12:56,854
towards other customers?

5147
03:12:59,157 --> 03:13:00,960
>> small cni, medium, and

5148
03:13:00,960 --> 03:13:02,960
large cni.

5149
03:13:03,362 --> 03:13:03,896
>> would you agree that

5150
03:13:03,896 --> 03:13:05,896
residential customers are

5151
03:13:08,467 --> 03:13:08,801
the vast majority of teco'

5152
03:13:08,801 --> 03:13:09,468
is customers?

5153
03:13:09,468 --> 03:13:09,936
>> MR. Whitworth: I would

5154
03:13:09,936 --> 03:13:11,938
say we have a higher

5155
03:13:11,938 --> 03:13:12,405
number of residential

5156
03:13:12,405 --> 03:13:14,405
customers, yes, then

5157
03:13:15,775 --> 03:13:16,109
commercial customers.

5158
03:13:16,109 --> 03:13:16,376
>> okay.

5159
03:13:16,376 --> 03:13:18,376
Thank you.

5160
03:13:19,746 --> 03:13:20,280
I'm not going to pull up

5161
03:13:20,280 --> 03:13:22,680
fll 266, which is master

5162
03:13:24,484 --> 03:13:27,484
number f fll 266, which is

5163
03:13:43,269 --> 03:13:45,505
master number f3.5-24492.

5164
03:13:45,505 --> 03:13:46,439
And once again might not

5165
03:13:46,439 --> 03:13:48,839
say this correctly, but

5166
03:13:58,584 --> 03:14:00,984
this shows the sadie

5167
03:14:13,700 --> 03:14:15,700
benefits?

5168
03:14:19,205 --> 03:14:19,705
>> MR. Whitworth: the

5169
03:14:19,705 --> 03:14:20,706
improvements look more

5170
03:14:20,706 --> 03:14:22,706
like customer minutes

5171
03:14:24,176 --> 03:14:25,211
improvements more so than

5172
03:14:25,211 --> 03:14:27,211
sadie improvements.

5173
03:14:27,213 --> 03:14:30,213
>> with the title of the

5174
03:14:30,216 --> 03:14:32,616
document jog your memory

5175
03:14:33,786 --> 03:14:34,287
on the top where it has

5176
03:14:34,287 --> 03:14:36,687
the bate stamp numbers?

5177
03:14:38,625 --> 03:14:38,824
>> MR. Whitworth: it

5178
03:14:38,824 --> 03:14:40,824
does.

5179
03:14:42,161 --> 03:14:42,427
Is is adi sadie ice

5180
03:14:42,427 --> 03:14:42,962
benefits.

5181
03:14:42,962 --> 03:14:46,562
Just not how I'm used to

5182
03:14:49,435 --> 03:14:49,802
seeing that data.

5183
03:14:49,802 --> 03:14:50,369
>> got it.

5184
03:14:50,369 --> 03:14:51,738
But if I can direct you to

5185
03:14:51,738 --> 03:14:52,238
column b third line this

5186
03:14:52,238 --> 03:14:52,739
shows that residential

5187
03:14:52,739 --> 03:14:55,139
customers have a total

5188
03:15:03,983 --> 03:15:04,584
benefit of 5%, correct?

5189
03:15:04,584 --> 03:15:06,551
>> MR. Whitworth: I do

5190
03:15:06,551 --> 03:15:09,551
not see 5% on this page.

5191
03:15:11,230 --> 03:15:14,623
>> are you on -- if you

5192
03:15:18,130 --> 03:15:20,130
scroll up,

5193
03:15:22,134 --> 03:15:22,368
>> MR. Whitworth: okay.

5194
03:15:22,368 --> 03:15:23,869
Yes, 5%.

5195
03:15:23,869 --> 03:15:26,269
>> thank you so much.

5196
03:15:27,720 --> 03:15:30,672
i believe those are all my

5197
03:15:31,844 --> 03:15:32,111
questions, MR. Whitworth.

5198
03:15:32,111 --> 03:15:32,678
Thank you.

5199
03:15:32,678 --> 03:15:34,678
>> CHAIRMAN La Rosa:

5200
03:15:35,681 --> 03:15:35,882
thank you.

5201
03:15:35,882 --> 03:15:36,382
Fipug.

5202
03:15:36,382 --> 03:15:37,884
>> thank you, MR.

5203
03:15:37,884 --> 03:15:38,384
CHAIRMAN.

5204
03:15:38,384 --> 03:15:40,286
Just a couple of quick

5205
03:15:40,286 --> 03:15:40,620
questions.

5206
03:15:40,620 --> 03:15:41,153
Good morning.

5207
03:15:41,153 --> 03:15:41,487
>> MR. Whitworth:

5208
03:15:41,487 --> 03:15:43,487
morning.

5209
03:15:44,890 --> 03:15:46,626
>> MR. Moyle: I had asked

5210
03:15:46,626 --> 03:15:49,495
a question about the smart

5211
03:15:49,495 --> 03:15:50,620
grid.

5212
03:15:50,620 --> 03:15:50,829
I'm interested in learning

5213
03:15:50,829 --> 03:15:53,829
a little bit more about

5214
03:15:56,101 --> 03:15:57,370
that and in particular

5215
03:15:57,370 --> 03:15:59,171
when do you believe you'll

5216
03:15:59,171 --> 03:16:02,171
have the ability for the

5217
03:16:03,308 --> 03:16:05,678
grid to notify the company

5218
03:16:05,678 --> 03:16:07,980
of an outage as compared

5219
03:16:07,980 --> 03:16:10,380
to customers having to

5220
03:16:11,517 --> 03:16:12,180
call and say hey, I have

5221
03:16:12,180 --> 03:16:14,520
an outage, can you come

5222
03:16:14,520 --> 03:16:14,986
fix it?

5223
03:16:14,986 --> 03:16:15,921
It seems like there's

5224
03:16:15,921 --> 03:16:16,289
evidence that suggests

5225
03:16:16,289 --> 03:16:18,289
that's a pretty

5226
03:16:19,158 --> 03:16:20,425
significant timepiece to

5227
03:16:20,425 --> 03:16:23,425
have a customer call and

5228
03:16:26,650 --> 03:16:26,432
then that message get

5229
03:16:26,432 --> 03:16:26,999
translated down?

5230
03:16:26,999 --> 03:16:27,500
I'm just looking for maybe

5231
03:16:27,500 --> 03:16:29,302
a narrative answer with

5232
03:16:29,302 --> 03:16:29,935
respect to the timing of

5233
03:16:29,935 --> 03:16:31,935
that and generally

5234
03:16:32,838 --> 03:16:33,380
speaking how it would

5235
03:16:33,380 --> 03:16:35,380
work.

5236
03:16:35,274 --> 03:16:36,875
>> MR. Whitworth: I did

5237
03:16:36,875 --> 03:16:38,875
hear witness sparkman's

5238
03:16:43,482 --> 03:16:43,949
testimony yesterday.

5239
03:16:43,949 --> 03:16:44,216
I'm familiar with the

5240
03:16:44,216 --> 03:16:44,783
question.

5241
03:16:44,783 --> 03:16:45,318
We do currently today have

5242
03:16:45,318 --> 03:16:48,318
the ability to know when

5243
03:16:48,921 --> 03:16:51,157
an entire circuit is out,

5244
03:16:51,157 --> 03:16:52,991
which translates to

5245
03:16:52,991 --> 03:16:53,559
customer outage as well.

5246
03:16:53,559 --> 03:16:54,600
we also have ami data that

5247
03:16:54,600 --> 03:16:55,528
comes through a system

5248
03:16:55,528 --> 03:16:57,928
that aggregates that shows

5249
03:16:59,899 --> 03:17:00,399
hey, these meters are out.

5250
03:17:00,399 --> 03:17:00,599
There MAY be a problem

5251
03:17:00,599 --> 03:17:02,134
here.

5252
03:17:02,134 --> 03:17:04,704
That coupled with a call

5253
03:17:04,704 --> 03:17:05,237
from a customer allows us

5254
03:17:05,237 --> 03:17:07,637
to troubleshoot from the

5255
03:17:08,874 --> 03:17:09,800
appropriate

5256
03:17:09,800 --> 03:17:09,542
.

5257
03:17:09,542 --> 03:17:12,542
We are not totally blind,

5258
03:17:14,814 --> 03:17:15,214
but not as specific as we

5259
03:17:15,214 --> 03:17:17,614
would like to get.

5260
03:17:22,321 --> 03:17:22,855
Something that witness

5261
03:17:22,855 --> 03:17:23,355
david lukcic can get at,

5262
03:17:23,355 --> 03:17:23,855
we expect to have that

5263
03:17:23,855 --> 03:17:24,389
technology to pinpoint

5264
03:17:24,389 --> 03:17:26,459
precisely where an outage

5265
03:17:26,459 --> 03:17:28,327
is and have the ability to

5266
03:17:28,327 --> 03:17:28,794
dispatch troubleshooters

5267
03:17:28,794 --> 03:17:31,194
and repair workers to

5268
03:17:36,902 --> 03:17:37,469
expedite those repairs.

5269
03:17:37,469 --> 03:17:38,300
>> MR. Moyle: just a

5270
03:17:38,300 --> 03:17:38,204
follow-up on the dispatch

5271
03:17:38,204 --> 03:17:38,738
piece.

5272
03:17:38,738 --> 03:17:39,270
Is that also projected to

5273
03:17:39,270 --> 03:17:41,507
be taking place at some

5274
03:17:41,507 --> 03:17:43,907
future point in time?

5275
03:17:44,276 --> 03:17:46,276
You referenced 2030, but

5276
03:17:47,146 --> 03:17:48,180
that would be done without

5277
03:17:48,180 --> 03:17:50,150
human beings being

5278
03:17:50,150 --> 03:17:50,483
involved?

5279
03:17:50,483 --> 03:17:53,483
You would just send a

5280
03:17:55,921 --> 03:17:56,422
message and go to a

5281
03:17:56,422 --> 03:17:56,922
message and no passing

5282
03:17:56,922 --> 03:17:58,922
along messages through

5283
03:17:59,225 --> 03:18:00,592
humans?

5284
03:18:00,592 --> 03:18:02,992
>> MR. Whitworth: as we

5285
03:18:11,504 --> 03:18:12,700
begin flssr, the

5286
03:18:12,700 --> 03:18:13,973
technology will be able to

5287
03:18:13,973 --> 03:18:16,973
detect an anomaly on the

5288
03:18:17,610 --> 03:18:18,143
grid or outage,

5289
03:18:18,143 --> 03:18:20,143
automatically restore as

5290
03:18:21,513 --> 03:18:21,880
many customers as possible

5291
03:18:21,880 --> 03:18:22,381
prior to human

5292
03:18:22,381 --> 03:18:23,449
intervention, and also

5293
03:18:23,449 --> 03:18:25,849
pinpoint where the fault

5294
03:18:29,155 --> 03:18:29,722
location is where we can

5295
03:18:29,722 --> 03:18:32,122
roll resources directly to

5296
03:18:32,558 --> 03:18:33,158
that location for repair.

5297
03:18:33,158 --> 03:18:34,192
>> MR. Moyle: and with

5298
03:18:34,192 --> 03:18:37,192
respect to where you are

5299
03:18:37,329 --> 03:18:37,796
rolling this system out,

5300
03:18:37,796 --> 03:18:39,796
are you prioritizing

5301
03:18:40,899 --> 03:18:41,432
circuits that say have

5302
03:18:41,432 --> 03:18:42,000
Mcdill air force base or

5303
03:18:42,000 --> 03:18:44,000
tampa general hospital

5304
03:18:45,271 --> 03:18:45,704
airport in a way so that

5305
03:18:45,704 --> 03:18:47,704
your more critical

5306
03:18:49,274 --> 03:18:51,674
infrastructure is going to

5307
03:18:53,511 --> 03:18:54,790
be plugged in first?

5308
03:18:54,790 --> 03:18:54,646
>> MR. Whitworth: we

5309
03:18:54,646 --> 03:18:55,180
currently do have customer

5310
03:18:55,180 --> 03:18:57,180
reliability programs for

5311
03:18:58,500 --> 03:19:01,500
folks like the airport or

5312
03:19:02,540 --> 03:19:02,421
tgh hospital and those

5313
03:19:02,421 --> 03:19:02,955
types of things.

5314
03:19:02,955 --> 03:19:04,890
Even walmart distribution

5315
03:19:04,890 --> 03:19:06,489
center where we track

5316
03:19:06,859 --> 03:19:09,259
those assets very closely

5317
03:19:09,995 --> 03:19:10,529
in the performance of

5318
03:19:10,529 --> 03:19:13,529
those already and we have

5319
03:19:15,134 --> 03:19:15,634
alarms and substation

5320
03:19:15,634 --> 03:19:16,101
alarms that come to the

5321
03:19:16,101 --> 03:19:17,736
control room on that

5322
03:19:17,736 --> 03:19:18,203
particular infrastructure.

5323
03:19:18,203 --> 03:19:19,710
As we roll out flisr

5324
03:19:19,710 --> 03:19:22,710
through gr are it's going

5325
03:19:26,578 --> 03:19:27,112
to -- as lims towers go in

5326
03:19:27,112 --> 03:19:27,579
we will then deploy field

5327
03:19:27,579 --> 03:19:28,514
devices and such that

5328
03:19:28,514 --> 03:19:30,514
follow that tower

5329
03:19:32,818 --> 03:19:33,385
construction and start to

5330
03:19:33,385 --> 03:19:33,619
bring that technology into

5331
03:19:33,619 --> 03:19:34,152
control.

5332
03:19:34,152 --> 03:19:34,586
>> MR. Moyle: just

5333
03:19:34,586 --> 03:19:36,986
briefly on the cell

5334
03:19:41,260 --> 03:19:41,559
network, is that going to

5335
03:19:41,559 --> 03:19:42,127
be a cell network that is

5336
03:19:42,127 --> 03:19:42,661
exclusive to teco's use or

5337
03:19:42,661 --> 03:19:43,162
a cell network that third

5338
03:19:43,162 --> 03:19:45,497
parties will be able to

5339
03:19:45,497 --> 03:19:46,165
use or something else?

5340
03:19:46,165 --> 03:19:49,165
>> MR. Whitworth: it is a

5341
03:19:50,436 --> 03:19:50,903
private cellular network

5342
03:19:50,903 --> 03:19:51,269
and was evaluated for

5343
03:19:51,269 --> 03:19:51,970
several reasons.

5344
03:19:51,970 --> 03:19:55,570
How we limit on that and

5345
03:19:55,607 --> 03:19:56,108
one of the biggest drivers

5346
03:19:56,108 --> 03:19:59,108
is that is more secure.

5347
03:19:59,211 --> 03:19:59,678
A much more secure way of

5348
03:19:59,678 --> 03:20:01,678
communication between

5349
03:20:04,950 --> 03:20:05,217
devices and data

5350
03:20:05,217 --> 03:20:05,850
transfers.

5351
03:20:05,850 --> 03:20:06,318
>> MR. Moyle: that's all

5352
03:20:06,318 --> 03:20:08,718
the questions I have.

5353
03:20:10,756 --> 03:20:13,156
>> CHAIRMAN La Rosa: fea.

5354
03:20:13,759 --> 03:20:15,494
>> no questions from fea.

5355
03:20:15,494 --> 03:20:15,794
>> CHAIRMAN La Rosa:

5356
03:20:15,794 --> 03:20:17,729
sierra club?

5357
03:20:17,729 --> 03:20:19,665
>> thank you, MR.

5358
03:20:19,665 --> 03:20:20,650
CHAIRMAN.

5359
03:20:20,650 --> 03:20:23,100
I have just a few

5360
03:20:23,100 --> 03:20:23,368
follow-up questions in

5361
03:20:23,368 --> 03:20:25,269
response to MS.

5362
03:20:25,269 --> 03:20:27,269
Christiansen.

5363
03:20:32,878 --> 03:20:34,746
My name is schef wright.

5364
03:20:34,746 --> 03:20:37,249
She asked you whether it

5365
03:20:37,249 --> 03:20:40,249
was normal to replace old

5366
03:20:43,387 --> 03:20:43,889
and obsolete equipment and

5367
03:20:43,889 --> 03:20:44,223
you said under certain

5368
03:20:44,223 --> 03:20:44,756
circumstances.

5369
03:20:44,756 --> 03:20:45,324
My question is when is it

5370
03:20:45,324 --> 03:20:47,792
not normal to replace old

5371
03:20:47,792 --> 03:20:49,228
and obsolete equipment?

5372
03:20:49,228 --> 03:20:51,628
>> MR. Whitworth: what I

5373
03:20:52,664 --> 03:20:55,901
meant by that is we have

5374
03:20:55,901 --> 03:20:58,301
to do that obsolete

5375
03:20:59,104 --> 03:21:01,104
equipment replacement in

5376
03:21:04,109 --> 03:21:04,343
an organized and timely

5377
03:21:04,343 --> 03:21:04,877
fashion.

5378
03:21:04,877 --> 03:21:05,244
And something that has to

5379
03:21:05,244 --> 03:21:07,120
be coordinated.

5380
03:21:07,120 --> 03:21:07,546
Typically that agreement

5381
03:21:07,546 --> 03:21:08,680
is integrated with other

5382
03:21:08,680 --> 03:21:10,449
pieces of equipment in and

5383
03:21:10,449 --> 03:21:10,883
around the system and as

5384
03:21:10,883 --> 03:21:13,283
soon as it becomes

5385
03:21:13,485 --> 03:21:13,852
obsolete we would have to

5386
03:21:13,852 --> 03:21:15,454
coordinate that.

5387
03:21:15,454 --> 03:21:18,454
The other thing is that

5388
03:21:18,557 --> 03:21:19,910
often times through proper

5389
03:21:19,910 --> 03:21:21,910
asset management programs

5390
03:21:22,560 --> 03:21:23,950
and health analysis we can

5391
03:21:23,950 --> 03:21:25,300
also work with that piece

5392
03:21:25,300 --> 03:21:25,430
of equipment for a

5393
03:21:25,430 --> 03:21:27,430
duration of time,

5394
03:21:32,771 --> 03:21:33,271
maximizing our capital

5395
03:21:33,271 --> 03:21:33,805
investment, which also

5396
03:21:33,805 --> 03:21:34,339
maximizes the customer's

5397
03:21:34,339 --> 03:21:34,840
investment as well so we

5398
03:21:34,840 --> 03:21:36,942
get the full use out of

5399
03:21:36,942 --> 03:21:39,342
that piece of equipment.

5400
03:21:41,847 --> 03:21:42,381
>> MR. Wright: so I think

5401
03:21:42,381 --> 03:21:42,881
I understood part of your

5402
03:21:42,881 --> 03:21:44,881
follow-on discussion to

5403
03:21:45,830 --> 03:21:46,952
indicate you might replace

5404
03:21:46,952 --> 03:21:50,552
the function of a piece of

5405
03:21:52,624 --> 03:21:53,125
equipment with better

5406
03:21:53,125 --> 03:21:54,760
equipment or equipment

5407
03:21:54,760 --> 03:21:55,727
that would do more than

5408
03:21:55,727 --> 03:21:55,894
the old obsolete equipment

5409
03:21:55,894 --> 03:21:57,894
did.

5410
03:21:58,797 --> 03:21:59,164
Is that kind of what you

5411
03:21:59,164 --> 03:22:01,164
were getting at?

5412
03:22:06,504 --> 03:22:07,500
>> MR. Whitworth: with

5413
03:22:07,500 --> 03:22:07,439
respect to gr and those

5414
03:22:07,439 --> 03:22:08,720
programs, I did.

5415
03:22:08,720 --> 03:22:08,473
>> MR. Wright: thank you.

5416
03:22:08,473 --> 03:22:09,400
That's all I had.

5417
03:22:09,400 --> 03:22:09,274
>> CHAIRMAN La Rosa:

5418
03:22:09,274 --> 03:22:11,274
walmart.

5419
03:22:13,611 --> 03:22:13,779
>> we have no cross, thank

5420
03:22:13,779 --> 03:22:14,346
you.

5421
03:22:14,346 --> 03:22:14,546
>> CHAIRMAN La Rosa:

5422
03:22:14,546 --> 03:22:15,147
staff.

5423
03:22:15,147 --> 03:22:15,414
>> Staff: staff has no

5424
03:22:15,414 --> 03:22:15,681
questions.

5425
03:22:15,681 --> 03:22:17,681
Thank you.

5426
03:22:18,283 --> 03:22:20,283
>> CHAIRMAN La Rosa:

5427
03:22:20,485 --> 03:22:22,154
staff has no questions.

5428
03:22:22,154 --> 03:22:22,354
I will send it back to

5429
03:22:22,354 --> 03:22:24,354
teco.

5430
03:22:25,257 --> 03:22:28,257
>> I would ask about this

5431
03:22:31,430 --> 03:22:31,964
document fll -- do you see

5432
03:22:31,964 --> 03:22:34,700
were at the top where it

5433
03:22:34,700 --> 03:22:35,000
says reliability

5434
03:22:35,000 --> 03:22:36,267
improvement?

5435
03:22:36,267 --> 03:22:38,667
>> MR. Whitworth: I do.

5436
03:22:39,971 --> 03:22:40,505
>> is the only benefit of

5437
03:22:40,505 --> 03:22:43,505
the grr project going to

5438
03:22:46,712 --> 03:22:47,212
be reliability benefit?

5439
03:22:47,212 --> 03:22:47,479
>> there are many

5440
03:22:47,479 --> 03:22:47,846
benefits.

5441
03:22:47,846 --> 03:22:48,146
In addition to

5442
03:22:48,146 --> 03:22:48,680
reliability.

5443
03:22:48,680 --> 03:22:51,490
Reliability is one of the

5444
03:22:51,490 --> 03:22:51,583
things we balance when we

5445
03:22:51,583 --> 03:22:53,285
consider what's happening

5446
03:22:53,285 --> 03:22:55,287
with the grid and how the

5447
03:22:55,287 --> 03:22:57,890
grid is changing.

5448
03:22:57,890 --> 03:22:58,890
I would add one of the

5449
03:22:58,890 --> 03:23:01,930
largest benefits to gr r

5450
03:23:01,930 --> 03:23:05,293
would be to weigh -- a way

5451
03:23:07,733 --> 03:23:08,199
to detect -- in 2030 we

5452
03:23:08,199 --> 03:23:10,599
expect to have around

5453
03:23:12,370 --> 03:23:12,370
27,000 customers with

5454
03:23:12,370 --> 03:23:12,871
rooftop power.

5455
03:23:12,871 --> 03:23:15,271
That's around 770 mw of

5456
03:23:15,306 --> 03:23:15,574
connected nameplate

5457
03:23:15,574 --> 03:23:16,740
capacity.

5458
03:23:16,740 --> 03:23:19,740
This will result in two

5459
03:23:20,879 --> 03:23:21,113
way power flows on our

5460
03:23:21,113 --> 03:23:21,580
system.

5461
03:23:21,580 --> 03:23:22,130
This is important for

5462
03:23:22,130 --> 03:23:24,130
three main reasons.

5463
03:23:24,949 --> 03:23:25,417
Number one, safety.

5464
03:23:25,417 --> 03:23:25,850
Safety of our workers.

5465
03:23:25,850 --> 03:23:26,385
Our workers need to

5466
03:23:26,385 --> 03:23:27,719
understand the direction

5467
03:23:27,719 --> 03:23:28,186
of power flow so they can

5468
03:23:28,186 --> 03:23:30,186
properly isolate the

5469
03:23:35,460 --> 03:23:36,260
system and remove the

5470
03:23:36,260 --> 03:23:36,227
hazardous energy and go to

5471
03:23:36,227 --> 03:23:36,762
work.

5472
03:23:36,762 --> 03:23:37,262
Number two, the implement

5473
03:23:37,262 --> 03:23:37,763
we install needs to be

5474
03:23:37,763 --> 03:23:39,763
technically capable to

5475
03:23:42,634 --> 03:23:42,834
handle two way power

5476
03:23:42,834 --> 03:23:43,301
flows.

5477
03:23:43,301 --> 03:23:43,835
Number three, to the

5478
03:23:43,835 --> 03:23:44,268
extent we can understand

5479
03:23:44,268 --> 03:23:44,769
the contribution of

5480
03:23:44,769 --> 03:23:46,769
renewable energy that's

5481
03:23:48,600 --> 03:23:48,506
being injected on our

5482
03:23:48,506 --> 03:23:51,506
grid, we can back down

5483
03:23:57,816 --> 03:23:58,316
traditional fossil fuels

5484
03:23:58,316 --> 03:23:58,884
and reduce line losses,

5485
03:23:58,884 --> 03:23:59,384
which saves the company --

5486
03:23:59,384 --> 03:23:59,618
customer money for fuel

5487
03:23:59,618 --> 03:24:00,185
savings.

5488
03:24:00,185 --> 03:24:00,552
There's many other reasons

5489
03:24:00,552 --> 03:24:00,919
from a security

5490
03:24:00,919 --> 03:24:01,486
perspective and

5491
03:24:01,486 --> 03:24:03,387
obsolescence perspective,

5492
03:24:03,387 --> 03:24:05,290
which we talked a lot

5493
03:24:05,290 --> 03:24:07,690
about and also improving

5494
03:24:07,893 --> 03:24:08,326
our customer experiences

5495
03:24:08,326 --> 03:24:10,326
and different data

5496
03:24:13,431 --> 03:24:13,831
offerings we will be able

5497
03:24:13,831 --> 03:24:14,399
to have access to.

5498
03:24:14,399 --> 03:24:16,635
>> will any of these

5499
03:24:16,635 --> 03:24:17,101
benefits accrue to

5500
03:24:17,101 --> 03:24:17,702
residential customers?

5501
03:24:17,702 --> 03:24:19,702
>> MR. Whitworth: yes,

5502
03:24:20,338 --> 03:24:20,939
they will.

5503
03:24:20,939 --> 03:24:21,506
>> no further questions.

5504
03:24:21,506 --> 03:24:21,773
>> CHAIRMAN La Rosa:

5505
03:24:21,773 --> 03:24:23,773
thank you.

5506
03:24:24,708 --> 03:24:25,760
It's now move exhibits

5507
03:24:25,760 --> 03:24:27,760
into the record.

5508
03:24:28,313 --> 03:24:28,847
>> table electric moves

5509
03:24:28,847 --> 03:24:30,115
exhibits 21 and 145 into

5510
03:24:30,115 --> 03:24:30,949
the record.

5511
03:24:30,949 --> 03:24:32,717
>> CHAIRMAN La Rosa: are

5512
03:24:32,717 --> 03:24:33,218
there objections?

5513
03:24:33,218 --> 03:24:35,618
Seeing none, show them

5514
03:24:36,755 --> 03:24:36,922
entered into the record.

5515
03:24:36,922 --> 03:24:38,623
Opc?

5516
03:24:38,623 --> 03:24:41,230
>> opc would move 370 into

5517
03:24:46,698 --> 03:24:47,165
the record if it has not

5518
03:24:47,165 --> 03:24:47,799
already been admitted.

5519
03:24:47,799 --> 03:24:48,200
>> CHAIRMAN La Rosa: is

5520
03:24:48,200 --> 03:24:48,666
there objections?

5521
03:24:48,666 --> 03:24:49,234
>> no objection.

5522
03:24:49,234 --> 03:24:49,701
>> CHAIRMAN La Rosa:

5523
03:24:49,701 --> 03:24:52,101
seeing none, so that

5524
03:24:55,974 --> 03:24:56,307
entered into the record.

5525
03:24:56,307 --> 03:24:56,874
Anybody else?

5526
03:24:56,874 --> 03:24:57,408
>> florida rising and

5527
03:24:57,408 --> 03:24:58,409
lulac would like to move

5528
03:24:58,409 --> 03:24:58,710
exhibits 725 and 726 into

5529
03:24:58,710 --> 03:25:00,710
the record.

5530
03:25:01,379 --> 03:25:01,646
>> CHAIRMAN La Rosa: any

5531
03:25:01,646 --> 03:25:03,646
objection?

5532
03:25:05,316 --> 03:25:05,950
>> no objection.

5533
03:25:05,950 --> 03:25:06,218
>> CHAIRMAN La Rosa: no

5534
03:25:06,218 --> 03:25:06,785
objection.

5535
03:25:06,785 --> 03:25:09,521
Show that entered into the

5536
03:25:09,521 --> 03:25:09,787
record.

5537
03:25:09,787 --> 03:25:11,787
Any other?

5538
03:25:11,923 --> 03:25:13,923
Seeing none, MR.

5539
03:25:15,327 --> 03:25:17,662
Whitworth, I almost said

5540
03:25:17,662 --> 03:25:19,130
you are recognized.

5541
03:25:19,130 --> 03:25:21,130
You are excused.

5542
03:25:23,568 --> 03:25:24,201
Thank you very much.

5543
03:25:24,201 --> 03:25:24,369
>> MR. Whitworth: thank

5544
03:25:24,369 --> 03:25:26,369
you.

5545
03:25:27,706 --> 03:25:28,340
Thank you so much.

5546
03:25:28,340 --> 03:25:30,740
>> CHAIRMAN La Rosa: all

5547
03:25:30,742 --> 03:25:31,242
right, teco.

5548
03:25:31,242 --> 03:25:31,810
I will throw it back to

5549
03:25:31,810 --> 03:25:32,777
you to introduce your next

5550
03:25:32,777 --> 03:25:35,777
witness and we will see

5551
03:25:39,350 --> 03:25:39,684
how far we get with him

5552
03:25:39,684 --> 03:25:40,185
before lunch.

5553
03:25:40,185 --> 03:25:40,452
>> thank you, MR.

5554
03:25:40,452 --> 03:25:41,190
CHAIRMAN.

5555
03:25:41,190 --> 03:25:43,880
Tampa electric calls david

5556
03:25:43,880 --> 03:25:44,522
lukcic.

5557
03:25:44,522 --> 03:25:46,922
>> MR. Wahlen: MR. Chair,

5558
03:25:53,300 --> 03:25:53,531
while we are on a break

5559
03:25:53,531 --> 03:25:54,650
would be all right if I

5560
03:25:54,650 --> 03:25:54,532
said congratulations for

5561
03:25:54,532 --> 03:25:54,966
making this document

5562
03:25:54,966 --> 03:25:55,466
system work and the

5563
03:25:55,466 --> 03:25:56,301
lawyers working at and

5564
03:25:56,301 --> 03:25:56,835
people working at?

5565
03:25:56,835 --> 03:25:59,137
It's actually turning out

5566
03:25:59,137 --> 03:25:59,704
to be fairly cool.

5567
03:25:59,704 --> 03:26:03,904
I don't want to jinx it or

5568
03:26:04,809 --> 03:26:05,410
anything.

5569
03:26:05,410 --> 03:26:05,877
>> CHAIRMAN La Rosa: I

5570
03:26:05,877 --> 03:26:06,511
had similar thoughts.

5571
03:26:06,511 --> 03:26:07,450
>> MR. Wahlen: so if it

5572
03:26:07,450 --> 03:26:09,280
fails this afternoon, you

5573
03:26:09,280 --> 03:26:09,814
can blame me, but I just

5574
03:26:09,814 --> 03:26:12,214
wanted to acknowledge all

5575
03:26:15,200 --> 03:26:15,253
of the hard work and

5576
03:26:15,253 --> 03:26:15,786
effort.

5577
03:26:15,786 --> 03:26:16,254
It looks like it's on its

5578
03:26:16,254 --> 03:26:18,654
way, and I appreciate

5579
03:26:19,790 --> 03:26:20,458
that.

5580
03:26:20,458 --> 03:26:20,958
>> CHAIRMAN La Rosa: from

5581
03:26:20,958 --> 03:26:23,358
my perspective up here

5582
03:26:23,594 --> 03:26:24,128
makes following along much

5583
03:26:24,128 --> 03:26:25,897
easier, especially doing

5584
03:26:25,897 --> 03:26:27,897
multiple things.

5585
03:26:28,867 --> 03:26:31,680
If you do jinx us, but

5586
03:26:31,680 --> 03:26:32,570
hopefully you don't.

5587
03:26:32,570 --> 03:26:35,570
MR. Lukcic, sorry I didn't

5588
03:26:37,275 --> 03:26:37,475
get you before you sat

5589
03:26:37,475 --> 03:26:38,420
down.

5590
03:26:38,420 --> 03:26:38,609
If you don't mind standing

5591
03:26:38,609 --> 03:26:41,609
up really quickly, I don't

5592
03:26:42,413 --> 03:26:42,881
believe you have been

5593
03:26:42,881 --> 03:26:43,381
administered the oath.

5594
03:26:43,381 --> 03:26:43,581
Please raise your right

5595
03:26:43,581 --> 03:26:44,810
hand.

5596
03:26:44,810 --> 03:26:46,484
do you swear and affirm

5597
03:26:46,484 --> 03:26:47,180
the testimony you are

5598
03:26:47,180 --> 03:26:47,519
about to give will be the

5599
03:26:47,519 --> 03:26:48,520
truth, the whole truth,

5600
03:26:48,520 --> 03:26:51,520
and nothing but the truth?

5601
03:26:52,323 --> 03:26:52,891
>> MR. Lukcic: I do.

5602
03:26:52,891 --> 03:26:53,158
>> CHAIRMAN La Rosa:

5603
03:26:53,158 --> 03:26:53,725
thank you.

5604
03:26:53,725 --> 03:26:55,725
>> good morning, MR.

5605
03:26:56,427 --> 03:26:56,961
Lukcic.

5606
03:26:56,961 --> 03:26:57,495
Can you please state your

5607
03:26:57,495 --> 03:26:58,163
full name for the record?

5608
03:26:58,163 --> 03:27:00,430
>> MR. Lukcic: yes, david

5609
03:27:00,430 --> 03:27:01,310
lukcic.

5610
03:27:01,310 --> 03:27:01,632
>> you were just sworn?

5611
03:27:01,632 --> 03:27:01,799
>> MR. Lukcic: yes, I

5612
03:27:01,799 --> 03:27:03,799
was.

5613
03:27:05,970 --> 03:27:06,437
>> who is your current

5614
03:27:06,437 --> 03:27:06,670
employer and business

5615
03:27:06,670 --> 03:27:07,238
address?

5616
03:27:07,238 --> 03:27:07,639
>> MR. Lukcic: tampa

5617
03:27:07,639 --> 03:27:09,639
electric company.

5618
03:27:14,412 --> 03:27:14,980
Business address is 702

5619
03:27:14,980 --> 03:27:15,146
north franklin st., tampa,

5620
03:27:15,146 --> 03:27:15,780
fl.

5621
03:27:15,780 --> 03:27:16,347
>> did you prepare cause

5622
03:27:16,347 --> 03:27:19,947
to be filed on this docket

5623
03:27:21,520 --> 03:27:21,452
APRIL 22, 2024 preparing

5624
03:27:21,452 --> 03:27:21,953
direct testimony

5625
03:27:21,953 --> 03:27:22,554
consisting of 61 pages?

5626
03:27:22,554 --> 03:27:22,720
>> MR. Lukcic: yes, I

5627
03:27:22,720 --> 03:27:23,354
did.

5628
03:27:23,354 --> 03:27:25,754
>> did you prepare cause

5629
03:27:28,927 --> 03:27:29,494
and file prepare rebuttal

5630
03:27:29,494 --> 03:27:29,694
testimony consisting of 20

5631
03:27:29,694 --> 03:27:30,127
pages?

5632
03:27:30,127 --> 03:27:30,662
>> yes, I did.

5633
03:27:30,662 --> 03:27:31,195
>> do you have any

5634
03:27:31,195 --> 03:27:33,164
additions or corrections

5635
03:27:33,164 --> 03:27:33,598
to your prepared or

5636
03:27:33,598 --> 03:27:35,598
rebuttal testimony?

5637
03:27:36,466 --> 03:27:39,466
>> MR. Lukcic: I do not.

5638
03:27:43,541 --> 03:27:44,750
>> MR. Lukcic, are you

5639
03:27:44,750 --> 03:27:44,608
familiar with the AUGUST

5640
03:27:44,608 --> 03:27:45,430
22 filing tampa electric

5641
03:27:45,430 --> 03:27:45,443
made to change the

5642
03:27:45,443 --> 03:27:47,443
company's revenue

5643
03:27:54,319 --> 03:27:54,953
requirement?

5644
03:27:54,953 --> 03:27:55,620
>> MR. Lukcic: yes, I am.

5645
03:27:55,620 --> 03:27:56,870
>> do you have any changes

5646
03:27:56,870 --> 03:27:56,321
associated with that

5647
03:27:56,321 --> 03:27:56,888
filing?

5648
03:27:56,888 --> 03:27:57,321
>> MR. Lukcic: I do.

5649
03:27:57,321 --> 03:27:57,889
On AUGUST 22, tampa

5650
03:27:57,889 --> 03:27:58,422
electric filed a change to

5651
03:27:58,422 --> 03:27:58,956
the revenue requirements

5652
03:27:58,956 --> 03:28:02,556
to remove the cost of the

5653
03:28:02,727 --> 03:28:03,227
project refined to as line

5654
03:28:03,227 --> 03:28:03,727
sensor software and the

5655
03:28:03,727 --> 03:28:04,128
distinguishing planning

5656
03:28:04,128 --> 03:28:06,128
software from the

5657
03:28:07,432 --> 03:28:07,932
company's sya.

5658
03:28:07,932 --> 03:28:08,366
This would change mike

5659
03:28:08,366 --> 03:28:10,366
direct and rebuttal

5660
03:28:12,370 --> 03:28:12,604
testimony in several

5661
03:28:12,604 --> 03:28:13,137
places.

5662
03:28:13,137 --> 03:28:13,671
Instead of going through

5663
03:28:13,671 --> 03:28:15,474
this page by page I want

5664
03:28:15,474 --> 03:28:15,974
to note on the record that

5665
03:28:15,974 --> 03:28:18,374
my testimony no longer

5666
03:28:20,411 --> 03:28:20,845
applies.

5667
03:28:20,845 --> 03:28:21,379
>> thank you.

5668
03:28:21,379 --> 03:28:21,813
Other than those changes,

5669
03:28:21,813 --> 03:28:23,414
if I would ask you

5670
03:28:23,414 --> 03:28:23,915
questions in your prepared

5671
03:28:23,915 --> 03:28:25,915
and rebuttal testimony

5672
03:28:28,860 --> 03:28:28,386
today, would your answers

5673
03:28:28,386 --> 03:28:28,820
be the same?

5674
03:28:28,820 --> 03:28:30,820
>> they would.

5675
03:28:32,900 --> 03:28:32,624
>> tampa electric requests

5676
03:28:32,624 --> 03:28:35,624
that -- be inserted into

5677
03:28:36,927 --> 03:28:37,462
the record as read.

5678
03:28:37,462 --> 03:28:37,995
MR. Lukcic, did you also

5679
03:28:37,995 --> 03:28:39,931
prepare cause to be filed

5680
03:28:39,931 --> 03:28:40,331
in your testimony

5681
03:28:40,331 --> 03:28:40,598
consisting of two

5682
03:28:40,598 --> 03:28:42,598
documents?

5683
03:28:48,500 --> 03:28:48,606
>> MR. Lukcic: I did.

5684
03:28:48,606 --> 03:28:49,106
>> MR. CHAIRMAN, tampa

5685
03:28:49,106 --> 03:28:49,607
electric would note for

5686
03:28:49,607 --> 03:28:50,174
the record that exhibit

5687
03:28:50,174 --> 03:28:50,641
dl-one has been identified

5688
03:28:50,641 --> 03:28:51,309
in the comprehensive

5689
03:28:51,309 --> 03:28:53,709
exhibit list as exhibit

5690
03:28:53,945 --> 03:28:54,379
22.

5691
03:28:54,379 --> 03:28:54,912
MR. Lukcic, did you

5692
03:28:54,912 --> 03:28:57,582
prepare a summary of your

5693
03:28:57,582 --> 03:28:57,849
direct and rebuttal

5694
03:28:57,849 --> 03:28:59,849
testimony?

5695
03:29:11,729 --> 03:29:12,630
>> MR. Lukcic: I did.

5696
03:29:12,630 --> 03:29:12,397
good morning,

5697
03:29:12,397 --> 03:29:12,830
commissioners.

5698
03:29:12,830 --> 03:29:13,331
My direct testimony

5699
03:29:13,331 --> 03:29:13,865
describes the company's

5700
03:29:13,865 --> 03:29:14,298
operation technology and

5701
03:29:14,298 --> 03:29:14,766
strategy department.

5702
03:29:14,766 --> 03:29:15,200
The ot resources and

5703
03:29:15,200 --> 03:29:15,733
applications tampa

5704
03:29:15,733 --> 03:29:16,167
electric uses to operate

5705
03:29:16,167 --> 03:29:16,734
its electric system

5706
03:29:16,734 --> 03:29:17,201
explains the progress made

5707
03:29:17,201 --> 03:29:19,601
to date in operation

5708
03:29:21,639 --> 03:29:22,172
technology and strategy

5709
03:29:22,172 --> 03:29:22,540
since the company's last

5710
03:29:22,540 --> 03:29:23,740
bait rate case.

5711
03:29:23,740 --> 03:29:23,474
The testimony summarizes

5712
03:29:23,474 --> 03:29:25,900
the ots plans and

5713
03:29:25,900 --> 03:29:25,376
explained the company's ot

5714
03:29:25,376 --> 03:29:27,376
and ask capital

5715
03:29:29,130 --> 03:29:31,130
investments and also

5716
03:29:41,391 --> 03:29:41,959
describes the grade

5717
03:29:41,959 --> 03:29:42,826
reliability and visit with

5718
03:29:42,826 --> 03:29:43,260
the project has been

5719
03:29:43,260 --> 03:29:43,828
created to increase

5720
03:29:43,828 --> 03:29:44,362
customer expectations, two

5721
03:29:44,362 --> 03:29:44,895
way power flows, obsolete

5722
03:29:44,895 --> 03:29:45,396
systems and equipment in

5723
03:29:45,396 --> 03:29:45,963
addition to safety and

5724
03:29:45,963 --> 03:29:47,531
reliability, concerns with

5725
03:29:47,531 --> 03:29:48,650
the evolving grid.

5726
03:29:48,650 --> 03:29:49,766
Grr is a collection of a

5727
03:29:49,766 --> 03:29:52,166
series of upgrades that

5728
03:29:53,937 --> 03:29:54,505
will deliver maximum value

5729
03:29:54,505 --> 03:29:54,738
in the most cost-effective

5730
03:29:54,738 --> 03:29:55,272
manner.

5731
03:29:55,272 --> 03:29:57,672
In addition to addressing

5732
03:30:03,781 --> 03:30:04,215
the issues above, grr will

5733
03:30:04,215 --> 03:30:04,681
also address cyber

5734
03:30:04,681 --> 03:30:05,216
security, operational

5735
03:30:05,216 --> 03:30:05,750
efficiencies, which will

5736
03:30:05,750 --> 03:30:06,216
reduce expenses, provide

5737
03:30:06,216 --> 03:30:06,750
fuel savings due to

5738
03:30:06,750 --> 03:30:07,518
reducing line losses, as

5739
03:30:07,518 --> 03:30:09,918
well as setting the

5740
03:30:11,955 --> 03:30:12,356
foundation for additional

5741
03:30:12,356 --> 03:30:12,890
customer programs.

5742
03:30:12,890 --> 03:30:15,890
The program will go into

5743
03:30:17,861 --> 03:30:18,396
service as subsequent year

5744
03:30:18,396 --> 03:30:20,396
adjustments in 26 and 27.

5745
03:30:20,665 --> 03:30:21,650
My rebuttal testimony

5746
03:30:21,650 --> 03:30:21,898
addresses why the

5747
03:30:21,898 --> 03:30:23,898
commission should address

5748
03:30:25,269 --> 03:30:27,669
inclusion of projects in

5749
03:30:29,306 --> 03:30:29,840
the company's sya.

5750
03:30:29,840 --> 03:30:31,976
My rebuttal testimony --

5751
03:30:31,976 --> 03:30:32,343
does allow recovery for

5752
03:30:32,343 --> 03:30:34,343
the grr project.

5753
03:30:36,314 --> 03:30:36,580
This concludes my summary.

5754
03:30:36,580 --> 03:30:37,748
Thank you.

5755
03:30:37,748 --> 03:30:40,148
>> tender the witness for

5756
03:30:44,188 --> 03:30:44,755
cross-examination.

5757
03:30:44,755 --> 03:30:45,220
>> CHAIRMAN La Rosa:

5758
03:30:45,220 --> 03:30:45,189
thank you.

5759
03:30:45,189 --> 03:30:45,790
Opc.

5760
03:30:45,790 --> 03:30:48,190
>> thank you, MR. Chair.

5761
03:30:50,261 --> 03:30:50,828
Good morning, teco team.

5762
03:30:50,828 --> 03:30:51,610
>> MR. Lukcic: good

5763
03:30:51,610 --> 03:30:51,729
morning.

5764
03:30:51,729 --> 03:30:52,960
>> I'm going to jump right

5765
03:30:52,960 --> 03:30:52,630
into questions.

5766
03:30:52,630 --> 03:30:53,330
Is a true the company has

5767
03:30:53,330 --> 03:30:53,864
already been implemented

5768
03:30:53,864 --> 03:30:55,864
individual components of

5769
03:31:00,972 --> 03:31:01,405
what you named the grr

5770
03:31:01,405 --> 03:31:02,600
project since 2022?

5771
03:31:02,600 --> 03:31:02,239
>> MR. Lukcic: that is

5772
03:31:02,239 --> 03:31:02,873
correct.

5773
03:31:02,873 --> 03:31:05,273
>> and the official name

5774
03:31:05,977 --> 03:31:06,410
is the advanced

5775
03:31:06,410 --> 03:31:06,844
distribution infra

5776
03:31:06,844 --> 03:31:07,444
structure, correct?

5777
03:31:07,444 --> 03:31:09,844
>> MR. Lukcic: I don't

5778
03:31:12,549 --> 03:31:12,950
know if I would call that

5779
03:31:12,950 --> 03:31:13,450
the official name.

5780
03:31:13,450 --> 03:31:14,180
Although it has been:

5781
03:31:14,180 --> 03:31:16,180
both advanced distribution

5782
03:31:23,560 --> 03:31:23,861
infrastructure and grid

5783
03:31:23,861 --> 03:31:24,462
reliability.

5784
03:31:24,462 --> 03:31:24,828
The names has been used

5785
03:31:24,828 --> 03:31:25,462
interchangeably.

5786
03:31:25,462 --> 03:31:25,996
>> would you agree it has

5787
03:31:25,996 --> 03:31:27,365
modernized its dispersion

5788
03:31:27,365 --> 03:31:29,365
network?

5789
03:31:30,968 --> 03:31:31,335
>> MR. Lukcic: I would

5790
03:31:31,335 --> 03:31:33,335
say that's fair.

5791
03:31:33,871 --> 03:31:34,405
>> and this is what the

5792
03:31:34,405 --> 03:31:34,939
individual components of

5793
03:31:34,939 --> 03:31:37,939
the adi were intended to

5794
03:31:39,176 --> 03:31:39,710
do when they were forecast

5795
03:31:39,710 --> 03:31:40,770
in the ordinary course of

5796
03:31:40,770 --> 03:31:40,678
business, right?

5797
03:31:40,678 --> 03:31:42,713
>> MR. Lukcic: I don't

5798
03:31:42,713 --> 03:31:42,880
know that I'd say it that

5799
03:31:42,880 --> 03:31:43,347
way.

5800
03:31:43,347 --> 03:31:46,347
I think what might be

5801
03:31:46,616 --> 03:31:47,672
helpful is understanding

5802
03:31:47,672 --> 03:31:49,672
what grr is.

5803
03:31:49,720 --> 03:31:50,870
Grr evolved out of a

5804
03:31:50,870 --> 03:31:50,654
series of grid

5805
03:31:50,654 --> 03:31:52,654
modernization projects and

5806
03:32:00,831 --> 03:32:01,298
as such as we gain through

5807
03:32:01,298 --> 03:32:01,832
time, I think archie

5808
03:32:01,832 --> 03:32:02,660
talked about it starting

5809
03:32:02,660 --> 03:32:02,599
in 2018.

5810
03:32:02,599 --> 03:32:03,330
Through time what we did

5811
03:32:03,330 --> 03:32:03,500
is we found a more

5812
03:32:03,500 --> 03:32:04,350
cost-effective way to

5813
03:32:04,350 --> 03:32:04,534
execute these projects by

5814
03:32:04,534 --> 03:32:04,868
looking at them in a

5815
03:32:04,868 --> 03:32:05,402
holistic way.

5816
03:32:05,402 --> 03:32:08,402
It really allowed us to

5817
03:32:09,306 --> 03:32:09,773
find the most

5818
03:32:09,773 --> 03:32:10,274
cost-effective way to

5819
03:32:10,274 --> 03:32:12,674
deploy them along with

5820
03:32:14,145 --> 03:32:14,645
providing the maximum

5821
03:32:14,645 --> 03:32:15,179
value to the customers.

5822
03:32:15,179 --> 03:32:16,513
It's more than a one plus

5823
03:32:16,513 --> 03:32:18,315
one equals two.

5824
03:32:18,315 --> 03:32:20,715
That's how these things

5825
03:32:21,485 --> 03:32:22,520
kind of evolved.

5826
03:32:22,520 --> 03:32:24,520
>> hasn't the company

5827
03:32:27,291 --> 03:32:27,724
already invested roughly

5828
03:32:27,724 --> 03:32:28,225
21 million in these

5829
03:32:28,225 --> 03:32:30,225
component projects from

5830
03:32:34,198 --> 03:32:34,798
2021-2024?

5831
03:32:34,798 --> 03:32:35,320
>> MR. Lukcic: that's

5832
03:32:35,320 --> 03:32:35,666
correct.

5833
03:32:35,666 --> 03:32:37,666
>> doesn't the 2025 test

5834
03:32:39,270 --> 03:32:40,571
year include for an

5835
03:32:40,571 --> 03:32:42,500
additional 65,871,743 for

5836
03:32:42,500 --> 03:32:44,500
these component grr

5837
03:32:46,509 --> 03:32:47,770
projects?

5838
03:32:47,770 --> 03:32:47,510
>> MR. Lukcic: that

5839
03:32:47,510 --> 03:32:48,112
numbers of accurate.

5840
03:32:48,112 --> 03:32:48,846
>> in other words, the

5841
03:32:48,846 --> 03:32:51,246
company has already been

5842
03:32:52,550 --> 03:32:52,983
accounted for adi projects

5843
03:32:52,983 --> 03:32:53,484
consistent with the

5844
03:32:53,484 --> 03:32:55,419
expectations underlying

5845
03:32:55,419 --> 03:32:58,419
the rate setting for the

5846
03:32:58,522 --> 03:32:59,122
2021 right settlement?

5847
03:32:59,122 --> 03:33:01,522
>> MR. Lukcic: can you

5848
03:33:06,630 --> 03:33:07,264
rephrase the question?

5849
03:33:07,264 --> 03:33:07,765
>> so these adi projects

5850
03:33:07,765 --> 03:33:08,332
are consistent with the

5851
03:33:08,332 --> 03:33:10,332
2021 settlement agreement,

5852
03:33:12,636 --> 03:33:13,170
correct?

5853
03:33:13,170 --> 03:33:13,670
>> MR. Lukcic: are

5854
03:33:13,670 --> 03:33:15,670
consistent with the 21

5855
03:33:16,807 --> 03:33:17,307
settlement agreement.

5856
03:33:17,307 --> 03:33:20,143
I'm not exact sure what

5857
03:33:20,143 --> 03:33:22,543
you are referring to.

5858
03:33:23,214 --> 03:33:25,214
>> these component capital

5859
03:33:27,151 --> 03:33:27,585
projects were planned for

5860
03:33:27,585 --> 03:33:28,118
and expected to be

5861
03:33:28,118 --> 03:33:30,118
deployed between the 2021

5862
03:33:32,356 --> 03:33:34,356
and 2024 rate case.

5863
03:33:35,325 --> 03:33:37,528
>> MR. Lukcic: so grr

5864
03:33:37,528 --> 03:33:39,928
hasn't evolved that way.

5865
03:33:41,998 --> 03:33:42,433
It is not a rate case

5866
03:33:42,433 --> 03:33:44,433
determined activity.

5867
03:33:48,238 --> 03:33:48,806
It's a continuation that

5868
03:33:48,806 --> 03:33:49,273
results from the increased

5869
03:33:49,273 --> 03:33:49,540
expectations from our

5870
03:33:49,540 --> 03:33:50,400
customers.

5871
03:33:50,400 --> 03:33:50,540
When we continue to see

5872
03:33:50,540 --> 03:33:51,775
the grid evolving out

5873
03:33:51,775 --> 03:33:54,175
underneath us as customers

5874
03:33:59,550 --> 03:33:59,949
make choices around

5875
03:33:59,949 --> 03:34:00,451
electric vehicle

5876
03:34:00,451 --> 03:34:00,951
selections, changes the

5877
03:34:00,951 --> 03:34:01,485
complexity of the grid.

5878
03:34:01,485 --> 03:34:04,485
We look at safety, which

5879
03:34:04,521 --> 03:34:05,220
chip mentioned pv are

5880
03:34:05,220 --> 03:34:07,220
becoming more prevalent.

5881
03:34:10,894 --> 03:34:11,362
We are seeing two way

5882
03:34:11,362 --> 03:34:11,628
power flow and safety

5883
03:34:11,628 --> 03:34:12,162
concerns.

5884
03:34:12,162 --> 03:34:12,596
In addition to customers

5885
03:34:12,596 --> 03:34:14,596
desires for better

5886
03:34:17,000 --> 03:34:17,468
expectations around

5887
03:34:17,468 --> 03:34:17,768
reliability and storm

5888
03:34:17,768 --> 03:34:18,202
restoration.

5889
03:34:18,202 --> 03:34:18,769
It's continuing to

5890
03:34:18,769 --> 03:34:20,337
methodically address those

5891
03:34:20,337 --> 03:34:20,838
issues that allow the grid

5892
03:34:20,838 --> 03:34:22,838
modernization first to

5893
03:34:24,800 --> 03:34:24,341
develop within devolve

5894
03:34:24,341 --> 03:34:24,808
into the most

5895
03:34:24,808 --> 03:34:26,808
cost-effective way to

5896
03:34:27,344 --> 03:34:27,878
deploy it and maximize

5897
03:34:27,878 --> 03:34:28,979
those benefits and that's

5898
03:34:28,979 --> 03:34:30,979
what evolved grr.

5899
03:34:40,490 --> 03:34:40,824
It's not a rate case

5900
03:34:40,824 --> 03:34:42,824
determination.

5901
03:34:42,893 --> 03:34:43,427
It's just next have been

5902
03:34:43,427 --> 03:34:43,927
in a relation continuing

5903
03:34:43,927 --> 03:34:44,294
to find better ways to

5904
03:34:44,294 --> 03:34:44,962
manage our grid.

5905
03:34:44,962 --> 03:34:45,495
>> yes or no these capital

5906
03:34:45,495 --> 03:34:46,290
plans are expected to be

5907
03:34:46,290 --> 03:34:46,397
deployed in the 2021 and

5908
03:34:46,397 --> 03:34:46,930
2024 rate cases.

5909
03:34:46,930 --> 03:34:47,898
>> MR. Lukcic: yes.

5910
03:34:47,898 --> 03:34:49,898
>> and these component

5911
03:34:50,634 --> 03:34:51,134
capital projects are

5912
03:34:51,134 --> 03:34:53,534
expected to be deployed

5913
03:34:54,671 --> 03:34:55,105
during the --

5914
03:34:55,105 --> 03:34:57,105
>> MR. Lukcic: yes.

5915
03:34:59,275 --> 03:34:59,743
>> the cost incurred in

5916
03:34:59,743 --> 03:35:00,177
2022 through 2024 are

5917
03:35:00,177 --> 03:35:00,744
being reviewed for

5918
03:35:00,744 --> 03:35:03,744
prudence in the next rate

5919
03:35:05,148 --> 03:35:05,682
case or the current one?

5920
03:35:05,682 --> 03:35:07,682
>> MR. Lukcic: the

5921
03:35:11,655 --> 03:35:12,289
current one.

5922
03:35:12,289 --> 03:35:12,756
>> is it fair to say the

5923
03:35:12,756 --> 03:35:14,324
main dispute between

5924
03:35:14,324 --> 03:35:16,724
yourself and opc witness

5925
03:35:22,799 --> 03:35:23,366
amera is at the prudence

5926
03:35:23,366 --> 03:35:23,834
included in the subsequent

5927
03:35:23,834 --> 03:35:24,301
year adjustments but

5928
03:35:24,301 --> 03:35:24,834
rather the company's

5929
03:35:24,834 --> 03:35:25,402
decision to seek separate

5930
03:35:25,402 --> 03:35:25,769
recovery of them over the

5931
03:35:25,769 --> 03:35:27,769
subsequent year

5932
03:35:28,772 --> 03:35:30,507
adjustments?

5933
03:35:30,507 --> 03:35:32,907
>> MR. Lukcic: I don't

5934
03:35:34,477 --> 03:35:36,877
want to necessarily speak

5935
03:35:43,220 --> 03:35:43,653
for -- there's four

5936
03:35:43,653 --> 03:35:45,653
components that are

5937
03:35:46,924 --> 03:35:47,390
critical we are asking for

5938
03:35:47,390 --> 03:35:49,790
in a subsequent year.

5939
03:35:55,332 --> 03:35:55,832
The first one is the plte

5940
03:35:55,832 --> 03:35:56,232
spectrum, which is the

5941
03:35:56,232 --> 03:35:56,733
background of the

5942
03:35:56,733 --> 03:35:57,200
communications network.

5943
03:35:57,200 --> 03:35:57,767
The second is another

5944
03:35:57,767 --> 03:35:58,168
significant but beneficial

5945
03:35:58,168 --> 03:36:00,168
investment of the

5946
03:36:05,508 --> 03:36:05,976
customers as it opens the

5947
03:36:05,976 --> 03:36:06,410
door to a tremendous

5948
03:36:06,410 --> 03:36:06,910
amount of customer

5949
03:36:06,910 --> 03:36:07,411
programs, more accurate

5950
03:36:07,411 --> 03:36:07,644
billing, those kind of

5951
03:36:07,644 --> 03:36:08,145
issues.

5952
03:36:08,145 --> 03:36:08,645
Then you also have the

5953
03:36:08,645 --> 03:36:10,179
work management system

5954
03:36:10,179 --> 03:36:10,614
that has been in for

5955
03:36:10,614 --> 03:36:10,847
decades and out of

5956
03:36:10,847 --> 03:36:11,314
support.

5957
03:36:11,314 --> 03:36:13,714
That will continue to

5958
03:36:13,884 --> 03:36:15,884
drive operating

5959
03:36:24,961 --> 03:36:25,528
efficiencies and -- back

5960
03:36:25,528 --> 03:36:26,620
office hardware portion of

5961
03:36:26,620 --> 03:36:26,563
it and those final pieces

5962
03:36:26,563 --> 03:36:28,963
go in in DECEMBER 2026.

5963
03:36:29,366 --> 03:36:29,665
Yes, there are substantial

5964
03:36:29,665 --> 03:36:30,233
investments.

5965
03:36:30,233 --> 03:36:31,969
Much of them are multiyear

5966
03:36:31,969 --> 03:36:34,969
projects and we felt the

5967
03:36:35,304 --> 03:36:37,304
sya was inappropriate

5968
03:36:38,208 --> 03:36:38,742
mechanism for recovery to

5969
03:36:38,742 --> 03:36:41,142
relieve pressure in some

5970
03:36:41,611 --> 03:36:44,110
of the out years.

5971
03:36:46,983 --> 03:36:49,383
>> and isn't spending on

5972
03:36:50,820 --> 03:36:53,820
the grr projects going to

5973
03:36:54,358 --> 03:36:54,957
continue beyond 2024?

5974
03:36:54,957 --> 03:36:55,191
>> MR. Lukcic: that is

5975
03:36:55,191 --> 03:36:55,792
correct.

5976
03:36:55,792 --> 03:36:56,693
>> in fact, the company

5977
03:36:56,693 --> 03:36:58,693
forecast these grr

5978
03:36:59,195 --> 03:37:01,595
spending to continue at

5979
03:37:04,367 --> 03:37:04,968
least until 2030, correct?

5980
03:37:04,968 --> 03:37:05,201
>> MR. Lukcic: that is

5981
03:37:05,201 --> 03:37:05,836
correct.

5982
03:37:05,836 --> 03:37:07,738
>> the company can choose

5983
03:37:07,738 --> 03:37:10,138
to re-profile the capital,

5984
03:37:10,339 --> 03:37:11,307
right?

5985
03:37:11,307 --> 03:37:13,576
>> MR. Lukcic: so it's

5986
03:37:13,576 --> 03:37:14,510
not a capital spend

5987
03:37:14,510 --> 03:37:16,510
project.

5988
03:37:18,314 --> 03:37:18,882
>> teco ting, can you

5989
03:37:18,882 --> 03:37:21,282
please answer the question

5990
03:37:23,186 --> 03:37:23,787
yes or no and then?

5991
03:37:23,787 --> 03:37:24,254
>> MR. Lukcic: I would

5992
03:37:24,254 --> 03:37:25,254
say no because these

5993
03:37:25,254 --> 03:37:27,254
projects are codependent.

5994
03:37:32,429 --> 03:37:32,995
You tried to drive towards

5995
03:37:32,995 --> 03:37:33,530
-- maximize the benefit to

5996
03:37:33,530 --> 03:37:34,630
the customers, they have

5997
03:37:34,630 --> 03:37:36,132
to go in a certain order.

5998
03:37:36,132 --> 03:37:36,666
A simple reorganizing

5999
03:37:36,666 --> 03:37:39,660
projects or delaying key

6000
03:37:40,203 --> 03:37:40,737
components is not an

6001
03:37:40,737 --> 03:37:41,137
effective way to maximize

6002
03:37:41,137 --> 03:37:43,537
the value to the

6003
03:37:47,430 --> 03:37:47,611
customers.

6004
03:37:47,611 --> 03:37:48,144
>> the company could

6005
03:37:48,144 --> 03:37:48,678
choose to cancel some of

6006
03:37:48,678 --> 03:37:49,112
the components that have

6007
03:37:49,112 --> 03:37:51,348
yet to be entered,

6008
03:37:51,348 --> 03:37:53,348
correct?

6009
03:37:53,917 --> 03:37:54,384
>> MR. Lukcic: it's a

6010
03:37:54,384 --> 03:37:54,784
possibility, but the

6011
03:37:54,784 --> 03:37:56,586
company would not.

6012
03:37:56,586 --> 03:37:58,488
>> wasn't the plte

6013
03:37:58,488 --> 03:37:58,988
component the only

6014
03:37:58,988 --> 03:38:00,988
component specifically

6015
03:38:01,758 --> 03:38:02,225
approved by the board

6016
03:38:02,225 --> 03:38:04,625
before this case was

6017
03:38:10,733 --> 03:38:12,733
filed?

6018
03:38:16,940 --> 03:38:17,474
>> MR. Lukcic: plte was

6019
03:38:17,474 --> 03:38:18,400
definitely approved by a

6020
03:38:18,400 --> 03:38:18,240
board before this case was

6021
03:38:18,240 --> 03:38:18,908
filed.

6022
03:38:18,908 --> 03:38:21,308
There have been several

6023
03:38:29,286 --> 03:38:29,786
grid modernization

6024
03:38:29,786 --> 03:38:30,530
projects that have been

6025
03:38:30,530 --> 03:38:30,586
approved.

6026
03:38:30,586 --> 03:38:31,120
I don't know of anything

6027
03:38:31,120 --> 03:38:31,688
else in grr that is been

6028
03:38:31,688 --> 03:38:32,222
approved by the board, but

6029
03:38:32,222 --> 03:38:32,656
the board did subsequent

6030
03:38:32,656 --> 03:38:33,156
league approve this

6031
03:38:33,156 --> 03:38:33,356
project in JUNE of this

6032
03:38:33,356 --> 03:38:35,356
year.

6033
03:38:36,359 --> 03:38:36,893
>> and is the plte

6034
03:38:36,893 --> 03:38:38,661
component still expected

6035
03:38:38,661 --> 03:38:40,864
to be in service by 2026?

6036
03:38:40,864 --> 03:38:42,265
>> MR. Lukcic: the plte

6037
03:38:42,265 --> 03:38:44,265
spectrum should be

6038
03:38:45,936 --> 03:38:48,336
deployed and functional in

6039
03:38:49,506 --> 03:38:49,973
AUGUST in AUGUST 2025.

6040
03:38:49,973 --> 03:38:52,373
Then the back office

6041
03:38:55,440 --> 03:38:55,445
hardware in DECEMBER 2026.

6042
03:38:55,445 --> 03:38:57,845
Those are the two

6043
03:39:00,750 --> 03:39:01,384
components.

6044
03:39:01,384 --> 03:39:04,384
>> isn't it true that one

6045
03:39:04,721 --> 03:39:05,155
of the criteria used by

6046
03:39:05,155 --> 03:39:05,955
teco are seeking to

6047
03:39:05,955 --> 03:39:08,955
contain what they name the

6048
03:39:10,726 --> 03:39:11,227
grr and subsequent year

6049
03:39:11,227 --> 03:39:11,761
adjustments was of the

6050
03:39:11,761 --> 03:39:14,161
project was large enough

6051
03:39:17,901 --> 03:39:18,435
to be eligible for afudc?

6052
03:39:18,435 --> 03:39:19,200
>> MR. Lukcic: no.

6053
03:39:19,200 --> 03:39:19,536
Afudc collection was not a

6054
03:39:19,536 --> 03:39:20,704
function for determining

6055
03:39:20,704 --> 03:39:23,104
what actually was asked

6056
03:39:25,708 --> 03:39:26,142
for recovery.

6057
03:39:26,142 --> 03:39:26,643
We picked the most

6058
03:39:26,643 --> 03:39:28,643
substantial investments.

6059
03:39:31,981 --> 03:39:33,916
Some of those qualify for

6060
03:39:33,916 --> 03:39:36,316
afudc, some did not.

6061
03:39:40,257 --> 03:39:40,623
>> do you have a copy of

6062
03:39:40,623 --> 03:39:41,191
that deposition?

6063
03:39:41,191 --> 03:39:41,791
>> MR. Lukcic: I do.

6064
03:39:41,791 --> 03:39:42,159
>> can you please go to

6065
03:39:42,159 --> 03:39:44,159
page 47 of that

6066
03:39:45,895 --> 03:39:47,363
deposition?

6067
03:39:47,363 --> 03:39:49,763
>> CHAIRMAN La Rosa: do

6068
03:39:54,971 --> 03:39:56,971
we know --

6069
03:39:57,574 --> 03:39:58,875
>> no.

6070
03:39:58,875 --> 03:40:00,243
One second.

6071
03:40:00,243 --> 03:40:02,243
Commissioners, can you

6072
03:40:02,245 --> 03:40:05,845
give us a moment to pass

6073
03:40:07,317 --> 03:40:07,883
out the depositions?

6074
03:40:07,883 --> 03:40:09,883
>> CHAIRMAN La Rosa:

6075
03:41:52,722 --> 03:41:54,722
sure.

6076
03:41:57,860 --> 03:41:58,327
I think we're ready when

6077
03:41:58,327 --> 03:41:58,862
you are, but just to

6078
03:41:58,862 --> 03:41:59,896
clarify the witness does

6079
03:41:59,896 --> 03:42:01,896
have a copy.

6080
03:42:03,933 --> 03:42:04,400
>> I do.

6081
03:42:04,400 --> 03:42:06,400
>> my apology,

6082
03:42:07,360 --> 03:42:09,360
commissioners, for the

6083
03:42:11,341 --> 03:42:11,874
delay.

6084
03:42:11,874 --> 03:42:13,900
Can you please take turn

6085
03:42:13,900 --> 03:42:13,609
to page 47?

6086
03:42:13,609 --> 03:42:16,900
>> MR. Lukcic: got it.

6087
03:42:16,846 --> 03:42:17,380
>> it sounds like you are

6088
03:42:17,380 --> 03:42:18,314
planning a standard here

6089
03:42:18,314 --> 03:42:20,714
that if something improves

6090
03:42:22,618 --> 03:42:23,886
efficiency it is -- can

6091
03:42:23,886 --> 03:42:26,286
you please read your

6092
03:42:28,558 --> 03:42:29,792
answer line 6-10?

6093
03:42:29,792 --> 03:42:30,927
>> MR. Lukcic: okay.

6094
03:42:30,927 --> 03:42:33,927
Can you state the first

6095
03:42:40,536 --> 03:42:41,700
part of that question or

6096
03:42:41,700 --> 03:42:41,337
just however you want to

6097
03:42:41,337 --> 03:42:41,671
phrase it.

6098
03:42:41,671 --> 03:42:42,204
>> yes.

6099
03:42:42,204 --> 03:42:42,939
Isn't it true that one of

6100
03:42:42,939 --> 03:42:45,939
the criteria used by teco

6101
03:42:46,575 --> 03:42:47,770
for seeking to recover

6102
03:42:47,770 --> 03:42:47,643
what they named the grr

6103
03:42:47,643 --> 03:42:48,110
project in subsequent year

6104
03:42:48,110 --> 03:42:48,645
adjustments as if the

6105
03:42:48,645 --> 03:42:51,645
project was subject to be

6106
03:42:56,218 --> 03:42:56,752
eligible for afudc?

6107
03:42:56,752 --> 03:42:57,687
And then the question you

6108
03:42:57,687 --> 03:42:58,922
were asked in your

6109
03:42:58,922 --> 03:43:01,322
deposition was it sounds

6110
03:43:02,524 --> 03:43:02,992
like you're planning a

6111
03:43:02,992 --> 03:43:04,260
standard here that if

6112
03:43:04,260 --> 03:43:05,528
something approves --

6113
03:43:05,528 --> 03:43:05,962
improves efficiency that

6114
03:43:05,962 --> 03:43:07,962
it's appropriate to

6115
03:43:10,199 --> 03:43:10,733
include in the sya?

6116
03:43:10,733 --> 03:43:11,000
Am I characterizing that

6117
03:43:11,000 --> 03:43:12,902
correctly?

6118
03:43:12,902 --> 03:43:15,902
Can you please read your

6119
03:43:16,500 --> 03:43:16,639
answer 6-10?

6120
03:43:16,639 --> 03:43:17,739
>> MR. Lukcic: a couple

6121
03:43:17,739 --> 03:43:19,739
of things.

6122
03:43:20,476 --> 03:43:22,876
The assertion that afudc

6123
03:43:23,212 --> 03:43:25,212
was the --

6124
03:43:26,480 --> 03:43:26,349
>> can you please read

6125
03:43:26,349 --> 03:43:27,160
your answer?

6126
03:43:27,160 --> 03:43:29,416
>> MR. Lukcic: my page 47

6127
03:43:37,393 --> 03:43:37,960
6-10 says lights in a --

6128
03:43:37,960 --> 03:43:38,461
along with potentially ev,

6129
03:43:38,461 --> 03:43:38,695
pv, and other edge type

6130
03:43:38,695 --> 03:43:40,695
devices.

6131
03:43:42,699 --> 03:43:45,990
>> MR. Lukcic, are you

6132
03:43:45,468 --> 03:43:48,468
looking at the -- second

6133
03:43:51,541 --> 03:43:53,541
deposition.

6134
03:43:58,147 --> 03:43:58,781
I apologize.

6135
03:43:58,781 --> 03:43:59,315
>> MR. Lukcic: I'm sorry.

6136
03:43:59,315 --> 03:43:59,749
Can you give me the page

6137
03:43:59,749 --> 03:44:01,749
number again three

6138
03:44:04,420 --> 03:44:04,987
>> 47.

6139
03:44:04,987 --> 03:44:06,422
>> MR. Lukcic: okay.

6140
03:44:06,422 --> 03:44:07,560
Which lines?

6141
03:44:07,560 --> 03:44:09,456
>> question I asked isn't

6142
03:44:09,792 --> 03:44:12,192
it true the criteria

6143
03:44:12,462 --> 03:44:12,962
seeking to recover adi

6144
03:44:12,962 --> 03:44:15,362
projects whether it was

6145
03:44:31,914 --> 03:44:32,448
eligible for afudc and in

6146
03:44:32,448 --> 03:44:32,948
this deposition you were

6147
03:44:32,948 --> 03:44:33,449
asked, I mean it sounds

6148
03:44:33,449 --> 03:44:33,916
like you're planning a

6149
03:44:33,916 --> 03:44:34,350
standard here that if

6150
03:44:34,350 --> 03:44:34,750
something improves

6151
03:44:34,750 --> 03:44:35,284
efficiency that's

6152
03:44:35,284 --> 03:44:35,518
appropriate to include in

6153
03:44:35,518 --> 03:44:36,520
the sya.

6154
03:44:36,520 --> 03:44:36,319
Am I characterizing that

6155
03:44:36,319 --> 03:44:36,852
correctly?

6156
03:44:36,852 --> 03:44:37,353
Can you please read your

6157
03:44:37,353 --> 03:44:37,519
answer from line 6-line

6158
03:44:37,519 --> 03:44:38,530
10?

6159
03:44:38,530 --> 03:44:40,530
>> MR. Lukcic: yes.

6160
03:44:40,589 --> 03:44:41,900
To be clear, number one

6161
03:44:41,900 --> 03:44:41,657
the project going to be

6162
03:44:41,657 --> 03:44:42,158
completed in that year and

6163
03:44:42,158 --> 03:44:42,658
the second criteria was

6164
03:44:42,658 --> 03:44:43,920
that the project large

6165
03:44:43,920 --> 03:44:45,492
enough to have been

6166
03:44:51,767 --> 03:44:53,767
eligible for afudc.

6167
03:44:54,603 --> 03:44:55,137
Is and that meet --

6168
03:44:55,137 --> 03:44:57,537
>> MR. Lukcic: the only

6169
03:45:01,109 --> 03:45:01,476
other thing I want to do

6170
03:45:01,476 --> 03:45:02,745
is add context.

6171
03:45:02,745 --> 03:45:03,450
You coming off reading

6172
03:45:03,450 --> 03:45:05,450
lines 6-10.

6173
03:45:05,614 --> 03:45:06,115
I want to add along with

6174
03:45:06,115 --> 03:45:06,782
adding benefits to the

6175
03:45:06,782 --> 03:45:08,782
customer.

6176
03:45:09,985 --> 03:45:12,421
>> so my next question is

6177
03:45:12,421 --> 03:45:12,955
with regards to the plte,

6178
03:45:12,955 --> 03:45:14,523
isn't it meant to replace

6179
03:45:14,523 --> 03:45:16,523
the company's current

6180
03:45:19,428 --> 03:45:19,861
obsolete radio system?

6181
03:45:19,861 --> 03:45:20,162
That is not in the

6182
03:45:20,162 --> 03:45:22,162
deposition.

6183
03:45:24,000 --> 03:45:24,367
>> MR. Lukcic: asked the

6184
03:45:24,367 --> 03:45:24,634
question again.

6185
03:45:24,634 --> 03:45:26,634
I'm sorry.

6186
03:45:28,670 --> 03:45:29,138
>> with regards to the

6187
03:45:29,138 --> 03:45:29,605
plte, is not meant to

6188
03:45:29,605 --> 03:45:31,605
replace the company's

6189
03:45:33,543 --> 03:45:35,543
obsolete radio system?

6190
03:45:40,616 --> 03:45:41,116
>> MR. Lukcic: yes.

6191
03:45:41,116 --> 03:45:41,917
If you start deviating

6192
03:45:41,917 --> 03:45:44,317
from the plan, doesn't

6193
03:45:49,224 --> 03:45:49,792
that create problems?

6194
03:45:49,792 --> 03:45:50,359
>> MR. Lukcic: if we

6195
03:45:50,359 --> 03:45:52,662
start deviating from plan,

6196
03:45:52,662 --> 03:45:53,328
that creates problems.

6197
03:45:53,328 --> 03:45:54,530
>> didn't the company just

6198
03:45:54,530 --> 03:45:56,930
file with the commission

6199
03:45:57,500 --> 03:45:59,500
adjustments -- or

6200
03:46:02,738 --> 03:46:02,904
eliminate elements to the

6201
03:46:02,904 --> 03:46:03,606
sya?

6202
03:46:03,606 --> 03:46:05,606
>> MR. Lukcic: the

6203
03:46:06,175 --> 03:46:08,575
company filed to eliminate

6204
03:46:08,711 --> 03:46:11,111
the recovery of elements

6205
03:46:12,215 --> 03:46:14,215
in the sya.

6206
03:46:16,520 --> 03:46:18,452
>> how many were removed

6207
03:46:29,865 --> 03:46:30,566
from your original asked?

6208
03:46:30,566 --> 03:46:31,132
>> MR. Lukcic: was listed

6209
03:46:31,132 --> 03:46:31,434
in my opening statement no

6210
03:46:31,434 --> 03:46:32,100
components.

6211
03:46:32,100 --> 03:46:32,367
>> thank you so much.

6212
03:46:32,367 --> 03:46:32,935
Nothing further.

6213
03:46:32,935 --> 03:46:33,202
>> CHAIRMAN La Rosa:

6214
03:46:33,202 --> 03:46:33,669
thank you.

6215
03:46:33,669 --> 03:46:33,870
Go to florida rising

6216
03:46:33,870 --> 03:46:34,537
lulac.

6217
03:46:34,537 --> 03:46:36,537
>> thank you.

6218
03:46:37,773 --> 03:46:38,740
Good afternoon/morning,

6219
03:46:38,740 --> 03:46:38,641
MR. Lukcic.

6220
03:46:38,641 --> 03:46:40,900
>> MR. Lukcic: good

6221
03:46:40,900 --> 03:46:41,210
afternoon.

6222
03:46:41,210 --> 03:46:43,879
>> I'm going to try to

6223
03:46:43,879 --> 03:46:44,279
keep this short and not

6224
03:46:44,279 --> 03:46:46,279
duplicate efforts.

6225
03:46:47,917 --> 03:46:48,350
So I will ask a few

6226
03:46:48,350 --> 03:46:50,350
questions about the

6227
03:46:51,353 --> 03:46:52,388
private plte network, but

6228
03:46:52,388 --> 03:46:54,357
just making sure that

6229
03:46:54,357 --> 03:46:56,757
nothing that I'm asking

6230
03:47:01,230 --> 03:47:01,764
has already been asked.

6231
03:47:01,764 --> 03:47:04,164
When considering I'm just

6232
03:47:05,801 --> 03:47:06,268
going to call it the plte

6233
03:47:06,268 --> 03:47:08,136
because that might be

6234
03:47:08,136 --> 03:47:10,136
easier.

6235
03:47:11,607 --> 03:47:14,700
Teco also considered the

6236
03:47:20,950 --> 03:47:21,417
cost of doing a

6237
03:47:21,417 --> 03:47:22,170
public/fiber network?

6238
03:47:22,170 --> 03:47:22,351
>> MR. Lukcic: that's

6239
03:47:22,351 --> 03:47:22,818
correct, yes.

6240
03:47:22,818 --> 03:47:23,319
>> and to these

6241
03:47:23,319 --> 03:47:25,319
considerations teco was

6242
03:47:25,320 --> 03:47:27,720
looking at other utilities

6243
03:47:29,191 --> 03:47:29,392
that currently have a

6244
03:47:29,392 --> 03:47:29,992
plte.

6245
03:47:29,992 --> 03:47:31,360
>> MR. Lukcic: that's

6246
03:47:31,360 --> 03:47:33,360
correct.

6247
03:47:36,532 --> 03:47:36,965
>> in those considerations

6248
03:47:36,965 --> 03:47:39,365
are there any other.

6249
03:47:42,571 --> 03:47:42,871
Utilities for teco that

6250
03:47:42,871 --> 03:47:43,538
use a plte?

6251
03:47:43,538 --> 03:47:44,206
>> MR. Lukcic: I'm sorry,

6252
03:47:44,206 --> 03:47:46,206
say that again?

6253
03:47:46,208 --> 03:47:48,177
>> are there any

6254
03:47:48,177 --> 03:47:48,711
.

6255
03:47:48,711 --> 03:47:51,111
Utilities in florida that

6256
03:47:52,848 --> 03:47:55,248
use a private plte

6257
03:48:00,356 --> 03:48:01,624
network?

6258
03:48:01,624 --> 03:48:04,624
The majority of the pure

6259
03:48:08,364 --> 03:48:08,697
utilities do not use a

6260
03:48:08,697 --> 03:48:09,999
plte network?

6261
03:48:09,999 --> 03:48:10,232
>> MR. Lukcic: that's

6262
03:48:10,232 --> 03:48:10,666
correct.

6263
03:48:10,666 --> 03:48:11,200
>> thank you.

6264
03:48:11,200 --> 03:48:14,800
I would like to bring up

6265
03:48:18,741 --> 03:48:21,741
this is fll 179 or master

6266
03:48:31,554 --> 03:48:33,550
number f3.3-5842.

6267
03:48:33,550 --> 03:48:35,455
Do you recognize this

6268
03:48:37,920 --> 03:48:37,726
document?

6269
03:48:37,726 --> 03:48:39,728
>> MR. Lukcic: I do, yes.

6270
03:48:39,728 --> 03:48:41,597
>> this is a document that

6271
03:48:41,597 --> 03:48:42,131
third parties burns and

6272
03:48:42,131 --> 03:48:45,131
Mcdonald used to look at

6273
03:48:46,835 --> 03:48:47,469
the private lte network?

6274
03:48:47,469 --> 03:48:48,871
>> MR. Lukcic: yes, they

6275
03:48:48,871 --> 03:48:51,271
were responsible for the

6276
03:48:52,207 --> 03:48:52,875
entire evaluation.

6277
03:48:52,875 --> 03:48:54,477
>> I think you scroll down

6278
03:48:54,477 --> 03:48:57,477
two or three pages you'll

6279
03:48:58,581 --> 03:48:59,181
see a pie chart.

6280
03:48:59,181 --> 03:48:59,581
>> MR. Lukcic: sorry,

6281
03:48:59,581 --> 03:49:01,217
there's lag here.

6282
03:49:01,217 --> 03:49:04,217
>> I was dealing with that

6283
03:49:05,754 --> 03:49:06,355
earlier.

6284
03:49:06,355 --> 03:49:08,755
>> MR. Lukcic: I guess

6285
03:49:09,124 --> 03:49:11,524
that lag was forever.

6286
03:49:11,927 --> 03:49:12,427
Yes, I'm there.

6287
03:49:12,427 --> 03:49:14,196
>> this shows the

6288
03:49:14,196 --> 03:49:16,596
breakdown of the estimate

6289
03:49:16,698 --> 03:49:18,698
of cost.

6290
03:49:19,968 --> 03:49:22,400
>> MR. Lukcic: summary of

6291
03:49:22,400 --> 03:49:23,405
10 year cost, yeah.

6292
03:49:23,405 --> 03:49:27,500
>> a huge chunk of it are

6293
03:49:27,909 --> 03:49:28,510
the lte devices.

6294
03:49:28,510 --> 03:49:30,345
>> MR. Lukcic: that is

6295
03:49:30,345 --> 03:49:32,345
correct.

6296
03:49:34,950 --> 03:49:35,551
>> followed by spectrum.

6297
03:49:35,551 --> 03:49:36,918
>> MR. Lukcic: that is

6298
03:49:36,918 --> 03:49:38,918
correct.

6299
03:49:46,161 --> 03:49:46,695
>> thank you.

6300
03:49:46,695 --> 03:49:47,896
Just making sure some of

6301
03:49:47,896 --> 03:49:49,198
the questions were not

6302
03:49:49,198 --> 03:49:49,398
asked.

6303
03:49:49,398 --> 03:49:51,398
Okay.

6304
03:49:52,667 --> 03:49:54,938
The last document I would

6305
03:49:54,938 --> 03:49:57,506
like to pull up is fll

6306
03:49:57,506 --> 03:49:59,506
189, which is master

6307
03:50:30,205 --> 03:50:30,739
number f f3.3-6365.

6308
03:50:30,739 --> 03:50:34,143
And if you can click the

6309
03:50:34,143 --> 03:50:36,143
hyperlink, the excel

6310
03:50:45,353 --> 03:50:45,921
there.

6311
03:50:45,921 --> 03:50:47,921
>> MR. Lukcic: okay.

6312
03:50:48,323 --> 03:50:50,323
>> this represents

6313
03:50:55,531 --> 03:50:57,332
different -- one second.

6314
03:50:57,332 --> 03:50:59,332
This represents different

6315
03:50:59,968 --> 03:51:01,968
operations projects and

6316
03:51:05,140 --> 03:51:05,807
the costs associated.

6317
03:51:05,807 --> 03:51:06,809
>> MR. Lukcic: I'm sorry,

6318
03:51:06,809 --> 03:51:08,809
what projects?

6319
03:51:08,911 --> 03:51:10,911
>> operation spending

6320
03:51:13,715 --> 03:51:14,216
cost.

6321
03:51:14,216 --> 03:51:14,483
And you recognize this

6322
03:51:14,483 --> 03:51:15,651
document?

6323
03:51:15,651 --> 03:51:16,218
>> MR. Lukcic: I do.

6324
03:51:16,218 --> 03:51:16,718
>> thank you so much.

6325
03:51:16,718 --> 03:51:17,152
Those are my questions,

6326
03:51:17,152 --> 03:51:17,419
MR. Lukcic.

6327
03:51:17,419 --> 03:51:18,860
Thank you.

6328
03:51:18,860 --> 03:51:20,860
>> CHAIRMAN La Rosa:

6329
03:51:20,522 --> 03:51:20,722
thank you.

6330
03:51:20,722 --> 03:51:22,524
Fipug?

6331
03:51:22,524 --> 03:51:24,524
>> no questions.

6332
03:51:26,562 --> 03:51:27,290
>> CHAIRMAN La Rosa: fea.

6333
03:51:27,290 --> 03:51:27,596
>> no questions.

6334
03:51:27,596 --> 03:51:27,896
>> CHAIRMAN La Rosa:

6335
03:51:27,896 --> 03:51:29,531
sierra club.

6336
03:51:29,531 --> 03:51:31,531
>> no questions.

6337
03:51:32,968 --> 03:51:33,202
>> CHAIRMAN La Rosa:

6338
03:51:33,202 --> 03:51:33,669
walmart?

6339
03:51:33,669 --> 03:51:34,369
>> no questions.

6340
03:51:34,369 --> 03:51:34,937
Thank you.

6341
03:51:34,937 --> 03:51:35,437
>> CHAIRMAN La Rosa:

6342
03:51:35,437 --> 03:51:37,500
staff.

6343
03:51:37,500 --> 03:51:38,540
>> Staff: no questions.

6344
03:51:38,540 --> 03:51:39,107
Thank you.

6345
03:51:39,107 --> 03:51:40,409
>> CHAIRMAN La Rosa:

6346
03:51:40,409 --> 03:51:42,343
commissioners, any

6347
03:51:42,343 --> 03:51:44,279
questions?

6348
03:51:44,279 --> 03:51:44,713
Seeing none, transit, give

6349
03:51:44,713 --> 03:51:46,782
it back to you for

6350
03:51:46,782 --> 03:51:47,282
redirect.

6351
03:51:47,282 --> 03:51:48,951
>> thank you, MR.

6352
03:51:48,951 --> 03:51:50,951
CHAIRMAN.

6353
03:51:57,125 --> 03:51:57,659
Just a few.

6354
03:51:57,659 --> 03:52:00,659
MR. Lukcic, do you recall

6355
03:52:04,466 --> 03:52:06,535
when MR. Waltrus asked you

6356
03:52:06,535 --> 03:52:07,350
and you said two?

6357
03:52:07,350 --> 03:52:09,300
Is the cost recovery in

6358
03:52:09,300 --> 03:52:09,271
this case for 40 trento

6359
03:52:09,271 --> 03:52:09,904
projects?

6360
03:52:09,904 --> 03:52:11,239
>> MR. Lukcic: they are

6361
03:52:11,239 --> 03:52:13,141
not.

6362
03:52:13,141 --> 03:52:13,608
>> how many are originally

6363
03:52:13,608 --> 03:52:14,209
included in this case?

6364
03:52:14,209 --> 03:52:14,576
>> MR. Lukcic: for the

6365
03:52:14,576 --> 03:52:16,211
subsequent year

6366
03:52:16,211 --> 03:52:16,712
adjustments there were six

6367
03:52:16,712 --> 03:52:19,112
and there are currently

6368
03:52:22,383 --> 03:52:23,551
four.

6369
03:52:23,551 --> 03:52:25,551
>> thank you.

6370
03:52:26,200 --> 03:52:28,420
Just one second, MR.

6371
03:52:32,994 --> 03:52:33,428
CHAIRMAN.

6372
03:52:33,428 --> 03:52:35,828
MR. Lukcic, do you

6373
03:52:36,630 --> 03:52:36,565
remember earlier when MR.

6374
03:52:36,565 --> 03:52:38,965
Waltrus asked you about

6375
03:52:38,967 --> 03:52:40,967
your deposition transcript

6376
03:52:42,237 --> 03:52:45,237
and you stated that afudc

6377
03:52:46,410 --> 03:52:46,608
was -- do you recall that?

6378
03:52:46,608 --> 03:52:48,610
>> MR. Lukcic: I do.

6379
03:52:48,610 --> 03:52:51,610
>> did you make a mistake

6380
03:52:51,913 --> 03:52:52,514
when you said that?

6381
03:52:52,514 --> 03:52:52,881
>> MR. Lukcic: in the

6382
03:52:52,881 --> 03:52:53,315
deposition, yes.

6383
03:52:53,315 --> 03:52:55,315
>> thank you.

6384
03:52:56,618 --> 03:52:57,185
No further questions.

6385
03:52:57,185 --> 03:52:57,452
>> CHAIRMAN La Rosa:

6386
03:52:57,452 --> 03:52:59,452
thank you.

6387
03:52:59,854 --> 03:53:00,155
Let's move exhibits into

6388
03:53:00,155 --> 03:53:02,155
the record.

6389
03:53:07,290 --> 03:53:07,462
Teco?

6390
03:53:07,462 --> 03:53:07,996
>> thank you.

6391
03:53:07,996 --> 03:53:08,363
We would move exhibits 22

6392
03:53:08,363 --> 03:53:08,997
into the record.

6393
03:53:08,997 --> 03:53:09,364
>> CHAIRMAN La Rosa: 22

6394
03:53:09,364 --> 03:53:10,451
into the record.

6395
03:53:10,451 --> 03:53:11,799
Any objection?

6396
03:53:11,799 --> 03:53:14,199
seeing none, show that

6397
03:53:21,900 --> 03:53:21,176
entered into the record.

6398
03:53:21,176 --> 03:53:21,777
Opc?

6399
03:53:21,777 --> 03:53:22,440
>> no exhibits from opc.

6400
03:53:22,440 --> 03:53:22,677
Thank you.

6401
03:53:22,677 --> 03:53:22,911
>> CHAIRMAN La Rosa: any

6402
03:53:22,911 --> 03:53:23,311
others?

6403
03:53:23,311 --> 03:53:24,846
Any other parties?

6404
03:53:24,846 --> 03:53:25,380
>> florida rising and

6405
03:53:25,380 --> 03:53:28,380
lulac would like to move

6406
03:53:30,519 --> 03:53:30,819
exhibits 649 and 639 into

6407
03:53:30,819 --> 03:53:31,453
the record.

6408
03:53:31,453 --> 03:53:31,920
>> CHAIRMAN La Rosa: any

6409
03:53:31,920 --> 03:53:32,120
opposition to moving

6410
03:53:32,120 --> 03:53:34,120
those?

6411
03:53:36,424 --> 03:53:37,590
>> no objections.

6412
03:53:37,590 --> 03:53:37,359
>> CHAIRMAN La Rosa: no

6413
03:53:37,359 --> 03:53:37,926
objections.

6414
03:53:37,926 --> 03:53:38,160
Show them entered into the

6415
03:53:38,160 --> 03:53:38,593
record.

6416
03:53:38,593 --> 03:53:39,461
Are there any other

6417
03:53:39,461 --> 03:53:39,695
exhibits entered into the

6418
03:53:39,695 --> 03:53:41,695
record?

6419
03:53:44,433 --> 03:53:44,966
Okay.

6420
03:53:44,966 --> 03:53:47,435
MR. Lukcic, thank you for

6421
03:53:47,435 --> 03:53:47,802
being with us today and

6422
03:53:47,802 --> 03:53:49,371
you are excused.

6423
03:53:49,371 --> 03:53:50,380
>> MR. Lukcic: thank you.

6424
03:53:50,380 --> 03:53:53,380
>> CHAIRMAN La Rosa: so I

6425
03:53:55,877 --> 03:53:56,178
think we are good for a

6426
03:53:56,178 --> 03:53:56,745
lunch break.

6427
03:53:56,745 --> 03:54:00,345
It is a few minutes before

6428
03:54:01,116 --> 03:54:03,850
12:0, so let's say 1:05.

6429
03:54:03,850 --> 03:54:04,119
Same 1:05 we will

6430
03:54:04,119 --> 03:54:06,119
reconvene here.

6431
03:54:06,121 --> 03:54:08,121
Fair?

6432
03:54:10,603 --> 03:54:13,300
Testing 10 987654321 this is a

6433
03:54:14,641 --> 03:54:17,641
test for the closed captioning

6434
03:54:18,878 --> 03:54:21,278
service for this afternoon.

6435
03:54:25,318 --> 03:54:27,718
Testing 10 987654321 this is a

6436
03:54:27,854 --> 03:54:30,854
test for the closed captioning

6437
03:54:45,400 --> 03:54:47,400
service test. 10 987654321

6438
03:54:48,408 --> 03:54:50,408
thank you.

6439
04:07:52,257 --> 04:07:55,857
A few minutes after 1 pm I

6440
04:07:56,995 --> 04:08:00,965
think we can start to get in

6441
04:08:00,965 --> 04:08:02,667
position to get rolling again.

6442
04:08:02,667 --> 04:08:04,769
We finished the last witness.

6443
04:08:04,769 --> 04:08:08,439
I think we will turn it back

6444
04:08:08,439 --> 04:08:09,540
over to teco to introduce the

6445
04:08:09,540 --> 04:08:11,540
next witness.

6446
04:08:13,344 --> 04:08:15,213
>> thank you MR. CHAIRMAN tampa

6447
04:08:15,213 --> 04:08:15,579
electric calls.

6448
04:08:15,579 --> 04:08:17,282
[Listing names]

6449
04:08:17,282 --> 04:08:18,316
>> Mike La Rosa,CHAIRMAN:

6450
04:08:18,316 --> 04:08:21,316
[Listing names] If you don't

6451
04:08:24,122 --> 04:08:25,389
mind before you sit down

6452
04:08:25,389 --> 04:08:27,392
administering the oath to swear

6453
04:08:27,392 --> 04:08:29,259
and affirm the testimony you

6454
04:08:29,259 --> 04:08:31,162
are about to give will be the

6455
04:08:31,162 --> 04:08:32,230
truth the whole truth and

6456
04:08:32,230 --> 04:08:34,630
nothing but the truth.

6457
04:08:35,367 --> 04:08:38,967
Have a seat and settle in.

6458
04:08:39,971 --> 04:08:40,772
>> teco: good afternoon will

6459
04:08:40,772 --> 04:08:41,373
state your name for

6460
04:08:41,373 --> 04:08:42,173
the record.

6461
04:08:42,173 --> 04:08:44,173
>>.

6462
04:08:44,509 --> 04:08:45,677
[Listing names].

6463
04:08:45,677 --> 04:08:48,280
Who is your current employer

6464
04:08:48,280 --> 04:08:49,514
what is your business address.

6465
04:08:49,514 --> 04:08:51,382
Tampa electric 702 n. Franklin

6466
04:08:51,382 --> 04:08:53,782
st. Tampa electric 702 n.

6467
04:08:54,385 --> 04:08:55,620
Franklin st., tampa, fl.

6468
04:08:55,620 --> 04:08:57,389
>> teco: did you prepare and

6469
04:08:57,389 --> 04:08:59,456
cause to be filed on this

6470
04:08:59,456 --> 04:09:01,856
docket APRIL 24 prepare direct

6471
04:09:02,227 --> 04:09:02,394
testimony insisting of 35 pages

6472
04:09:02,394 --> 04:09:02,660
.

6473
04:09:02,660 --> 04:09:04,660
>> I did.

6474
04:09:05,263 --> 04:09:07,297
>> teco: any corrections or

6475
04:09:07,297 --> 04:09:10,897
durations if I were to answer

6476
04:09:16,700 --> 04:09:17,108
the questions contained in your

6477
04:09:17,108 --> 04:09:19,100
prepared testimony would

6478
04:09:19,100 --> 04:09:20,110
renters be the same as those

6479
04:09:20,110 --> 04:09:21,379
written testimony.

6480
04:09:21,379 --> 04:09:23,140
>> Witnes: they would.

6481
04:09:23,140 --> 04:09:24,249
>> teco: MR. CHAIRMAN temple

6482
04:09:24,249 --> 04:09:26,184
electric prepared testimony to

6483
04:09:26,184 --> 04:09:27,170
be inserted into the record as

6484
04:09:27,170 --> 04:09:29,170
read.

6485
04:09:29,190 --> 04:09:31,220
Did you also prepare and cause

6486
04:09:31,220 --> 04:09:32,323
to be filed with your direct

6487
04:09:32,323 --> 04:09:32,490
testimony and exhibits marked

6488
04:09:32,490 --> 04:09:33,900
ch

6489
04:09:33,900 --> 04:09:34,920
b

6490
04:09:34,920 --> 04:09:34,359
one consisting of 2

6491
04:09:34,359 --> 04:09:35,393
documents.

6492
04:09:35,393 --> 04:09:37,393
>> Witnes: I did.

6493
04:09:37,395 --> 04:09:39,397
>> teco: MR. CHAIRMAN temple

6494
04:09:39,397 --> 04:09:41,298
electric window for the record

6495
04:09:41,298 --> 04:09:43,301
that exhibit seat one is

6496
04:09:43,301 --> 04:09:46,901
identified on the cl as exhibit

6497
04:09:50,475 --> 04:09:52,475
number 23.

6498
04:09:54,512 --> 04:09:56,512
Yes it is 23.

6499
04:09:56,514 --> 04:09:58,820
Would you please summarize your

6500
04:09:58,820 --> 04:09:59,284
testimony.

6501
04:09:59,284 --> 04:10:01,352
>> Witness: I will thank you

6502
04:10:01,352 --> 04:10:03,352
good afternoon commissioners

6503
04:10:04,210 --> 04:10:06,157
might direct testimony has five

6504
04:10:06,157 --> 04:10:06,253
primary objectives. Number one

6505
04:10:06,253 --> 04:10:08,253
,

6506
04:10:09,694 --> 04:10:11,729
it describes tampa electric

6507
04:10:11,729 --> 04:10:13,231
informational technology

6508
04:10:13,231 --> 04:10:16,231
department and the key services

6509
04:10:16,968 --> 04:10:18,970
it provides the company's

6510
04:10:18,970 --> 04:10:20,972
functional areas. Number two it

6511
04:10:20,972 --> 04:10:22,240
discusses our comprehensive

6512
04:10:22,240 --> 04:10:23,975
cybersecurity program now we

6513
04:10:23,975 --> 04:10:24,976
are addressing the ever

6514
04:10:24,976 --> 04:10:26,144
escalating and more

6515
04:10:26,144 --> 04:10:28,144
sophisticated cyber security

6516
04:10:29,580 --> 04:10:31,980
threats and data privacy

6517
04:10:33,585 --> 04:10:34,786
concerns. Number three,

6518
04:10:34,786 --> 04:10:37,688
explains the cost to operate

6519
04:10:37,688 --> 04:10:37,789
and maintain the idf locations

6520
04:10:37,789 --> 04:10:39,757
,

6521
04:10:39,757 --> 04:10:41,259
number four, it addresses the

6522
04:10:41,259 --> 04:10:43,659
important changes made since

6523
04:10:45,960 --> 04:10:47,980
our 2021 rate case to our major

6524
04:10:47,980 --> 04:10:48,933
idf locations. Lastly, I direct

6525
04:10:48,933 --> 04:10:50,933
testimony demonstrates the

6526
04:10:50,935 --> 04:10:52,303
information technology rate

6527
04:10:52,303 --> 04:10:55,303
base amount and operation and

6528
04:10:56,640 --> 04:10:58,509
maintenance expenses for 2025

6529
04:10:58,509 --> 04:10:59,277
test year are reasonable and

6530
04:10:59,277 --> 04:11:00,511
prudent.

6531
04:11:00,511 --> 04:11:00,712
That concludes my summary thank

6532
04:11:00,712 --> 04:11:02,712
you.

6533
04:11:03,915 --> 04:11:05,483
>> teco: [Listing names] Is

6534
04:11:05,483 --> 04:11:06,184
available for cross-examination

6535
04:11:06,184 --> 04:11:08,184
.

6536
04:11:08,186 --> 04:11:08,453
> Mike La Rosa,CHAIRMAN:

6537
04:11:08,453 --> 04:11:09,888
thank you.

6538
04:11:09,888 --> 04:11:11,888
>> MR. CHAIRMAN and

6539
04:11:12,757 --> 04:11:14,757
commissioners good afternoon

6540
04:11:19,764 --> 04:11:20,932
MR. Haack nice meeting you.

6541
04:11:20,932 --> 04:11:22,967
>> Witness: nice to meet you.

6542
04:11:22,967 --> 04:11:24,836
>> I think you just stated your

6543
04:11:24,836 --> 04:11:25,970
title is vice PRESIDENT Of

6544
04:11:25,970 --> 04:11:27,970
information technology?

6545
04:11:29,139 --> 04:11:29,407
Chief information officer tampa

6546
04:11:29,407 --> 04:11:31,175
electric.

6547
04:11:31,175 --> 04:11:33,440
>> Witness: that is correct.

6548
04:11:33,440 --> 04:11:35,460
>> at the time you filed your

6549
04:11:35,460 --> 04:11:37,480
testimony you have been a tampa

6550
04:11:37,480 --> 04:11:37,682
electric for exactly one year.

6551
04:11:37,682 --> 04:11:38,215
>> Witness: that's

6552
04:11:38,215 --> 04:11:40,215
correct.

6553
04:11:41,520 --> 04:11:42,186
>> immediately prior to APRIL

6554
04:11:42,186 --> 04:11:43,588
2023 you were the chief digital

6555
04:11:43,588 --> 04:11:44,555
officer beginning in 2020 is

6556
04:11:44,555 --> 04:11:45,890
that correct.

6557
04:11:45,890 --> 04:11:47,890
>> Witness: that's correct.

6558
04:11:49,661 --> 04:11:51,562
>> teco: [Listing names] Shows

6559
04:11:51,562 --> 04:11:55,162
you in that role on their

6560
04:11:55,733 --> 04:11:56,670
website is there a dual role

6561
04:11:56,670 --> 04:11:56,868
that you have.

6562
04:11:56,868 --> 04:11:58,669
> Witness:

6563
04:11:58,669 --> 04:11:59,737
there is a dual role that I

6564
04:11:59,737 --> 04:12:01,638
have I am doing both.

6565
04:12:01,638 --> 04:12:04,380
>> teco: are you transitioning

6566
04:12:06,977 --> 04:12:07,345
is it something that you do for

6567
04:12:07,345 --> 04:12:09,147
both companies.

6568
04:12:09,147 --> 04:12:11,150
>> Witness: I do it for both

6569
04:12:11,150 --> 04:12:12,215
companies for some period of

6570
04:12:12,215 --> 04:12:13,251
time undefined at this point.

6571
04:12:13,251 --> 04:12:15,119
>> teco: okay.

6572
04:12:15,119 --> 04:12:16,254
>> is all of your time on the

6573
04:12:16,254 --> 04:12:18,188
books of tampa electric that

6574
04:12:18,188 --> 04:12:18,283
you allocate time

6575
04:12:18,283 --> 04:12:19,924
.

6576
04:12:19,924 --> 04:12:22,924
>> Witness: I allocate based on

6577
04:12:26,631 --> 04:12:27,765
calendar entries and reviewing

6578
04:12:27,765 --> 04:12:28,766
that is my longing for our

6579
04:12:28,766 --> 04:12:29,767
spread.

6580
04:12:29,767 --> 04:12:31,402
>> do have an idea of what

6581
04:12:31,402 --> 04:12:31,499
roughly what split

6582
04:12:31,499 --> 04:12:33,336
.

6583
04:12:33,336 --> 04:12:35,539
>> Witness: it is exactly 75

6584
04:12:35,539 --> 04:12:37,539
tampa electric 25.

6585
04:12:38,750 --> 04:12:40,750
[Listing names].

6586
04:12:40,711 --> 04:12:43,648
>> in your role or your roles

6587
04:12:43,648 --> 04:12:45,648
different do perform

6588
04:12:49,200 --> 04:12:49,187
essentially the same functions

6589
04:12:49,187 --> 04:12:51,550
at.

6590
04:12:51,550 --> 04:12:51,322
[Listing names] And tampa

6591
04:12:51,322 --> 04:12:53,322
electric.

6592
04:12:54,570 --> 04:12:55,590
>> Witness: and the technology

6593
04:12:55,590 --> 04:12:55,859
guy if you will and both

6594
04:12:55,859 --> 04:12:57,600
companies there is

6595
04:12:57,600 --> 04:12:58,328
a lot of

6596
04:12:58,328 --> 04:12:59,163
similarities and overlap but my

6597
04:12:59,163 --> 04:13:01,132
role at.

6598
04:13:01,132 --> 04:13:03,101
[Listing names] Is broader and

6599
04:13:03,101 --> 04:13:04,135
done for the parent company

6600
04:13:04,135 --> 04:13:04,602
overall affiliates.

6601
04:13:04,602 --> 04:13:06,471
>> do you

6602
04:13:06,471 --> 04:13:06,566
do work for

6603
04:13:06,566 --> 04:13:08,566
.

6604
04:13:12,243 --> 04:13:14,243
[Listing names]

6605
04:13:18,316 --> 04:13:20,151
>> in your role before at emera

6606
04:13:20,151 --> 04:13:20,451
you are the cio or chief

6607
04:13:20,451 --> 04:13:22,530
information

6608
04:13:22,530 --> 04:13:22,186
officer be 13 I was

6609
04:13:22,186 --> 04:13:23,587
.

6610
04:13:23,587 --> 04:13:26,190
>> arguably one of the largest

6611
04:13:26,190 --> 04:13:28,526
if not one of the largest five

6612
04:13:28,526 --> 04:13:29,727
utilities in the company.

6613
04:13:29,727 --> 04:13:32,727
Was your role there essentially

6614
04:13:34,198 --> 04:13:35,366
the same as what you do at

6615
04:13:35,366 --> 04:13:36,434
emera@tampa electric.

6616
04:13:36,434 --> 04:13:38,434
>> Witness: yes.

6617
04:13:42,606 --> 04:13:45,476
>> with your experience in the

6618
04:13:45,476 --> 04:13:46,844
utility world and your current

6619
04:13:46,844 --> 04:13:48,844
responsibilities you would've

6620
04:13:49,646 --> 04:13:51,649
had oversight knowledge and

6621
04:13:51,649 --> 04:13:52,949
responsibilities integration of

6622
04:13:52,949 --> 04:13:54,685
software application into a

6623
04:13:54,685 --> 04:13:57,850
whole array of business

6624
04:13:57,621 --> 04:13:57,821
operations of all the companies

6625
04:13:57,821 --> 04:13:58,689
?

6626
04:13:58,689 --> 04:13:59,790
Is that right.

6627
04:13:59,790 --> 04:14:02,190
>> Witness: this is true.

6628
04:14:03,894 --> 04:14:06,294
>> your responsibility as the

6629
04:14:15,939 --> 04:14:17,410
cdo chief digital officer.

6630
04:14:17,410 --> 04:14:19,410
>> Witness: I do.

6631
04:14:19,810 --> 04:14:20,878
>> at emera would include both

6632
04:14:20,878 --> 04:14:22,878
oversight knowledge and

6633
04:14:22,880 --> 04:14:24,682
oversight responsibility of the

6634
04:14:24,682 --> 04:14:25,983
integration of software

6635
04:14:25,983 --> 04:14:27,885
applications into the whole

6636
04:14:27,885 --> 04:14:29,853
array of business operations of

6637
04:14:29,853 --> 04:14:31,122
the emera operating companies

6638
04:14:31,122 --> 04:14:32,890
including tampa.

6639
04:14:32,890 --> 04:14:33,991
>> Witness: it is the knowledge

6640
04:14:33,991 --> 04:14:35,826
of as an employee of the parent

6641
04:14:35,826 --> 04:14:37,600
company it is more about

6642
04:14:37,600 --> 04:14:39,300
governance of what is done at

6643
04:14:39,300 --> 04:14:40,898
the affiliates than intimate

6644
04:14:40,898 --> 04:14:41,198
knowledge within the

6645
04:14:41,198 --> 04:14:43,340
affiliates.

6646
04:14:43,340 --> 04:14:45,736
>> I take it every single

6647
04:14:45,736 --> 04:14:47,605
software application does not

6648
04:14:47,605 --> 04:14:48,720
come across your desk.

6649
04:14:48,720 --> 04:14:48,739
>> Witness:

6650
04:14:48,739 --> 04:14:50,739
exactly.

6651
04:14:50,774 --> 04:14:52,843
>> I think in your testimony

6652
04:14:52,843 --> 04:14:52,976
you talked about cybersecurity

6653
04:14:52,976 --> 04:14:53,845
.

6654
04:14:53,845 --> 04:14:55,713
>> Witness: I do.

6655
04:14:55,713 --> 04:14:56,647
>> I both emera and tampa

6656
04:14:56,647 --> 04:14:57,681
electric.

6657
04:14:57,681 --> 04:14:59,650
>> Witness: yes.

6658
04:14:59,650 --> 04:15:00,817
>> would that role require all

6659
04:15:00,817 --> 04:15:02,653
software that supports

6660
04:15:02,653 --> 04:15:03,219
operations must at some degree

6661
04:15:03,219 --> 04:15:05,619
your organization and under

6662
04:15:13,864 --> 04:15:15,800
your overall supervision be

6663
04:15:15,800 --> 04:15:17,268
screened for compliance with

6664
04:15:17,268 --> 04:15:19,203
company security standards?

6665
04:15:19,203 --> 04:15:20,972
>> Witness: that's correct yes.

6666
04:15:20,972 --> 04:15:22,873
>> also for compliance with any

6667
04:15:22,873 --> 04:15:24,809
relations that you describe in

6668
04:15:24,809 --> 04:15:26,277
your testimony pages 14 and 15.

6669
04:15:26,277 --> 04:15:27,878
>> Witness: that's correct.

6670
04:15:27,878 --> 04:15:29,113
>> this concept would apply to

6671
04:15:29,113 --> 04:15:31,282
the software that you show in

6672
04:15:31,282 --> 04:15:31,815
document number two of your

6673
04:15:31,815 --> 04:15:31,982
exhibit.

6674
04:15:31,982 --> 04:15:32,850
>>.

6675
04:15:32,850 --> 04:15:34,510
>> Witness: gas.

6676
04:15:34,510 --> 04:15:35,219
>> that would be when I say

6677
04:15:35,219 --> 04:15:36,654
this concept I would say the

6678
04:15:36,654 --> 04:15:38,389
screening or governance of

6679
04:15:38,389 --> 04:15:40,789
cybersecurity reasons for the

6680
04:15:40,925 --> 04:15:43,925
software that was resident in

6681
04:15:46,960 --> 04:15:47,598
the capital budget of the other

6682
04:15:47,598 --> 04:15:49,333
operating departments of the

6683
04:15:49,333 --> 04:15:49,467
company presented in this case

6684
04:15:49,467 --> 04:15:51,467
.

6685
04:15:51,669 --> 04:15:52,470
>> Witness: can you repeat that

6686
04:15:52,470 --> 04:15:54,470
for me.

6687
04:15:57,475 --> 04:15:58,609
>> what I'm asking you present

6688
04:15:58,609 --> 04:16:01,609
your capital budget or your

6689
04:16:02,780 --> 04:16:02,913
department

6690
04:16:02,913 --> 04:16:03,280
.

6691
04:16:03,280 --> 04:16:04,810
>> Witness: yes.

6692
04:16:04,810 --> 04:16:06,490
> some of

6693
04:16:06,490 --> 04:16:08,452
the other operations they have

6694
04:16:08,452 --> 04:16:08,652
their own dedicated software

6695
04:16:08,652 --> 04:16:09,520
right.

6696
04:16:09,520 --> 04:16:11,520
>> Witness: yes.

6697
04:16:12,990 --> 04:16:14,191
>> even though you were not

6698
04:16:14,191 --> 04:16:16,259
talking about the prudence of

6699
04:16:16,259 --> 04:16:18,162
the software for software that

6700
04:16:18,162 --> 04:16:19,430
they use still has to come up

6701
04:16:19,430 --> 04:16:21,198
under your cybersecurity

6702
04:16:21,198 --> 04:16:22,166
governance.

6703
04:16:22,166 --> 04:16:24,566
>> Witness: this is correct.

6704
04:16:24,802 --> 04:16:26,403
>> in this sense you have a

6705
04:16:26,403 --> 04:16:28,439
general awareness of at least

6706
04:16:28,439 --> 04:16:30,839
the major software application

6707
04:16:33,877 --> 04:16:35,346
that support all areas of the

6708
04:16:35,346 --> 04:16:35,545
company's operation is that

6709
04:16:35,545 --> 04:16:36,980
there.

6710
04:16:36,980 --> 04:16:39,380
>> Witness: that is fair.

6711
04:16:41,151 --> 04:16:41,318
>> no rebuttal testimony from

6712
04:16:41,318 --> 04:16:43,200
you.

6713
04:16:43,200 --> 04:16:44,889
> Witness: correct.

6714
04:16:44,889 --> 04:16:46,924
>> no one has filed testimony

6715
04:16:46,924 --> 04:16:48,959
in response to your testimony

6716
04:16:48,959 --> 04:16:50,600
describe the historical and

6717
04:16:50,600 --> 04:16:51,162
projected cost of your

6718
04:16:51,162 --> 04:16:52,960
department.

6719
04:16:52,960 --> 04:16:53,931
>> Witness: that is correct.

6720
04:16:53,931 --> 04:16:55,933
>> I note in your that you

6721
04:16:55,933 --> 04:16:57,968
justify your testimony does not

6722
04:16:57,968 --> 04:16:59,690
include operations technology

6723
04:16:59,690 --> 04:17:01,500
applications and their

6724
04:17:01,500 --> 04:17:03,500
supporting staff their

6725
04:17:03,941 --> 04:17:05,175
supporting software supporting

6726
04:17:05,175 --> 04:17:07,110
hardware, which is described in

6727
04:17:07,110 --> 04:17:09,411
the direct testimony of.

6728
04:17:11,715 --> 04:17:12,950
[Listing names]

6729
04:17:12,950 --> 04:17:14,885
>> Witness: that's correct.

6730
04:17:14,885 --> 04:17:16,887
>> one might conclude the lack

6731
04:17:16,887 --> 04:17:18,722
of rebuttal would indicate

6732
04:17:18,722 --> 04:17:19,890
there is no controversy or

6733
04:17:19,890 --> 04:17:21,240
dispute relative to the it

6734
04:17:21,240 --> 04:17:21,858
department is that how you

6735
04:17:21,858 --> 04:17:22,580
look

6736
04:17:22,580 --> 04:17:23,727
at it.

6737
04:17:23,727 --> 04:17:24,600
>> Witness: I made no

6738
04:17:24,600 --> 04:17:24,962
assumptions.

6739
04:17:24,962 --> 04:17:26,962
>> fair enough.

6740
04:17:27,998 --> 04:17:29,833
In your testimony at 481

6741
04:17:29,833 --> 04:17:31,833
,

6742
04:17:34,638 --> 04:17:37,638
[Unclear audio] It is page 5.

6743
04:17:45,883 --> 04:17:47,840
Line 8-17 you recount tampa

6744
04:17:47,840 --> 04:17:49,190
electric company's major areas

6745
04:17:49,190 --> 04:17:52,190
of strategic focus and pointed

6746
04:17:52,389 --> 04:17:52,556
to MR. Collins testimony to do

6747
04:17:52,556 --> 04:17:53,524
it.

6748
04:17:53,524 --> 04:17:55,458
>> Witness: I do.

6749
04:17:55,458 --> 04:17:57,460
>> can you read aloud items one

6750
04:17:57,460 --> 04:17:59,460
and two please.

6751
04:18:00,364 --> 04:18:01,865
>> Witness: item 1 is carefully

6752
04:18:01,865 --> 04:18:03,567
imprudently manage operating

6753
04:18:03,567 --> 04:18:05,569
expenses and capital spending

6754
04:18:05,569 --> 04:18:07,437
to meet growing and changing

6755
04:18:07,437 --> 04:18:10,437
needs in our service area

6756
04:18:11,175 --> 04:18:13,177
excuse me and 2 to continuously

6757
04:18:13,177 --> 04:18:14,244
improve the safety of the

6758
04:18:14,244 --> 04:18:15,312
liability and resiliency of our

6759
04:18:15,312 --> 04:18:17,180
electric system.

6760
04:18:17,180 --> 04:18:19,183
>> in your testimony in this

6761
04:18:19,183 --> 04:18:21,185
vicinity you testified that the

6762
04:18:21,185 --> 04:18:22,386
company's it department your

6763
04:18:22,386 --> 04:18:25,386
department plays a vital role

6764
04:18:26,790 --> 04:18:26,890
in supporting those areas

6765
04:18:26,890 --> 04:18:27,891
.

6766
04:18:27,891 --> 04:18:29,859
>> Witness: yes.

6767
04:18:29,859 --> 04:18:31,662
>> would you agree that in your

6768
04:18:31,662 --> 04:18:33,130
testimony that you focus on

6769
04:18:33,130 --> 04:18:34,932
presenting the cost of both

6770
04:18:34,932 --> 04:18:37,332
capital and deity in

6771
04:18:42,439 --> 04:18:43,307
cybersecurity projects under

6772
04:18:43,307 --> 04:18:44,441
your purview.

6773
04:18:44,441 --> 04:18:46,242
>> Witness: I do.

6774
04:18:46,242 --> 04:18:48,178
>> would also be fair to

6775
04:18:48,178 --> 04:18:50,214
conclude at least in the area

6776
04:18:50,214 --> 04:18:50,614
of cybersecurity the company is

6777
04:18:50,614 --> 04:18:52,215
somewhat less

6778
04:18:52,215 --> 04:18:53,450
focused on

6779
04:18:53,450 --> 04:18:55,850
efficiencies and more focused

6780
04:18:56,220 --> 04:18:57,688
on striving to minimize if not

6781
04:18:57,688 --> 04:18:59,223
eliminate security threats.

6782
04:18:59,223 --> 04:19:00,623
>> Witness: it is risk

6783
04:19:00,623 --> 04:19:01,492
management that is what

6784
04:19:01,492 --> 04:19:03,892
cybersecurity is focused on.

6785
04:19:05,229 --> 04:19:06,229
>> outside cybersecurity aspect

6786
04:19:06,229 --> 04:19:08,732
of your role item 3 on page 41

6787
04:19:08,732 --> 04:19:11,732
lines 13-14 it would indicate

6788
04:19:13,604 --> 04:19:15,505
that the it department has a

6789
04:19:15,505 --> 04:19:17,700
significant role in developing

6790
04:19:17,700 --> 04:19:18,275
and implement thing software

6791
04:19:18,275 --> 04:19:20,277
solutions to achieve and

6792
04:19:20,277 --> 04:19:21,445
improve on efficiency in all

6793
04:19:21,445 --> 04:19:23,845
areas of temporal separation

6794
04:19:25,816 --> 04:19:25,949
that right

6795
04:19:25,949 --> 04:19:27,918
.

6796
04:19:27,918 --> 04:19:29,920
>> Witness: that's right we

6797
04:19:29,920 --> 04:19:31,540
partner with the other business

6798
04:19:31,540 --> 04:19:32,923
units and functions within

6799
04:19:32,923 --> 04:19:34,124
tampa electric and all

6800
04:19:34,124 --> 04:19:36,124
technology initiatives.

6801
04:19:36,160 --> 04:19:38,929
>> would you agree with me that

6802
04:19:38,929 --> 04:19:41,929
a growing aspect of achieving

6803
04:19:45,469 --> 04:19:46,536
efficiencies in electric

6804
04:19:46,536 --> 04:19:48,472
utilities sphere is the

6805
04:19:48,472 --> 04:19:50,472
application of artificial

6806
04:19:50,474 --> 04:19:52,474
intelligence machine learning

6807
04:19:52,476 --> 04:19:53,644
and advanced data analytics to

6808
04:19:53,644 --> 04:19:55,479
processes that are fundamental

6809
04:19:55,479 --> 04:19:56,480
to the utility operating

6810
04:19:56,480 --> 04:19:58,480
systems?

6811
04:19:58,715 --> 04:19:59,917
>> Witness: artificial

6812
04:19:59,917 --> 04:20:01,952
intelligence really is a broad

6813
04:20:01,952 --> 04:20:03,819
term. Artificial intelligence

6814
04:20:03,819 --> 04:20:05,722
has been around for decades.

6815
04:20:05,722 --> 04:20:07,157
There is artificial

6816
04:20:07,157 --> 04:20:08,825
intelligence and that the

6817
04:20:08,825 --> 04:20:10,727
systems we deploy in use today.

6818
04:20:10,727 --> 04:20:12,763
But it is not the height

6819
04:20:12,763 --> 04:20:14,970
artificial intelligence since

6820
04:20:14,970 --> 04:20:14,897
NOVEMBER artificial

6821
04:20:14,897 --> 04:20:16,897
intelligence since NOVEMBER

6822
04:20:17,834 --> 04:20:18,935
2022 when chad gpd was

6823
04:20:18,935 --> 04:20:20,837
introduced that's a whole

6824
04:20:20,837 --> 04:20:22,372
another legal artificial

6825
04:20:22,372 --> 04:20:23,974
intelligence and we do not use

6826
04:20:23,974 --> 04:20:26,610
and utilize today much in the

6827
04:20:26,610 --> 04:20:27,711
way of general ai.

6828
04:20:27,711 --> 04:20:28,978
>> when we talk about

6829
04:20:28,978 --> 04:20:30,978
artificial intelligence I'm

6830
04:20:32,649 --> 04:20:35,490
talking about generative ai.

6831
04:20:39,256 --> 04:20:40,357
>> Witness: fair enough I don't

6832
04:20:40,357 --> 04:20:40,624
agree can you ask your

6833
04:20:40,624 --> 04:20:42,426
question.

6834
04:20:42,426 --> 04:20:44,260
>> that is fair I was asking is

6835
04:20:44,260 --> 04:20:45,395
a growing aspect of achieving

6836
04:20:45,395 --> 04:20:47,395
efficiencies in electric

6837
04:20:48,765 --> 04:20:51,165
utility sphere and application

6838
04:20:51,602 --> 04:20:53,637
we can insert generative ai.

6839
04:20:53,637 --> 04:20:56,807
>> Witness: I would say it is a

6840
04:20:56,807 --> 04:20:59,807
potential it is emerging and

6841
04:20:59,809 --> 04:21:01,809
not growing.

6842
04:21:01,812 --> 04:21:02,913
That is not the right way to

6843
04:21:02,913 --> 04:21:04,913
characterize it today.

6844
04:21:10,754 --> 04:21:12,754
>> okay.

6845
04:21:12,756 --> 04:21:13,924
To your understanding of

6846
04:21:13,924 --> 04:21:16,260
generative ai would you agree

6847
04:21:16,260 --> 04:21:16,193
that these are overwhelmingly

6848
04:21:16,193 --> 04:21:18,193
if

6849
04:21:18,729 --> 04:21:19,963
not entirely software driven

6850
04:21:19,963 --> 04:21:21,764
applications to the extent that

6851
04:21:21,764 --> 04:21:23,330
they are being used.

6852
04:21:23,330 --> 04:21:25,350
>> Witness: yes software might

6853
04:21:25,350 --> 04:21:26,936
be embedded in hardware but it

6854
04:21:26,936 --> 04:21:28,839
is absolutely software.

6855
04:21:28,839 --> 04:21:30,740
>> are you familiar with human

6856
04:21:30,740 --> 04:21:32,740
interface human machine

6857
04:21:35,245 --> 04:21:36,246
interface applications?

6858
04:21:36,246 --> 04:21:36,479
>> Witness: sure!

6859
04:21:36,479 --> 04:21:38,381
Hmi yes.

6860
04:21:38,381 --> 04:21:39,582
>> is that a potential area as

6861
04:21:39,582 --> 04:21:41,451
an example where artificial

6862
04:21:41,451 --> 04:21:42,386
intelligence might be used in

6863
04:21:42,386 --> 04:21:44,386
the future.

6864
04:21:44,388 --> 04:21:46,356
>> Witness: into the future

6865
04:21:46,356 --> 04:21:48,258
yes.

6866
04:21:48,258 --> 04:21:51,258
>> do you know what machine

6867
04:21:53,864 --> 04:21:55,650
laurie learning is referred to

6868
04:21:55,650 --> 04:21:55,732
you considered that to be under

6869
04:21:55,732 --> 04:21:57,732
the

6870
04:21:57,868 --> 04:21:58,201
broad umbrella of artificial

6871
04:21:58,201 --> 04:22:00,360
intelligence.

6872
04:22:00,360 --> 04:22:02,500
>> Witness: it is it is not

6873
04:22:02,500 --> 04:22:03,173
generative ai.

6874
04:22:03,173 --> 04:22:05,573
>> teco: what about advanced

6875
04:22:05,709 --> 04:22:07,110
data analytics is that a

6876
04:22:07,110 --> 04:22:07,778
byproduct of machine learning

6877
04:22:07,778 --> 04:22:09,778
and ai.

6878
04:22:13,150 --> 04:22:15,550
>> Witness: again analytics can

6879
04:22:15,952 --> 04:22:17,954
be human based analytics or

6880
04:22:17,954 --> 04:22:18,955
artificial intelligence-based

6881
04:22:18,955 --> 04:22:19,455
analytics will be

6882
04:22:19,455 --> 04:22:20,757
pre-generative ai.

6883
04:22:20,757 --> 04:22:20,852
>> what was the word used

6884
04:22:20,852 --> 04:22:22,852
.

6885
04:22:23,260 --> 04:22:24,928
>> Witness: heuristics self

6886
04:22:24,928 --> 04:22:26,928
learning.

6887
04:22:35,138 --> 04:22:37,700
>> heuristics.

6888
04:22:37,700 --> 04:22:39,676
I have an exhibit MR. CHAIRMAN

6889
04:22:39,676 --> 04:22:40,343
I would like to discuss at this

6890
04:22:40,343 --> 04:22:42,343
time.

6891
04:22:45,382 --> 04:22:47,651
To see if it is in your book

6892
04:22:47,651 --> 04:22:49,719
that redbook over there, opc

6893
04:22:49,719 --> 04:22:51,719
217.

6894
04:22:56,760 --> 04:22:57,994
Confidential exhibit.

6895
04:22:57,994 --> 04:23:01,594
This has a number assigned to

6896
04:23:07,204 --> 04:23:08,771
it within the case center.

6897
04:23:08,771 --> 04:23:10,707
>> Witness: can you repeat the

6898
04:23:10,707 --> 04:23:10,807
number

6899
04:23:10,807 --> 04:23:11,174
.

6900
04:23:11,174 --> 04:23:13,574
>> it is opc b

6901
04:23:27,290 --> 04:23:29,290
217.

6902
04:23:37,200 --> 04:23:38,368
>> is it that cl 442?

6903
04:23:38,368 --> 04:23:39,970
>> I've been told yes it is.

6904
04:23:39,970 --> 04:23:41,271
>> okay thank you.

6905
04:23:41,271 --> 04:23:44,574
>> I forgot to bring my cl work

6906
04:23:44,574 --> 04:23:46,574
with me.

6907
04:23:47,911 --> 04:23:49,911
Okay.

6908
04:23:50,614 --> 04:23:51,915
This is a confidential document

6909
04:23:51,915 --> 04:23:53,917
it is labeled highly competent

6910
04:23:53,917 --> 04:23:57,517
by the company. I'm going to

6911
04:23:59,355 --> 04:24:00,523
ask you some preliminary

6912
04:24:00,523 --> 04:24:02,425
questions about it without

6913
04:24:02,425 --> 04:24:04,394
getting into the details of it.

6914
04:24:04,394 --> 04:24:06,729
I would ask you first off are

6915
04:24:06,729 --> 04:24:09,729
you familiar with this document

6916
04:24:12,335 --> 04:24:15,335
or what is in it?

6917
04:24:18,541 --> 04:24:21,344
It appears to be a document

6918
04:24:21,344 --> 04:24:23,744
presented at the NOVEMBER 7,

6919
04:24:25,681 --> 04:24:28,810
2023 tampa electric peoples gas

6920
04:24:34,491 --> 04:24:35,592
board meeting.

6921
04:24:35,592 --> 04:24:36,493
>> Witness: I have seen it

6922
04:24:36,493 --> 04:24:37,760
before.

6923
04:24:37,760 --> 04:24:39,529
>> okay you are familiar with

6924
04:24:39,529 --> 04:24:40,696
this document.

6925
04:24:40,696 --> 04:24:43,696
Would you agree that this

6926
04:24:45,101 --> 04:24:48,104
document is a document that was

6927
04:24:48,104 --> 04:24:50,140
presented to tampa electric

6928
04:24:50,140 --> 04:24:53,740
sort of as an information about

6929
04:24:56,346 --> 04:24:58,314
what potential generative

6930
04:24:58,314 --> 04:24:59,716
artificial intelligence

6931
04:24:59,716 --> 04:25:02,116
applications might exist for

6932
04:25:04,521 --> 04:25:06,523
the company in the future?

6933
04:25:06,523 --> 04:25:08,558
Or do have a different

6934
04:25:08,558 --> 04:25:10,558
characterization?

6935
04:25:12,529 --> 04:25:14,531
>> Witness: first it's been a

6936
04:25:14,531 --> 04:25:18,131
long time since I thought the

6937
04:25:18,134 --> 04:25:19,369
document NOVEMBER 7, 2023.

6938
04:25:19,369 --> 04:25:23,569
I have not seen it since then

6939
04:25:24,407 --> 04:25:25,642
before now.

6940
04:25:25,642 --> 04:25:27,544
I really cannot tell you what

6941
04:25:27,544 --> 04:25:27,744
the major themes are through

6942
04:25:27,744 --> 04:25:28,511
there.

6943
04:25:28,511 --> 04:25:28,977
>> okay.

6944
04:25:28,977 --> 04:25:30,947
There are

6945
04:25:30,947 --> 04:25:32,181
enough.

6946
04:25:32,181 --> 04:25:33,316
i was looking for his name I

6947
04:25:33,316 --> 04:25:36,316
saw men who presented this

6948
04:25:36,719 --> 04:25:39,719
seemed like his first name

6949
04:25:40,590 --> 04:25:44,190
began with a. Would you have

6950
04:25:53,636 --> 04:25:54,871
been at this presentation?

6951
04:25:54,871 --> 04:25:57,400
>> Witness: I'm sure I was am

6952
04:25:57,400 --> 04:25:58,141
not sure who presented it.

6953
04:25:58,141 --> 04:26:01,141
>> that is fair. In this

6954
04:26:05,348 --> 04:26:05,748
document can you read the title

6955
04:26:05,748 --> 04:26:07,917
on the first page?

6956
04:26:07,917 --> 04:26:09,917
Without revealing confidential

6957
04:26:10,587 --> 04:26:11,788
information?

6958
04:26:11,788 --> 04:26:13,723
I don't know if you worked out

6959
04:26:13,723 --> 04:26:15,491
with your attorney if I ask you

6960
04:26:15,491 --> 04:26:18,227
to do something and ask you if

6961
04:26:18,227 --> 04:26:20,196
it would reveal confidential

6962
04:26:20,196 --> 04:26:22,310
information is only hope you

6963
04:26:22,310 --> 04:26:23,233
look down the row and get a

6964
04:26:23,233 --> 04:26:25,633
thumbs up or something.

6965
04:26:26,235 --> 04:26:29,380
>> Witness: okay thank you for

6966
04:26:29,380 --> 04:26:30,507
that but yes I can remember it

6967
04:26:30,507 --> 04:26:31,174
generative ai use cases and

6968
04:26:31,174 --> 04:26:32,708
next steps.

6969
04:26:32,708 --> 04:26:33,943
>> okay.

6970
04:26:33,943 --> 04:26:36,312
Can you turn to the second page

6971
04:26:36,312 --> 04:26:40,512
which has a base number the big

6972
04:26:41,117 --> 04:26:43,117
large 7826?

6973
04:26:44,420 --> 04:26:47,290
On the left-hand side of the

6974
04:26:47,290 --> 04:26:48,124
landscape.

6975
04:26:48,124 --> 04:26:50,124
>> Witness: yes.

6976
04:26:53,695 --> 04:26:56,695
>> in this document on this

6977
04:26:58,368 --> 04:26:59,902
page would you agree that the

6978
04:26:59,902 --> 04:27:02,205
far right-hand column with the

6979
04:27:02,205 --> 04:27:05,205
darker blue arrow talks about

6980
04:27:11,514 --> 04:27:13,514
potential ai

6981
04:27:14,717 --> 04:27:15,985
.

6982
04:27:15,985 --> 04:27:19,122
Can you tell me what generally

6983
04:27:19,122 --> 04:27:21,122
that talks about?

6984
04:27:21,124 --> 04:27:22,525
It's without revealing

6985
04:27:22,525 --> 04:27:24,525
confidential information.

6986
04:27:24,594 --> 04:27:26,562
>> Witness: underneath the

6987
04:27:26,562 --> 04:27:27,196
fourth arrow is that which were

6988
04:27:27,196 --> 04:27:27,630
looking at.

6989
04:27:27,630 --> 04:27:29,630
>> yes.

6990
04:27:37,373 --> 04:27:38,207
>> Witness: okay you would like

6991
04:27:38,207 --> 04:27:40,207
me to.

6992
04:27:41,210 --> 04:27:42,344
>> above the number what is the

6993
04:27:42,344 --> 04:27:42,432
subheading in that arrow

6994
04:27:42,432 --> 04:27:43,379
.

6995
04:27:43,379 --> 04:27:43,471
>>

6996
04:27:43,471 --> 04:27:45,471
.

6997
04:27:45,481 --> 04:27:47,481
>> Witness: distributed

6998
04:27:53,890 --> 04:27:53,356
intelligence apps 2022 through

6999
04:27:53,356 --> 04:27:55,910
ongoing.

7000
04:27:55,910 --> 04:27:56,258
>> does this area show some

7001
04:27:56,258 --> 04:27:59,258
potential for the use of

7002
04:28:00,530 --> 04:28:03,530
generative ai in the future?

7003
04:28:05,968 --> 04:28:07,968
If you know?

7004
04:28:07,970 --> 04:28:09,472
>> Witness: this has to do with

7005
04:28:09,472 --> 04:28:12,375
applications that can run on

7006
04:28:12,375 --> 04:28:14,277
meters our new ami meters on

7007
04:28:14,277 --> 04:28:16,277
the edge.

7008
04:28:20,116 --> 04:28:23,116
Again, this is potential stuff.

7009
04:28:25,521 --> 04:28:27,589
That is not been deployed yet.

7010
04:28:27,589 --> 04:28:29,491
It would be part of the gr rr.

7011
04:28:29,491 --> 04:28:33,910
Were we helped use of these

7012
04:28:35,832 --> 04:28:37,700
edge applications that is

7013
04:28:37,700 --> 04:28:38,267
distributed on the distribution

7014
04:28:38,267 --> 04:28:40,267
network yes.

7015
04:28:45,700 --> 04:28:48,607
>> on the next 1278-28 and at

7016
04:28:50,713 --> 04:28:52,882
the same area of that page

7017
04:28:52,882 --> 04:28:53,148
there are some

7018
04:28:53,148 --> 04:28:55,148
, there is a

7019
04:28:57,219 --> 04:29:00,819
column it has a subheading that

7020
04:29:04,694 --> 04:29:07,940
starts with p pb.

7021
04:29:08,865 --> 04:29:09,932
On the far right-hand side.

7022
04:29:09,932 --> 04:29:10,200
>> Witness: yes

7023
04:29:10,200 --> 04:29:12,200
.

7024
04:29:14,300 --> 04:29:15,338
>> can you read those four

7025
04:29:15,338 --> 04:29:17,338
words without revealing

7026
04:29:22,577 --> 04:29:24,480
financial information.

7027
04:29:24,480 --> 04:29:25,548
>> Witness: driving value

7028
04:29:25,548 --> 04:29:27,548
across business.

7029
04:29:27,550 --> 04:29:30,353
>> does is talk about potential

7030
04:29:30,353 --> 04:29:32,388
overall areas where artificial

7031
04:29:32,388 --> 04:29:33,489
intelligence applications might

7032
04:29:33,489 --> 04:29:34,190
provide a benefit in the

7033
04:29:34,190 --> 04:29:35,992
future?

7034
04:29:35,992 --> 04:29:37,426
>> Witness: yes sure yes these

7035
04:29:37,426 --> 04:29:41,260
are all areas that would be

7036
04:29:42,932 --> 04:29:45,735
areas in the future would have

7037
04:29:45,735 --> 04:29:46,969
high potential to benefit from

7038
04:29:46,969 --> 04:29:48,969
artificial intelligence.

7039
04:29:51,674 --> 04:29:51,907
>> on the next 78 30

7040
04:29:51,907 --> 04:29:52,908
, if you

7041
04:29:52,908 --> 04:29:53,976
can look at that.

7042
04:29:53,976 --> 04:29:55,911
>> Witness: 7830?

7043
04:29:55,911 --> 04:29:56,177
>> teco: if you can read the

7044
04:29:56,177 --> 04:29:56,912
first

7045
04:29:56,912 --> 04:29:58,912
headline.

7046
04:30:00,883 --> 04:30:02,785
>> there without revealing

7047
04:30:02,785 --> 04:30:04,190
confidential information?

7048
04:30:04,190 --> 04:30:05,854
>> Witness: the main headline

7049
04:30:05,854 --> 04:30:05,988
or the one underneath.

7050
04:30:05,988 --> 04:30:07,123
>> it

7051
04:30:07,123 --> 04:30:09,123
starts with g.

7052
04:30:11,160 --> 04:30:12,194
>> Witness: generative ai at

7053
04:30:12,194 --> 04:30:14,194
tampa electric.

7054
04:30:15,497 --> 04:30:17,333
>> can you read what is below

7055
04:30:17,333 --> 04:30:18,533
that without revealing

7056
04:30:18,533 --> 04:30:19,702
confidential information?

7057
04:30:19,702 --> 04:30:22,102
>> Witness: yes I can.

7058
04:30:23,906 --> 04:30:25,141
Our foray into generative ai

7059
04:30:25,141 --> 04:30:27,900
again this year with a pallet

7060
04:30:27,900 --> 04:30:29,111
to assist team members with

7061
04:30:29,111 --> 04:30:31,111
annual benefits enrollment.

7062
04:30:33,150 --> 04:30:35,484
>> okay now I believe that has

7063
04:30:35,484 --> 04:30:37,453
been discussed in some of the

7064
04:30:37,453 --> 04:30:38,587
testimony at least in the

7065
04:30:38,587 --> 04:30:40,890
deposition in this case.

7066
04:30:40,890 --> 04:30:42,191
>> Witness: I'm not familiar

7067
04:30:42,191 --> 04:30:44,226
but I will trust you will not.

7068
04:30:44,226 --> 04:30:47,226
Box in the lower right-hand

7069
04:30:48,273 --> 04:30:50,132
corner you see the lower

7070
04:30:50,132 --> 04:30:50,866
right-hand quadrant with a

7071
04:30:50,866 --> 04:30:52,866
subheading there?

7072
04:30:53,869 --> 04:30:53,963
Can you read that

7073
04:30:53,963 --> 04:30:55,937
.

7074
04:30:55,937 --> 04:30:56,839
>> Witness: the subheading next

7075
04:30:56,839 --> 04:30:57,730
steps.

7076
04:30:57,730 --> 04:30:58,741
>> yes.

7077
04:30:58,741 --> 04:31:00,741
>> Witness:

7078
04:31:02,378 --> 04:31:05,378
>> is the three bullets under

7079
04:31:07,183 --> 04:31:08,383
that is that confidential if

7080
04:31:08,383 --> 04:31:09,518
they are not trying to push you

7081
04:31:09,518 --> 04:31:11,518
to read that?

7082
04:31:11,554 --> 04:31:11,887
>> Witness: I don't think it is

7083
04:31:11,887 --> 04:31:12,121
confidential.

7084
04:31:12,121 --> 04:31:13,756
>>

7085
04:31:13,756 --> 04:31:13,889
okay can you read each bullet

7086
04:31:13,889 --> 04:31:15,657
.

7087
04:31:15,657 --> 04:31:18,570
>> Witness: continue to evolve

7088
04:31:20,463 --> 04:31:21,630
existing data and ai governance

7089
04:31:21,630 --> 04:31:23,498
bullet number two, pursue

7090
04:31:23,498 --> 04:31:24,500
increasingly complex

7091
04:31:24,500 --> 04:31:24,633
applications of ai.

7092
04:31:24,633 --> 04:31:26,633
Ullet

7093
04:31:26,669 --> 04:31:28,671
number three explore potential

7094
04:31:28,671 --> 04:31:28,871
for ai across borders, business

7095
04:31:28,871 --> 04:31:30,871
units.

7096
04:31:33,943 --> 04:31:36,780
>> thank you there is no

7097
04:31:36,780 --> 04:31:37,112
timeframe associated with those

7098
04:31:37,112 --> 04:31:39,800
steps is that there.

7099
04:31:39,800 --> 04:31:42,800
>> Witness: there is not a

7100
04:31:44,119 --> 04:31:46,254
tempera I might add that that I

7101
04:31:46,254 --> 04:31:48,224
would characterize our position

7102
04:31:48,224 --> 04:31:51,224
on this technology and others

7103
04:31:52,261 --> 04:31:53,329
as a fast follower.

7104
04:31:53,329 --> 04:31:56,231
Where today many of the

7105
04:31:56,231 --> 04:31:57,833
articles that you provided on a

7106
04:31:57,833 --> 04:31:58,701
daily basis

7107
04:31:58,701 --> 04:32:00,701
, many vendors and

7108
04:32:02,638 --> 04:32:03,806
consultants talk about what

7109
04:32:03,806 --> 04:32:05,806
might happen.

7110
04:32:07,876 --> 04:32:10,679
We are more as being a fast

7111
04:32:10,679 --> 04:32:12,581
follower looking for show me

7112
04:32:12,581 --> 04:32:12,882
where the value has been

7113
04:32:12,882 --> 04:32:14,882
achieved?

7114
04:32:17,519 --> 04:32:19,221
This is all very high potential

7115
04:32:19,221 --> 04:32:21,621
very exciting technology. It

7116
04:32:22,725 --> 04:32:25,160
has high high potential. I

7117
04:32:25,160 --> 04:32:26,328
would liken it to the internet.

7118
04:32:26,328 --> 04:32:29,198
Back in the 90s. If you will

7119
04:32:29,198 --> 04:32:32,198
call all the speculation around

7120
04:32:34,970 --> 04:32:36,137
the internet and runs on the

7121
04:32:36,137 --> 04:32:37,972
stock market etc. Then the

7122
04:32:37,972 --> 04:32:39,173
subsequent bust. We didn't

7123
04:32:39,173 --> 04:32:40,209
start getting value out of the

7124
04:32:40,209 --> 04:32:42,609
internet for a decade.

7125
04:32:42,811 --> 04:32:44,812
This technology and its

7126
04:32:44,812 --> 04:32:47,812
potential is emerging and it's

7127
04:32:48,816 --> 04:32:50,786
in the same sort of category.

7128
04:32:50,786 --> 04:32:51,987
I think it has higher potential

7129
04:32:51,987 --> 04:32:53,922
than the internet does in the

7130
04:32:53,922 --> 04:32:55,124
long term. Right now it is even

7131
04:32:55,124 --> 04:32:56,225
more risky than the internet

7132
04:32:56,225 --> 04:32:59,825
was back in the mid-90s.

7133
04:33:00,495 --> 04:33:01,997
>> okay thank you.

7134
04:33:01,997 --> 04:33:03,599
In your role that we talked

7135
04:33:03,599 --> 04:33:03,898
about at the very outset of the

7136
04:33:03,898 --> 04:33:05,898
questioning.

7137
04:33:06,680 --> 04:33:09,471
Would it be fair to say as the

7138
04:33:09,471 --> 04:33:10,972
cdl at emera and in your role

7139
04:33:10,972 --> 04:33:13,972
at tampa electric you would

7140
04:33:17,479 --> 04:33:20,349
have some significant level of

7141
04:33:20,349 --> 04:33:22,284
awareness if there were it

7142
04:33:22,284 --> 04:33:23,485
applications that were going to

7143
04:33:23,485 --> 04:33:25,688
utilize generative ai machine

7144
04:33:25,688 --> 04:33:28,880
learning is that correct.

7145
04:33:28,958 --> 04:33:30,359
>> Witness: that is correct in

7146
04:33:30,359 --> 04:33:33,359
fact I helped develop a

7147
04:33:35,640 --> 04:33:38,640
strategy emera level that teco

7148
04:33:39,680 --> 04:33:40,269
participated heavily in for ai.

7149
04:33:40,269 --> 04:33:42,237
It is called the emera aia

7150
04:33:42,237 --> 04:33:43,205
strategy I helped to put that

7151
04:33:43,205 --> 04:33:45,205
together.

7152
04:33:45,841 --> 04:33:50,410
>> I think there is as we read

7153
04:33:50,812 --> 04:33:53,515
and hr pallet that is using

7154
04:33:53,515 --> 04:33:54,716
some level of generative ai in

7155
04:33:54,716 --> 04:33:56,716
limited applications.

7156
04:33:56,785 --> 04:33:58,654
>> Witness: that was for annual

7157
04:33:58,654 --> 04:34:01,230
enrollment and benefits yes.

7158
04:34:01,230 --> 04:34:04,360
>> we were told that there is a

7159
04:34:04,360 --> 04:34:06,495
vegetation management ai trial

7160
04:34:06,495 --> 04:34:10,695
that is going on maybe up in

7161
04:34:14,535 --> 04:34:14,736
canada that teco hopes to

7162
04:34:14,736 --> 04:34:16,505
learn.

7163
04:34:16,505 --> 04:34:19,505
>> Witness: this is correct I

7164
04:34:21,976 --> 04:34:23,212
would characterize it as a

7165
04:34:23,212 --> 04:34:25,470
proof of concept at this point.

7166
04:34:25,470 --> 04:34:26,949
But yes that is true. They

7167
04:34:26,949 --> 04:34:28,116
would like to pursue the use of

7168
04:34:28,116 --> 04:34:30,152
generative area to help with

7169
04:34:30,152 --> 04:34:31,620
their vegetation management.

7170
04:34:31,620 --> 04:34:33,555
>> apart from those to proof of

7171
04:34:33,555 --> 04:34:37,155
concept and pilot is there any

7172
04:34:37,659 --> 04:34:39,561
other application that is being

7173
04:34:39,561 --> 04:34:40,763
rolled out within tampa

7174
04:34:40,763 --> 04:34:43,732
electric company in the sphere

7175
04:34:43,732 --> 04:34:46,732
of this rate case 25, 26, and

7176
04:34:47,502 --> 04:34:47,603
27 that you are aware of

7177
04:34:47,603 --> 04:34:49,603
.

7178
04:34:49,605 --> 04:34:50,806
>> Witness: there is another

7179
04:34:50,806 --> 04:34:52,808
proof of concept that is at

7180
04:34:52,808 --> 04:34:54,420
tampa electric it is within the

7181
04:34:54,420 --> 04:34:56,420
customer experience realm.

7182
04:34:56,945 --> 04:34:59,945
Using generative ai in some

7183
04:35:00,849 --> 04:35:02,417
capacity is very much potential

7184
04:35:02,417 --> 04:35:05,821
it is a proof of concept to aid

7185
04:35:05,821 --> 04:35:07,122
our customer service

7186
04:35:07,122 --> 04:35:09,122
representatives humans being

7187
04:35:09,124 --> 04:35:11,524
better customer service reps.

7188
04:35:12,127 --> 04:35:15,727
>> okay is it sort of in

7189
04:35:16,310 --> 04:35:16,131
concert with a cht gpt

7190
04:35:16,131 --> 04:35:18,131
.

7191
04:35:19,670 --> 04:35:20,335
>> this would be poor for

7192
04:35:20,335 --> 04:35:22,237
something that would pop up on

7193
04:35:22,237 --> 04:35:24,239
the screen for the customer

7194
04:35:24,239 --> 04:35:24,439
service rep while they handle a

7195
04:35:24,439 --> 04:35:26,439
call.

7196
04:35:27,676 --> 04:35:27,943
>> apart from that anything

7197
04:35:27,943 --> 04:35:28,744
that you

7198
04:35:28,744 --> 04:35:30,646
are aware of.

7199
04:35:30,646 --> 04:35:33,114
>> Witness: that is it for the

7200
04:35:33,114 --> 04:35:33,382
entire time period that you

7201
04:35:33,382 --> 04:35:35,382
mentioned.

7202
04:35:37,520 --> 04:35:38,921
>> with respect to the customer

7203
04:35:38,921 --> 04:35:41,921
experience area have there been

7204
04:35:44,393 --> 04:35:45,627
any assumptions made about the

7205
04:35:45,627 --> 04:35:47,396
efficiencies that might begin

7206
04:35:47,396 --> 04:35:50,996
to through the use of that

7207
04:35:56,104 --> 04:35:56,305
proof of concept effort

7208
04:35:56,305 --> 04:35:57,538
.

7209
04:35:57,538 --> 04:35:59,408
>> Witness: I would say it's

7210
04:35:59,408 --> 04:36:00,508
far too early to have done that

7211
04:36:00,508 --> 04:36:02,511
and no, we have not.

7212
04:36:02,511 --> 04:36:04,412
>> okay beyond the three that

7213
04:36:04,412 --> 04:36:05,581
we talked about it your

7214
04:36:05,581 --> 04:36:07,315
testimony to the commission

7215
04:36:07,315 --> 04:36:08,784
that with respect to the

7216
04:36:08,784 --> 04:36:10,418
projected test year in the

7217
04:36:10,418 --> 04:36:12,321
subsequent years at issue here,

7218
04:36:12,321 --> 04:36:13,555
there are no known or under

7219
04:36:13,555 --> 04:36:15,490
implementation ai efficiencies

7220
04:36:15,490 --> 04:36:16,591
that you are aware of that are

7221
04:36:16,591 --> 04:36:18,560
not being included in the

7222
04:36:18,560 --> 04:36:20,560
revenue requirements.

7223
04:36:21,563 --> 04:36:23,963
>> Witness: I would further

7224
04:36:25,167 --> 04:36:25,267
clarify pricing generative ai

7225
04:36:25,267 --> 04:36:26,368
.

7226
04:36:26,368 --> 04:36:27,235
[Unclear audio] That is

7227
04:36:27,235 --> 04:36:29,235
correct.

7228
04:36:30,839 --> 04:36:30,972
>>

7229
04:36:30,972 --> 04:36:32,140
.

7230
04:36:32,140 --> 04:36:34,175
[Listing names] Thank you I

7231
04:36:34,175 --> 04:36:36,144
just needed to go through that

7232
04:36:36,144 --> 04:36:37,111
for the record I appreciate

7233
04:36:37,111 --> 04:36:38,947
your help and

7234
04:36:38,947 --> 04:36:40,115
information. Thank

7235
04:36:40,115 --> 04:36:40,382
you very much MR. CHAIRMAN

7236
04:36:40,382 --> 04:36:41,950
thank you.

7237
04:36:41,950 --> 04:36:43,950
> Mike La

7238
04:36:43,952 --> 04:36:44,953
Rosa,CHAIRMAN: thank you.

7239
04:36:44,953 --> 04:36:46,953
[Listing names].

7240
04:36:46,955 --> 04:36:48,123
>> thank you MR. CHAIRMAN good

7241
04:36:48,123 --> 04:36:49,924
afternoon MR. Heck I believe

7242
04:36:49,924 --> 04:36:51,125
all of my questions have been

7243
04:36:51,125 --> 04:36:53,610
covered I'm going to take a

7244
04:36:53,610 --> 04:36:55,300
quick second to make sure.

7245
04:36:55,300 --> 04:36:56,999
I believe I don't have any

7246
04:36:56,999 --> 04:36:59,101
other questions thank you.

7247
04:36:59,101 --> 04:37:00,135
>> Mike La Rosa,CHAIRMAN: thank

7248
04:37:00,135 --> 04:37:02,135
you. [Listing names]

7249
04:37:03,380 --> 04:37:06,638
>> I have just a few questions.

7250
04:37:10,245 --> 04:37:11,446
Page 8 line 4.

7251
04:37:11,446 --> 04:37:13,846
>> Witness: of my testimony?

7252
04:37:18,620 --> 04:37:19,787
>> yes sir.

7253
04:37:19,787 --> 04:37:22,560
You have a sentence in here I

7254
04:37:22,560 --> 04:37:25,260
will read it it says for

7255
04:37:25,260 --> 04:37:26,828
cybersecurity emera maintains a

7256
04:37:26,828 --> 04:37:28,620
set of standards based on

7257
04:37:28,620 --> 04:37:30,132
national institute of standards

7258
04:37:30,132 --> 04:37:32,132
and technology nist

7259
04:37:33,735 --> 04:37:35,735
cybersecurity framework csf

7260
04:37:37,372 --> 04:37:39,908
brian what is the national

7261
04:37:39,908 --> 04:37:41,843
institute of standards and

7262
04:37:41,843 --> 04:37:43,912
technology I was wondering is

7263
04:37:43,912 --> 04:37:45,680
that a canadian organization.

7264
04:37:45,680 --> 04:37:46,214
>> Witness: it is us

7265
04:37:46,214 --> 04:37:48,214
government.

7266
04:37:49,551 --> 04:37:51,520
It is indeed. I don't know what

7267
04:37:51,520 --> 04:37:54,456
branch it rolls up into but it

7268
04:37:54,456 --> 04:37:55,456
is an agency within the united

7269
04:37:55,456 --> 04:37:57,456
states government.

7270
04:38:01,630 --> 04:38:03,632
>> I will ask a few questions

7271
04:38:03,632 --> 04:38:05,634
about your cybersecurity will

7272
04:38:05,634 --> 04:38:07,669
hear a lot about that person if

7273
04:38:07,669 --> 04:38:09,671
there's anything were not

7274
04:38:09,671 --> 04:38:11,671
comfortable answering because

7275
04:38:11,673 --> 04:38:13,208
of a security reason just say

7276
04:38:13,208 --> 04:38:14,810
that you are not comfortable we

7277
04:38:14,810 --> 04:38:15,677
will figure out how to deal

7278
04:38:15,677 --> 04:38:16,211
with that.

7279
04:38:16,211 --> 04:38:16,977
You put a lot in

7280
04:38:16,977 --> 04:38:18,813
here about what

7281
04:38:18,813 --> 04:38:20,140
you all are doing just a few

7282
04:38:20,140 --> 04:38:21,750
questions it looks like you

7283
04:38:21,750 --> 04:38:21,844
have a full-time staff.

7284
04:38:21,844 --> 04:38:22,918
N

7285
04:38:22,918 --> 04:38:24,753
your department of 18 folks

7286
04:38:24,753 --> 04:38:26,754
that are tasked with

7287
04:38:26,754 --> 04:38:28,255
cybersecurity operations but

7288
04:38:28,255 --> 04:38:29,524
then you also say that you have

7289
04:38:29,524 --> 04:38:31,459
a team that you contract with

7290
04:38:31,459 --> 04:38:33,361
or others that you contract

7291
04:38:33,361 --> 04:38:34,629
with can you share a little bit

7292
04:38:34,629 --> 04:38:37,399
the relative composition of how

7293
04:38:37,399 --> 04:38:37,665
that works and it works

7294
04:38:37,665 --> 04:38:39,665
together?

7295
04:38:43,710 --> 04:38:44,339
>> Witness: part of it is the

7296
04:38:44,339 --> 04:38:46,207
realization you cannot go it

7297
04:38:46,207 --> 04:38:49,207
alone. As talented as our 18

7298
04:38:50,845 --> 04:38:52,647
people might be you need a

7299
04:38:52,647 --> 04:38:53,882
broader perspective etc. We

7300
04:38:53,882 --> 04:38:55,783
have a consulting firm I would

7301
04:38:55,783 --> 04:38:58,553
call it and a strategic advisor

7302
04:38:58,553 --> 04:39:02,153
or spread we have been other

7303
04:39:03,758 --> 04:39:04,960
companies that do more

7304
04:39:04,960 --> 04:39:07,360
repetitive routine type work.

7305
04:39:22,210 --> 04:39:23,445
That would be as an example, 7

7306
04:39:23,445 --> 04:39:25,380
x 24 monitoring particularly in

7307
04:39:25,380 --> 04:39:27,282
the overnight hours they review

7308
04:39:27,282 --> 04:39:29,284
all of our logs etc. And they

7309
04:39:29,284 --> 04:39:31,186
are very falstaff to make sure

7310
04:39:31,186 --> 04:39:32,387
we see every alert and everett

7311
04:39:32,387 --> 04:39:34,289
handle every alert around the

7312
04:39:34,289 --> 04:39:36,191
clock seven days a week. As an

7313
04:39:36,191 --> 04:39:37,392
example both strategic and the

7314
04:39:37,392 --> 04:39:38,326
more nuts and bolts of it as

7315
04:39:38,326 --> 04:39:39,361
well.

7316
04:39:39,361 --> 04:39:41,229
The 18 people they are loyal

7317
04:39:41,229 --> 04:39:43,229
employees that investigate

7318
04:39:43,264 --> 04:39:46,864
alerts and they do reporting to

7319
04:39:47,535 --> 04:39:49,337
mitigate risk and understand

7320
04:39:49,337 --> 04:39:51,272
risk etc.) That type of the

7321
04:39:51,272 --> 04:39:52,507
core work is done within tampa

7322
04:39:52,507 --> 04:39:54,776
electric by those 18 employees.

7323
04:39:54,776 --> 04:39:57,776
>> are you aware of the

7324
04:39:57,846 --> 04:40:00,846
situations in which cyber has

7325
04:40:01,583 --> 04:40:04,452
been used worldwide to take

7326
04:40:04,452 --> 04:40:06,852
down grades for extended

7327
04:40:07,550 --> 04:40:08,289
periods of time?

7328
04:40:08,289 --> 04:40:09,190
>> Witness: yes jiggly lately

7329
04:40:09,190 --> 04:40:11,190
in ukraine.

7330
04:40:11,592 --> 04:40:14,395
That would be the most dramatic

7331
04:40:14,395 --> 04:40:16,395
example.

7332
04:40:16,398 --> 04:40:17,598
>> any in the united states you

7333
04:40:17,598 --> 04:40:19,598
are aware of?

7334
04:40:20,168 --> 04:40:22,168
>> Witness: nothing material.

7335
04:40:24,205 --> 04:40:25,373
Or it would have been reported.

7336
04:40:25,373 --> 04:40:28,973
>> you said your job is to

7337
04:40:29,944 --> 04:40:30,450
manage risk

7338
04:40:30,450 --> 04:40:31,546
.

7339
04:40:31,546 --> 04:40:34,282
>> Witness: that is one of them

7340
04:40:34,282 --> 04:40:36,282
for cybersecurity absolutely!

7341
04:40:36,317 --> 04:40:40,517
>> a lot of times people in the

7342
04:40:40,855 --> 04:40:42,900
insurance business will save

7343
04:40:42,900 --> 04:40:44,240
your managing to risk there is

7344
04:40:44,240 --> 04:40:45,860
a policy for you. You have any

7345
04:40:45,860 --> 04:40:48,860
way to manage risk through

7346
04:40:49,130 --> 04:40:49,430
insurance and if so are you

7347
04:40:49,430 --> 04:40:50,765
doing that?

7348
04:40:50,765 --> 04:40:53,165
>> Witness: we do have

7349
04:40:53,167 --> 04:40:53,401
cybersecurity insurance the

7350
04:40:53,401 --> 04:40:54,369
aspirin.

7351
04:40:54,369 --> 04:40:56,769
>> what is it called.

7352
04:40:57,172 --> 04:40:57,438
>> Witness: cybersecurity

7353
04:40:57,438 --> 04:40:59,207
insurance.

7354
04:40:59,207 --> 04:41:01,750
>> that would cover revenue

7355
04:41:01,750 --> 04:41:03,440
that were not able to receive

7356
04:41:03,440 --> 04:41:05,460
because of a separate outage it

7357
04:41:05,460 --> 04:41:07,182
would cover any damages to the

7358
04:41:07,182 --> 04:41:10,182
customers explain that to me.

7359
04:41:12,820 --> 04:41:14,220
>> Witness: it's an insurance

7360
04:41:14,220 --> 04:41:15,856
policy that would basically

7361
04:41:15,856 --> 04:41:17,859
after the developable capital

7362
04:41:17,859 --> 04:41:19,994
losses from an incident where

7363
04:41:19,994 --> 04:41:21,994
cybersecurity criminals got

7364
04:41:24,650 --> 04:41:26,670
into our computer network and

7365
04:41:26,670 --> 04:41:27,602
data center etc. And brought

7366
04:41:27,602 --> 04:41:29,570
harm to the company.

7367
04:41:29,570 --> 04:41:31,973
The entire cost to restore

7368
04:41:31,973 --> 04:41:34,973
etc., they would cover a

7369
04:41:36,344 --> 04:41:37,745
portion of that above the

7370
04:41:37,745 --> 04:41:37,839
deductible

7371
04:41:37,839 --> 04:41:39,839
.

7372
04:41:41,583 --> 04:41:42,784
>> would it cover rent

7373
04:41:42,784 --> 04:41:45,184
somewhere payments as well.

7374
04:41:48,156 --> 04:41:49,323
>> Witness: it would cover that

7375
04:41:49,323 --> 04:41:51,259
all of it has to be approved

7376
04:41:51,259 --> 04:41:54,859
our cyber risk or audited by

7377
04:42:05,973 --> 04:42:07,909
the insurers etc. To make sure

7378
04:42:07,909 --> 04:42:09,811
we mitigate risk well good

7379
04:42:09,811 --> 04:42:11,120
cyber security programs to be

7380
04:42:11,120 --> 04:42:12,814
insured you have to go through

7381
04:42:12,814 --> 04:42:14,815
a lot of hoops to get there.

7382
04:42:14,815 --> 04:42:16,817
>> lost revenue because of

7383
04:42:16,817 --> 04:42:17,510
businesses that part of what is

7384
04:42:17,510 --> 04:42:18,953
insured.

7385
04:42:18,953 --> 04:42:19,420
>> Witness: that is a better

7386
04:42:19,420 --> 04:42:20,822
question for

7387
04:42:20,822 --> 04:42:21,823
an insurance person

7388
04:42:21,823 --> 04:42:23,240
I do not recall.

7389
04:42:23,240 --> 04:42:24,826
>> just a few more a lot of

7390
04:42:24,826 --> 04:42:25,993
acronyms in this spring.

7391
04:42:25,993 --> 04:42:28,993
>> Witness: I'm sorry it comes

7392
04:42:30,420 --> 04:42:30,187
with the territory.

7393
04:42:30,187 --> 04:42:30,284
>>.

7394
04:42:30,284 --> 04:42:30,865
[Listing names] Asked you a

7395
04:42:30,865 --> 04:42:31,999
question about.

7396
04:42:31,999 --> 04:42:33,100
[Listing names] What is.

7397
04:42:33,100 --> 04:42:35,100
[Listing names]

7398
04:42:35,200 --> 04:42:37,200
>> Witness: supervisor control

7399
04:42:37,710 --> 04:42:39,400
data acquisition is aware human

7400
04:42:39,400 --> 04:42:40,974
and operating center remotely

7401
04:42:40,974 --> 04:42:42,877
control equipment on the grid

7402
04:42:42,877 --> 04:42:43,770
basically. Within a generating

7403
04:42:43,770 --> 04:42:44,879
plant.

7404
04:42:44,879 --> 04:42:45,212
>> made a note in your answer

7405
04:42:45,212 --> 04:42:47,480
you said hmi.

7406
04:42:47,480 --> 04:42:47,915
>> Witness: human machine

7407
04:42:47,915 --> 04:42:49,350
interface.

7408
04:42:49,350 --> 04:42:50,418
>> you made a point about

7409
04:42:50,418 --> 04:42:52,818
analysis of information that

7410
04:42:54,655 --> 04:42:58,255
you received and there are two

7411
04:42:59,460 --> 04:43:00,628
ways that analysis can be done

7412
04:43:00,628 --> 04:43:03,628
heuristic is the word brian.

7413
04:43:04,999 --> 04:43:05,132
>> Witness: heuristics

7414
04:43:05,132 --> 04:43:07,101
.

7415
04:43:07,101 --> 04:43:07,435
>> that is machine analysis is

7416
04:43:07,435 --> 04:43:09,435
that correct.

7417
04:43:10,400 --> 04:43:11,238
>> Witness: is a term used for

7418
04:43:11,238 --> 04:43:12,407
the earliest forms of ai. I

7419
04:43:12,407 --> 04:43:15,407
think the word means self

7420
04:43:15,476 --> 04:43:16,611
learning.

7421
04:43:16,611 --> 04:43:18,611
Something like that.

7422
04:43:19,614 --> 04:43:19,881
>> you compared it with human

7423
04:43:19,881 --> 04:43:21,881
analysis.

7424
04:43:22,750 --> 04:43:22,848
Do you do both

7425
04:43:22,848 --> 04:43:24,848
.

7426
04:43:29,123 --> 04:43:29,389
>> Witness: for sure

7427
04:43:29,389 --> 04:43:31,359
, analytics

7428
04:43:31,359 --> 04:43:33,261
is a field where you can take a

7429
04:43:33,261 --> 04:43:35,196
bunch of data and manipulate it

7430
04:43:35,196 --> 04:43:37,231
in ways and I human can review

7431
04:43:37,231 --> 04:43:38,733
the results and make decisions.

7432
04:43:38,733 --> 04:43:40,733
Then artificial intelligence

7433
04:43:41,402 --> 04:43:42,570
would be using the same data to

7434
04:43:42,570 --> 04:43:44,970
make its own predictions

7435
04:43:46,274 --> 04:43:47,174
instead of human making the

7436
04:43:47,174 --> 04:43:48,242
analysis.

7437
04:43:48,242 --> 04:43:50,242
Typically it would

7438
04:43:51,779 --> 04:43:53,814
lead to human judgment.

7439
04:43:53,814 --> 04:43:54,582
At this point especially. It is

7440
04:43:54,582 --> 04:43:58,782
not meant to often to make its

7441
04:44:04,891 --> 04:44:05,626
own decisions on the fly.

7442
04:44:05,626 --> 04:44:06,127
>> here is what the

7443
04:44:06,127 --> 04:44:07,995
machines are

7444
04:44:07,995 --> 04:44:09,163
saying here is what the human

7445
04:44:09,163 --> 04:44:11,980
folks are saying. In that

7446
04:44:11,980 --> 04:44:12,900
decision ultimately would be

7447
04:44:12,900 --> 04:44:13,234
made by a human at this point

7448
04:44:13,234 --> 04:44:14,101
not a machine?

7449
04:44:14,101 --> 04:44:16,101
>> Witness:).

7450
04:44:16,937 --> 04:44:17,205
>> just a couple of other quick

7451
04:44:17,205 --> 04:44:19,600
questions.

7452
04:44:19,600 --> 04:44:20,173
The amide meters those are

7453
04:44:20,173 --> 04:44:23,173
meters that are smart meters

7454
04:44:23,311 --> 04:44:24,411
they can go on businesses and

7455
04:44:24,411 --> 04:44:26,313
homes is that right.

7456
04:44:26,313 --> 04:44:27,415
>> Witness: that is correct all

7457
04:44:27,415 --> 04:44:28,516
of our meters other than

7458
04:44:28,516 --> 04:44:29,917
exceptions are ami meters.

7459
04:44:29,917 --> 04:44:32,720
>> are they settled in such a

7460
04:44:32,720 --> 04:44:35,720
way that third parties cannot

7461
04:44:37,900 --> 04:44:40,928
hack in to the smart meter and

7462
04:44:40,928 --> 04:44:42,963
then begin access to turn on

7463
04:44:42,963 --> 04:44:44,465
lights in your house and listen

7464
04:44:44,465 --> 04:44:45,666
in and all of that self. Can

7465
04:44:45,666 --> 04:44:47,301
you explain that.

7466
04:44:47,301 --> 04:44:48,502
>> Witness: absolutely!

7467
04:44:48,502 --> 04:44:51,502
Cybersecurity is a big concern

7468
04:44:51,739 --> 04:44:52,840
with the ami they were designed

7469
04:44:52,840 --> 04:44:53,840
from the ground up with

7470
04:44:53,840 --> 04:44:55,840
cybersecurity in mind.

7471
04:44:56,376 --> 04:44:58,312
What you engine is a nuisance

7472
04:44:58,312 --> 04:44:59,480
but if they were to turn off

7473
04:44:59,480 --> 04:45:01,281
all meters at once we would

7474
04:45:01,281 --> 04:45:04,952
have a really bad day on the

7475
04:45:04,952 --> 04:45:06,952
distribution network.

7476
04:45:06,954 --> 04:45:09,523
So yes, a lot of cybersecurity

7477
04:45:09,523 --> 04:45:10,791
controls architected for the

7478
04:45:10,791 --> 04:45:13,191
ground up for cybersecurity

7479
04:45:16,464 --> 04:45:16,764
they are very secured devices.

7480
04:45:16,764 --> 04:45:18,764
Bless you.

7481
04:45:18,933 --> 04:45:20,234
>> I notice in your testimony

7482
04:45:20,234 --> 04:45:22,770
you did not list how many times

7483
04:45:22,770 --> 04:45:23,938
you have given testimony before

7484
04:45:23,938 --> 04:45:26,440
but I understand you have

7485
04:45:26,440 --> 04:45:28,209
worked previously is this your

7486
04:45:28,209 --> 04:45:29,576
first time testimony in a

7487
04:45:29,576 --> 04:45:29,677
regulatory proceeding

7488
04:45:29,677 --> 04:45:31,112
.

7489
04:45:31,112 --> 04:45:32,313
>> Witness: this is the first

7490
04:45:32,313 --> 04:45:34,313
time under oath.

7491
04:45:34,348 --> 04:45:37,348
>> thank you for answering my

7492
04:45:38,386 --> 04:45:40,386
questions.

7493
04:45:40,421 --> 04:45:41,389
>> Mike La Rosa,CHAIRMAN:

7494
04:45:41,389 --> 04:45:42,423
[Listing names]

7495
04:45:42,423 --> 04:45:44,391
>> no questions.

7496
04:45:44,391 --> 04:45:45,626
>> Mike La Rosa,CHAIRMAN:

7497
04:45:45,626 --> 04:45:47,626
sierra club.

7498
04:45:50,296 --> 04:45:50,398
>> no questions are on

7499
04:45:50,398 --> 04:45:50,564
.

7500
04:45:50,564 --> 04:45:52,366
>>.

7501
04:45:52,366 --> 04:45:53,767
[Listing names] For retail

7502
04:45:53,767 --> 04:45:55,369
federation no questions.

7503
04:45:55,369 --> 04:45:55,603
>> Mike La Rosa,CHAIRMAN:

7504
04:45:55,603 --> 04:45:56,804
walmart.

7505
04:45:56,804 --> 04:45:56,900
>> no question thank you

7506
04:45:56,900 --> 04:45:58,772
.

7507
04:45:58,772 --> 04:45:59,373
>> Mike La Rosa,CHAIRMAN:

7508
04:45:59,373 --> 04:46:00,774
[Listing names] Commissioners

7509
04:46:00,774 --> 04:46:02,774
any questions.

7510
04:46:08,683 --> 04:46:10,685
>> Giles Fay,Commissioner: that

7511
04:46:10,685 --> 04:46:12,586
you MR. CHAIRMAN and thank you

7512
04:46:12,586 --> 04:46:16,786
MR. Heck for being here it's an

7513
04:46:19,860 --> 04:46:21,929
interesting subject matter and

7514
04:46:21,929 --> 04:46:23,798
I can understand maybe why you

7515
04:46:23,798 --> 04:46:24,965
have not testified before.

7516
04:46:24,965 --> 04:46:26,801
It's a complicated thing to

7517
04:46:26,801 --> 04:46:27,968
talk about publicly. I will am

7518
04:46:27,968 --> 04:46:29,804
going to ask fairly specific

7519
04:46:29,804 --> 04:46:31,805
questions if any way you feel

7520
04:46:31,805 --> 04:46:33,808
that it's not appropriate to

7521
04:46:33,808 --> 04:46:34,809
answer that question please

7522
04:46:34,809 --> 04:46:34,909
feel free to do so.

7523
04:46:34,909 --> 04:46:36,810
Ur

7524
04:46:36,810 --> 04:46:38,450
commission like a lot of

7525
04:46:38,450 --> 04:46:39,813
jurisdictions have processes in

7526
04:46:39,813 --> 04:46:41,140
place that review the

7527
04:46:41,140 --> 04:46:42,950
implementation and consistency

7528
04:46:42,950 --> 04:46:44,885
of the sap standards through

7529
04:46:44,885 --> 04:46:46,860
the american that's in your

7530
04:46:46,860 --> 04:46:48,220
testimony you mentioned that

7531
04:46:48,220 --> 04:46:49,824
but do interpret anything that

7532
04:46:49,824 --> 04:46:51,325
this body does or the

7533
04:46:51,325 --> 04:46:52,960
commission does to limit the

7534
04:46:52,960 --> 04:46:55,495
utility's ability to go beyond

7535
04:46:55,495 --> 04:46:57,495
those requirements?

7536
04:46:59,133 --> 04:47:00,234
>> Witness: if I understand the

7537
04:47:00,234 --> 04:47:03,234
question correctly I think my

7538
04:47:05,172 --> 04:47:06,340
answer is no.

7539
04:47:06,340 --> 04:47:08,175
We don't feel like there is

7540
04:47:08,175 --> 04:47:09,510
limited funding for

7541
04:47:09,510 --> 04:47:11,178
cybersecurity today.

7542
04:47:11,178 --> 04:47:11,579
We are able to do what we think

7543
04:47:11,579 --> 04:47:12,346
we need to do to

7544
04:47:12,346 --> 04:47:14,281
satisfy.

7545
04:47:14,281 --> 04:47:15,182
[Listing names] And the other

7546
04:47:15,182 --> 04:47:16,350
standards.

7547
04:47:16,350 --> 04:47:17,284
Am I answering the question

7548
04:47:17,284 --> 04:47:19,284
that you asked.

7549
04:47:19,320 --> 04:47:21,720
>> Giles Fay,Commissioner: let

7550
04:47:25,459 --> 04:47:27,561
me ask it this way.

7551
04:47:27,561 --> 04:47:29,463
With the implementation of what

7552
04:47:29,463 --> 04:47:30,631
you do for both emera and more

7553
04:47:30,631 --> 04:47:33,631
importantly teco it is driven

7554
04:47:34,534 --> 04:47:38,134
by the mission to protect the

7555
04:47:40,374 --> 04:47:41,575
systems and continue operations

7556
04:47:41,575 --> 04:47:43,377
which you are able to do so in

7557
04:47:43,377 --> 04:47:45,412
a way that allows for

7558
04:47:45,412 --> 04:47:47,412
government coordination but

7559
04:47:47,514 --> 04:47:48,249
also not interference when need

7560
04:47:48,249 --> 04:47:50,249
be.

7561
04:47:50,684 --> 04:47:53,840
>> Witness: it is accurate.

7562
04:47:55,722 --> 04:47:59,922
I will add maybe a little bit

7563
04:48:00,327 --> 04:48:01,595
tangentially but I will add.

7564
04:48:01,595 --> 04:48:01,795
As I said you cannot go it

7565
04:48:01,795 --> 04:48:03,795
alone.

7566
04:48:05,566 --> 04:48:07,966
I think APRIL for

7567
04:48:08,502 --> 04:48:09,669
government agencies where it is

7568
04:48:09,669 --> 04:48:12,669
applicable would be to help

7569
04:48:12,873 --> 04:48:14,873
coordinate information flow

7570
04:48:17,440 --> 04:48:19,444
etc. With cybersecurity across

7571
04:48:20,948 --> 04:48:22,948
the utility industry.

7572
04:48:22,983 --> 04:48:25,753
There is ever sleep reporting

7573
04:48:25,753 --> 04:48:26,921
requirements on our side.

7574
04:48:26,921 --> 04:48:29,756
We would like to see some

7575
04:48:29,756 --> 04:48:31,792
benefit from those reporting

7576
04:48:31,792 --> 04:48:33,794
requirements as well with the

7577
04:48:33,794 --> 04:48:34,962
two-way flow of information.

7578
04:48:34,962 --> 04:48:36,764
Anything to help with that

7579
04:48:36,764 --> 04:48:36,964
conduit would be helpful I

7580
04:48:36,964 --> 04:48:38,765
think.

7581
04:48:38,765 --> 04:48:40,765
>> Giles Fay,Commissioner:

7582
04:48:45,380 --> 04:48:46,173
great!

7583
04:48:46,173 --> 04:48:48,750
I appreciate what you do

7584
04:48:48,750 --> 04:48:49,310
whenever we talk about this

7585
04:48:49,310 --> 04:48:51,145
topic I think the more you know

7586
04:48:51,145 --> 04:48:52,346
the less you sleep. I can

7587
04:48:52,346 --> 04:48:54,181
appreciate the commitment that

7588
04:48:54,181 --> 04:48:55,149
you have to keeping the grid

7589
04:48:55,149 --> 04:48:56,250
save so thank you.

7590
04:48:56,250 --> 04:48:57,518
Thank you MR. CHAIRMAN.

7591
04:48:57,518 --> 04:48:58,185
>> Mike La Rosa,CHAIRMAN:

7592
04:48:58,185 --> 04:48:59,252
back

7593
04:48:59,252 --> 04:49:00,287
to teco for redirect.

7594
04:49:00,287 --> 04:49:02,287
>> teco: no redirect.

7595
04:49:03,223 --> 04:49:05,920
>> Mike La Rosa,CHAIRMAN: let's

7596
04:49:05,920 --> 04:49:05,325
move the exhibits into the

7597
04:49:05,325 --> 04:49:07,940
record.

7598
04:49:07,940 --> 04:49:09,940
>> let's move exhibit 23.

7599
04:49:09,129 --> 04:49:10,497
>> Mike La Rosa,CHAIRMAN:

7600
04:49:10,497 --> 04:49:10,764
exhibit 23 is there an

7601
04:49:10,764 --> 04:49:11,980
objection?

7602
04:49:11,980 --> 04:49:11,190
>>

7603
04:49:11,190 --> 04:49:13,167
.

7604
04:49:13,167 --> 04:49:16,135
>> Mike La Rosa,CHAIRMAN: is

7605
04:49:16,135 --> 04:49:17,970
there an objection I thought

7606
04:49:17,970 --> 04:49:19,339
you were checking on. 23 I

7607
04:49:19,339 --> 04:49:20,540
believe no objection?

7608
04:49:20,540 --> 04:49:22,109
Show 23 is moved into the

7609
04:49:22,109 --> 04:49:24,109
record.

7610
04:49:27,181 --> 04:49:28,281
>> opc would move on?

7611
04:49:28,281 --> 04:49:30,281
>> teco: no objection.

7612
04:49:31,518 --> 04:49:33,520
>> Mike La Rosa,CHAIRMAN: no

7613
04:49:33,520 --> 04:49:34,854
diction show entered into the

7614
04:49:34,854 --> 04:49:36,789
record. Any other exhibits

7615
04:49:36,789 --> 04:49:38,325
seeing none. MR. Heck thank

7616
04:49:38,325 --> 04:49:40,325
you very much.

7617
04:49:44,764 --> 04:49:45,966
You are excused.

7618
04:49:45,966 --> 04:49:47,768
Teco I will forward back to you

7619
04:49:47,768 --> 04:49:49,736
for your next witness.

7620
04:49:49,736 --> 04:49:50,904
>> teco: thank you MR. CHAIRMAN

7621
04:49:50,904 --> 04:49:52,904
tampa electric calls.

7622
04:49:55,776 --> 04:49:57,776
[Listing names].

7623
04:49:59,146 --> 04:50:00,347
>> Mike La Rosa,CHAIRMAN:

7624
04:50:00,347 --> 04:50:03,947
miriam before you sit down to

7625
04:50:06,920 --> 04:50:08,880
mind administering the oath.

7626
04:50:08,880 --> 04:50:10,560
Thank you. Do you swear and

7627
04:50:10,560 --> 04:50:11,925
affirm the testimony you're

7628
04:50:11,925 --> 04:50:13,460
about to get but with the truth

7629
04:50:13,460 --> 04:50:14,270
the whole truth and nothing but

7630
04:50:14,270 --> 04:50:15,950
the truth?

7631
04:50:15,950 --> 04:50:15,295
Excellent thank you.

7632
04:50:15,295 --> 04:50:16,997
Feel

7633
04:50:16,997 --> 04:50:19,997
free to get settled in.

7634
04:50:27,875 --> 04:50:29,109
>> teco: thank you.

7635
04:50:29,109 --> 04:50:30,110
Would you please state your

7636
04:50:30,110 --> 04:50:32,450
name for the record.

7637
04:50:32,450 --> 04:50:34,450
>> Witness: [Listing names].

7638
04:50:35,150 --> 04:50:36,149
>> teco: who is your current

7639
04:50:36,149 --> 04:50:39,149
employer and what is your

7640
04:50:43,991 --> 04:50:45,991
business address.

7641
04:50:46,260 --> 04:50:47,995
>> Witness: tampa electric

7642
04:50:47,995 --> 04:50:49,863
company 702 n. Franklin temple

7643
04:50:49,863 --> 04:50:51,980
for to. 11 to prepare and cost

7644
04:50:51,980 --> 04:50:52,265
be filed in this document and

7645
04:50:52,265 --> 04:50:54,340
APRIL 2 address.

7646
04:50:54,340 --> 04:50:56,300
>> Witness: tampa electric

7647
04:50:56,300 --> 04:50:57,838
company 702 n. Franklin temple

7648
04:50:57,838 --> 04:50:59,720
for to. 11 to prepare and cost

7649
04:50:59,720 --> 04:51:01,875
be filed in this document and

7650
04:51:01,875 --> 04:51:02,943
APRIL 2, 2024 direct testimony

7651
04:51:02,943 --> 04:51:04,378
consisting of 55 pages.

7652
04:51:04,378 --> 04:51:05,846
>> Witness: visited.

7653
04:51:05,846 --> 04:51:07,881
>> teco: do you prepare and

7654
04:51:07,881 --> 04:51:09,383
cost be filed in this document

7655
04:51:09,383 --> 04:51:09,983
rebuttal testimony consisting

7656
04:51:09,983 --> 04:51:11,510
of 18 pages.

7657
04:51:11,510 --> 04:51:12,986
>> Witness: yes I did.

7658
04:51:12,986 --> 04:51:14,922
>> teco: do you have any

7659
04:51:14,922 --> 04:51:16,890
additions or corrections to

7660
04:51:16,890 --> 04:51:16,356
prepare direct rebuttal

7661
04:51:16,356 --> 04:51:17,958
testimony.

7662
04:51:17,958 --> 04:51:18,125
> Witness: yes I

7663
04:51:18,125 --> 04:51:19,926
do.

7664
04:51:19,926 --> 04:51:20,127
>> teco: would you please list

7665
04:51:20,127 --> 04:51:21,928
them.

7666
04:51:21,928 --> 04:51:23,130
>> Witness: in my direct

7667
04:51:23,130 --> 04:51:24,998
testimony on page 30 line 19,

7668
04:51:24,998 --> 04:51:26,660
the word million should be

7669
04:51:26,660 --> 04:51:27,133
billion in both places.

7670
04:51:27,133 --> 04:51:28,935
>> Witness:

7671
04:51:28,935 --> 04:51:29,936
>> teco: do have another

7672
04:51:29,936 --> 04:51:30,360
correct correction.

7673
04:51:30,360 --> 04:51:31,104
>

7674
04:51:31,104 --> 04:51:32,939
Witness: in my rebuttal

7675
04:51:32,939 --> 04:51:34,942
testimony on page 8 line 23

7676
04:51:34,942 --> 04:51:36,943
delete the words gulf power the

7677
04:51:36,943 --> 04:51:38,178
first order is a florida power

7678
04:51:38,178 --> 04:51:38,411
corporation and the second one

7679
04:51:38,411 --> 04:51:40,460
is golf.

7680
04:51:40,460 --> 04:51:42,460
> teco: with those

7681
04:51:44,484 --> 04:51:45,651
provisions if I were to issue

7682
04:51:45,651 --> 04:51:47,487
questions prepared in your

7683
04:51:47,487 --> 04:51:48,689
direction rebuttal testimony

7684
04:51:48,689 --> 04:51:50,490
would your answers be the same

7685
04:51:50,490 --> 04:51:51,491
listed in the testimony.

7686
04:51:51,491 --> 04:51:53,491
>> Witness: yes.

7687
04:51:53,526 --> 04:51:55,526
>> teco: tampa electric

7688
04:51:55,829 --> 04:51:56,997
requests the corrected prepared

7689
04:51:56,997 --> 04:51:57,864
direction rebuttal testimony

7690
04:51:57,864 --> 04:51:59,320
of.

7691
04:51:59,320 --> 04:52:00,834
[Listing names] Be inserted

7692
04:52:00,834 --> 04:52:02,836
into the record as the red.

7693
04:52:02,836 --> 04:52:05,236
> Mike La Rosa,CHAIRMAN:

7694
04:52:05,638 --> 04:52:06,873
okay.

7695
04:52:06,873 --> 04:52:08,674
Did you prepare and cause to be

7696
04:52:08,674 --> 04:52:09,975
filed with your direct

7697
04:52:09,975 --> 04:52:10,710
testimony and exhibits marked

7698
04:52:10,710 --> 04:52:11,745
mc b

7699
04:52:11,745 --> 04:52:12,450
one consisting of 10

7700
04:52:12,450 --> 04:52:12,913
documents.

7701
04:52:12,913 --> 04:52:14,781
>> Witness: yes.

7702
04:52:14,781 --> 04:52:16,683
>> teco: MR. CHAIRMAN tampa

7703
04:52:16,683 --> 04:52:17,784
electric would note for the

7704
04:52:17,784 --> 04:52:17,884
record that exhibit mc b

7705
04:52:17,884 --> 04:52:19,719
one

7706
04:52:19,719 --> 04:52:21,721
has been identified on the

7707
04:52:21,721 --> 04:52:22,220
comprehensive exhibit list as

7708
04:52:22,220 --> 04:52:23,957
exhibit 24.

7709
04:52:23,957 --> 04:52:24,791
You did not have a rebuttal

7710
04:52:24,791 --> 04:52:26,726
exhibited you?

7711
04:52:26,726 --> 04:52:26,993
>> Witness: I did have a

7712
04:52:26,993 --> 04:52:28,762
rebuttal.

7713
04:52:28,762 --> 04:52:29,730
>> teco: you did have a

7714
04:52:29,730 --> 04:52:29,896
rebuttal exhibit.

7715
04:52:29,896 --> 04:52:31,896
Hat was

7716
04:52:42,342 --> 04:52:42,542
that.

7717
04:52:42,542 --> 04:52:44,542
It's.

7718
04:52:44,911 --> 04:52:46,713
>> Witness: no did not.

7719
04:52:46,713 --> 04:52:48,713
I'm sorry. [Laughter].

7720
04:52:50,951 --> 04:52:54,540
>> teco: I was going to have to

7721
04:52:54,540 --> 04:52:55,989
blame case lines for that.

7722
04:52:55,989 --> 04:52:56,823
I thought I was wrong but I was

7723
04:52:56,823 --> 04:52:58,823
wrong.

7724
04:53:01,728 --> 04:53:02,596
Okay.

7725
04:53:02,596 --> 04:53:03,730
Would you please

7726
04:53:03,730 --> 04:53:04,931
summarize your

7727
04:53:04,931 --> 04:53:06,931
direction rebuttal testimony.

7728
04:53:07,733 --> 04:53:08,868
>> Witness: good afternoon

7729
04:53:08,868 --> 04:53:10,868
commissioners my direct

7730
04:53:11,471 --> 04:53:13,306
testimony provides an overview

7731
04:53:13,306 --> 04:53:15,800
of the priorities that the

7732
04:53:15,800 --> 04:53:16,976
human resource department it

7733
04:53:16,976 --> 04:53:19,790
explains the elements of our

7734
04:53:19,790 --> 04:53:21,790
employee compensation system.

7735
04:53:21,147 --> 04:53:24,747
And it shows that the companies

7736
04:53:25,218 --> 04:53:27,870
2025 expenses for total direct

7737
04:53:27,870 --> 04:53:29,890
composition and benefits are

7738
04:53:29,890 --> 04:53:30,256
reasonable.

7739
04:53:30,256 --> 04:53:32,920
We target our total direct

7740
04:53:32,920 --> 04:53:35,920
compensation to be at market

7741
04:53:35,862 --> 04:53:37,731
median so that we can balance

7742
04:53:37,731 --> 04:53:39,699
the need to hire and retain

7743
04:53:39,699 --> 04:53:41,101
quality team members without

7744
04:53:41,101 --> 04:53:42,602
desire and commitment to

7745
04:53:42,602 --> 04:53:44,204
maintain reasonable customer

7746
04:53:44,204 --> 04:53:46,204
rates.

7747
04:53:46,239 --> 04:53:49,239
Our current employee count is

7748
04:53:52,512 --> 04:53:53,747
approximately 2550.

7749
04:53:53,747 --> 04:53:56,820
In 2024 we expect to maintain

7750
04:53:56,820 --> 04:53:58,820
that level in 2025.

7751
04:54:00,530 --> 04:54:02,210
My rebuttal testimony response

7752
04:54:02,210 --> 04:54:03,423
to criticisms from the office

7753
04:54:03,423 --> 04:54:03,531
of public counsel and

7754
04:54:03,531 --> 04:54:04,624
.

7755
04:54:04,624 --> 04:54:05,992
[Listing names] About our

7756
04:54:05,992 --> 04:54:07,226
variable pay programs and it

7757
04:54:07,226 --> 04:54:10,826
shows that variable or at risk

7758
04:54:12,650 --> 04:54:15,650
pay is commonly used by

7759
04:54:17,937 --> 04:54:19,105
companies in the united states.

7760
04:54:19,105 --> 04:54:20,907
These programs serve as

7761
04:54:20,907 --> 04:54:22,800
valuable tools that both

7762
04:54:22,800 --> 04:54:23,175
motivate and focus our

7763
04:54:23,175 --> 04:54:25,111
employees and also help the

7764
04:54:25,111 --> 04:54:27,511
company manage total direct

7765
04:54:32,952 --> 04:54:34,952
composition expenses.

7766
04:54:34,988 --> 04:54:36,189
I also show that the financial

7767
04:54:36,189 --> 04:54:38,158
performance metrics within our

7768
04:54:38,158 --> 04:54:39,993
short term incentive plans are

7769
04:54:39,993 --> 04:54:41,194
part of a balanced scorecard

7770
04:54:41,194 --> 04:54:43,594
performance goals that reflect

7771
04:54:46,332 --> 04:54:48,401
the diverse priorities that all

7772
04:54:48,401 --> 04:54:50,270
our employees or managers and

7773
04:54:50,270 --> 04:54:52,172
senior leaders balance every

7774
04:54:52,172 --> 04:54:53,473
day so that we can provide

7775
04:54:53,473 --> 04:54:55,341
high-quality electric service

7776
04:54:55,341 --> 04:54:56,276
to our customers and maintain

7777
04:54:56,276 --> 04:54:58,276
reasonable rates.

7778
04:54:58,478 --> 04:55:00,346
This concludes my summary.

7779
04:55:00,346 --> 04:55:02,182
>> teco: the spec is available

7780
04:55:02,182 --> 04:55:04,182
for cross-examination.

7781
04:55:04,317 --> 04:55:04,551
>> Mike La Rosa,CHAIRMAN: thank

7782
04:55:04,551 --> 04:55:05,785
you opc.

7783
04:55:05,785 --> 04:55:06,453
>> thank you MR.

7784
04:55:06,453 --> 04:55:07,353
CHAIRMAN and

7785
04:55:07,353 --> 04:55:09,353
hello again.

7786
04:55:10,223 --> 04:55:11,324
>> Witness: good afternoon.

7787
04:55:11,324 --> 04:55:13,259
>> opc: I would like to start

7788
04:55:13,259 --> 04:55:14,861
off if I could MR. CHAIRMAN

7789
04:55:14,861 --> 04:55:16,861
within exhibit not

7790
04:55:16,863 --> 04:55:18,731
confidential.

7791
04:55:18,731 --> 04:55:21,131
It is opc b

7792
04:55:48,194 --> 04:55:50,194
42.

7793
04:55:50,430 --> 04:55:52,430
That is 267.

7794
04:55:54,968 --> 04:55:56,968
Yes.

7795
04:55:58,237 --> 04:55:59,939
MS. Catcher tori I have a

7796
04:55:59,939 --> 04:56:02,339
composite exhibit of the

7797
04:56:05,778 --> 04:56:07,778
responses to opc

7798
04:56:11,217 --> 04:56:13,617
interrogatories 12-17 cod 30 do

7799
04:56:21,995 --> 04:56:23,995
you see that?

7800
04:56:24,797 --> 04:56:26,797
>> Witness: yes.

7801
04:56:37,410 --> 04:56:38,478
>> opc: okay.

7802
04:56:38,478 --> 04:56:40,878
Going to response to

7803
04:56:41,314 --> 04:56:43,249
interrogatory 12 it asked for a

7804
04:56:43,249 --> 04:56:44,417
list of each of the company's

7805
04:56:44,417 --> 04:56:46,417
existing incentive composition

7806
04:56:46,987 --> 04:56:49,387
plans to see that.

7807
04:56:57,960 --> 04:56:58,298
It refers the viewer to cod 30

7808
04:56:58,298 --> 04:57:00,698
which contains the description

7809
04:57:01,233 --> 04:57:03,200
of the existing compensation

7810
04:57:03,200 --> 04:57:04,304
plans which is attached to this

7811
04:57:04,304 --> 04:57:06,138
exhibit do see that.

7812
04:57:06,138 --> 04:57:07,340
>> Witness: yes I do.

7813
04:57:07,340 --> 04:57:10,340
>> opc: under the answer here

7814
04:57:14,414 --> 04:57:15,615
on 53 5396.

7815
04:57:15,615 --> 04:57:18,615
There is a variety of

7816
04:57:21,888 --> 04:57:23,888
stock-based plans.

7817
04:57:23,889 --> 04:57:24,958
Emera senior measurement stock

7818
04:57:24,958 --> 04:57:27,358
option plan emera restricted

7819
04:57:28,828 --> 04:57:32,970
share unit or as you plan.

7820
04:57:32,970 --> 04:57:33,199
And emera deferred share unit

7821
04:57:33,199 --> 04:57:33,499
bs you plan to see that.

7822
04:57:33,499 --> 04:57:34,200
>> Witness:

7823
04:57:34,200 --> 04:57:36,200
endo.

7824
04:57:37,236 --> 04:57:37,336
>>

7825
04:57:37,336 --> 04:57:39,305
.

7826
04:57:39,305 --> 04:57:39,638
[Listing names] You mind moving

7827
04:57:39,638 --> 04:57:40,540
correct phone

7828
04:57:40,540 --> 04:57:41,341
closer as you

7829
04:57:41,341 --> 04:57:43,309
speak.

7830
04:57:43,309 --> 04:57:46,110
>> Witness: I would be glad to.

7831
04:57:46,110 --> 04:57:48,470
>> opc: which long-term and

7832
04:57:48,470 --> 04:57:49,248
short-term incentives which

7833
04:57:49,248 --> 04:57:50,148
category do those stock plans

7834
04:57:50,148 --> 04:57:52,148
on climax.

7835
04:57:52,485 --> 04:57:55,485
>> Witness: the ones that apply

7836
04:57:56,222 --> 04:57:58,157
to tampa electric is the emera

7837
04:57:58,157 --> 04:57:59,292
restricted stock share unit

7838
04:57:59,292 --> 04:58:02,892
yaris you plan the emera share

7839
04:58:09,402 --> 04:58:11,437
unit drs you and that psu or

7840
04:58:11,437 --> 04:58:13,339
long-term incentive plans that

7841
04:58:13,339 --> 04:58:15,341
will apply to a small group of

7842
04:58:15,341 --> 04:58:16,843
tampa electric senior leaders.

7843
04:58:16,843 --> 04:58:19,100
Also the short term incentive

7844
04:58:19,100 --> 04:58:19,115
plan and the teco

7845
04:58:19,115 --> 04:58:20,179
.

7846
04:58:20,179 --> 04:58:21,314
[Listing names] And the

7847
04:58:21,314 --> 04:58:23,314
restoration plan.

7848
04:58:23,816 --> 04:58:26,816
>> opc: the top one emera

7849
04:58:28,530 --> 04:58:29,455
senior stock option plan is

7850
04:58:29,455 --> 04:58:29,555
that not tampa electric

7851
04:58:29,555 --> 04:58:30,589
.

7852
04:58:30,589 --> 04:58:32,240
>> Witness: that is

7853
04:58:32,240 --> 04:58:35,240
administered at emera it would

7854
04:58:37,960 --> 04:58:38,330
not be within my purview it

7855
04:58:38,330 --> 04:58:40,660
might be MR. Collins is the

7856
04:58:40,660 --> 04:58:41,733
only one I'm not sure.

7857
04:58:41,733 --> 04:58:45,333
>> opc: the cost of any awards

7858
04:58:48,541 --> 04:58:50,410
under the emera senior

7859
04:58:50,410 --> 04:58:51,644
management stock option plan

7860
04:58:51,644 --> 04:58:52,845
does are included if any fear

7861
04:58:52,845 --> 04:58:54,647
included in this rate case?

7862
04:58:54,647 --> 04:58:55,715
>> Witness: that would be a

7863
04:58:55,715 --> 04:58:56,682
good question for jeff.

7864
04:58:56,682 --> 04:58:57,817
[Listing names]

7865
04:58:57,817 --> 04:59:00,217
>> opc: do you know.

7866
04:59:03,723 --> 04:59:04,991
>> Witness: I do not know.

7867
04:59:04,991 --> 04:59:06,993
I assume so any costs incurred

7868
04:59:06,993 --> 04:59:07,893
for tampa electric would appear

7869
04:59:07,893 --> 04:59:09,893
in this.

7870
04:59:09,929 --> 04:59:11,798
>> opc: okay but if I'm looking

7871
04:59:11,798 --> 04:59:13,799
to divide this list of

7872
04:59:13,799 --> 04:59:14,933
compensation incentive

7873
04:59:14,933 --> 04:59:16,802
compensation plans between

7874
04:59:16,802 --> 04:59:18,802
long-term short-term. The

7875
04:59:19,571 --> 04:59:23,771
first 4 at the same emera was a

7876
04:59:26,612 --> 04:59:26,812
long-term incentive plans that)

7877
04:59:26,812 --> 04:59:28,648
Right?

7878
04:59:28,648 --> 04:59:29,715
>> Witness: that is correct it

7879
04:59:29,715 --> 04:59:32,115
would appear that way.

7880
04:59:39,191 --> 04:59:41,594
>> opc: the pod 30 I don't want

7881
04:59:41,594 --> 04:59:44,564
to it's a lengthy document.

7882
04:59:44,564 --> 04:59:45,764
Would it suffice to say that

7883
04:59:45,764 --> 04:59:48,164
this describes the incentive

7884
04:59:50,200 --> 04:59:51,671
plan and it has some scorecards

7885
04:59:51,671 --> 04:59:55,271
attached to it that show what

7886
04:59:56,375 --> 04:59:57,977
is needed to achieve an award

7887
04:59:57,977 --> 04:59:59,178
under the plan?

7888
04:59:59,178 --> 05:00:01,578
>> Witness: that is correct.

7889
05:00:04,149 --> 05:00:06,510
>> opc: would you agree that

7890
05:00:06,510 --> 05:00:07,453
the long-term incentive plan

7891
05:00:07,453 --> 05:00:09,540
purpose is to align the

7892
05:00:09,540 --> 05:00:11,454
long-term incentive pay for

7893
05:00:11,657 --> 05:00:14,570
senior leaders with corporate

7894
05:00:19,465 --> 05:00:20,465
and shareholder goals?

7895
05:00:20,465 --> 05:00:21,667
>> Witness: yes.

7896
05:00:21,667 --> 05:00:23,603
>> opc: would you agree that

7897
05:00:23,603 --> 05:00:26,300
100% of the long-term incentive

7898
05:00:27,640 --> 05:00:29,809
plan compensation is tied to

7899
05:00:29,809 --> 05:00:31,809
reaching financial performance

7900
05:00:35,948 --> 05:00:36,849
goals that include the emera

7901
05:00:36,849 --> 05:00:38,849
stock price?

7902
05:00:38,884 --> 05:00:39,151
>> Witness: can you repeat the

7903
05:00:39,151 --> 05:00:41,151
question.

7904
05:00:43,322 --> 05:00:45,223
>> opc: would you agree 100%

7905
05:00:45,223 --> 05:00:46,359
long-term incentive

7906
05:00:46,359 --> 05:00:48,427
compensation is tied to

7907
05:00:48,427 --> 05:00:50,329
reaching financial performance

7908
05:00:50,329 --> 05:00:51,230
goals that include the emera

7909
05:00:51,230 --> 05:00:52,498
stock price.

7910
05:00:52,498 --> 05:00:54,200
>> Witness: yes.

7911
05:00:54,200 --> 05:00:57,360
>> opc: have you provided any

7912
05:00:57,360 --> 05:00:59,338
evidence to the commission if

7913
05:00:59,338 --> 05:01:01,338
they required long-term

7914
05:01:03,575 --> 05:01:06,575
incentive plans cost to be

7915
05:01:07,313 --> 05:01:09,281
borne by the shareholder that

7916
05:01:09,281 --> 05:01:12,585
it would require the company to

7917
05:01:12,585 --> 05:01:14,585
redesign its composition

7918
05:01:14,586 --> 05:01:16,986
structure and replace long-term

7919
05:01:19,391 --> 05:01:20,226
incentive with higher fixed

7920
05:01:20,226 --> 05:01:21,227
base pay?

7921
05:01:21,227 --> 05:01:23,227
>> Witness: yes.

7922
05:01:25,564 --> 05:01:25,664
>> opc: what is that

7923
05:01:25,664 --> 05:01:26,832
.

7924
05:01:26,832 --> 05:01:29,232
>> Witness: the mercer data

7925
05:01:29,635 --> 05:01:30,169
would show our total direct

7926
05:01:30,169 --> 05:01:32,569
compensation is in market

7927
05:01:36,741 --> 05:01:38,644
median verse or data would also

7928
05:01:38,644 --> 05:01:39,812
show that 62% of companies

7929
05:01:39,812 --> 05:01:41,647
leverage long-term incentive

7930
05:01:41,647 --> 05:01:42,581
for this small population of

7931
05:01:42,581 --> 05:01:44,581
senior leaders

7932
05:01:45,351 --> 05:01:47,351
.

7933
05:01:51,457 --> 05:01:53,359
Because we target market median

7934
05:01:53,359 --> 05:01:54,593
for these executives it

7935
05:01:54,593 --> 05:01:56,428
requires us the components of

7936
05:01:56,428 --> 05:01:58,397
that as our base salary our

7937
05:01:58,397 --> 05:01:59,298
short-term incentive and are

7938
05:01:59,298 --> 05:02:01,233
long-term incentive mercer data

7939
05:02:01,233 --> 05:02:04,833
market data would show this is

7940
05:02:07,390 --> 05:02:10,475
common in and regularly used to

7941
05:02:10,475 --> 05:02:10,976
attract and retain senior

7942
05:02:10,976 --> 05:02:11,110
leaders

7943
05:02:11,110 --> 05:02:13,780
.

7944
05:02:13,780 --> 05:02:14,280
>> opc: the people at mercer do

7945
05:02:14,280 --> 05:02:15,813
not require you to do anything

7946
05:02:15,813 --> 05:02:17,783
right?

7947
05:02:17,783 --> 05:02:20,783
>> Witness: mercer's role is to

7948
05:02:23,689 --> 05:02:25,591
look at the market and report

7949
05:02:25,591 --> 05:02:27,526
out on what is customary what

7950
05:02:27,526 --> 05:02:28,727
is going on in the businesses.

7951
05:02:28,727 --> 05:02:30,629
They do not dictate what we do

7952
05:02:30,629 --> 05:02:32,631
they show us data that informs

7953
05:02:32,631 --> 05:02:32,898
our decisions on our benefit

7954
05:02:32,898 --> 05:02:34,633
packages?

7955
05:02:34,633 --> 05:02:35,868
>> opc: have you provided any

7956
05:02:35,868 --> 05:02:38,868
evidence to the commission in

7957
05:02:39,710 --> 05:02:41,600
this case, that any utility has

7958
05:02:41,600 --> 05:02:42,740
ever canceled or scrapped a

7959
05:02:42,740 --> 05:02:44,740
long-term incentive plan

7960
05:02:44,977 --> 05:02:46,977
because regulator disallowed

7961
05:02:47,279 --> 05:02:47,580
ratepayer recovery of part or

7962
05:02:47,580 --> 05:02:49,415
all of that.

7963
05:02:49,415 --> 05:02:53,150
>> Witness: not that I am aware

7964
05:02:56,455 --> 05:02:57,623
of.

7965
05:02:57,623 --> 05:02:59,625
>> opc: is it your testimony

7966
05:02:59,625 --> 05:03:00,960
from MR. Collins in the public

7967
05:03:00,960 --> 05:03:03,960
counsel have the burden of

7968
05:03:05,364 --> 05:03:08,364
proof to prove that incentive

7969
05:03:09,969 --> 05:03:12,369
that incentive tampa electric

7970
05:03:14,706 --> 05:03:14,806
executives to help bolster

7971
05:03:14,806 --> 05:03:16,806
.

7972
05:03:20,312 --> 05:03:21,680
>> I'm going to object to the

7973
05:03:21,680 --> 05:03:23,382
question it calls for a legal

7974
05:03:23,382 --> 05:03:24,216
conclusion about the burden of

7975
05:03:24,216 --> 05:03:26,185
proof.

7976
05:03:26,185 --> 05:03:29,785
>> opc: let's go to 400 of your

7977
05:03:34,927 --> 05:03:36,927
testimony please.

7978
05:03:43,602 --> 05:03:45,602
400?

7979
05:03:45,604 --> 05:03:46,939
I think that is in her direct

7980
05:03:46,939 --> 05:03:49,939
testimony I'm sorry it is

7981
05:04:11,196 --> 05:04:12,464
rebuttal testimony.

7982
05:04:12,464 --> 05:04:15,464
On line number 10 dc where

7983
05:04:18,103 --> 05:04:20,105
you'll fill testimony says MR.

7984
05:04:20,105 --> 05:04:23,105
Colin has presented no evidence

7985
05:04:28,412 --> 05:04:30,415
that denying cost recovery of

7986
05:04:30,415 --> 05:04:32,417
the lt/ip of the element of the

7987
05:04:32,417 --> 05:04:33,585
company total compensation

7988
05:04:33,585 --> 05:04:35,420
program will not harm the

7989
05:04:35,420 --> 05:04:37,423
company's ability to attract

7990
05:04:37,423 --> 05:04:39,823
and retain executive team

7991
05:04:41,492 --> 05:04:42,761
members were responsible for

7992
05:04:42,761 --> 05:04:44,663
procuring the company's needs

7993
05:04:44,663 --> 05:04:45,597
and obligation to its customers

7994
05:04:45,597 --> 05:04:46,765
to see that.

7995
05:04:46,765 --> 05:04:48,700
>> Witness: do.

7996
05:04:48,700 --> 05:04:52,300
>> opc: are you not saying that

7997
05:04:52,938 --> 05:04:54,107
it is MR. Collins burden of

7998
05:04:54,107 --> 05:04:56,740
approving the lack of harm.

7999
05:04:56,740 --> 05:04:59,740
>> I'm going to object she's

8000
05:05:01,480 --> 05:05:03,382
just sitting what she things

8001
05:05:03,382 --> 05:05:04,315
but the evidence is she's not

8002
05:05:04,315 --> 05:05:05,484
making a

8003
05:05:05,484 --> 05:05:07,352
comment in the burden

8004
05:05:07,352 --> 05:05:08,520
prove that a legal concept and

8005
05:05:08,520 --> 05:05:09,521
the org lawyers can argue about

8006
05:05:09,521 --> 05:05:11,220
that in the brief.

8007
05:05:11,220 --> 05:05:11,390
>> I will look over to

8008
05:05:11,390 --> 05:05:11,623
my

8009
05:05:11,623 --> 05:05:13,459
advisor.

8010
05:05:13,459 --> 05:05:17,590
>> I think we need to let.

8011
05:05:17,662 --> 05:05:17,762
[Listing names] Find

8012
05:05:17,762 --> 05:05:18,864
.

8013
05:05:18,864 --> 05:05:20,864
>> opc: this testimony

8014
05:05:21,332 --> 05:05:23,732
literally says burden to

8015
05:05:24,903 --> 05:05:26,903
demonstrate on climax.

8016
05:05:28,307 --> 05:05:29,441
[Unclear audio].

8017
05:05:29,441 --> 05:05:32,441
I'm not asking for legal

8018
05:05:37,248 --> 05:05:38,649
conclusion this is literally

8019
05:05:38,649 --> 05:05:40,252
what her testimony is.

8020
05:05:40,252 --> 05:05:41,453
>> I don't think he is reading

8021
05:05:41,453 --> 05:05:43,455
that correctly it says MR.

8022
05:05:43,455 --> 05:05:45,424
Colin has presented no evidence

8023
05:05:45,424 --> 05:05:47,292
it is not same it is his burden

8024
05:05:47,292 --> 05:05:48,293
to present it. It says he is

8025
05:05:48,293 --> 05:05:50,128
not presented it.

8026
05:05:50,128 --> 05:05:52,528
There is a difference.

8027
05:05:52,798 --> 05:05:56,398
But she can answer the question

8028
05:05:57,502 --> 05:05:58,704
I will withdraw the objection.

8029
05:05:58,704 --> 05:06:00,939
>> Witness: can you repeat the

8030
05:06:00,939 --> 05:06:01,380
question of what time

8031
05:06:01,380 --> 05:06:02,241
.

8032
05:06:02,241 --> 05:06:03,375
>> opc: are you saying is MR.

8033
05:06:03,375 --> 05:06:04,743
Colin response ability to

8034
05:06:04,743 --> 05:06:07,143
demonstrate to this commission

8035
05:06:08,480 --> 05:06:11,917
the lack of harm when he

8036
05:06:11,917 --> 05:06:14,317
testifies that the shareholders

8037
05:06:19,491 --> 05:06:20,726
should shoulder the cost of

8038
05:06:20,726 --> 05:06:22,628
long-term compensation?

8039
05:06:22,628 --> 05:06:24,528
>> Witness: no, what I would

8040
05:06:24,528 --> 05:06:26,928
ask the commissioners to

8041
05:06:36,410 --> 05:06:37,575
consider we are targeting

8042
05:06:37,575 --> 05:06:39,144
market median for reasons we

8043
05:06:39,144 --> 05:06:41,790
need to balance the ability to

8044
05:06:41,790 --> 05:06:42,314
attract and retain our senior

8045
05:06:42,314 --> 05:06:45,117
leaders with some cost putting

8046
05:06:45,117 --> 05:06:46,840
say I do feel like the mercer

8047
05:06:46,840 --> 05:06:47,319
data shows us what we need to

8048
05:06:47,319 --> 05:06:49,154
be competitive especially in

8049
05:06:49,154 --> 05:06:50,550
the tampa bay area is an

8050
05:06:50,550 --> 05:06:51,890
extremely

8051
05:06:51,890 --> 05:06:51,323
competitive job

8052
05:06:51,323 --> 05:06:53,225
market.

8053
05:06:53,225 --> 05:06:55,930
In order to retain our current

8054
05:06:55,930 --> 05:06:57,950
leaders and attract new ones is

8055
05:06:57,950 --> 05:06:59,970
important part is part of doing

8056
05:06:59,970 --> 05:07:00,265
business as part of our total

8057
05:07:00,265 --> 05:07:02,200
competition strategy.

8058
05:07:02,200 --> 05:07:04,102
>> opc: would you agree that.

8059
05:07:04,102 --> 05:07:05,270
[Listing names] The senior

8060
05:07:05,270 --> 05:07:07,305
leadership of tampa electric

8061
05:07:07,305 --> 05:07:09,307
company are provided incentives

8062
05:07:09,307 --> 05:07:11,142
to increase rate base and cash

8063
05:07:11,142 --> 05:07:12,310
flow in order to help emera

8064
05:07:12,310 --> 05:07:14,310
earnings-per-share and stock

8065
05:07:15,460 --> 05:07:17,460
price?

8066
05:07:18,784 --> 05:07:20,285
>> Witness: that is one element

8067
05:07:20,285 --> 05:07:22,685
of our overall balance

8068
05:07:24,722 --> 05:07:25,924
financial goals.

8069
05:07:25,924 --> 05:07:28,326
>> opc: you came to emera from

8070
05:07:28,326 --> 05:07:31,129
another company you did not

8071
05:07:31,129 --> 05:07:32,596
come because the incentive

8072
05:07:32,596 --> 05:07:34,320
compensation tampa electric

8073
05:07:34,320 --> 05:07:37,320
company was better than what

8074
05:07:42,773 --> 05:07:43,842
you had with your then current

8075
05:07:43,842 --> 05:07:45,777
employer is that correct?

8076
05:07:45,777 --> 05:07:47,646
>> Witness: that is correct.

8077
05:07:47,646 --> 05:07:48,713
>> opc: I have no further

8078
05:07:48,713 --> 05:07:49,915
questions thank you.

8079
05:07:49,915 --> 05:07:51,649
>> Mike La Rosa,CHAIRMAN:

8080
05:07:51,649 --> 05:07:52,851
florida rising.

8081
05:07:52,851 --> 05:07:54,852
>> thank you MR. CHAIRMAN we

8082
05:07:54,852 --> 05:07:57,852
are one confidential exhibit to

8083
05:07:59,924 --> 05:08:01,960
head out for this witness.

8084
05:08:01,960 --> 05:08:04,960
>> Mike La Rosa,CHAIRMAN: go

8085
05:08:24,549 --> 05:08:26,217
ahead and do that.

8086
05:08:26,217 --> 05:08:29,217
>> Florida Rising,Inc.: I think

8087
05:08:36,394 --> 05:08:36,628
MR. CHAIRMAN can we get

8088
05:08:36,628 --> 05:08:38,196
started.

8089
05:08:38,196 --> 05:08:39,364
> Mike La

8090
05:08:39,364 --> 05:08:42,200
Rosa,CHAIRMAN: yes go ahead.

8091
05:08:42,200 --> 05:08:44,202
>> Florida Rising,Inc.: before

8092
05:08:44,202 --> 05:08:46,204
we get to that document had

8093
05:08:46,204 --> 05:08:48,204
questions on non-confidential

8094
05:08:48,206 --> 05:08:49,241
documents. If I can direct your

8095
05:08:49,241 --> 05:08:49,441
attention to fl all b

8096
05:08:49,441 --> 05:08:51,242
197 this

8097
05:08:51,242 --> 05:08:55,442
is gonna be MR. Kamber f 3.3 b

8098
05:08:56,948 --> 05:08:58,116
6487.

8099
05:08:58,116 --> 05:08:59,551
This document shows the board

8100
05:08:59,551 --> 05:09:01,951
expenses that teco customers

8101
05:09:04,550 --> 05:09:05,890
are responsible for.

8102
05:09:05,890 --> 05:09:07,890
>> Witness: guess.

8103
05:09:07,910 --> 05:09:08,860
>> Florida Rising,Inc.: joe's

8104
05:09:08,860 --> 05:09:11,260
for 2023 that amount was 573

8105
05:09:16,601 --> 05:09:18,470
$507 for teco board and 189,006

8106
05:09:18,470 --> 05:09:20,870
earned 7004 emera support for

8107
05:09:22,474 --> 05:09:24,474
total 673,000.

8108
05:09:26,945 --> 05:09:28,947
>> Witness: I see that.

8109
05:09:28,947 --> 05:09:30,949
>> Florida Rising,Inc.: next I

8110
05:09:30,949 --> 05:09:32,217
would like to direct your

8111
05:09:32,217 --> 05:09:32,350
attention to exhibit f ll b

8112
05:09:32,350 --> 05:09:34,350
the

8113
05:09:34,986 --> 05:09:37,986
ninth is a webmaster number.

8114
05:09:49,300 --> 05:09:51,300
[Listing names].

8115
05:09:53,380 --> 05:09:54,272
This table is an interrogatory

8116
05:09:54,272 --> 05:09:56,672
answer providing the estimated

8117
05:09:56,941 --> 05:09:58,800
cost of the short-term

8118
05:09:58,800 --> 05:10:00,408
incentive plan and the

8119
05:10:00,544 --> 05:10:00,912
long-term incentive plan in the

8120
05:10:00,912 --> 05:10:01,780
2025 test year.

8121
05:10:01,780 --> 05:10:03,780
>> Witness: yes.

8122
05:10:13,858 --> 05:10:15,827
>> Florida Rising,Inc.: the

8123
05:10:15,827 --> 05:10:17,610
long-term incentive plan is a

8124
05:10:17,610 --> 05:10:18,929
little bit over $6.2 million

8125
05:10:18,929 --> 05:10:19,264
that is attributed to teco?

8126
05:10:19,264 --> 05:10:19,998
>> Witness:

8127
05:10:19,998 --> 05:10:21,998
correct.

8128
05:10:22,833 --> 05:10:24,936
>> Florida Rising,Inc.: the

8129
05:10:24,936 --> 05:10:25,969
short-term incentive plan would

8130
05:10:25,969 --> 05:10:27,969
be about 26.5 million.

8131
05:10:29,540 --> 05:10:31,643
>> Witness: that is correct.

8132
05:10:31,643 --> 05:10:33,678
>> Florida Rising,Inc.: keep in

8133
05:10:33,678 --> 05:10:33,778
mind as we go to f ll b

8134
05:10:33,778 --> 05:10:35,778
101

8135
05:10:37,820 --> 05:10:37,215
this will be MR. Number f-3

8136
05:10:37,215 --> 05:10:38,182
.2 b

8137
05:10:38,182 --> 05:10:40,182
31.2 b

8138
05:10:55,567 --> 05:10:57,567
3126.

8139
05:11:04,175 --> 05:11:05,343
This you see this interrogatory

8140
05:11:05,343 --> 05:11:06,444
answer at the bottom.

8141
05:11:06,444 --> 05:11:08,444
>> Witness: yes.

8142
05:11:09,214 --> 05:11:11,215
>> Florida Rising,Inc.: this

8143
05:11:11,215 --> 05:11:12,383
includes similar data but also

8144
05:11:12,383 --> 05:11:13,451
includes seconded employee

8145
05:11:13,451 --> 05:11:13,618
expense is that correct.

8146
05:11:13,618 --> 05:11:15,286
>>

8147
05:11:15,286 --> 05:11:16,387
Witness: that would be

8148
05:11:16,387 --> 05:11:18,387
counted employee expense.

8149
05:11:19,257 --> 05:11:22,257
>> Florida Rising,Inc.: what is

8150
05:11:26,831 --> 05:11:27,650
a seconded employee

8151
05:11:27,650 --> 05:11:28,266
.

8152
05:11:28,266 --> 05:11:30,201
>> Witness: that is a employee

8153
05:11:30,201 --> 05:11:32,700
from another country say canada

8154
05:11:32,700 --> 05:11:34,720
working in the united states.

8155
05:11:34,720 --> 05:11:35,306
> Florida Rising,Inc.: once

8156
05:11:35,306 --> 05:11:37,108
include that those numbers go

8157
05:11:37,108 --> 05:11:38,276
up a bit for short-term

8158
05:11:38,276 --> 05:11:40,144
incentive and long-term

8159
05:11:40,144 --> 05:11:41,790
incentive cost attributable to

8160
05:11:41,790 --> 05:11:43,790
teco customers?

8161
05:11:43,810 --> 05:11:45,116
>> Witness: they are working on

8162
05:11:45,116 --> 05:11:47,850
tampa electric business so yes.

8163
05:11:47,850 --> 05:11:48,186
>> Florida Rising,Inc.: long

8164
05:11:48,186 --> 05:11:50,121
term incentive plan is

8165
05:11:50,121 --> 05:11:51,322
administered through the emera

8166
05:11:51,322 --> 05:11:53,258
performance share unit and it

8167
05:11:53,258 --> 05:11:54,292
emera restricted share unit is

8168
05:11:54,292 --> 05:11:55,492
the right be 13 yes.

8169
05:11:55,492 --> 05:11:57,161
>> Florida

8170
05:11:57,161 --> 05:11:58,696
Rising,Inc.: that

8171
05:11:58,696 --> 05:12:00,265
refers to unit equivalent value

8172
05:12:00,265 --> 05:12:01,699
of eight emera common share?

8173
05:12:01,699 --> 05:12:04,990
>> Witness: that is correct.

8174
05:12:04,201 --> 05:12:05,402
>> Florida Rising,Inc.: so it

8175
05:12:05,402 --> 05:12:07,338
cannot share values affect the

8176
05:12:07,338 --> 05:12:07,472
share price of the psu and rcu

8177
05:12:07,472 --> 05:12:08,473
.

8178
05:12:08,473 --> 05:12:10,374
>> Witness: truck.

8179
05:12:10,374 --> 05:12:12,374
>> Commissioner: teco provides

8180
05:12:12,410 --> 05:12:14,245
term incentive plan composition

8181
05:12:14,245 --> 05:12:14,345
let me direct you to f ll b

8182
05:12:14,345 --> 05:12:16,345
93

8183
05:12:36,233 --> 05:12:38,236
this will be f 3.1-2915 this is

8184
05:12:38,236 --> 05:12:40,137
another interrogatory answer

8185
05:12:40,137 --> 05:12:40,504
regarding the long-term

8186
05:12:40,504 --> 05:12:41,272
incentive plan?

8187
05:12:41,272 --> 05:12:43,272
>> Witness: yes.

8188
05:12:43,341 --> 05:12:45,741
>> Florida Rising,Inc.: it

8189
05:12:48,279 --> 05:12:50,414
shows that long-term incentive

8190
05:12:50,414 --> 05:12:51,648
plans are made available

8191
05:12:51,648 --> 05:12:53,518
predominantly at the director

8192
05:12:53,518 --> 05:12:54,852
and above level at teco?

8193
05:12:54,852 --> 05:12:56,852
>> Witness: does correct.

8194
05:12:57,421 --> 05:12:58,956
>> Florida Rising,Inc.: the

8195
05:12:58,956 --> 05:13:00,425
document referenced earlier if

8196
05:13:00,425 --> 05:13:00,525
we can go to exhibit f ll b

8197
05:13:00,525 --> 05:13:01,559
53

8198
05:13:01,559 --> 05:13:03,959
this week MR. Number

8199
05:13:10,701 --> 05:13:12,701
f-3-1-1267.

8200
05:13:18,809 --> 05:13:20,430
This is going to be one of the

8201
05:13:20,430 --> 05:13:22,120
mercer benchmark survey data

8202
05:13:22,120 --> 05:13:24,315
that you referenced earlier.

8203
05:13:24,315 --> 05:13:26,350
>> Witness: that is correct.

8204
05:13:26,350 --> 05:13:27,785
>> Florida Rising,Inc.: it

8205
05:13:27,785 --> 05:13:29,420
shows that 53% of the companies

8206
05:13:29,420 --> 05:13:31,355
in the survey do not offer

8207
05:13:31,355 --> 05:13:32,523
long-term incentive plans?

8208
05:13:32,523 --> 05:13:35,523
>> Witness: what I would call

8209
05:13:39,329 --> 05:13:40,498
your attention to is under the

8210
05:13:40,498 --> 05:13:42,367
long-term incentive eligibility

8211
05:13:42,367 --> 05:13:44,335
that 66% of executives are

8212
05:13:44,335 --> 05:13:46,335
offered long-term incentive

8213
05:13:46,337 --> 05:13:48,339
that is really important part.

8214
05:13:48,339 --> 05:13:50,341
What I would really ask for

8215
05:13:50,341 --> 05:13:52,741
consideration is this lti

8216
05:13:59,550 --> 05:14:01,586
therapy is a small part of the

8217
05:14:01,586 --> 05:14:03,487
total composition strategy that

8218
05:14:03,487 --> 05:14:05,389
is targeted at the market

8219
05:14:05,389 --> 05:14:06,924
median that means is half the

8220
05:14:06,924 --> 05:14:08,459
companies that more than we do

8221
05:14:08,459 --> 05:14:10,361
in half of the companies pay

8222
05:14:10,361 --> 05:14:11,595
less and we feel strongly that

8223
05:14:11,595 --> 05:14:13,397
this market median is born it

8224
05:14:13,397 --> 05:14:14,565
will be able to attract and

8225
05:14:14,565 --> 05:14:15,599
retain the talent we need to

8226
05:14:15,599 --> 05:14:17,599
serve our customers.

8227
05:14:18,402 --> 05:14:19,670
>> Florida Rising,Inc.:

8228
05:14:19,670 --> 05:14:21,505
directing your attention back

8229
05:14:21,505 --> 05:14:23,373
to my question the survey

8230
05:14:23,373 --> 05:14:25,373
indicates of the 3220

8231
05:14:25,376 --> 05:14:26,544
organizations surveyed 53% do

8232
05:14:26,544 --> 05:14:27,478
not operate any long-term

8233
05:14:27,478 --> 05:14:28,613
incentive plans?

8234
05:14:28,613 --> 05:14:30,613
>> Witness: does correct.

8235
05:14:31,382 --> 05:14:32,617
>> Florida Rising,Inc.: if I

8236
05:14:32,617 --> 05:14:34,452
could direct your attention to

8237
05:14:34,452 --> 05:14:34,785
f ll-200 this will be MR.

8238
05:14:34,785 --> 05:14:36,785
Number f-3 b

8239
05:14:44,662 --> 05:14:46,662
6641.

8240
05:14:51,735 --> 05:14:52,837
This is going to be the

8241
05:14:52,837 --> 05:14:54,771
equivalent survey for

8242
05:14:54,771 --> 05:14:55,873
short-term incentive plan.

8243
05:14:55,873 --> 05:14:57,873
>> Witness: does correct.

8244
05:14:58,743 --> 05:14:59,176
>> Florida Rising,Inc.:

8245
05:14:59,176 --> 05:15:00,810
'ssurvey showed for

8246
05:15:00,810 --> 05:15:01,913
short-term

8247
05:15:01,913 --> 05:15:03,147
incentive plan that 80% of

8248
05:15:03,147 --> 05:15:04,949
companies offer those.

8249
05:15:04,949 --> 05:15:07,349
>> Witness: that is correct.

8250
05:15:07,785 --> 05:15:09,520
>> Florida Rising,Inc.: if I

8251
05:15:09,520 --> 05:15:11,220
get next direct your attention

8252
05:15:11,220 --> 05:15:14,258
to f ll-269 that is master

8253
05:15:14,258 --> 05:15:17,858
number f-3-five f-3-5-2451

8254
05:15:34,511 --> 05:15:36,547
f-3-5-24515 this is a historic

8255
05:15:36,547 --> 05:15:38,115
comparison of the short-term

8256
05:15:38,115 --> 05:15:40,515
incentive budget for actuals

8257
05:15:46,289 --> 05:15:47,458
for teco?

8258
05:15:47,458 --> 05:15:49,458
>> Witness: correct.

8259
05:15:50,394 --> 05:15:50,761
>> Florida Rising,Inc.: in 2023

8260
05:15:50,761 --> 05:15:51,528
the budget was

8261
05:15:51,528 --> 05:15:52,529
26.1 million?

8262
05:15:52,529 --> 05:15:54,529
>> Witness: yes.

8263
05:15:55,299 --> 05:15:55,866
>> Florida Rising,Inc.: the

8264
05:15:55,866 --> 05:15:57,267
actual for that

8265
05:15:57,267 --> 05:15:57,534
year was 24.9

8266
05:15:57,534 --> 05:15:59,436
million.

8267
05:15:59,436 --> 05:16:01,836
>> Witness: that is correct.

8268
05:16:02,306 --> 05:16:04,706
>> Florida Rising,Inc.: then

8269
05:16:04,909 --> 05:16:06,176
teco's 2024 budget is $27.2

8270
05:16:06,176 --> 05:16:06,269
million

8271
05:16:06,269 --> 05:16:07,878
.

8272
05:16:07,878 --> 05:16:09,446
>> Witness: that is correct.

8273
05:16:09,446 --> 05:16:12,516
What I might add that we

8274
05:16:12,516 --> 05:16:13,149
budgeted we are going to

8275
05:16:13,149 --> 05:16:16,749
achieve target that is more of

8276
05:16:19,323 --> 05:16:21,359
a accounting budgeting process

8277
05:16:21,359 --> 05:16:22,460
then whatever we actually

8278
05:16:22,460 --> 05:16:22,626
achieve that is what is paid

8279
05:16:22,626 --> 05:16:24,626
out.

8280
05:16:26,864 --> 05:16:28,866
That is why the discrepancy.

8281
05:16:28,866 --> 05:16:30,133
>> Florida Rising,Inc.: if I

8282
05:16:30,133 --> 05:16:31,936
can next direct your attention

8283
05:16:31,936 --> 05:16:33,270
to f ll-101 this will be

8284
05:16:33,270 --> 05:16:35,670
master number f-3-two-

8285
05:16:55,292 --> 05:16:56,460
f-3-2-3124.

8286
05:16:56,460 --> 05:16:57,628
This shows the number of

8287
05:16:57,628 --> 05:17:00,280
employees eligible to receive

8288
05:17:00,798 --> 05:17:01,932
incentive compensation.

8289
05:17:01,932 --> 05:17:03,968
>> Witness: yes that is

8290
05:17:03,968 --> 05:17:05,968
correct.

8291
05:17:06,700 --> 05:17:08,470
>> Florida Rising,Inc.: and

8292
05:17:13,100 --> 05:17:14,144
2023 there were 722 employees

8293
05:17:14,144 --> 05:17:16,130
that were eligible for the

8294
05:17:16,130 --> 05:17:17,381
performance sharing program for

8295
05:17:17,381 --> 05:17:17,487
union employees

8296
05:17:17,487 --> 05:17:17,815
.

8297
05:17:17,815 --> 05:17:19,815
>> Witness: yes.

8298
05:17:20,450 --> 05:17:22,450
>> Florida

8299
05:17:26,256 --> 05:17:27,324
Rising,Inc.: then there was

8300
05:17:27,324 --> 05:17:28,525
1860 eligible for the

8301
05:17:28,525 --> 05:17:30,394
short-term incentive plan.

8302
05:17:30,394 --> 05:17:32,794
>> Witness: that is correct.

8303
05:17:33,264 --> 05:17:35,265
>> Florida Rising,Inc.: then

8304
05:17:35,265 --> 05:17:36,700
went 24 were eligible for both

8305
05:17:36,700 --> 05:17:37,501
long-term and short-term.

8306
05:17:37,501 --> 05:17:39,501
>> Witness: yes.

8307
05:17:40,270 --> 05:17:41,438
>> Florida Rising,Inc.: is a

8308
05:17:41,438 --> 05:17:43,274
total of 2000 1006 employees

8309
05:17:43,274 --> 05:17:43,573
eligible for incentive

8310
05:17:43,573 --> 05:17:45,476
composition.

8311
05:17:45,476 --> 05:17:47,411
>> Witness: what you have there

8312
05:17:47,411 --> 05:17:49,280
is employees that were started

8313
05:17:49,280 --> 05:17:50,748
the year then they left they

8314
05:17:50,748 --> 05:17:53,748
might have been retired you

8315
05:17:55,719 --> 05:17:57,621
might have some people know

8316
05:17:57,621 --> 05:17:59,156
employees people or employees

8317
05:17:59,156 --> 05:17:59,890
were there to get in than they

8318
05:17:59,890 --> 05:18:01,890
(It's a combination.

8319
05:18:02,626 --> 05:18:02,993
>> Florida Rising,Inc.: that's

8320
05:18:02,993 --> 05:18:04,962
the right rate.

8321
05:18:04,962 --> 05:18:05,950
>> Witness: visitors

8322
05:18:05,950 --> 05:18:07,950
.

8323
05:18:07,164 --> 05:18:07,497
>> Florida Rising,Inc.: in 2023

8324
05:18:07,497 --> 05:18:09,660
only 40 teco

8325
05:18:09,660 --> 05:18:10,301
employees did not

8326
05:18:10,301 --> 05:18:12,236
receive incentive composition.

8327
05:18:12,236 --> 05:18:14,104
>> Witness: that is correct

8328
05:18:14,104 --> 05:18:16,106
spacing in the group of 40

8329
05:18:16,106 --> 05:18:17,341
include business operation

8330
05:18:17,341 --> 05:18:19,341
competitive student interns

8331
05:18:20,770 --> 05:18:22,477
employs a voluntary resign

8332
05:18:22,980 --> 05:18:24,148
before payout of the incentive

8333
05:18:24,148 --> 05:18:25,983
composition and employees

8334
05:18:25,983 --> 05:18:27,151
received a final performance

8335
05:18:27,151 --> 05:18:29,119
review rating of it does not

8336
05:18:29,119 --> 05:18:31,540
meet expectations or on a step

8337
05:18:31,540 --> 05:18:32,188
of discipline during the

8338
05:18:32,188 --> 05:18:33,290
performance plan year.

8339
05:18:33,290 --> 05:18:34,158
>> Witness: tells

8340
05:18:34,158 --> 05:18:36,158
correct.

8341
05:18:36,994 --> 05:18:39,630
>> Florida Rising,Inc.: is not

8342
05:18:39,630 --> 05:18:41,310
like I listed a bunch each one

8343
05:18:41,310 --> 05:18:41,231
of those categories had people

8344
05:18:41,231 --> 05:18:43,100
in it.

8345
05:18:43,100 --> 05:18:43,968
>> Witness: the totality of

8346
05:18:43,968 --> 05:18:45,903
that yes.

8347
05:18:45,903 --> 05:18:47,170
>> Florida Rising,Inc.: if I

8348
05:18:47,170 --> 05:18:49,730
can next direct your attention

8349
05:18:49,730 --> 05:18:49,406
to fll-193 this will be master

8350
05:18:49,406 --> 05:18:51,406
number

8351
05:19:11,195 --> 05:19:13,195
f-3.3-3-633.

8352
05:19:13,197 --> 05:19:14,398
This spreadsheet shows the

8353
05:19:14,398 --> 05:19:16,366
comparison of the budget and

8354
05:19:16,366 --> 05:19:18,435
actual for long-term incentive

8355
05:19:18,435 --> 05:19:20,637
versus short-term incentive for

8356
05:19:20,637 --> 05:19:22,637
2020-2023.

8357
05:19:27,211 --> 05:19:29,211
>> Witness: yes.

8358
05:19:29,346 --> 05:19:31,348
>> Florida Rising,Inc.: looking

8359
05:19:31,348 --> 05:19:32,849
at the actual for range ranges

8360
05:19:32,849 --> 05:19:34,849
from 23.5 million-29.5

8361
05:19:38,655 --> 05:19:40,655
million.

8362
05:19:42,593 --> 05:19:44,594
>> Witness: that is correct.

8363
05:19:44,594 --> 05:19:45,863
>> Florida Rising,Inc.: if I

8364
05:19:45,863 --> 05:19:47,297
can next direct your attention

8365
05:19:47,297 --> 05:19:49,766
to fll when and six this will

8366
05:19:49,766 --> 05:19:52,166
be master number f-3

8367
05:20:02,612 --> 05:20:04,800
.3-6485.

8368
05:20:04,800 --> 05:20:07,680
This would show the total test

8369
05:20:07,885 --> 05:20:09,510
your budget for both short-term

8370
05:20:09,510 --> 05:20:11,451
incentive plan and long-term

8371
05:20:14,157 --> 05:20:16,557
incentive plan that is

8372
05:20:24,367 --> 05:20:25,680
attributable to teco the final

8373
05:20:25,680 --> 05:20:26,403
expense on the

8374
05:20:26,403 --> 05:20:27,504
general ledger.

8375
05:20:27,504 --> 05:20:29,904
>> Witness: that is correct.

8376
05:20:30,340 --> 05:20:31,541
>> Florida Rising,Inc.: if you

8377
05:20:31,541 --> 05:20:33,477
add those numbers together

8378
05:20:33,477 --> 05:20:34,545
there would be a little over

8379
05:20:34,545 --> 05:20:36,513
$34 million budgeted.

8380
05:20:36,513 --> 05:20:38,382
>> Witness: yes stp at target.

8381
05:20:38,382 --> 05:20:39,816
>> Florida Rising,Inc.: if I

8382
05:20:39,816 --> 05:20:41,485
can next direct your attention

8383
05:20:41,485 --> 05:20:45,850
to fll-89 this will be master

8384
05:20:54,131 --> 05:20:56,531
number f-3-one-1.23-eight.

8385
05:20:56,900 --> 05:20:59,300
This was an interrogatory

8386
05:21:00,270 --> 05:21:02,339
question regarding the amount

8387
05:21:02,339 --> 05:21:04,739
of short-term and long-term

8388
05:21:11,148 --> 05:21:12,349
incentive program cost that

8389
05:21:12,349 --> 05:21:13,183
shareholders were responsible

8390
05:21:13,183 --> 05:21:14,184
for?

8391
05:21:14,184 --> 05:21:16,153
>> Witness: yes.

8392
05:21:16,153 --> 05:21:17,287
>> Florida Rising,Inc.: it

8393
05:21:17,287 --> 05:21:19,155
indicates that teco cannot

8394
05:21:19,155 --> 05:21:20,357
calculate a precise amount

8395
05:21:20,357 --> 05:21:22,325
because the actual amounts and

8396
05:21:22,325 --> 05:21:25,161
the amount used to establish

8397
05:21:25,161 --> 05:21:25,395
the revenue requirements MAY

8398
05:21:25,395 --> 05:21:27,330
differ?

8399
05:21:27,330 --> 05:21:29,299
>> Witness: I don't actually

8400
05:21:29,299 --> 05:21:32,899
see that where are you reading

8401
05:21:38,800 --> 05:21:40,800
that?

8402
05:21:40,430 --> 05:21:42,450
>> Florida Rising,Inc.: I'm

8403
05:21:42,450 --> 05:21:45,450
looking at the second left

8404
05:21:46,883 --> 05:21:48,685
sentence after each because the

8405
05:21:48,685 --> 05:21:49,820
shelter is impacted by the

8406
05:21:49,820 --> 05:21:51,688
difference between actual

8407
05:21:51,688 --> 05:21:55,288
amount and the amount used to

8408
05:21:57,828 --> 05:21:59,290
establish revenue requirements

8409
05:21:59,290 --> 05:21:59,830
in the prior rate case do see

8410
05:21:59,830 --> 05:22:01,310
that?

8411
05:22:01,310 --> 05:22:02,966
>> Witness: I do I don't think

8412
05:22:02,966 --> 05:22:05,100
that was the question maybe you

8413
05:22:05,100 --> 05:22:07,401
can repeat the question.

8414
05:22:07,838 --> 05:22:09,720
>> Florida Rising,Inc.: let me

8415
05:22:09,720 --> 05:22:10,940
ask in a different way what I'm

8416
05:22:10,940 --> 05:22:12,843
trying to get up if the actual

8417
05:22:12,843 --> 05:22:14,770
amount the amount used to

8418
05:22:14,770 --> 05:22:15,946
establish revenue requirements

8419
05:22:15,946 --> 05:22:18,815
of the same shareholders will

8420
05:22:18,815 --> 05:22:19,983
not be impacted by short-term

8421
05:22:19,983 --> 05:22:21,818
incentive program long-term

8422
05:22:21,818 --> 05:22:22,953
incentive program cost better

8423
05:22:22,953 --> 05:22:23,920
in the past year as part of

8424
05:22:23,920 --> 05:22:25,822
this rate case?

8425
05:22:25,822 --> 05:22:27,357
>> Witness: believe that to be

8426
05:22:27,357 --> 05:22:28,825
true I think is a good question

8427
05:22:28,825 --> 05:22:29,826
to direct to.

8428
05:22:29,826 --> 05:22:31,826
[Listing names].

8429
05:22:31,828 --> 05:22:33,363
>> Florida Rising,Inc.: if I

8430
05:22:33,363 --> 05:22:33,530
can next direct your attention

8431
05:22:33,530 --> 05:22:35,310
to

8432
05:22:35,310 --> 05:22:38,310
fll-240 this will be master

8433
05:22:53,817 --> 05:22:55,785
number f-3.4-1482 if I can

8434
05:22:55,785 --> 05:22:57,788
direct your attention within

8435
05:22:57,788 --> 05:23:00,123
this document to master number

8436
05:23:00,123 --> 05:23:02,123
f-3

8437
05:23:12,702 --> 05:23:13,770
.4-14971.

8438
05:23:13,770 --> 05:23:14,370
>> Witness: this is it

8439
05:23:14,370 --> 05:23:16,370
sideways.

8440
05:23:16,940 --> 05:23:18,842
>> Florida Rising,Inc.: there

8441
05:23:18,842 --> 05:23:19,876
should be a rotate right

8442
05:23:19,876 --> 05:23:20,176
feature.

8443
05:23:20,176 --> 05:23:22,176
[Laughter].

8444
05:23:23,780 --> 05:23:23,880
>> Witness: thank you

8445
05:23:23,880 --> 05:23:25,810
.

8446
05:23:25,810 --> 05:23:28,681
>> teco: what is that I cannot

8447
05:23:30,200 --> 05:23:31,154
read it.

8448
05:23:31,154 --> 05:23:31,388
The number. The exhibit

8449
05:23:31,388 --> 05:23:33,388
number?

8450
05:23:34,890 --> 05:23:37,890
>> Florida Rising,Inc.: this is

8451
05:23:43,366 --> 05:23:43,700
exhibit fll-240 I have the cll

8452
05:23:43,700 --> 05:23:45,700
number here.

8453
05:23:48,338 --> 05:23:49,673
700.

8454
05:23:49,673 --> 05:23:51,673
>> teco: thank you.

8455
05:23:59,683 --> 05:24:00,830
>> Florida

8456
05:24:00,830 --> 05:24:01,685
Rising,Inc.: this

8457
05:24:01,685 --> 05:24:02,719
is the 2023

8458
05:24:02,719 --> 05:24:03,820
corporate scorecard.

8459
05:24:03,820 --> 05:24:06,220
>> teco Witness: that is

8460
05:24:08,692 --> 05:24:09,793
correct what is the purpose of

8461
05:24:09,793 --> 05:24:11,727
the corporate scorecard.

8462
05:24:11,727 --> 05:24:13,630
>> teco Witness: I'm so glad

8463
05:24:13,630 --> 05:24:14,764
you asked the balance scorecard

8464
05:24:14,764 --> 05:24:17,164
really allows tampa electric

8465
05:24:19,336 --> 05:24:20,637
employees and that is employees

8466
05:24:20,637 --> 05:24:23,372
are managers and senior leaders

8467
05:24:23,372 --> 05:24:24,507
to focus on all the different

8468
05:24:24,507 --> 05:24:27,143
priorities that we need to

8469
05:24:27,143 --> 05:24:28,311
focus on in a year. It is

8470
05:24:28,311 --> 05:24:30,212
balanced because has the

8471
05:24:30,212 --> 05:24:32,212
different categories called

8472
05:24:33,516 --> 05:24:34,784
out.

8473
05:24:34,784 --> 05:24:36,686
It mobilizes and focuses people

8474
05:24:36,686 --> 05:24:38,621
on the things that are going to

8475
05:24:38,621 --> 05:24:41,491
matter most for customers that

8476
05:24:41,491 --> 05:24:43,491
your.

8477
05:24:43,526 --> 05:24:44,995
>> Florida Rising,Inc.: this

8478
05:24:44,995 --> 05:24:45,962
indicates if tampa electric

8479
05:24:45,962 --> 05:24:46,663
does not meet their net

8480
05:24:46,663 --> 05:24:48,565
income

8481
05:24:48,565 --> 05:24:50,660
goal the entire scorecard

8482
05:24:50,660 --> 05:24:50,532
cannot pay out more than the

8483
05:24:50,532 --> 05:24:51,667
target.

8484
05:24:51,667 --> 05:24:53,670
>> teco Witness: that is

8485
05:24:53,670 --> 05:24:55,571
correct spacing measure with

8486
05:24:55,571 --> 05:24:56,406
ice wheat and the scorecard is

8487
05:24:56,406 --> 05:24:56,906
the tampa electric net income

8488
05:24:56,906 --> 05:24:58,408
measure.

8489
05:24:58,408 --> 05:25:00,760
>> teco Witness: or financial

8490
05:25:00,760 --> 05:25:02,450
goals or 35% of our balanced

8491
05:25:02,450 --> 05:25:03,880
scorecard but there is balance

8492
05:25:03,880 --> 05:25:04,800
with the other priorities as

8493
05:25:04,800 --> 05:25:05,915
well.

8494
05:25:05,915 --> 05:25:07,884
>> Florida Rising,Inc.: does

8495
05:25:07,884 --> 05:25:08,885
the higher weight and any other

8496
05:25:08,885 --> 05:25:10,520
measure on there.

8497
05:25:10,520 --> 05:25:11,521
>> teco Witness: that is

8498
05:25:11,521 --> 05:25:13,521
correct.

8499
05:25:13,556 --> 05:25:14,758
>> Florida Rising,Inc.: next I

8500
05:25:14,758 --> 05:25:14,958
like to direct your question to

8501
05:25:14,958 --> 05:25:16,958
fll b

8502
05:25:17,926 --> 05:25:19,926
-298 that is the

8503
05:25:32,208 --> 05:25:33,376
confidential.

8504
05:25:33,376 --> 05:25:34,210
Are you familiar with this

8505
05:25:34,210 --> 05:25:35,211
document.

8506
05:25:35,211 --> 05:25:36,446
> teco Witness:

8507
05:25:36,446 --> 05:25:37,280
actually this did not come from

8508
05:25:37,280 --> 05:25:39,280
yes.

8509
05:25:39,315 --> 05:25:40,784
The executive compensation

8510
05:25:40,784 --> 05:25:41,918
strategy

8511
05:25:41,918 --> 05:25:44,918
, is done at the emera

8512
05:25:48,591 --> 05:25:50,591
level.

8513
05:25:50,693 --> 05:25:52,629
>> Florida Rising,Inc.: you are

8514
05:25:52,629 --> 05:25:54,731
the witness responsible for

8515
05:25:54,731 --> 05:25:56,166
executive composition for teco

8516
05:25:56,166 --> 05:25:58,167
in this case. The information

8517
05:25:58,167 --> 05:25:59,168
that is not highlighted that is

8518
05:25:59,168 --> 05:25:59,669
not confidential?

8519
05:25:59,669 --> 05:26:01,171
>> teco Witness:

8520
05:26:01,171 --> 05:26:01,437
the information

8521
05:26:01,437 --> 05:26:03,437
that is.

8522
05:26:04,174 --> 05:26:05,207
>> Florida Rising,Inc.: not

8523
05:26:05,207 --> 05:26:05,542
highlighted is not

8524
05:26:05,542 --> 05:26:07,542
confidential?

8525
05:26:09,946 --> 05:26:11,114
Is that right?

8526
05:26:11,114 --> 05:26:13,514
>> teco Attorney: are we

8527
05:26:15,919 --> 05:26:19,519
getting ready to talk about fll

8528
05:26:24,127 --> 05:26:24,297
290 8c

8529
05:26:24,297 --> 05:26:26,297
.

8530
05:26:26,328 --> 05:26:28,264
>> teco Attorney: I'm going to

8531
05:26:28,264 --> 05:26:30,266
object. This is detailed

8532
05:26:30,266 --> 05:26:32,266
compensation information for

8533
05:26:32,268 --> 05:26:33,670
individual employees. I'm not

8534
05:26:33,670 --> 05:26:35,471
sure why it is relevant.

8535
05:26:35,471 --> 05:26:36,472
Were helpful to the commission

8536
05:26:36,472 --> 05:26:38,274
in this case.

8537
05:26:38,274 --> 05:26:39,408
>> Florida Rising,Inc.: I

8538
05:26:39,408 --> 05:26:41,277
believe teco are seeking

8539
05:26:41,277 --> 05:26:42,445
recovery of these costs from

8540
05:26:42,445 --> 05:26:44,514
the ratepayers and certainly

8541
05:26:44,514 --> 05:26:46,449
those costs are reasonable or

8542
05:26:46,449 --> 05:26:48,284
not reasonable it is certainly

8543
05:26:48,284 --> 05:26:48,518
an issue in this case I

8544
05:26:48,518 --> 05:26:50,353
believe.

8545
05:26:50,353 --> 05:26:53,353
[Listing names]'s testimony is

8546
05:26:54,401 --> 05:26:54,546
it is reasonable we think the

8547
05:26:54,546 --> 05:26:56,291
numbers help can speak for

8548
05:26:56,291 --> 05:26:58,294
themselves as to their

8549
05:26:58,294 --> 05:26:59,562
reasonableness. We think there

8550
05:26:59,562 --> 05:27:00,530
opposition is highly relevant

8551
05:27:00,530 --> 05:27:02,465
to this case.

8552
05:27:02,465 --> 05:27:04,334
>> teco Attorney: I just looked

8553
05:27:04,334 --> 05:27:06,335
at your position in your

8554
05:27:06,335 --> 05:27:07,569
prehearing statement you are

8555
05:27:07,569 --> 05:27:08,338
suggesting that this is issue

8556
05:27:08,338 --> 05:27:09,538
53.

8557
05:27:09,538 --> 05:27:11,507
Your position is that salaries

8558
05:27:11,507 --> 05:27:13,309
and benefits expense should be

8559
05:27:13,309 --> 05:27:14,477
produced for incentive

8560
05:27:14,477 --> 05:27:16,312
compensation and to remove ds

8561
05:27:16,312 --> 05:27:17,480
you are. But there is no

8562
05:27:17,480 --> 05:27:19,315
allegation in your position

8563
05:27:19,315 --> 05:27:20,917
that the general level of

8564
05:27:20,917 --> 05:27:22,151
composition is inappropriate?

8565
05:27:22,151 --> 05:27:24,151
>> Florida Rising,Inc.:

8566
05:27:24,387 --> 05:27:26,155
>> teco Attorney: don't see how

8567
05:27:26,155 --> 05:27:27,223
going through individual

8568
05:27:27,223 --> 05:27:29,223
composition amounts for

8569
05:27:29,891 --> 05:27:30,994
individual employees has

8570
05:27:30,994 --> 05:27:33,763
anything to do with the

8571
05:27:33,763 --> 05:27:34,764
positions you have taken in the

8572
05:27:34,764 --> 05:27:36,764
prehearing order.

8573
05:27:36,766 --> 05:27:38,801
>> Florida Rising,Inc.: unless

8574
05:27:38,801 --> 05:27:40,769
I'm mistaken I don't get is

8575
05:27:40,769 --> 05:27:43,390
confidential to state that

8576
05:27:43,390 --> 05:27:44,700
short-term incentive and

8577
05:27:44,700 --> 05:27:45,108
long-term incentive plan

8578
05:27:45,108 --> 05:27:47,900
compositions within this

8579
05:27:47,900 --> 05:27:49,409
document and certainly goes

8580
05:27:55,351 --> 05:27:57,351
towards total composition.

8581
05:28:00,723 --> 05:28:03,723
The objection is relevant can

8582
05:28:07,730 --> 05:28:08,864
we limit the scope.

8583
05:28:08,864 --> 05:28:11,670
>> MR. CHAIRMAN can have a

8584
05:28:11,670 --> 05:28:13,369
quick conversation with your

8585
05:28:13,369 --> 05:28:13,469
lawyers work this case

8586
05:28:13,469 --> 05:28:15,469
.

8587
05:28:15,538 --> 05:28:18,538
>> Mike La Rosa,CHAIRMAN: let's

8588
05:33:09,598 --> 05:33:11,998
take three minute break.

8589
05:35:57,532 --> 05:35:59,932
>> Mike La Rosa,CHAIRMAN:

8590
05:36:00,469 --> 05:36:03,469
discussion with my advisor I

8591
05:36:05,140 --> 05:36:07,809
will take it over to her to

8592
05:36:07,809 --> 05:36:09,440
talk about the legal position.

8593
05:36:09,440 --> 05:36:12,440
>> thank you MR. CHAIRMAN and

8594
05:36:12,748 --> 05:36:14,616
thank you for letting us take a

8595
05:36:14,616 --> 05:36:15,917
break to discuss this

8596
05:36:15,917 --> 05:36:18,317
internally. I recognize that

8597
05:36:21,456 --> 05:36:23,491
this is a highly sensitive area

8598
05:36:23,491 --> 05:36:24,660
that we are doubling into now

8599
05:36:24,660 --> 05:36:26,495
that MR. Marshall has brought

8600
05:36:26,495 --> 05:36:29,498
us to. When I look at MR.

8601
05:36:29,498 --> 05:36:30,665
Marshall's position and the

8602
05:36:30,665 --> 05:36:33,468
prehearing order to me he is

8603
05:36:33,468 --> 05:36:34,669
made an issue of the incentive

8604
05:36:34,669 --> 05:36:36,638
compensation. As I understand

8605
05:36:36,638 --> 05:36:37,973
this exhibit it addresses

8606
05:36:37,973 --> 05:36:39,174
incentive compensation.

8607
05:36:39,174 --> 05:36:42,774
I think it is relevant to

8608
05:36:44,613 --> 05:36:46,481
discuss I think we need to talk

8609
05:36:46,481 --> 05:36:48,483
about maybe a little bit about

8610
05:36:48,483 --> 05:36:50,619
how to go about discussing it.

8611
05:36:50,619 --> 05:36:51,753
This information is it has been

8612
05:36:51,753 --> 05:36:54,753
presented to us as highly

8613
05:36:57,592 --> 05:36:58,827
granular.

8614
05:36:58,827 --> 05:37:01,827
Meaning there is persons names

8615
05:37:02,930 --> 05:37:04,166
and specific numbers attached

8616
05:37:04,166 --> 05:37:05,933
to each. I'm not sure from the

8617
05:37:05,933 --> 05:37:08,333
company's perspective the names

8618
05:37:13,975 --> 05:37:15,844
here are confidential because

8619
05:37:15,844 --> 05:37:17,450
the way our process works

8620
05:37:17,450 --> 05:37:19,140
usually it is the information

8621
05:37:19,140 --> 05:37:20,882
that is highlighted in yellow

8622
05:37:20,882 --> 05:37:22,150
that is confidential I'm

8623
05:37:22,150 --> 05:37:24,686
confused about whether it is

8624
05:37:24,686 --> 05:37:25,821
all information on the page or

8625
05:37:25,821 --> 05:37:26,788
certain information on the

8626
05:37:26,788 --> 05:37:27,688
page?

8627
05:37:27,688 --> 05:37:29,691
Maybe if MR. Marshall can

8628
05:37:29,691 --> 05:37:31,693
direct this question on a more

8629
05:37:31,693 --> 05:37:34,429
global level instead of of a

8630
05:37:34,429 --> 05:37:35,663
with a particular level.

8631
05:37:35,663 --> 05:37:37,531
>> Florida Rising: I think that

8632
05:37:37,531 --> 05:37:39,301
is the right approach to this

8633
05:37:39,301 --> 05:37:41,269
document.

8634
05:37:41,269 --> 05:37:42,470
We certainly believe it is

8635
05:37:42,470 --> 05:37:44,339
relevant and within the scope

8636
05:37:44,339 --> 05:37:47,339
of our position in the

8637
05:37:50,679 --> 05:37:52,614
prehearing statement box.

8638
05:37:52,614 --> 05:37:53,815
>> Mike La Rosa,CHAIRMAN: I

8639
05:37:53,815 --> 05:37:55,683
want to make sure we clarify

8640
05:37:55,683 --> 05:37:57,618
but it's confidential what is

8641
05:37:57,618 --> 05:37:58,687
not confidential I'm confused

8642
05:37:58,687 --> 05:38:00,588
about what is and what is not.

8643
05:38:00,588 --> 05:38:02,624
>> teco Attorney: all the

8644
05:38:02,624 --> 05:38:02,958
numbers on these pages are

8645
05:38:02,958 --> 05:38:04,958
confidential.

8646
05:38:05,627 --> 05:38:06,795
this is the specific employee

8647
05:38:06,795 --> 05:38:08,596
compensation for specific

8648
05:38:08,596 --> 05:38:09,764
people. I guess the point I'm

8649
05:38:09,764 --> 05:38:11,600
trying to make is you don't

8650
05:38:11,600 --> 05:38:12,867
need this information to

8651
05:38:12,867 --> 05:38:15,267
calculate the adjustment we

8652
05:38:15,270 --> 05:38:17,305
have just gone through about

8653
05:38:17,305 --> 05:38:18,506
maybe half a dozen or one dozen

8654
05:38:18,506 --> 05:38:20,308
documents that show up with the

8655
05:38:20,308 --> 05:38:21,542
total amount of the

8656
05:38:21,542 --> 05:38:23,512
compensation is. And the basis

8657
05:38:23,512 --> 05:38:25,347
for their adjustment and what

8658
05:38:25,347 --> 05:38:27,382
I'm trying to say is that this

8659
05:38:27,382 --> 05:38:28,449
detailed information is not

8660
05:38:28,449 --> 05:38:29,351
needed to calculate that

8661
05:38:29,351 --> 05:38:30,519
adjustment.

8662
05:38:30,519 --> 05:38:32,354
Or to prove their point. We

8663
05:38:32,354 --> 05:38:34,356
don't think it is really

8664
05:38:34,356 --> 05:38:35,557
probative or as much to the

8665
05:38:35,557 --> 05:38:37,425
discussion except that it is

8666
05:38:37,425 --> 05:38:39,527
really interesting to find out

8667
05:38:39,527 --> 05:38:41,927
how much individual employees

8668
05:38:43,899 --> 05:38:45,267
might be making. I just don't

8669
05:38:45,267 --> 05:38:46,868
think that is appropriate.

8670
05:38:46,868 --> 05:38:48,870
>> Florida Rising: if I MAY

8671
05:38:48,870 --> 05:38:50,405
respond to that MR. CHAIRMAN if

8672
05:38:50,405 --> 05:38:51,640
it was $10 million estate

8673
05:38:51,640 --> 05:38:53,640
spread across 1 million

8674
05:38:55,110 --> 05:38:56,311
employees at $10 each that's a

8675
05:38:56,311 --> 05:38:58,280
very different scenario than

8676
05:38:58,280 --> 05:39:00,680
$10 million being spread over

8677
05:39:02,684 --> 05:39:03,952
one employee. The amount going

8678
05:39:03,952 --> 05:39:05,820
for these top executives we

8679
05:39:05,820 --> 05:39:07,722
think is a relevant issue as to

8680
05:39:07,722 --> 05:39:09,257
whether the cost that are being

8681
05:39:09,257 --> 05:39:09,758
charged to teco's customers are

8682
05:39:09,758 --> 05:39:10,725
fair.

8683
05:39:10,725 --> 05:39:13,125
Hat is what this

8684
05:39:13,795 --> 05:39:14,963
document shows.

8685
05:39:14,963 --> 05:39:17,365
>> teco Attorney: he is not

8686
05:39:17,365 --> 05:39:19,234
offering any evidence that it

8687
05:39:19,234 --> 05:39:20,235
is fair he just wants to talk

8688
05:39:20,235 --> 05:39:22,235
about the amounts.

8689
05:39:25,873 --> 05:39:27,750
There is no competing evidence

8690
05:39:27,750 --> 05:39:29,100
that this is not the right

8691
05:39:29,100 --> 05:39:30,110
answer. He just wants to talk

8692
05:39:30,110 --> 05:39:31,713
about the amounts.

8693
05:39:31,713 --> 05:39:33,615
>> Florida Rising: the amounts

8694
05:39:33,615 --> 05:39:33,847
go to whether it is the right

8695
05:39:33,847 --> 05:39:35,847
amount.

8696
05:39:37,118 --> 05:39:39,154
>> teco Attorney: he is not

8697
05:39:39,154 --> 05:39:40,388
contesting the amount with

8698
05:39:40,388 --> 05:39:42,289
evidence he just wants to make

8699
05:39:42,289 --> 05:39:44,125
a big deal out of the numbers.

8700
05:39:44,125 --> 05:39:45,360
I just think it is

8701
05:39:45,360 --> 05:39:46,394
inappropriate not needed for

8702
05:39:46,394 --> 05:39:48,128
the calculation.

8703
05:39:48,128 --> 05:39:50,131
That is our objection.

8704
05:39:50,131 --> 05:39:51,599
>> Mike La Rosa,CHAIRMAN: I

8705
05:39:51,599 --> 05:39:51,766
understand where both sides

8706
05:39:51,766 --> 05:39:53,766
are.

8707
05:39:54,135 --> 05:39:56,137
I will go back to my advisor.

8708
05:39:56,137 --> 05:39:56,705
Straight-line looks to be on

8709
05:39:56,705 --> 05:39:57,739
highlighted.

8710
05:39:57,739 --> 05:40:00,175
That is probably what concerns

8711
05:40:00,175 --> 05:40:02,175
me.

8712
05:40:02,176 --> 05:40:03,144
I don't understand what is then

8713
05:40:03,144 --> 05:40:04,179
confidential?

8714
05:40:04,179 --> 05:40:06,179
From that point?

8715
05:40:10,180 --> 05:40:11,953
>> teco Attorney: the

8716
05:40:11,953 --> 05:40:13,154
information we claim is

8717
05:40:13,154 --> 05:40:14,990
confidential and we put in our

8718
05:40:14,990 --> 05:40:16,124
request for confidential

8719
05:40:16,124 --> 05:40:17,992
classification is all the

8720
05:40:17,992 --> 05:40:19,992
individual compensation amount

8721
05:40:19,994 --> 05:40:22,630
shown on here for all of the

8722
05:40:22,630 --> 05:40:23,164
individual employees.

8723
05:40:23,164 --> 05:40:25,233
Everything that is highlighted

8724
05:40:25,233 --> 05:40:27,680
in yellow is confidential.

8725
05:40:27,680 --> 05:40:28,269
>> the first line for each

8726
05:40:28,269 --> 05:40:30,238
employee where it said straight

8727
05:40:30,238 --> 05:40:31,205
those are not highlighted is

8728
05:40:31,205 --> 05:40:33,174
that information.

8729
05:40:33,174 --> 05:40:35,343
>> teco Attorney: that has been

8730
05:40:35,343 --> 05:40:36,544
disclosed in forum number one.

8731
05:40:36,544 --> 05:40:38,944
>> MR. CHAIRMAN my recognition

8732
05:40:47,889 --> 05:40:49,791
is understand there is grave

8733
05:40:49,791 --> 05:40:51,793
concern on the part of the

8734
05:40:51,793 --> 05:40:53,862
company with respect to this

8735
05:40:53,862 --> 05:40:55,797
exhibit. I appreciate that. But

8736
05:40:55,797 --> 05:40:56,965
MR. Marshall has not been able

8737
05:40:56,965 --> 05:40:58,900
to ask a question. Maybe a

8738
05:40:58,900 --> 05:41:00,869
better approach would be to

8739
05:41:00,869 --> 05:41:02,303
have MR. Marshall as his

8740
05:41:02,303 --> 05:41:04,380
question then we can see if

8741
05:41:04,380 --> 05:41:05,840
there is a specific objection

8742
05:41:05,840 --> 05:41:07,876
to the question because we

8743
05:41:07,876 --> 05:41:08,309
don't know quite frankly how he

8744
05:41:08,309 --> 05:41:09,430
plans on using it.

8745
05:41:09,430 --> 05:41:09,277
I think we

8746
05:41:09,277 --> 05:41:10,845
are all

8747
05:41:10,845 --> 05:41:12,460
sensitive now to.

8748
05:41:12,460 --> 05:41:13,848
>> teco Attorney: I'm sorry I

8749
05:41:13,848 --> 05:41:15,850
was just following the

8750
05:41:15,850 --> 05:41:17,852
instructions I got yesterday to

8751
05:41:17,852 --> 05:41:19,854
announce in objection early.

8752
05:41:19,854 --> 05:41:22,254
>> duly noted I apologize.

8753
05:41:24,392 --> 05:41:25,593
[Laughter].

8754
05:41:25,593 --> 05:41:26,394
I'm just trying to play along

8755
05:41:26,394 --> 05:41:27,629
here.

8756
05:41:27,629 --> 05:41:28,796
>> Florida Rising: MR. CHAIRMAN

8757
05:41:28,796 --> 05:41:29,564
if I MAY have a moment

8758
05:41:29,564 --> 05:41:31,465
to confer

8759
05:41:31,465 --> 05:41:33,401
with MR. Whelan, questions to

8760
05:41:33,401 --> 05:41:34,903
see if he thinks they are

8761
05:41:34,903 --> 05:41:36,903
confidential or problematic.

8762
05:41:37,404 --> 05:41:39,373
>> Mike La Rosa,CHAIRMAN: if

8763
05:41:39,373 --> 05:41:42,373
that helps to be smoother

8764
05:42:14,475 --> 05:42:15,643
absolutely.

8765
05:42:15,643 --> 05:42:17,612
>> Florida Rising: thank you

8766
05:42:17,612 --> 05:42:19,714
MR. CHAIRMAN MAY I proceed.

8767
05:42:19,714 --> 05:42:21,649
>> teco Attorney: understand he

8768
05:42:21,649 --> 05:42:23,484
will ask very general question

8769
05:42:23,484 --> 05:42:24,652
will not identify specific

8770
05:42:24,652 --> 05:42:25,620
people. But he does want this

8771
05:42:25,620 --> 05:42:27,588
in the record.

8772
05:42:27,588 --> 05:42:29,457
As long as we not going to talk

8773
05:42:29,457 --> 05:42:30,591
about specific people in at the

8774
05:42:30,591 --> 05:42:30,792
hearing I guess we will be

8775
05:42:30,792 --> 05:42:32,792
okay.

8776
05:42:33,594 --> 05:42:33,828
>> Mike La Rosa,CHAIRMAN: let's

8777
05:42:33,828 --> 05:42:35,630
proceed.

8778
05:42:35,630 --> 05:42:38,300
>> Florida Rising: thank you

8779
05:42:38,499 --> 05:42:40,468
MR. CHAIRMAN this document does

8780
05:42:40,468 --> 05:42:41,302
contain become position of top

8781
05:42:41,302 --> 05:42:41,669
teco executives you

8782
05:42:41,669 --> 05:42:43,604
added up is

8783
05:42:43,604 --> 05:42:44,705
in the millions of dollars.

8784
05:42:44,705 --> 05:42:46,608
>> teco Witness: yes.

8785
05:42:46,608 --> 05:42:48,509
>> Florida Rising: in many

8786
05:42:48,509 --> 05:42:49,677
cases the bonus another

8787
05:42:49,677 --> 05:42:50,711
compensation exceed the base

8788
05:42:50,711 --> 05:42:52,613
salary depicted.

8789
05:42:52,613 --> 05:42:54,549
>> teco Witness: would have to

8790
05:42:54,549 --> 05:42:54,882
look line by line before I

8791
05:42:54,882 --> 05:42:56,617
confirm that.

8792
05:42:56,617 --> 05:42:58,319
>> teco Witness: would you

8793
05:42:58,319 --> 05:42:58,452
accept that subject object

8794
05:42:58,452 --> 05:43:00,421
.

8795
05:43:00,421 --> 05:43:02,423
>> Florida Rising: would do

8796
05:43:02,423 --> 05:43:04,425
except in many cases long-term

8797
05:43:04,425 --> 05:43:06,425
incentive compensation exceed

8798
05:43:06,427 --> 05:43:07,528
the short-term extent of

8799
05:43:07,528 --> 05:43:08,429
competition for those

8800
05:43:08,429 --> 05:43:09,630
executives.

8801
05:43:09,630 --> 05:43:11,432
>> teco Witness: yes that is

8802
05:43:11,432 --> 05:43:12,633
based on compensation

8803
05:43:12,633 --> 05:43:13,701
strategies to keep a long-term

8804
05:43:13,701 --> 05:43:15,603
focus for customers.

8805
05:43:15,603 --> 05:43:17,538
>> Florida Rising: thank you

8806
05:43:17,538 --> 05:43:17,805
that's all my questions MR.

8807
05:43:17,805 --> 05:43:19,805
CHAIRMAN.

8808
05:43:20,474 --> 05:43:21,943
>> Mike La Rosa,CHAIRMAN:

8809
05:43:21,943 --> 05:43:24,343
[Listing names] Sierra club.

8810
05:43:27,448 --> 05:43:29,448
>> no questions.

8811
05:43:32,530 --> 05:43:32,150
Walmart

8812
05:43:32,150 --> 05:43:34,150
.

8813
05:43:34,855 --> 05:43:34,954
>> no questions

8814
05:43:34,954 --> 05:43:36,924
.

8815
05:43:36,924 --> 05:43:38,392
>> Mike La Rosa,CHAIRMAN:

8816
05:43:38,392 --> 05:43:39,994
commissioners any questions?

8817
05:43:39,994 --> 05:43:42,994
Seeing no questions teco back

8818
05:43:43,865 --> 05:43:43,998
in your hands for redirect

8819
05:43:43,998 --> 05:43:45,966
.

8820
05:43:45,966 --> 05:43:47,502
>> teco Attorney: think you

8821
05:43:47,502 --> 05:43:49,300
want to thank you for taking

8822
05:43:49,300 --> 05:43:49,203
the time to be careful about

8823
05:43:49,203 --> 05:43:49,904
that.

8824
05:43:49,904 --> 05:43:51,272
I

8825
05:43:51,272 --> 05:43:53,400
appreciated very much for the

8826
05:43:53,400 --> 05:43:54,575
snack one question.

8827
05:43:54,575 --> 05:43:56,430
[Listing names] You were asked

8828
05:43:56,430 --> 05:43:57,645
about whether the company

8829
05:43:57,645 --> 05:43:59,645
executives were being

8830
05:44:01,470 --> 05:44:04,470
incentivized to grow rate base

8831
05:44:04,500 --> 05:44:06,120
do you remember that?

8832
05:44:06,120 --> 05:44:08,120
>> teco Witness: yes.

8833
05:44:13,227 --> 05:44:15,162
>> teco Attorney: you answered

8834
05:44:15,162 --> 05:44:16,129
in terms the balanced scorecard

8835
05:44:16,129 --> 05:44:17,998
is that correct.

8836
05:44:17,998 --> 05:44:18,232
>> teco Witness: that is

8837
05:44:18,232 --> 05:44:19,400
correct.

8838
05:44:19,400 --> 05:44:21,167
>> teco Attorney: that goal is

8839
05:44:21,167 --> 05:44:23,170
net income is not rate based.

8840
05:44:23,170 --> 05:44:23,638
>> teco Witness: yes it is

8841
05:44:23,638 --> 05:44:25,306
answered incorrectly.

8842
05:44:25,306 --> 05:44:26,340
>> teco Attorney: that is all

8843
05:44:26,340 --> 05:44:28,275
of our questions.

8844
05:44:28,275 --> 05:44:29,343
>> Mike La Rosa,CHAIRMAN: let's

8845
05:44:29,343 --> 05:44:31,178
move to the exhibits.

8846
05:44:31,178 --> 05:44:32,313
>> teco Attorney: tampa

8847
05:44:32,313 --> 05:44:33,180
electric would move exhibit

8848
05:44:33,180 --> 05:44:34,181
number 24).

8849
05:44:34,181 --> 05:44:35,383
> Mike La

8850
05:44:35,383 --> 05:44:37,251
Rosa,CHAIRMAN: any objections?

8851
05:44:37,251 --> 05:44:38,319
Seeing no objections show it

8852
05:44:38,319 --> 05:44:40,719
entered into the record.

8853
05:44:45,760 --> 05:44:45,993
Other exhibits?

8854
05:44:45,993 --> 05:44:47,795
>> 267.

8855
05:44:47,795 --> 05:44:48,996
>> Mike La Rosa,CHAIRMAN: any

8856
05:44:48,996 --> 05:44:50,932
objection seeing no let's show

8857
05:44:50,932 --> 05:44:52,800
that entered into the record.

8858
05:44:52,800 --> 05:44:53,801
>> Florida Rising: we have a

8859
05:44:53,801 --> 05:44:56,201
bit of a series.

8860
05:44:58,806 --> 05:45:00,806
Exhibits 513, 549, 553, 561,

8861
05:45:09,283 --> 05:45:11,283
653, 656, 657, 660, 700, 729,

8862
05:45:11,285 --> 05:45:13,285
and it 758,

8863
05:45:13,286 --> 05:45:16,286
>> Mike La Rosa,CHAIRMAN: any

8864
05:45:17,191 --> 05:45:17,290
objection

8865
05:45:17,290 --> 05:45:19,290
.

8866
05:45:19,427 --> 05:45:21,262
>> teco Attorney: we continue

8867
05:45:21,262 --> 05:45:23,297
to object to the detailed

8868
05:45:23,297 --> 05:45:24,265
compensation exhibit whatever

8869
05:45:24,265 --> 05:45:25,433
that one is.

8870
05:45:25,433 --> 05:45:26,634
770.

8871
05:45:26,634 --> 05:45:29,634
16 758 that would be the last

8872
05:45:33,574 --> 05:45:34,809
one.

8873
05:45:34,809 --> 05:45:36,744
>> teco Attorney: understand

8874
05:45:36,744 --> 05:45:38,579
that that has been ruled on but

8875
05:45:38,579 --> 05:45:40,715
I will continue to object.

8876
05:45:40,715 --> 05:45:42,480
>> Mike La Rosa,CHAIRMAN: let's

8877
05:45:42,480 --> 05:45:43,617
show it into the record.

8878
05:45:43,617 --> 05:45:44,500
Any other exhibits.

8879
05:45:44,500 --> 05:45:44,157
Seeing none

8880
05:45:44,157 --> 05:45:45,252
.

8881
05:45:45,252 --> 05:45:47,652
[Listing names] You are

8882
05:45:50,890 --> 05:45:52,920
excused.

8883
05:45:52,920 --> 05:45:53,894
I will hand it back over to you

8884
05:45:53,894 --> 05:45:53,991
for your next witness.

8885
05:45:53,991 --> 05:45:55,991
>

8886
05:45:56,430 --> 05:45:58,298
teco Attorney: tampa electric

8887
05:45:58,298 --> 05:45:58,393
calls

8888
05:45:58,393 --> 05:46:00,393
.

8889
05:46:13,947 --> 05:46:15,950
[Listing names] To the stand.

8890
05:46:15,950 --> 05:46:17,985
>> Mike La Rosa,CHAIRMAN: MS.

8891
05:46:17,985 --> 05:46:19,186
Fuentes I don't believe you had

8892
05:46:19,186 --> 05:46:21,121
been administered the oath

8893
05:46:21,121 --> 05:46:24,121
whenever you're ready we will

8894
05:46:45,790 --> 05:46:48,679
do that before you sit down.

8895
05:46:51,152 --> 05:46:53,154
Please raise your right hand.

8896
05:46:53,154 --> 05:46:54,388
do you swear and affirm the

8897
05:46:54,388 --> 05:46:56,257
testimony you are about to give

8898
05:46:56,257 --> 05:46:58,159
will be the truth the whole

8899
05:46:58,159 --> 05:46:58,358
truth and nothing but the

8900
05:46:58,358 --> 05:46:59,426
truth.

8901
05:46:59,426 --> 05:47:01,826
>> teco Witness: I do.

8902
05:47:02,196 --> 05:47:03,297
>> Mike La Rosa,CHAIRMAN: feel

8903
05:47:03,297 --> 05:47:04,165
free to have a seat and get

8904
05:47:04,165 --> 05:47:05,165
settled in.

8905
05:47:05,165 --> 05:47:07,165
Will turn it

8906
05:47:10,237 --> 05:47:11,338
over to teco when you're ready.

8907
05:47:11,338 --> 05:47:13,338
>> teco Attorney: good

8908
05:47:13,774 --> 05:47:16,774
afternoon would you state your

8909
05:47:16,810 --> 05:47:18,946
full name for the record.

8910
05:47:18,946 --> 05:47:20,847
>> Mike La Rosa,CHAIRMAN: moved

8911
05:47:20,847 --> 05:47:22,847
the microphone closer.

8912
05:47:22,849 --> 05:47:24,510
I'm sorry MS. Fuentes.

8913
05:47:24,510 --> 05:47:27,510
>> teco Attorney: who is your

8914
05:47:30,124 --> 05:47:31,191
current employer what is your

8915
05:47:31,191 --> 05:47:33,191
business address.

8916
05:47:33,227 --> 05:47:35,128
>> teco Witness: tampa electric

8917
05:47:35,128 --> 05:47:35,396
company 702 w. Franklin st.,

8918
05:47:35,396 --> 05:47:37,131
tampa, fl.

8919
05:47:37,131 --> 05:47:39,660
>> teco Attorney: did you

8920
05:47:39,660 --> 05:47:41,680
prepare and cause to be filed

8921
05:47:41,680 --> 05:47:43,370
this document in APRIL 2, 2024

8922
05:47:43,370 --> 05:47:45,370
prepared direct testimony

8923
05:47:55,115 --> 05:47:55,448
consisting of 22 pages

8924
05:47:55,448 --> 05:47:56,884
.

8925
05:47:56,884 --> 05:47:58,419
>> teco Witness: his I did.

8926
05:47:58,419 --> 05:47:58,885
>> teco Attorney: did you

8927
05:47:58,885 --> 05:47:59,687
prepare and cause

8928
05:47:59,687 --> 05:48:01,522
to be filed in

8929
05:48:01,522 --> 05:48:03,457
this docket on JULY 2, 2024

8930
05:48:03,457 --> 05:48:04,524
prepare rebuttal testimony

8931
05:48:04,524 --> 05:48:06,492
consisting of 13 pages.

8932
05:48:06,492 --> 05:48:07,394
>> teco Witness: kiss I did.

8933
05:48:07,394 --> 05:48:08,495
>> teco

8934
05:48:08,495 --> 05:48:09,697
Attorney: you have any

8935
05:48:09,697 --> 05:48:11,465
additions or corrections to

8936
05:48:11,465 --> 05:48:11,732
your prepared direct or

8937
05:48:11,732 --> 05:48:13,467
rebuttal.

8938
05:48:13,467 --> 05:48:15,235
>> teco Witness: yes I do.

8939
05:48:15,235 --> 05:48:16,804
>> teco Attorney: do you have

8940
05:48:16,804 --> 05:48:18,472
any additions or corrections to

8941
05:48:18,472 --> 05:48:18,772
your direct or rebuttal

8942
05:48:18,772 --> 05:48:19,773
testimony.

8943
05:48:19,773 --> 05:48:20,841
>> teco Witness: no.

8944
05:48:20,841 --> 05:48:21,842
Speed 11 about.

8945
05:48:21,842 --> 05:48:22,609
>> teco Attorney:

8946
05:48:22,609 --> 05:48:24,545
always

8947
05:48:24,545 --> 05:48:26,480
cultures aggression prepared in

8948
05:48:26,480 --> 05:48:27,681
your direct rebuttal testimony

8949
05:48:27,681 --> 05:48:29,616
would treasures be the same as

8950
05:48:29,616 --> 05:48:29,750
her insurance prepared therein

8951
05:48:29,750 --> 05:48:30,684
.

8952
05:48:30,684 --> 05:48:32,485
>> teco Witness: yes.

8953
05:48:32,485 --> 05:48:33,620
>> Gabriella

8954
05:48:33,620 --> 05:48:35,620
Passidomo,Commissioner: MR.

8955
05:48:37,737 --> 05:48:37,865
CHAIRMAN electric request the

8956
05:48:37,865 --> 05:48:38,725
direct rebuttal testimony be

8957
05:48:38,725 --> 05:48:40,394
entered into the record. MISS

8958
05:48:40,394 --> 05:48:40,694
Point as doom repair

8959
05:48:40,694 --> 05:48:42,629
request be

8960
05:48:42,629 --> 05:48:44,498
filed in your direct testimony

8961
05:48:44,498 --> 05:48:45,932
and exhibits marked lc 1

8962
05:48:45,932 --> 05:48:47,932
consisting of 11 documents.

8963
05:48:48,680 --> 05:48:51,680
>> teco Witness: yes I did.

8964
05:48:53,107 --> 05:48:54,241
>> teco Attorney: did you

8965
05:48:54,241 --> 05:48:55,642
prepare and costly filed

8966
05:48:55,642 --> 05:48:57,210
provisions to document number

8967
05:48:57,210 --> 05:48:58,245
32 exhibit lc 1 on MAY 21,

8968
05:48:58,245 --> 05:48:59,146
2024?

8969
05:48:59,146 --> 05:48:59,245
>> teco Witness: yes I did.

8970
05:48:59,245 --> 05:49:00,380
>

8971
05:49:00,380 --> 05:49:02,116
teco Attorney: did you prepare

8972
05:49:02,116 --> 05:49:03,584
and cause to be filed

8973
05:49:03,584 --> 05:49:05,385
replacement nonconfidential

8974
05:49:05,385 --> 05:49:07,121
pages for mfr schedule f7 and

8975
05:49:07,121 --> 05:49:08,288
f8 on MAY 21, 2024.

8976
05:49:08,288 --> 05:49:08,422
>> teco Witness: yes I did

8977
05:49:08,422 --> 05:49:10,422
.

8978
05:49:11,258 --> 05:49:12,393
>> teco Attorney: to prepare

8979
05:49:12,393 --> 05:49:15,393
and cause be filed rebuttal

8980
05:49:23,637 --> 05:49:25,639
testimony in exhibit marked lc

8981
05:49:25,639 --> 05:49:26,707
2 consisting seven documents.

8982
05:49:26,707 --> 05:49:28,675
>> teco Witness: yes.

8983
05:49:28,675 --> 05:49:30,610
>> teco Attorney: MR. CHAIRMAN

8984
05:49:30,610 --> 05:49:32,613
logic would note for the record

8985
05:49:32,613 --> 05:49:34,548
that exhibits lc one and lcm to

8986
05:49:34,548 --> 05:49:35,616
have been identified on the cl

8987
05:49:35,616 --> 05:49:37,616
as exhibits 25 and 146.

8988
05:49:37,650 --> 05:49:39,486
MS. Fuentes did you personally

8989
05:49:39,486 --> 05:49:40,820
discover an error on the

8990
05:49:40,820 --> 05:49:41,722
company's answer to

8991
05:49:41,722 --> 05:49:43,722
interrogatory number 177 and

8992
05:49:43,757 --> 05:49:45,492
this 12 set of interrogatories

8993
05:49:45,492 --> 05:49:48,492
as part of the content

8994
05:49:50,731 --> 05:49:50,898
identified as exhibit 212

8995
05:49:50,898 --> 05:49:51,965
.

8996
05:49:51,965 --> 05:49:53,965
>> teco Witness: yes.

8997
05:49:54,340 --> 05:49:55,869
>> teco Attorney: MR. CHAIRMAN

8998
05:49:55,869 --> 05:49:57,871
electric would ask that the

8999
05:49:57,871 --> 05:49:59,373
revised answer which is been

9000
05:49:59,373 --> 05:50:01,700
dissipated to all parties and

9001
05:50:01,700 --> 05:50:02,876
to the commissioners be marked

9002
05:50:02,876 --> 05:50:05,876
and entered into the record.

9003
05:50:09,383 --> 05:50:10,517
>> Mike La Rosa,CHAIRMAN: okay.

9004
05:50:10,517 --> 05:50:12,385
>> I want to note for the

9005
05:50:12,385 --> 05:50:13,587
record commissioners

9006
05:50:13,587 --> 05:50:15,987
interminably that is exhibit

9007
05:50:23,960 --> 05:50:24,364
838.

9008
05:50:24,364 --> 05:50:26,299
>> teco Attorney: this point as

9009
05:50:26,299 --> 05:50:29,102
we do summarize your prepared

9010
05:50:29,102 --> 05:50:31,102
and direct testimony.

9011
05:50:31,939 --> 05:50:33,730
>> teco Witness: good afternoon

9012
05:50:33,730 --> 05:50:34,908
commissioners. My direct

9013
05:50:34,908 --> 05:50:36,908
testimony explains tampa

9014
05:50:40,614 --> 05:50:41,882
electric's load forecasting

9015
05:50:41,882 --> 05:50:43,850
process in the methodologies

9016
05:50:43,850 --> 05:50:45,652
and assumptions that were used.

9017
05:50:45,652 --> 05:50:46,886
It also describes the load

9018
05:50:46,886 --> 05:50:48,822
forecast used in the companies

9019
05:50:48,822 --> 05:50:50,757
test your budget that supports

9020
05:50:50,757 --> 05:50:52,659
the request for a base rate

9021
05:50:52,659 --> 05:50:53,894
increase. It demonstrates that

9022
05:50:53,894 --> 05:50:54,861
the forecast are appropriate

9023
05:50:54,861 --> 05:50:56,830
and reasonable.

9024
05:50:56,830 --> 05:50:58,732
My rebuttal testimony explains

9025
05:50:58,732 --> 05:51:01,732
by the commission should not

9026
05:51:03,704 --> 05:51:05,605
adopt the office of public

9027
05:51:05,605 --> 05:51:07,574
counsel's proposal as it

9028
05:51:07,574 --> 05:51:09,576
relates to load forecast. Also

9029
05:51:09,576 --> 05:51:11,976
demonstrate that the company's

9030
05:51:12,479 --> 05:51:13,981
projected 2025 2026 and 2027

9031
05:51:13,981 --> 05:51:15,682
retail energy sales forecast

9032
05:51:15,682 --> 05:51:17,684
are appropriate and reasonable.

9033
05:51:17,684 --> 05:51:18,485
This concludes my summary thank

9034
05:51:18,485 --> 05:51:19,486
you.

9035
05:51:19,486 --> 05:51:20,620
>> Gabriella

9036
05:51:20,620 --> 05:51:22,389
Passidomo,Commissioner: tampa

9037
05:51:22,389 --> 05:51:24,789
electric would enter MS.

9038
05:51:26,493 --> 05:51:26,598
Pointers for testimony

9039
05:51:26,598 --> 05:51:28,595
.

9040
05:51:28,595 --> 05:51:29,830
>> opc: good afternoon would

9041
05:51:29,830 --> 05:51:33,430
make sure I get this correct

9042
05:51:38,672 --> 05:51:40,674
new world direct upload

9043
05:51:40,674 --> 05:51:41,675
research and forecasting for

9044
05:51:41,675 --> 05:51:42,809
temper electric.

9045
05:51:42,809 --> 05:51:43,430
>> teco Witness: that's

9046
05:51:43,430 --> 05:51:44,511
correct.

9047
05:51:44,511 --> 05:51:45,679
>> opc: one of the

9048
05:51:45,679 --> 05:51:46,913
many things

9049
05:51:46,913 --> 05:51:49,683
the temple object forecasts is

9050
05:51:49,683 --> 05:51:50,150
their expected energy sales.

9051
05:51:50,150 --> 05:51:51,752
>> teco Witness: yes.

9052
05:51:51,752 --> 05:51:53,720
>> opc: tampa electric use a

9053
05:51:53,720 --> 05:51:55,688
process called econometric is

9054
05:51:55,688 --> 05:51:57,157
physically adjusted and use

9055
05:51:57,157 --> 05:51:57,923
forecasting models to develop

9056
05:51:57,923 --> 05:51:59,693
the forecast.

9057
05:51:59,693 --> 05:51:59,926
>> teco Witness: that is

9058
05:51:59,926 --> 05:52:01,695
correct.

9059
05:52:01,695 --> 05:52:02,195
>> opc: believe you just

9060
05:52:02,195 --> 05:52:02,896
referred to this

9061
05:52:02,896 --> 05:52:04,698
but you're

9062
05:52:04,698 --> 05:52:06,733
worth it opc expert witness

9063
05:52:06,733 --> 05:52:07,701
testimony challenging certain

9064
05:52:07,701 --> 05:52:08,100
aspects of tampa

9065
05:52:08,100 --> 05:52:08,868
electric's

9066
05:52:08,868 --> 05:52:10,737
energy sales.

9067
05:52:10,737 --> 05:52:11,370
>> teco Witness: I am aware

9068
05:52:11,370 --> 05:52:12,772
that brian.

9069
05:52:12,772 --> 05:52:13,840
>> teco Attorney: opc

9070
05:52:13,840 --> 05:52:14,206
challenged out of model

9071
05:52:14,206 --> 05:52:15,575
adjustments

9072
05:52:15,575 --> 05:52:15,842
the temple it took

9073
05:52:15,842 --> 05:52:17,100
me

9074
05:52:17,100 --> 05:52:17,944
to the results of its energy

9075
05:52:17,944 --> 05:52:19,813
sales forecast.

9076
05:52:19,813 --> 05:52:21,815
That is your understanding.

9077
05:52:21,815 --> 05:52:22,182
>> teco Witness: that is my

9078
05:52:22,182 --> 05:52:23,950
understanding.

9079
05:52:23,950 --> 05:52:25,819
>> teco Attorney: if we can go

9080
05:52:25,819 --> 05:52:27,200
to mfr at five which would be

9081
05:52:27,200 --> 05:52:30,620
page the case and number number

9082
05:52:31,958 --> 05:52:34,958
would be j135 police j1325.

9083
05:52:38,632 --> 05:52:39,799
Please. Hopefully that is

9084
05:52:39,799 --> 05:52:43,399
showing up on the screen in

9085
05:52:45,305 --> 05:52:46,440
front of you.

9086
05:52:46,440 --> 05:52:47,507
Do you see it there.

9087
05:52:47,507 --> 05:52:49,442
>> teco Witness: yes.

9088
05:52:49,442 --> 05:52:51,277
>> opc: you might have a copy

9089
05:52:51,277 --> 05:52:51,511
whichever is easier for you to

9090
05:52:51,511 --> 05:52:53,346
look at.

9091
05:52:53,346 --> 05:52:56,946
>> teco Witness: let me go to

9092
05:53:04,758 --> 05:53:06,758
my copy.

9093
05:53:06,793 --> 05:53:07,561
>> teco Attorney: adjustment to

9094
05:53:07,561 --> 05:53:07,994
confirm that this

9095
05:53:07,994 --> 05:53:09,796
page within

9096
05:53:09,796 --> 05:53:10,130
the mfr is one that you

9097
05:53:10,130 --> 05:53:11,898
cosponsored.

9098
05:53:11,898 --> 05:53:13,867
>> teco Witness: yes it is.

9099
05:53:13,867 --> 05:53:15,802
>> teco Attorney: this page is

9100
05:53:15,802 --> 05:53:17,803
where the three out of model

9101
05:53:17,803 --> 05:53:19,806
adjustments that we were just

9102
05:53:19,806 --> 05:53:22,206
discussing are located within

9103
05:53:26,179 --> 05:53:27,314
tampa electric's petition and

9104
05:53:27,314 --> 05:53:29,215
mfr is that accurate.

9105
05:53:29,215 --> 05:53:31,117
>> teco Witness: this is where

9106
05:53:31,117 --> 05:53:32,252
the three separate forecasts

9107
05:53:32,252 --> 05:53:34,120
are we refer to them as

9108
05:53:34,120 --> 05:53:34,421
separate forecast versus an

9109
05:53:34,421 --> 05:53:36,222
adjustment.

9110
05:53:36,222 --> 05:53:38,910
>> teco Attorney: you would

9111
05:53:38,910 --> 05:53:39,225
agree if the commission accepts

9112
05:53:39,225 --> 05:53:41,126
some or all of these

9113
05:53:41,126 --> 05:53:42,295
adjustments the customers bills

9114
05:53:42,295 --> 05:53:43,530
would be higher than they

9115
05:53:43,530 --> 05:53:44,197
otherwise would be without

9116
05:53:44,197 --> 05:53:45,131
the

9117
05:53:45,131 --> 05:53:45,799
adjustment.

9118
05:53:45,799 --> 05:53:48,799
>> teco Witness: no I don't

9119
05:53:49,169 --> 05:53:51,169
agree with that.

9120
05:53:51,204 --> 05:53:54,908
That is just one piece of the

9121
05:53:54,908 --> 05:53:57,908
picture if these were removed

9122
05:53:58,645 --> 05:54:00,579
from the forecast it will have

9123
05:54:00,579 --> 05:54:01,414
an effect on other things as

9124
05:54:01,414 --> 05:54:03,414
well.

9125
05:54:03,783 --> 05:54:05,585
>> opc: ultimately the effect

9126
05:54:05,585 --> 05:54:07,420
that would have another things

9127
05:54:07,420 --> 05:54:10,223
would lead to customers paying

9128
05:54:10,223 --> 05:54:12,192
more than if they were to pay

9129
05:54:12,192 --> 05:54:13,426
without these adjustments do

9130
05:54:13,426 --> 05:54:13,593
agree with that?

9131
05:54:13,593 --> 05:54:15,161
>> teco

9132
05:54:15,161 --> 05:54:15,462
Witness: all other things

9133
05:54:15,462 --> 05:54:17,462
equal. Yes.

9134
05:54:21,401 --> 05:54:22,502
>> opc: if the commission were

9135
05:54:22,502 --> 05:54:24,403
to reject each of these

9136
05:54:24,403 --> 05:54:26,803
adjustments then that would

9137
05:54:41,855 --> 05:54:43,857
result in a reduction of the

9138
05:54:43,857 --> 05:54:45,258
2025 revenue requirement of $12

9139
05:54:45,258 --> 05:54:46,860
million to 2026 revenue

9140
05:54:46,860 --> 05:54:47,994
requirement of $21 in the 2027

9141
05:54:47,994 --> 05:54:48,228
revenue requirement of $26

9142
05:54:48,228 --> 05:54:49,950
million?

9143
05:54:49,950 --> 05:54:50,997
Is that correct?

9144
05:54:50,997 --> 05:54:51,964
>> teco Witness: those are his

9145
05:54:51,964 --> 05:54:53,867
estimates yes.

9146
05:54:53,867 --> 05:54:55,868
>> opc: you have any reason to

9147
05:54:55,868 --> 05:54:57,370
believe that those numbers are

9148
05:54:57,370 --> 05:54:58,872
inaccurate if the commission

9149
05:54:58,872 --> 05:54:59,172
were to reject those

9150
05:54:59,172 --> 05:55:01,410
adjustments.

9151
05:55:01,410 --> 05:55:01,875
>> teco Witness: yes I disagree

9152
05:55:01,875 --> 05:55:03,430
with.

9153
05:55:03,430 --> 05:55:04,440
[Listing names]'s analysis.

9154
05:55:04,440 --> 05:55:05,945
Strongly disagree.

9155
05:55:05,945 --> 05:55:07,113
Those adjustments that he is

9156
05:55:07,113 --> 05:55:09,490
referring to are actually what

9157
05:55:09,490 --> 05:55:10,984
we call exertion is forecasts

9158
05:55:10,984 --> 05:55:12,919
there are three forecasts that

9159
05:55:12,919 --> 05:55:14,421
would be very careless of the

9160
05:55:14,421 --> 05:55:15,540
company if we left them out of

9161
05:55:15,540 --> 05:55:17,540
our process.

9162
05:55:17,189 --> 05:55:18,958
The conservation savings is a

9163
05:55:18,958 --> 05:55:20,960
piece that we have been

9164
05:55:20,960 --> 05:55:21,961
adjusting our forecast by for

9165
05:55:21,961 --> 05:55:23,430
probably 30 years.

9166
05:55:23,430 --> 05:55:25,131
It's been approved in every

9167
05:55:25,131 --> 05:55:26,966
rate proceeding the electric

9168
05:55:26,966 --> 05:55:28,100
vehicle adjustment he is

9169
05:55:28,100 --> 05:55:30,690
wanting to exclude in the

9170
05:55:30,690 --> 05:55:31,971
rooftop solar forecast that he

9171
05:55:31,971 --> 05:55:33,473
is wanting to exclude have also

9172
05:55:33,473 --> 05:55:34,807
been in all of our forecasts

9173
05:55:34,807 --> 05:55:36,420
for 10 years.

9174
05:55:36,420 --> 05:55:37,911
They have been approved in

9175
05:55:37,911 --> 05:55:39,846
prior rate cases as well. All

9176
05:55:39,846 --> 05:55:41,147
utilities in florida and

9177
05:55:41,147 --> 05:55:44,147
throughout the nation if they

9178
05:55:47,954 --> 05:55:49,155
have the electric vehicles and

9179
05:55:49,155 --> 05:55:51,230
rooftop solar within the

9180
05:55:51,230 --> 05:55:52,125
service territory they have to

9181
05:55:52,125 --> 05:55:54,930
forecast them. There is

9182
05:55:54,930 --> 05:55:55,962
absolutely no reason to exclude

9183
05:55:55,962 --> 05:55:56,229
them from the forecasted

9184
05:55:56,229 --> 05:55:58,229
results.

9185
05:55:59,199 --> 05:56:00,330
>> opc: understand you disagree

9186
05:56:00,330 --> 05:56:01,234
with.

9187
05:56:01,234 --> 05:56:03,360
[Listing names] But my question

9188
05:56:03,360 --> 05:56:04,437
is the numbers that he has

9189
05:56:04,437 --> 05:56:05,671
associated with the 2025-

9190
05:56:05,671 --> 05:56:07,640
2026-2027 testers as being the

9191
05:56:07,640 --> 05:56:09,575
amount the revenue requirement

9192
05:56:09,575 --> 05:56:11,443
would be reduced by you dispute

9193
05:56:11,443 --> 05:56:12,411
that those numbers are the

9194
05:56:12,411 --> 05:56:12,512
correct numbers if

9195
05:56:12,512 --> 05:56:14,481
the

9196
05:56:14,481 --> 05:56:14,781
commission were to reject the

9197
05:56:14,781 --> 05:56:16,616
adjustment.

9198
05:56:16,616 --> 05:56:20,216
>> teco Witness: his math is a

9199
05:56:22,255 --> 05:56:23,488
very high level calculation. He

9200
05:56:23,488 --> 05:56:25,458
just takes a composite rate.

9201
05:56:25,458 --> 05:56:27,327
And multiplies it by the energy

9202
05:56:27,327 --> 05:56:28,494
to get to those numbers if it

9203
05:56:28,494 --> 05:56:30,296
was done with the normal

9204
05:56:30,296 --> 05:56:31,697
process using building

9205
05:56:31,697 --> 05:56:31,965
determinants it could be

9206
05:56:31,965 --> 05:56:33,965
different.

9207
05:56:35,434 --> 05:56:37,437
>> opc: I need a

9208
05:56:37,437 --> 05:56:39,472
yes or no do you agree with the

9209
05:56:39,472 --> 05:56:39,705
numbers or do disagree with the

9210
05:56:39,705 --> 05:56:41,473
numbers.

9211
05:56:41,473 --> 05:56:42,608
>> teco Witness: no I don't

9212
05:56:42,608 --> 05:56:43,642
believe there are hundred

9213
05:56:43,642 --> 05:56:45,578
percent accurate.

9214
05:56:45,578 --> 05:56:47,480
>> opc: regarding the eb sales

9215
05:56:47,480 --> 05:56:49,482
adjustment if the eb sales were

9216
05:56:49,482 --> 05:56:51,483
under stated that would have

9217
05:56:51,483 --> 05:56:53,519
implications for the test your

9218
05:56:53,519 --> 05:56:54,720
revenue requirements are

9219
05:56:54,720 --> 05:56:56,622
failing to capture the impact

9220
05:56:56,622 --> 05:56:58,524
that eb growth would have been

9221
05:56:58,524 --> 05:57:01,524
company load is that accurate.

9222
05:57:04,797 --> 05:57:06,797
>> teco Witness: yes.

9223
05:57:06,833 --> 05:57:08,834
The ev sales adjustment relies

9224
05:57:08,834 --> 05:57:10,300
on assumptions regarding future

9225
05:57:10,300 --> 05:57:13,300
penetration levels of ev is

9226
05:57:14,440 --> 05:57:14,641
that correct

9227
05:57:14,641 --> 05:57:15,807
.

9228
05:57:15,807 --> 05:57:17,610
>> teco Witness: yes the ev

9229
05:57:17,610 --> 05:57:18,778
forecast relies on that.

9230
05:57:18,778 --> 05:57:19,579
>> opc: you agree that the

9231
05:57:19,579 --> 05:57:20,746
tampa area

9232
05:57:20,746 --> 05:57:22,749
is one of the fastest

9233
05:57:22,749 --> 05:57:24,617
growing regions in the country

9234
05:57:24,617 --> 05:57:26,180
with one of the fastest growing

9235
05:57:26,180 --> 05:57:27,720
states in the country.

9236
05:57:27,720 --> 05:57:28,870
>> teco Witness: I would agree

9237
05:57:28,870 --> 05:57:29,789
with that.

9238
05:57:29,789 --> 05:57:31,624
>> opc: the company predicts

9239
05:57:31,624 --> 05:57:32,625
customer growth of

9240
05:57:32,625 --> 05:57:33,826
approximately 3%.

9241
05:57:33,826 --> 05:57:36,826
>> teco Witness: no not 3% that

9242
05:57:40,933 --> 05:57:42,680
is too high.

9243
05:57:42,680 --> 05:57:43,970
>> opc: what is the number.

9244
05:57:43,970 --> 05:57:45,104
>> teco Witness: we are

9245
05:57:45,104 --> 05:57:47,600
projecting customer growth

9246
05:57:47,600 --> 05:57:48,141
around 1.8% over the next few

9247
05:57:48,141 --> 05:57:49,108
years over 10 years I believe

9248
05:57:49,108 --> 05:57:50,943
is closer to 1.4%.

9249
05:57:50,943 --> 05:57:52,780
>> opc: would you greet the

9250
05:57:52,780 --> 05:57:53,946
customer growth has been

9251
05:57:53,946 --> 05:57:55,810
significant enough to at least

9252
05:57:55,810 --> 05:57:56,949
partially offset higher

9253
05:57:56,949 --> 05:57:57,316
depreciation and all in them

9254
05:57:57,316 --> 05:57:58,217
expense and net

9255
05:57:58,217 --> 05:57:58,985
income year to

9256
05:57:58,985 --> 05:58:00,186
date.

9257
05:58:00,186 --> 05:58:00,520
>> teco Witness: I don't know

9258
05:58:00,520 --> 05:58:02,155
the

9259
05:58:02,155 --> 05:58:03,956
answer to that they'll be

9260
05:58:03,956 --> 05:58:05,956
best answered by.

9261
05:58:08,961 --> 05:58:10,961
[Listing names].

9262
05:58:12,165 --> 05:58:14,167
>> opc: 2017 is the only time

9263
05:58:14,167 --> 05:58:16,168
the company has reported sales

9264
05:58:16,168 --> 05:58:16,402
decrease in the last decade.

9265
05:58:16,402 --> 05:58:18,402
Correct?

9266
05:58:18,771 --> 05:58:21,771
>> teco Witness: I would have

9267
05:58:22,410 --> 05:58:22,942
to subject to check I will

9268
05:58:22,942 --> 05:58:24,942
agree.

9269
05:58:27,913 --> 05:58:28,948
>> opc: are you familiar with

9270
05:58:28,948 --> 05:58:30,683
the decrease in 2017?

9271
05:58:30,683 --> 05:58:33,683
>> teco Witness: I have to

9272
05:58:33,986 --> 05:58:36,386
refer to the graph.

9273
05:58:44,797 --> 05:58:46,699
>> opc: let me ask you a

9274
05:58:46,699 --> 05:58:47,867
question if you need to refer

9275
05:58:47,867 --> 05:58:49,702
to something let me know. Do

9276
05:58:49,702 --> 05:58:50,837
agree the forecasted sales

9277
05:58:50,837 --> 05:58:52,772
decreased in this case is

9278
05:58:52,772 --> 05:58:53,873
almost 10 times larger than the

9279
05:58:53,873 --> 05:58:55,873
2017 sales decrease?

9280
05:58:55,875 --> 05:58:57,810
>> teco Witness: the decrease

9281
05:58:57,810 --> 05:58:59,712
in again would have to see some

9282
05:58:59,712 --> 05:58:59,912
numbers to be able to confirm

9283
05:58:59,912 --> 05:59:01,912
that.

9284
05:59:04,160 --> 05:59:07,160
>> opc: with regard to usage

9285
05:59:11,323 --> 05:59:13,159
per customer has that climbed

9286
05:59:13,159 --> 05:59:15,126
by.6% on an annual average

9287
05:59:15,126 --> 05:59:16,262
basis between 2013 and 2023?

9288
05:59:16,262 --> 05:59:18,262
>> teco Witness: yes.

9289
05:59:19,365 --> 05:59:20,833
>> opc: is in this

9290
05:59:20,833 --> 05:59:21,934
significantly less than the

9291
05:59:21,934 --> 05:59:23,903
customers forecasted forecasted

9292
05:59:23,903 --> 05:59:25,903
decrease of 3.9% in 2024?

9293
05:59:28,307 --> 05:59:29,475
>> teco Witness: yes but you

9294
05:59:29,475 --> 05:59:31,344
are comparing apples and

9295
05:59:31,344 --> 05:59:33,312
oranges we are talking about

9296
05:59:33,312 --> 05:59:35,712
our historical average use

9297
05:59:36,716 --> 05:59:38,384
decline really without the

9298
05:59:38,384 --> 05:59:41,984
impacts of whether if you look

9299
05:59:42,355 --> 05:59:43,956
at the forecast for 2024 and

9300
05:59:43,956 --> 05:59:47,556
beyond it is based on normal

9301
05:59:48,260 --> 05:59:50,260
weather.

9302
05:59:50,290 --> 05:59:52,429
Decline your specifically talk

9303
05:59:52,564 --> 05:59:54,567
about is from 2023 which was a

9304
05:59:54,567 --> 05:59:57,567
very hot year. The forecast

9305
05:59:58,137 --> 05:59:59,272
transitions to what is called

9306
05:59:59,272 --> 06:00:01,107
what is based on normal

9307
06:00:01,107 --> 06:00:03,107
weather.

9308
06:00:03,142 --> 06:00:07,342
It is kind of apples to oranges

9309
06:00:10,182 --> 06:00:11,350
comparison.

9310
06:00:11,350 --> 06:00:13,185
I do have in my rebuttal

9311
06:00:13,185 --> 06:00:14,320
testimony graph that

9312
06:00:14,320 --> 06:00:16,320
illustrates this well.

9313
06:00:16,588 --> 06:00:20,788
I think it is in the cel

9314
06:00:22,695 --> 06:00:23,829
exhibit as well 146.

9315
06:00:23,829 --> 06:00:25,531
>> opc: the answer to that

9316
06:00:25,531 --> 06:00:28,531
question is you disagree that

9317
06:00:30,970 --> 06:00:32,970
the.6 decrease between 2023

9318
06:00:39,412 --> 06:00:40,612
and 2023 is significantly less

9319
06:00:40,612 --> 06:00:42,614
then the company's forecasted

9320
06:00:42,614 --> 06:00:43,916
usage per customer decrease of

9321
06:00:43,916 --> 06:00:45,916
3.0% in 2024.

9322
06:00:45,918 --> 06:00:47,954
>> teco Witness: obviously the

9323
06:00:47,954 --> 06:00:49,155
numbers are accurate but what

9324
06:00:49,155 --> 06:00:51,900
I'm saying is the comparison

9325
06:00:51,900 --> 06:00:53,250
that you are making is really

9326
06:00:53,250 --> 06:00:54,393
apples to oranges comparison.

9327
06:00:54,393 --> 06:00:56,295
>> opc: I'm not sure if you

9328
06:00:56,295 --> 06:00:58,197
were in the room listening but

9329
06:00:58,197 --> 06:00:59,364
if you could try to answer each

9330
06:00:59,364 --> 06:01:01,200
question yes or no and then

9331
06:01:01,200 --> 06:01:01,434
explain if you feel like you

9332
06:01:01,434 --> 06:01:03,269
need to.

9333
06:01:03,269 --> 06:01:04,537
It's important to try to get

9334
06:01:04,537 --> 06:01:05,604
the answer.

9335
06:01:05,604 --> 06:01:07,604
>> teco Witness: yes.

9336
06:01:09,775 --> 06:01:11,100
>> opc: thank you.

9337
06:01:11,100 --> 06:01:15,810
If we could can we go to page 8

9338
06:01:21,354 --> 06:01:22,521
of your rebuttal testimony?

9339
06:01:22,521 --> 06:01:26,121
I don't have the case center

9340
06:01:30,296 --> 06:01:31,397
number here.

9341
06:01:31,397 --> 06:01:33,397
>> teco Witness: okay.

9342
06:01:37,569 --> 06:01:39,505
>> opc: on line 7-10 you

9343
06:01:39,505 --> 06:01:40,906
mentioned load forecasters rely

9344
06:01:40,906 --> 06:01:43,609
on normal or expected whether

9345
06:01:43,609 --> 06:01:43,909
in terms of degrees.

9346
06:01:43,909 --> 06:01:45,909
do see this.

9347
06:01:46,879 --> 06:01:46,972
>> teco Witness: yes I do

9348
06:01:46,972 --> 06:01:48,972
.

9349
06:01:51,150 --> 06:01:52,318
>> opc: could you define what

9350
06:01:52,318 --> 06:01:54,320
the company defines is normal

9351
06:01:54,320 --> 06:01:55,254
or expected whether in terms of

9352
06:01:55,254 --> 06:01:57,222
degree days.

9353
06:01:57,222 --> 06:01:58,424
>> teco Witness: forecaster has

9354
06:01:58,424 --> 06:01:59,358
to rely on some assumptions for

9355
06:01:59,358 --> 06:02:01,193
the future.

9356
06:02:01,193 --> 06:02:03,195
The future whether the

9357
06:02:03,195 --> 06:02:04,797
seasonality throughout the

9358
06:02:04,797 --> 06:02:05,998
year.

9359
06:02:05,998 --> 06:02:07,900
Etc.. Since nobody can really

9360
06:02:07,900 --> 06:02:10,300
project accurately the weather

9361
06:02:11,137 --> 06:02:12,972
that far with the forecasters

9362
06:02:12,972 --> 06:02:14,673
do israelite history.

9363
06:02:14,673 --> 06:02:16,509
In the most common period of

9364
06:02:16,509 --> 06:02:16,709
time to use is the past 20

9365
06:02:16,709 --> 06:02:18,709
years.

9366
06:02:20,579 --> 06:02:21,514
Although florida utilities are

9367
06:02:21,514 --> 06:02:24,514
using 20 years or more I

9368
06:02:34,927 --> 06:02:36,862
believe one might use one

9369
06:02:36,862 --> 06:02:38,960
utility might use 30 years.

9370
06:02:38,960 --> 06:02:39,965
Nobody is using less than 20

9371
06:02:39,965 --> 06:02:42,670
years. What we do is we use a

9372
06:02:42,670 --> 06:02:43,969
20 year period that represents

9373
06:02:43,969 --> 06:02:45,871
to us what normal weather will

9374
06:02:45,871 --> 06:02:46,172
be and abuse of that in our

9375
06:02:46,172 --> 06:02:47,873
projections.

9376
06:02:47,873 --> 06:02:49,800
>> opc: thank you.

9377
06:02:49,800 --> 06:02:50,943
Not true that the number of

9378
06:02:50,943 --> 06:02:52,878
cooling degree days during the

9379
06:02:52,878 --> 06:02:54,846
years 2015-2023 the past nine

9380
06:02:54,846 --> 06:02:55,948
years is higher than during the

9381
06:02:55,948 --> 06:02:56,181
remainder of the 20 year

9382
06:02:56,181 --> 06:02:58,116
period.

9383
06:02:58,116 --> 06:02:58,984
>> teco Witness: I would agree

9384
06:02:58,984 --> 06:03:00,984
with that.

9385
06:03:01,520 --> 06:03:02,688
>> opc: again by late exhibit

9386
06:03:02,688 --> 06:03:04,623
illustrates that as well that

9387
06:03:04,623 --> 06:03:08,223
is document number six it is

9388
06:03:08,694 --> 06:03:10,694
also cel exhibit 216.

9389
06:03:10,796 --> 06:03:14,396
>> opc: just for the record bc

9390
06:03:19,138 --> 06:03:20,405
that identifying.

9391
06:03:20,405 --> 06:03:22,206
If you could turn to page 10 of

9392
06:03:22,206 --> 06:03:24,206
your rebuttal testimony.

9393
06:03:30,883 --> 06:03:32,818
On

9394
06:03:32,818 --> 06:03:33,953
lines 824 you dispute.

9395
06:03:33,953 --> 06:03:35,190
[Listing names] Conclusion that

9396
06:03:35,190 --> 06:03:36,955
a forecasting model has a

9397
06:03:36,955 --> 06:03:39,355
history of understating energy

9398
06:03:40,292 --> 06:03:42,294
sales productions you state

9399
06:03:42,294 --> 06:03:44,162
that you claim that to assess

9400
06:03:44,162 --> 06:03:46,164
the accuracy and reliability of

9401
06:03:46,164 --> 06:03:48,166
your models it would be more

9402
06:03:48,166 --> 06:03:49,702
reasonable to compare the

9403
06:03:49,702 --> 06:03:51,303
company's prior forecasts to

9404
06:03:51,303 --> 06:03:53,205
whether normalized sales

9405
06:03:53,205 --> 06:03:54,306
whether is that an accurate

9406
06:03:54,306 --> 06:03:55,206
characterization of your

9407
06:03:55,206 --> 06:03:56,375
testimony.

9408
06:03:56,375 --> 06:03:58,310
>> teco Witness: yes it is.

9409
06:03:58,310 --> 06:04:00,112
>> opc: on pages four and five

9410
06:04:00,112 --> 06:04:00,279
so lines of 15-25 then on to

9411
06:04:00,279 --> 06:04:02,214
the

9412
06:04:02,214 --> 06:04:03,749
next page I'm sorry what page.

9413
06:04:03,749 --> 06:04:06,749
>> opc: starting at page 4 line

9414
06:04:06,952 --> 06:04:08,854
15-page 5 line 3 you state

9415
06:04:08,854 --> 06:04:10,880
that the purpose of the

9416
06:04:10,880 --> 06:04:13,250
forecasting model is to support

9417
06:04:13,250 --> 06:04:14,893
rate case proceedings as well

9418
06:04:14,893 --> 06:04:16,929
as a public plan for future

9419
06:04:16,929 --> 06:04:17,963
generation and infrastructure

9420
06:04:17,963 --> 06:04:19,640
needs that correct?

9421
06:04:19,640 --> 06:04:19,999
>> teco

9422
06:04:19,999 --> 06:04:21,999
Witness: yes.

9423
06:04:25,200 --> 06:04:26,906
>> opc: would you agree the

9424
06:04:26,906 --> 06:04:28,140
prices customers pay for

9425
06:04:28,140 --> 06:04:30,420
electricity as well as utility

9426
06:04:30,420 --> 06:04:31,977
system for liability is in part

9427
06:04:31,977 --> 06:04:33,412
dependent on customer's actual

9428
06:04:33,412 --> 06:04:36,412
usage and those given years?

9429
06:04:40,685 --> 06:04:41,886
>> teco Witness: no not 100%.

9430
06:04:41,886 --> 06:04:44,857
>> teco Witness: in part would

9431
06:04:44,857 --> 06:04:46,857
you agree.

9432
06:04:57,236 --> 06:04:59,236
In part.

9433
06:04:59,238 --> 06:05:00,405
>> opc: this is somewhat of a

9434
06:05:00,405 --> 06:05:02,241
more general question would you

9435
06:05:02,241 --> 06:05:04,243
agree if a forecasting model

9436
06:05:04,243 --> 06:05:05,411
I'm not speaking about anything

9437
06:05:05,411 --> 06:05:06,311
specific.

9438
06:05:06,311 --> 06:05:07,445
As far as what tampa uses but

9439
06:05:07,445 --> 06:05:09,247
in general if a forecasting

9440
06:05:09,247 --> 06:05:10,716
model is consistently

9441
06:05:10,716 --> 06:05:12,484
inaccurate and at the same

9442
06:05:12,484 --> 06:05:14,252
directions meaning consistently

9443
06:05:14,252 --> 06:05:16,221
always overestimating or

9444
06:05:16,221 --> 06:05:18,221
submitting something, when

9445
06:05:18,223 --> 06:05:20,225
compared to the actuals it's

9446
06:05:20,225 --> 06:05:21,325
reasonable to question the

9447
06:05:21,325 --> 06:05:23,228
accuracy of that model?

9448
06:05:23,228 --> 06:05:24,263
>> teco Witness: I would

9449
06:05:24,263 --> 06:05:24,362
disagree with that.

9450
06:05:24,362 --> 06:05:26,231
Ou

9451
06:05:26,231 --> 06:05:28,631
actually in forecasting pickups

9452
06:05:29,867 --> 06:05:31,671
the weather has such an impact

9453
06:05:31,671 --> 06:05:33,605
on your actual usage to

9454
06:05:33,605 --> 06:05:34,706
understand the accuracy of your

9455
06:05:34,706 --> 06:05:36,608
bottles which are in a

9456
06:05:36,608 --> 06:05:38,760
normalized basis and to

9457
06:05:38,760 --> 06:05:39,711
understand if there is any

9458
06:05:39,711 --> 06:05:41,479
other underlying trends that

9459
06:05:41,479 --> 06:05:43,315
could be influencing customers

9460
06:05:43,315 --> 06:05:46,915
usage you have to remove the

9461
06:05:48,186 --> 06:05:50,222
impacts of whether we call that

9462
06:05:50,222 --> 06:05:52,191
the weather normalization. What

9463
06:05:52,191 --> 06:05:53,358
we do is look at the weather

9464
06:05:53,358 --> 06:05:55,193
normalization trends

9465
06:05:55,193 --> 06:05:58,193
historically and it is very

9466
06:05:59,970 --> 06:06:00,599
consistent with our forecast.

9467
06:06:00,599 --> 06:06:03,267
I just want to add one more

9468
06:06:03,267 --> 06:06:05,137
thing. I agree and understand

9469
06:06:05,137 --> 06:06:07,720
what you're saying about our

9470
06:06:07,720 --> 06:06:09,410
forecast being over or too low

9471
06:06:09,410 --> 06:06:10,242
for the past nine years.

9472
06:06:10,242 --> 06:06:11,910
That is strictly a result of

9473
06:06:11,910 --> 06:06:13,910
the weather.

9474
06:06:16,470 --> 06:06:19,684
If we were to show you what the

9475
06:06:19,684 --> 06:06:21,684
weather normalized accuracy

9476
06:06:21,686 --> 06:06:25,286
which we do somewhere we are

9477
06:06:26,425 --> 06:06:27,592
over and under it is not like

9478
06:06:27,592 --> 06:06:29,428
we are consistently over and

9479
06:06:29,428 --> 06:06:30,595
over the past 10 years are

9480
06:06:30,595 --> 06:06:33,595
accuracy has been a tense 1%

9481
06:06:33,965 --> 06:06:34,966
are forecast on the weather

9482
06:06:34,966 --> 06:06:35,233
normalized basis has been very

9483
06:06:35,233 --> 06:06:36,702
accurate.

9484
06:06:36,702 --> 06:06:41,502
It is not skewed to one side or

9485
06:06:42,107 --> 06:06:43,274
the other.

9486
06:06:43,274 --> 06:06:45,109
>> opc: even though it always

9487
06:06:45,109 --> 06:06:46,111
results in always

9488
06:06:46,111 --> 06:06:47,278
overestimating or

9489
06:06:47,278 --> 06:06:49,114
underestimating the same data?

9490
06:06:49,114 --> 06:06:50,615
>> teco Witness: not on the

9491
06:06:50,615 --> 06:06:51,882
weather delays basis that is

9492
06:06:51,882 --> 06:06:53,840
that always the same.

9493
06:06:53,840 --> 06:06:54,920
You have to realize you need to

9494
06:06:54,920 --> 06:06:56,922
break your forecast down.

9495
06:06:56,922 --> 06:06:58,490
residential forecast is what

9496
06:06:58,490 --> 06:07:00,492
has been driving our work has

9497
06:07:00,492 --> 06:07:04,692
to be on the low side because

9498
06:07:05,563 --> 06:07:06,798
that is the most the weather

9499
06:07:06,798 --> 06:07:08,700
sensitive sector that we have.

9500
06:07:08,700 --> 06:07:11,503
It has been hot and have used

9501
06:07:11,503 --> 06:07:13,572
more but if you were to look at

9502
06:07:13,572 --> 06:07:15,374
the commercial and industrial

9503
06:07:15,374 --> 06:07:16,608
our non-residential and

9504
06:07:16,608 --> 06:07:18,477
governmental they eventually

9505
06:07:18,477 --> 06:07:18,677
are forecast have been too

9506
06:07:18,677 --> 06:07:19,878
high.

9507
06:07:19,878 --> 06:07:21,713
>> opc: looking at the accuracy

9508
06:07:21,713 --> 06:07:24,713
speaking of accuracy of the

9509
06:07:27,185 --> 06:07:29,121
companies forecasting from MAY

9510
06:07:29,121 --> 06:07:30,222
2023 until APRIL 2024 each

9511
06:07:30,222 --> 06:07:31,356
forecast has been under

9512
06:07:31,356 --> 06:07:32,390
forecasted in total correct.

9513
06:07:32,390 --> 06:07:33,225
>> teco Witness: you

9514
06:07:33,225 --> 06:07:34,426
have

9515
06:07:34,426 --> 06:07:35,694
someplace I can.

9516
06:07:35,694 --> 06:07:37,696
>> opc: this is a florida

9517
06:07:37,696 --> 06:07:38,290
rising exhibit if I can refer

9518
06:07:38,290 --> 06:07:39,831
to that one?

9519
06:07:39,831 --> 06:07:40,865
Florida rising 120 which is

9520
06:07:40,865 --> 06:07:42,865
during exhibit 580.

9521
06:07:49,874 --> 06:07:51,874
>> opc: we

9522
06:08:00,585 --> 06:08:01,820
are pulling it up.

9523
06:08:01,820 --> 06:08:03,788
The bottom line here at the

9524
06:08:03,788 --> 06:08:05,723
totals for each of the customer

9525
06:08:05,723 --> 06:08:07,920
average use and energy sales

9526
06:08:07,920 --> 06:08:08,660
forecast each of those were

9527
06:08:08,660 --> 06:08:10,562
under forecasted correct?

9528
06:08:10,562 --> 06:08:11,762
>>

9529
06:08:11,762 --> 06:08:13,632
teco Witness: you are talking

9530
06:08:13,632 --> 06:08:16,320
of the total line?

9531
06:08:18,690 --> 06:08:20,472
Yes by 2/10 of a percent.

9532
06:08:20,472 --> 06:08:21,673
>> opc: that is underestimated

9533
06:08:21,673 --> 06:08:25,273
that is what the graph means.

9534
06:08:25,643 --> 06:08:27,579
>> teco Witness: if you look at

9535
06:08:27,579 --> 06:08:31,179
the piece some are under some

9536
06:08:31,316 --> 06:08:33,218
are over but to be off by 2/10

9537
06:08:33,218 --> 06:08:33,484
of a percent is a very good

9538
06:08:33,484 --> 06:08:35,286
forecast.

9539
06:08:35,286 --> 06:08:36,855
>> opc: you do agree there were

9540
06:08:36,855 --> 06:08:38,855
offspring nothing further.

9541
06:08:41,793 --> 06:08:43,828
>> Florida Rising: thank you

9542
06:08:43,828 --> 06:08:45,828
MR. CHAIRMAN.

9543
06:08:47,866 --> 06:08:49,000
Good afternoon MS. Boyd says

9544
06:08:49,000 --> 06:08:50,869
good to see you again.

9545
06:08:50,869 --> 06:08:51,136
>> teco Witness: good

9546
06:08:51,136 --> 06:08:53,300
afternoon.

9547
06:08:53,300 --> 06:08:55,500
>> Florida Rising: to start off

9548
06:08:55,500 --> 06:08:56,908
really quick I want to go over

9549
06:08:56,908 --> 06:08:58,420
the revisions to your door

9550
06:08:58,420 --> 06:09:00,442
response the newly filed

9551
06:09:00,579 --> 06:09:01,746
response.

9552
06:09:01,746 --> 06:09:03,581
I just want to make sure I'm

9553
06:09:03,581 --> 06:09:05,584
reading it right the basically

9554
06:09:05,584 --> 06:09:07,919
real changes here are that the

9555
06:09:07,919 --> 06:09:09,200
difference also minus column on

9556
06:09:09,200 --> 06:09:12,200
average is going from the

9557
06:09:15,526 --> 06:09:16,727
original 153 to 539?

9558
06:09:16,727 --> 06:09:19,727
>> teco Witness: what are we

9559
06:09:20,899 --> 06:09:20,999
looking at

9560
06:09:20,999 --> 06:09:22,999
.

9561
06:09:23,000 --> 06:09:24,169
>> Florida Rising: and looking

9562
06:09:24,169 --> 06:09:27,169
at a comparison of exhibit 212

9563
06:09:30,942 --> 06:09:32,942
and exhibit a 38?

9564
06:09:32,944 --> 06:09:34,179
Maybe the right way to do this

9565
06:09:34,179 --> 06:09:37,779
would be to pull up master

9566
06:09:39,150 --> 06:09:42,150
number 38210 if you can refer

9567
06:09:42,787 --> 06:09:43,855
to the updated copy.

9568
06:09:43,855 --> 06:09:45,855
Which would be 838.

9569
06:09:51,962 --> 06:09:53,962
>> teco

9570
06:09:55,433 --> 06:09:57,468
Witness: I'm sorry I didn't

9571
06:09:57,468 --> 06:09:58,670
know we were talking about my

9572
06:09:58,670 --> 06:09:59,304
revised one.

9573
06:09:59,304 --> 06:10:01,704
>> Florida Rising: I apologize

9574
06:10:02,407 --> 06:10:05,900
I'm just trying to get a feel

9575
06:10:05,900 --> 06:10:06,978
for the changes. If you look at

9576
06:10:06,978 --> 06:10:08,813
the difference: there is a bold

9577
06:10:08,813 --> 06:10:11,813
number at the bottom for

9578
06:10:18,757 --> 06:10:19,991
average.

9579
06:10:19,991 --> 06:10:20,992
The original number was 153 now

9580
06:10:20,992 --> 06:10:21,993
it is 539.

9581
06:10:21,993 --> 06:10:23,895
>> teco Witness: yes.

9582
06:10:23,895 --> 06:10:25,797
>> Florida Rising: the percent

9583
06:10:25,797 --> 06:10:26,931
difference: the same bold

9584
06:10:26,931 --> 06:10:29,667
number for average went from

9585
06:10:29,667 --> 06:10:31,667
.08% to 2.8%.

9586
06:10:31,669 --> 06:10:32,837
>> teco Witness: let me explain

9587
06:10:32,837 --> 06:10:35,837
initially when we read the

9588
06:10:38,900 --> 06:10:39,878
question it was talking about

9589
06:10:39,878 --> 06:10:41,913
her accuracy and the weather

9590
06:10:41,913 --> 06:10:43,470
normalized accuracy of 0.8%.

9591
06:10:43,470 --> 06:10:45,160
Incorrectly we put under the

9592
06:10:45,160 --> 06:10:46,918
table in the column that says

9593
06:10:46,918 --> 06:10:47,185
actual sales we just put

9594
06:10:47,185 --> 06:10:48,886
projected.

9595
06:10:48,886 --> 06:10:51,886
then as we were reviewing

9596
06:10:54,292 --> 06:10:56,126
things this week I realized

9597
06:10:56,126 --> 06:10:57,362
that that mistake. We have

9598
06:10:57,362 --> 06:10:59,264
corrected it and now we have

9599
06:10:59,264 --> 06:11:01,165
our actual sales. The first

9600
06:11:01,165 --> 06:11:02,600
time what you're seeing where

9601
06:11:02,600 --> 06:11:05,600
you saw 0.8% was really our

9602
06:11:10,375 --> 06:11:12,410
forecast versus the weather

9603
06:11:12,410 --> 06:11:14,379
normalized sales. That is the

9604
06:11:14,379 --> 06:11:15,646
accuracy look. Now I responded

9605
06:11:15,646 --> 06:11:17,515
correctly and we are looking at

9606
06:11:17,515 --> 06:11:19,417
the actual energy sales versus

9607
06:11:19,417 --> 06:11:20,585
the weather normalized sales.

9608
06:11:20,585 --> 06:11:22,387
Those differences basically

9609
06:11:22,387 --> 06:11:23,421
represent our estimate of the

9610
06:11:23,421 --> 06:11:24,556
impacted weather.

9611
06:11:24,556 --> 06:11:26,956
>> Florida Rising: thank you

9612
06:11:27,392 --> 06:11:28,193
and that's a very helpful

9613
06:11:28,193 --> 06:11:29,360
clarification.

9614
06:11:29,360 --> 06:11:31,396
In your role as the director

9615
06:11:31,396 --> 06:11:31,696
for load research and

9616
06:11:31,696 --> 06:11:33,696
forecasting.

9617
06:11:36,300 --> 06:11:39,170
Your team developed inputs that

9618
06:11:39,170 --> 06:11:40,438
will then be turned over to

9619
06:11:40,438 --> 06:11:42,240
teco cost of service team?

9620
06:11:42,240 --> 06:11:42,474
>> teco Witness: that is

9621
06:11:42,474 --> 06:11:44,474
correct.

9622
06:11:45,209 --> 06:11:45,977
>> Florida Rising: teco is

9623
06:11:45,977 --> 06:11:46,777
recommending for cp cost of

9624
06:11:46,777 --> 06:11:49,113
service in this case.

9625
06:11:49,113 --> 06:11:50,281
>> teco Witness: yes.

9626
06:11:50,281 --> 06:11:52,182
>> Florida Rising: know you

9627
06:11:52,182 --> 06:11:53,617
know you just want to get it on

9628
06:11:53,617 --> 06:11:55,853
the record the 4 specific peak

9629
06:11:55,853 --> 06:11:58,853
months that teco uses is

9630
06:12:03,727 --> 06:12:04,828
generally

9631
06:12:04,828 --> 06:12:05,630
, JUNE, JULY, and

9632
06:12:05,630 --> 06:12:06,998
AUGUST.

9633
06:12:06,998 --> 06:12:09,867
>> teco Witness: I'm not really

9634
06:12:09,867 --> 06:12:10,368
familiar with 4 cp but subject

9635
06:12:10,368 --> 06:12:13,300
to check I would agree.

9636
06:12:13,300 --> 06:12:14,305
>> Florida Rising: okay.

9637
06:12:14,305 --> 06:12:15,706
I believe it comes from your

9638
06:12:15,706 --> 06:12:18,706
testimony give me one second.

9639
06:12:44,735 --> 06:12:46,237
We can come back to that.

9640
06:12:46,237 --> 06:12:47,939
Would you agree that among

9641
06:12:47,939 --> 06:12:49,774
other reasons it is important

9642
06:12:49,774 --> 06:12:50,942
for teco to have an accurate

9643
06:12:50,942 --> 06:12:52,777
sales forecast to ensure it

9644
06:12:52,777 --> 06:12:54,312
will have enough generating

9645
06:12:54,312 --> 06:12:54,879
capacity to meet demand at any

9646
06:12:54,879 --> 06:12:56,879
given time?

9647
06:12:56,881 --> 06:12:58,783
>> teco Witness: I would agree.

9648
06:12:58,783 --> 06:12:59,984
>> Florida Rising: an accurate

9649
06:12:59,984 --> 06:13:01,919
forecast is also important to

9650
06:13:01,919 --> 06:13:03,788
make sure that teco has enough

9651
06:13:03,788 --> 06:13:04,989
sales in a given year tour

9652
06:13:04,989 --> 06:13:06,791
require its revenue requirement

9653
06:13:06,791 --> 06:13:08,793
to recover its revenue

9654
06:13:08,793 --> 06:13:09,260
requirement for that year.

9655
06:13:09,260 --> 06:13:11,280
>> teco Witness: yes.

9656
06:13:11,280 --> 06:13:13,300
>> Florida Rising: teco total

9657
06:13:13,300 --> 06:13:14,999
rate based revenue requirement

9658
06:13:14,999 --> 06:13:16,834
for any given year is recovered

9659
06:13:16,834 --> 06:13:18,836
from customers through a

9660
06:13:18,836 --> 06:13:19,870
combination of fixed and

9661
06:13:19,870 --> 06:13:20,380
volumetric charges?

9662
06:13:20,380 --> 06:13:21,973
> teco

9663
06:13:21,973 --> 06:13:24,973
Witness: can you repeat that.

9664
06:13:25,476 --> 06:13:27,444
>> Florida Rising: these are

9665
06:13:27,444 --> 06:13:28,546
foundational questions it's not

9666
06:13:28,546 --> 06:13:29,847
meant to be a trap. Just

9667
06:13:29,847 --> 06:13:32,247
clarifying that teco recovers

9668
06:13:32,583 --> 06:13:34,519
its revenue requirements for

9669
06:13:34,519 --> 06:13:36,621
any given year from customers

9670
06:13:36,621 --> 06:13:38,556
through a culmination of fixed

9671
06:13:38,556 --> 06:13:38,655
and volumetric charges.

9672
06:13:38,655 --> 06:13:39,824
>

9673
06:13:39,824 --> 06:13:41,592
teco Witness: I would agree.

9674
06:13:41,592 --> 06:13:43,528
>> Florida Rising: for the

9675
06:13:43,528 --> 06:13:44,995
volumetric portion of that

9676
06:13:44,995 --> 06:13:46,631
recovery and in very simple

9677
06:13:46,631 --> 06:13:49,233
terms the rate for any given

9678
06:13:49,233 --> 06:13:50,367
class are derived as a function

9679
06:13:50,367 --> 06:13:52,236
basically of the revenue

9680
06:13:52,236 --> 06:13:54,238
requirement that is allocated

9681
06:13:54,238 --> 06:13:56,974
to that class divided by the

9682
06:13:56,974 --> 06:13:59,974
kilowatt hours of load that

9683
06:14:01,270 --> 06:14:01,165
class is expected to consume

9684
06:14:01,165 --> 06:14:01,679
over that your.

9685
06:14:01,679 --> 06:14:02,913
>> teco Witness: I think you're

9686
06:14:02,913 --> 06:14:05,182
getting into an area that is

9687
06:14:05,182 --> 06:14:06,417
not my area of expertise.

9688
06:14:06,417 --> 06:14:08,219
>> would object is not in MS.

9689
06:14:08,219 --> 06:14:10,619
Puente's testimony I believe

9690
06:14:15,590 --> 06:14:17,610
these are questions directed to

9691
06:14:17,610 --> 06:14:18,229
MR. Williams testimony there is

9692
06:14:18,229 --> 06:14:20,164
no where in MS. Puente's

9693
06:14:20,164 --> 06:14:22,660
testimony that addresses this.

9694
06:14:22,660 --> 06:14:25,660
The subject you are being

9695
06:14:26,437 --> 06:14:26,604
questions prior

9696
06:14:26,604 --> 06:14:28,604
.

9697
06:14:28,605 --> 06:14:30,107
>> Mike La Rosa,CHAIRMAN: any

9698
06:14:30,107 --> 06:14:30,708
further thought if not I can

9699
06:14:30,708 --> 06:14:31,809
roll.

9700
06:14:31,809 --> 06:14:33,778
>> Florida Rising: I will try

9701
06:14:33,778 --> 06:14:36,614
to reframe what I'm trying to

9702
06:14:36,614 --> 06:14:37,615
get at is I believe is directly

9703
06:14:37,615 --> 06:14:38,749
properly directed at MS.

9704
06:14:38,749 --> 06:14:40,585
Fuentes inasmuch as it is the

9705
06:14:40,585 --> 06:14:41,719
impact of the forecasting on

9706
06:14:41,719 --> 06:14:44,719
the other piece bring a

9707
06:14:45,255 --> 06:14:47,124
recognize that she's not a cost

9708
06:14:47,124 --> 06:14:48,392
witness and trying to get a

9709
06:14:48,392 --> 06:14:48,593
look at the pieces they go into

9710
06:14:48,593 --> 06:14:50,160
that.

9711
06:14:50,160 --> 06:14:51,696
> Mike La

9712
06:14:51,696 --> 06:14:53,297
Rosa,CHAIRMAN: if you can point

9713
06:14:53,297 --> 06:14:54,532
to her testimony then do that

9714
06:14:54,532 --> 06:14:56,366
one or when applicable then she

9715
06:14:56,366 --> 06:14:59,637
can state if it is not in her

9716
06:14:59,637 --> 06:14:59,737
purview

9717
06:14:59,737 --> 06:15:01,737
.

9718
06:15:01,739 --> 06:15:02,873
>> Florida Rising: can attract

9719
06:15:02,873 --> 06:15:04,808
one or two and then move on.

9720
06:15:04,808 --> 06:15:06,710
>> Mike La Rosa,CHAIRMAN: yes.

9721
06:15:06,710 --> 06:15:07,912
>> Florida Rising: essentially

9722
06:15:07,912 --> 06:15:09,914
what I'm getting at is if teco

9723
06:15:09,914 --> 06:15:11,549
is loaded forecast ended up

9724
06:15:11,549 --> 06:15:12,984
being much higher or lower

9725
06:15:12,984 --> 06:15:16,821
rather if the actual sales in a

9726
06:15:16,821 --> 06:15:18,756
given year into being much

9727
06:15:18,756 --> 06:15:20,724
higher or lower than its loaded

9728
06:15:20,724 --> 06:15:22,660
forecast would you agree that

9729
06:15:22,660 --> 06:15:23,828
could be a problem for revenue

9730
06:15:23,828 --> 06:15:25,828
department recovery.

9731
06:15:28,466 --> 06:15:31,466
>> teco Witness: I don't think

9732
06:15:33,204 --> 06:15:34,371
I would agree with that.

9733
06:15:34,371 --> 06:15:35,306
>> Florida Rising: can you

9734
06:15:35,306 --> 06:15:37,306
explain why not.

9735
06:15:40,644 --> 06:15:41,845
>> teco Witness: I am thinking

9736
06:15:41,845 --> 06:15:43,780
in a given year if it is over

9737
06:15:43,780 --> 06:15:44,882
or under there is other things

9738
06:15:44,882 --> 06:15:46,651
also going on.

9739
06:15:46,651 --> 06:15:47,884
Expenses, it is not the big

9740
06:15:47,884 --> 06:15:51,484
picture I would need to make

9741
06:15:52,957 --> 06:15:54,825
that determination on the

9742
06:15:54,825 --> 06:15:55,159
revenue requirement

9743
06:15:55,159 --> 06:15:56,961
calculation.

9744
06:15:56,961 --> 06:15:58,262
>> Florida Rising: if we are

9745
06:15:58,262 --> 06:15:59,430
looking at revenue requirement

9746
06:15:59,430 --> 06:16:01,265
this is the picture that the

9747
06:16:01,265 --> 06:16:02,366
company says it needs to

9748
06:16:02,366 --> 06:16:04,334
recover for a given year.

9749
06:16:04,334 --> 06:16:05,636
That is allocated across the

9750
06:16:05,636 --> 06:16:07,404
classes and then broken down by

9751
06:16:07,404 --> 06:16:09,373
the expected consumption of

9752
06:16:09,373 --> 06:16:12,373
those numbers coming from your

9753
06:16:13,711 --> 06:16:15,679
department I'm just asking if

9754
06:16:15,679 --> 06:16:17,181
the actuals and up being for

9755
06:16:17,181 --> 06:16:18,849
instance much lower than what

9756
06:16:18,849 --> 06:16:20,851
you forecast is it possible

9757
06:16:20,851 --> 06:16:21,886
that teco would end up not

9758
06:16:21,886 --> 06:16:22,853
recovering the revenue

9759
06:16:22,853 --> 06:16:24,355
requirement anticipated for the

9760
06:16:24,355 --> 06:16:24,450
year

9761
06:16:24,450 --> 06:16:25,489
.

9762
06:16:25,489 --> 06:16:27,889
>> teco Witness: it is

9763
06:16:34,465 --> 06:16:35,666
possible.

9764
06:16:35,666 --> 06:16:37,467
>> Florida Rising: just one

9765
06:16:37,467 --> 06:16:39,503
more thing we will move on.

9766
06:16:39,503 --> 06:16:43,700
If teco is load were actually

9767
06:16:43,700 --> 06:16:44,207
much higher than the forecast

9768
06:16:44,207 --> 06:16:47,807
is it possible that teco could

9769
06:16:49,120 --> 06:16:50,113
over recover versus the revenue

9770
06:16:50,113 --> 06:16:51,248
requirement that they

9771
06:16:51,248 --> 06:16:53,830
anticipated for that year?

9772
06:16:53,830 --> 06:16:55,483
>> teco Witness: again all

9773
06:16:55,619 --> 06:16:57,554
other things equal possibly but

9774
06:16:57,554 --> 06:16:59,456
all things are not equal.

9775
06:16:59,456 --> 06:17:02,456
>> Florida Rising: thank you if

9776
06:17:04,394 --> 06:17:06,463
we can go to master number f1

9777
06:17:06,463 --> 06:17:09,463
6-nine for this is confidential

9778
06:17:18,108 --> 06:17:20,110
exhibit a 31 it is f16-94.

9779
06:17:20,110 --> 06:17:24,310
This is going to be an excel

9780
06:17:30,387 --> 06:17:31,588
spreadsheet.

9781
06:17:31,588 --> 06:17:32,556
MS. Fuentes are you familiar

9782
06:17:32,556 --> 06:17:34,556
with this document?

9783
06:17:34,858 --> 06:17:36,858
>> teco Witness:

9784
06:17:36,860 --> 06:17:38,761
>> Florida Rising: once it

9785
06:17:38,761 --> 06:17:39,963
comes up and you can see it.

9786
06:17:39,963 --> 06:17:42,963
>> teco Witness: yes I am.

9787
06:17:44,201 --> 06:17:46,700
>> Florida Rising: this is a

9788
06:17:46,700 --> 06:17:46,437
workpaper used in developing

9789
06:17:46,437 --> 06:17:46,603
your testimony.

9790
06:17:46,603 --> 06:17:48,603
>>

9791
06:17:49,730 --> 06:17:50,730
teco Witness: yes it is.

9792
06:17:50,730 --> 06:17:50,440
>> Florida Rising: [Unclear

9793
06:17:50,440 --> 06:17:51,641
audio].

9794
06:17:51,641 --> 06:17:56,441
If we go to the tab in summary

9795
06:17:59,817 --> 06:18:01,819
which we are on.

9796
06:18:01,819 --> 06:18:03,821
This shows the variance between

9797
06:18:03,821 --> 06:18:04,989
teco forecasts and actuals with

9798
06:18:04,989 --> 06:18:05,989
respect to the number of

9799
06:18:05,989 --> 06:18:07,191
customers and sales?

9800
06:18:07,191 --> 06:18:09,260
>> teco Witness: yes.

9801
06:18:09,260 --> 06:18:11,280
>> Florida Rising: teco is in

9802
06:18:11,280 --> 06:18:13,130
your average sales actuals are

9803
06:18:13,130 --> 06:18:14,640
1.9% below the forecasted sales

9804
06:18:14,640 --> 06:18:15,866
in this document?

9805
06:18:15,866 --> 06:18:16,133
>> teco Witness: that is

9806
06:18:16,133 --> 06:18:18,350
correct.

9807
06:18:18,350 --> 06:18:19,836
>> Florida Rising: since 2021

9808
06:18:19,836 --> 06:18:21,836
teco's three-year average

9809
06:18:21,872 --> 06:18:22,239
actual sales were below 3.2 the

9810
06:18:22,239 --> 06:18:23,340
actual sales.

9811
06:18:23,340 --> 06:18:25,242
Her forecasted sales.

9812
06:18:25,242 --> 06:18:27,144
>> teco Witness: that is

9813
06:18:27,144 --> 06:18:31,344
correct spacing if we can go to

9814
06:18:33,150 --> 06:18:33,283
master number 3.14

9815
06:18:33,283 --> 06:18:35,252
.

9816
06:18:35,252 --> 06:18:37,254
>> teco Witness: can we stay

9817
06:18:37,254 --> 06:18:38,388
there or to point out that 3.2%

9818
06:18:38,388 --> 06:18:40,257
commission on the weather

9819
06:18:40,257 --> 06:18:41,792
normalized basis which is how

9820
06:18:41,792 --> 06:18:43,294
you assess how your forecasts

9821
06:18:43,294 --> 06:18:44,461
are doing our forecasts are

9822
06:18:44,461 --> 06:18:46,397
only 1/10 of a percent off.

9823
06:18:46,397 --> 06:18:48,165
Then he would mention 1.9 our

9824
06:18:48,165 --> 06:18:50,334
tenure average 1.9% on the

9825
06:18:50,334 --> 06:18:52,734
weather normalized basis was

9826
06:18:53,337 --> 06:18:54,537
0.8% off.

9827
06:18:54,537 --> 06:18:56,173
That is the way we should look

9828
06:18:56,173 --> 06:18:58,173
at forecast accuracy.

9829
06:19:02,980 --> 06:19:04,915
>> Florida Rising: thank you

9830
06:19:04,915 --> 06:19:06,850
for the additional context you

9831
06:19:06,850 --> 06:19:07,952
would agree these numbers are

9832
06:19:07,952 --> 06:19:09,953
accurate and the start.

9833
06:19:09,953 --> 06:19:11,855
>> teco Witness: I agree with

9834
06:19:11,855 --> 06:19:12,122
the numbers that they are

9835
06:19:12,122 --> 06:19:13,990
accurate.

9836
06:19:13,990 --> 06:19:15,250
>> Florida Rising: if we can

9837
06:19:15,250 --> 06:19:16,994
move on to 3.4-6645.

9838
06:19:16,994 --> 06:19:20,594
This is hearing exhibit this is

9839
06:19:27,370 --> 06:19:29,437
hearing exhibit 663 or fll 203.

9840
06:19:31,742 --> 06:19:32,909
Do you recognize this document?

9841
06:19:32,909 --> 06:19:34,878
>> teco Witness: I see two

9842
06:19:34,878 --> 06:19:35,979
different documents can I look

9843
06:19:35,979 --> 06:19:37,181
at the one on my screen?

9844
06:19:37,181 --> 06:19:39,182
>> Florida Rising: what is the

9845
06:19:39,182 --> 06:19:40,117
number in the upper right-hand

9846
06:19:40,117 --> 06:19:41,985
corner for you?

9847
06:19:41,985 --> 06:19:43,985
>> teco Witness: [Listing

9848
06:19:44,870 --> 06:19:46,870
names].

9849
06:19:49,159 --> 06:19:50,394
>> Florida Rising: 6645.

9850
06:19:50,394 --> 06:19:52,362
>> teco Witness: that is what

9851
06:19:52,362 --> 06:19:54,264
we were looking at previously

9852
06:19:54,264 --> 06:19:54,431
that matches what is up there

9853
06:19:54,431 --> 06:19:56,431
now.

9854
06:20:12,249 --> 06:20:13,550
>> Florida Rising: okay.

9855
06:20:13,550 --> 06:20:16,252
This should be a different page

9856
06:20:16,252 --> 06:20:17,287
than the one we're looking at

9857
06:20:17,287 --> 06:20:19,289
before but it should have a

9858
06:20:19,289 --> 06:20:21,258
very similar looking chart. I

9859
06:20:21,258 --> 06:20:22,793
just want to confirm what we're

9860
06:20:22,793 --> 06:20:24,428
looking at here is the response

9861
06:20:24,428 --> 06:20:26,263
to a discovery request this is

9862
06:20:26,263 --> 06:20:27,697
an updated copy of the last

9863
06:20:27,697 --> 06:20:27,964
exhibit of your rebuttal

9864
06:20:27,964 --> 06:20:29,964
testimony?

9865
06:20:30,901 --> 06:20:32,901
>> teco Witness: I

9866
06:20:32,936 --> 06:20:34,104
don't recall this being in my

9867
06:20:34,104 --> 06:20:34,938
rebuttal testimony I have to

9868
06:20:34,938 --> 06:20:36,139
check.

9869
06:20:36,139 --> 06:20:38,400
>> Florida Rising: let me ask

9870
06:20:38,400 --> 06:20:39,943
the question fisher. What

9871
06:20:39,943 --> 06:20:41,111
changes were made to be updated

9872
06:20:41,111 --> 06:20:43,511
document in your rebuttal

9873
06:20:44,414 --> 06:20:45,415
testimony compared to your

9874
06:20:45,415 --> 06:20:45,582
original testimony.

9875
06:20:45,582 --> 06:20:47,417
> teco

9876
06:20:47,417 --> 06:20:48,585
Witness: I believe in my

9877
06:20:48,585 --> 06:20:50,754
rebuttal testimony what I

9878
06:20:50,754 --> 06:20:53,754
updated was I re-created some

9879
06:20:53,957 --> 06:20:54,958
numbers but on the weather

9880
06:20:54,958 --> 06:20:56,958
normalized basis.

9881
06:21:01,598 --> 06:21:03,466
No numbers were revised I just

9882
06:21:03,466 --> 06:21:03,901
pulled out the numbers that I

9883
06:21:03,901 --> 06:21:05,502
felt were the ones

9884
06:21:05,502 --> 06:21:06,636
we should be

9885
06:21:06,636 --> 06:21:07,638
looking at on the weather

9886
06:21:07,638 --> 06:21:09,505
normalized basis.

9887
06:21:09,505 --> 06:21:11,374
>> Florida Rising: as opposed

9888
06:21:11,374 --> 06:21:12,209
to the non-weather normalized

9889
06:21:12,209 --> 06:21:13,510
basis.

9890
06:21:13,510 --> 06:21:14,378
>> teco Witness: no

9891
06:21:14,378 --> 06:21:16,378
spreadsheets were revised.

9892
06:21:16,880 --> 06:21:19,280
>> Florida Rising: thank you.

9893
06:21:21,118 --> 06:21:25,318
If we can go to master number

9894
06:21:29,526 --> 06:21:30,726
16-95 hearing exhibit 831

9895
06:21:30,726 --> 06:21:30,926
there will be a number of

9896
06:21:30,926 --> 06:21:32,926
these.

9897
06:21:36,866 --> 06:21:38,866
[Unclear audio].

9898
06:21:57,320 --> 06:21:58,488
F 16-95.

9899
06:21:58,488 --> 06:22:01,488
MS. Fuentes is this another

9900
06:22:01,524 --> 06:22:02,926
workpaper of yours?

9901
06:22:02,926 --> 06:22:05,926
>> teco Witness: I cannot see

9902
06:22:07,864 --> 06:22:09,864
that.

9903
06:22:10,333 --> 06:22:12,333
Yes this is.

9904
06:22:14,938 --> 06:22:16,806
>> Florida Rising: yes we are

9905
06:22:16,806 --> 06:22:20,406
in the tab year to date

9906
06:22:21,178 --> 06:22:23,146
FEBRUARY.

9907
06:22:23,146 --> 06:22:24,214
This tab shows the forecasted

9908
06:22:24,214 --> 06:22:27,214
versus actual retail sales by

9909
06:22:28,618 --> 06:22:28,985
the month from JUNE 2023 until

9910
06:22:28,985 --> 06:22:30,721
FEBRUARY 2024.

9911
06:22:30,721 --> 06:22:30,954
>> teco Witness: that is

9912
06:22:30,954 --> 06:22:32,889
correct.

9913
06:22:32,889 --> 06:22:34,758
>> Florida Rising: energy sales

9914
06:22:34,758 --> 06:22:35,892
during the summer months trend

9915
06:22:35,892 --> 06:22:37,260
above teco's forecast?

9916
06:22:37,260 --> 06:22:37,894
>> teco Witness: that is

9917
06:22:37,894 --> 06:22:39,960
correct.

9918
06:22:39,960 --> 06:22:39,296
>> Florida Rising: 5% above in

9919
06:22:39,296 --> 06:22:41,296
JULY?

9920
06:22:43,800 --> 06:22:45,735
>> teco Witness: yes honey on

9921
06:22:45,735 --> 06:22:48,305
the weather normalized basis it

9922
06:22:48,305 --> 06:22:48,407
is have a percent

9923
06:22:48,407 --> 06:22:50,373
.

9924
06:22:50,373 --> 06:22:52,375
>> Florida Rising: I will be

9925
06:22:52,375 --> 06:22:53,610
talking about than non-weather

9926
06:22:53,610 --> 06:22:55,378
normalized basis and I respect

9927
06:22:55,378 --> 06:22:57,614
your position that then

9928
06:22:57,614 --> 06:22:59,482
normalized once is where we

9929
06:22:59,482 --> 06:22:59,850
should be looking. It was 6%

9930
06:22:59,850 --> 06:23:00,584
above in AUGUST?

9931
06:23:00,584 --> 06:23:00,851
> teco

9932
06:23:00,851 --> 06:23:01,518
Witness:

9933
06:23:01,518 --> 06:23:03,486
yes.

9934
06:23:03,486 --> 06:23:05,886
>> Florida Rising: 7.7 above in

9935
06:23:07,424 --> 06:23:07,624
SEPTEMBER

9936
06:23:07,624 --> 06:23:09,593
.

9937
06:23:09,593 --> 06:23:09,826
>> teco Witness: that is

9938
06:23:09,826 --> 06:23:10,827
correct.

9939
06:23:10,827 --> 06:23:12,696
>> Florida Rising: on the other

9940
06:23:12,696 --> 06:23:14,598
hand additional sales were

9941
06:23:14,598 --> 06:23:15,765
lower than forecast between

9942
06:23:15,765 --> 06:23:16,199
NOVEMBER and FEBRUARY?

9943
06:23:16,199 --> 06:23:17,734
>> teco

9944
06:23:17,734 --> 06:23:19,702
Witness: does correct.

9945
06:23:19,702 --> 06:23:21,671
>> Florida Rising: you will

9946
06:23:21,671 --> 06:23:23,573
create the biggest variances in

9947
06:23:23,573 --> 06:23:23,840
JANUARY 5.1% less than the

9948
06:23:23,840 --> 06:23:24,840
forecast.

9949
06:23:24,840 --> 06:23:26,710
>> teco Witness: yes.

9950
06:23:26,710 --> 06:23:29,279
Our forecast was too high.

9951
06:23:29,279 --> 06:23:31,515
>> Florida Rising: can we go to

9952
06:23:31,515 --> 06:23:33,515
master number e7770.

9953
06:23:36,653 --> 06:23:38,653
This from exhibit 208.

9954
06:23:49,232 --> 06:23:51,232
Admitted exhibit 208.

9955
06:23:53,403 --> 06:23:54,671
Once there it might be better

9956
06:23:54,671 --> 06:23:56,539
to do with the master number

9957
06:23:56,539 --> 06:23:58,909
this is for derogatory number

9958
06:23:58,909 --> 06:24:00,777
139 master number associate

9959
06:24:00,777 --> 06:24:04,377
with that is e master number

9960
06:24:18,610 --> 06:24:19,262
associate with that is e7796.

9961
06:24:19,262 --> 06:24:21,131
MS. Winters if you can give me

9962
06:24:21,131 --> 06:24:23,990
a nod when it has come up for

9963
06:24:23,990 --> 06:24:23,300
you. I recognize there is a

9964
06:24:23,300 --> 06:24:25,680
lag.

9965
06:24:25,680 --> 06:24:26,201
>> teco Witness: it is up.

9966
06:24:26,201 --> 06:24:28,710
>> Florida Rising: did you

9967
06:24:28,710 --> 06:24:28,404
sponsor the answer to this

9968
06:24:28,404 --> 06:24:28,496
interrogatory

9969
06:24:28,496 --> 06:24:29,405
.

9970
06:24:29,405 --> 06:24:31,341
>> teco Witness: gas.

9971
06:24:31,341 --> 06:24:32,475
>> Florida Rising: in this

9972
06:24:32,475 --> 06:24:33,877
insert to attribute higher

9973
06:24:33,877 --> 06:24:34,911
error rates and sales forecast

9974
06:24:34,911 --> 06:24:35,778
to "hotter than normal

9975
06:24:35,778 --> 06:24:37,460
weather".

9976
06:24:37,460 --> 06:24:38,949
>> teco Witness: does correct.

9977
06:24:38,949 --> 06:24:41,949
>> Florida Rising: go to the

9978
06:24:51,260 --> 06:24:53,260
next page.

9979
06:24:56,733 --> 06:24:57,834
Rather than zooming in on all

9980
06:24:57,834 --> 06:25:00,234
this unless good general

9981
06:25:00,737 --> 06:25:01,271
question about the spring you

9982
06:25:01,271 --> 06:25:03,730
would agree that teco is

9983
06:25:03,730 --> 06:25:05,730
forecast experienced greater

9984
06:25:05,108 --> 06:25:07,108
variance for non-weather

9985
06:25:08,511 --> 06:25:10,280
normalized sales and the

9986
06:25:10,280 --> 06:25:10,380
weather normalized sales

9987
06:25:10,380 --> 06:25:11,581
.

9988
06:25:11,581 --> 06:25:12,449
>> teco Witness: I would agree

9989
06:25:12,449 --> 06:25:14,449
with that.

9990
06:25:21,191 --> 06:25:22,325
>> Florida Rising: okay.

9991
06:25:22,325 --> 06:25:24,194
I guess what we are talking

9992
06:25:24,194 --> 06:25:25,462
about normalization and a

9993
06:25:25,462 --> 06:25:27,862
conversation with MS. Wessling

9994
06:25:28,231 --> 06:25:29,399
about whether normalization we

9995
06:25:29,399 --> 06:25:31,334
danced around the subject a

9996
06:25:31,334 --> 06:25:32,435
little bit. How exactly does

9997
06:25:32,435 --> 06:25:33,737
teco normalize for weather?

9998
06:25:33,737 --> 06:25:35,605
>> teco Witness: let me see if

9999
06:25:35,605 --> 06:25:35,972
I can explain where it makes

10000
06:25:35,972 --> 06:25:37,972
sense.

10001
06:25:42,245 --> 06:25:45,245
Whether normalizing is based on

10002
06:25:53,256 --> 06:25:54,457
a coefficient which represents

10003
06:25:54,457 --> 06:25:56,359
the kilowatt hour per degree

10004
06:25:56,359 --> 06:25:58,261
day this coefficient comes from

10005
06:25:58,261 --> 06:26:00,263
our regression models which

10006
06:26:00,263 --> 06:26:01,731
correlates the weather and

10007
06:26:01,731 --> 06:26:03,731
customer usage.

10008
06:26:03,733 --> 06:26:05,768
That is one piece we have this

10009
06:26:05,768 --> 06:26:07,771
coefficient that represent this

10010
06:26:07,771 --> 06:26:08,300
relationship between energy and

10011
06:26:08,300 --> 06:26:09,772
weather.

10012
06:26:09,772 --> 06:26:10,940
Then we look at our whether

10013
06:26:10,940 --> 06:26:13,940
what was normal what was

10014
06:26:15,979 --> 06:26:17,947
expected and what we used the

10015
06:26:17,947 --> 06:26:19,281
forecast and what actually

10016
06:26:19,281 --> 06:26:20,950
happened. We take the

10017
06:26:20,950 --> 06:26:22,180
difference in those degree days

10018
06:26:22,180 --> 06:26:23,953
multiply them by the

10019
06:26:23,953 --> 06:26:25,188
coefficient then multiplied

10020
06:26:25,188 --> 06:26:27,257
them by the terms of customers

10021
06:26:27,257 --> 06:26:28,991
that we have that gives you

10022
06:26:28,991 --> 06:26:30,993
what the weather impact was

10023
06:26:30,993 --> 06:26:32,228
that's how you normalize you

10024
06:26:32,228 --> 06:26:34,998
remove that when they're back

10025
06:26:34,998 --> 06:26:36,320
from your actual energy sales.

10026
06:26:36,320 --> 06:26:36,365
That is how you do the weather

10027
06:26:36,365 --> 06:26:38,301
normalization.

10028
06:26:38,301 --> 06:26:40,136
>> Florida Rising: would be for

10029
06:26:40,136 --> 06:26:43,136
the safe large loads and

10030
06:26:46,375 --> 06:26:47,544
ecosystem by the end use would

10031
06:26:47,544 --> 06:26:48,644
be space heating and cooling?

10032
06:26:48,644 --> 06:26:50,646
Depending on the season?

10033
06:26:50,646 --> 06:26:52,582
>> teco Witness: I would agree.

10034
06:26:52,582 --> 06:26:54,982
>> Florida Rising: would you

10035
06:26:55,418 --> 06:26:57,620
agree with those end-users are

10036
06:26:57,620 --> 06:26:59,620
entirely temperature dependent

10037
06:26:59,622 --> 06:27:01,424
entirely temperature dependent.

10038
06:27:01,424 --> 06:27:02,659
>> teco Witness: yes.

10039
06:27:02,659 --> 06:27:04,627
Specifically that is to go uses

10040
06:27:04,627 --> 06:27:06,596
a 65b0f breakpoint above or

10041
06:27:06,596 --> 06:27:08,464
below which each hvac systems

10042
06:27:08,464 --> 06:27:08,698
are soon to be heating or

10043
06:27:08,698 --> 06:27:10,533
cooling.

10044
06:27:10,533 --> 06:27:10,800
>> teco Witness: 65b0 is the

10045
06:27:10,800 --> 06:27:12,635
base yes.

10046
06:27:12,635 --> 06:27:14,671
>> Florida Rising: would you

10047
06:27:14,671 --> 06:27:16,706
agree there's a difference

10048
06:27:16,706 --> 06:27:17,940
between weather and climate.

10049
06:27:17,940 --> 06:27:19,876
>> teco Witness: I would agree.

10050
06:27:19,876 --> 06:27:21,811
>> Florida Rising: would you

10051
06:27:21,811 --> 06:27:23,713
agree that the weather would

10052
06:27:23,713 --> 06:27:26,150
capture the kinds of day-to-day

10053
06:27:26,150 --> 06:27:27,483
month to month even dirtier

10054
06:27:27,483 --> 06:27:28,318
variation in temperature within

10055
06:27:28,318 --> 06:27:30,318
a baseline.

10056
06:27:31,487 --> 06:27:33,356
>> teco Witness: I'm not an

10057
06:27:33,356 --> 06:27:36,356
expert in commonality but I

10058
06:27:39,495 --> 06:27:39,662
would high-level yes

10059
06:27:39,662 --> 06:27:41,631
.

10060
06:27:41,631 --> 06:27:42,698
>> Florida Rising: in general.

10061
06:27:42,698 --> 06:27:44,634
> teco Witness: gas.

10062
06:27:44,634 --> 06:27:46,669
>> Florida Rising: would you

10063
06:27:46,669 --> 06:27:47,937
also greet the comets more

10064
06:27:47,937 --> 06:27:50,337
describes the meta-system or

10065
06:27:50,673 --> 06:27:51,174
the baseline from which that

10066
06:27:51,174 --> 06:27:52,709
day-to-day or seasonal

10067
06:27:52,709 --> 06:27:53,709
variation is taking place?

10068
06:27:53,709 --> 06:27:53,876
>> Florida Rising:

10069
06:27:53,876 --> 06:27:55,745
> teco

10070
06:27:55,745 --> 06:27:55,944
Witness: I could agree with

10071
06:27:55,944 --> 06:27:57,714
that.

10072
06:27:57,714 --> 06:27:58,948
>> Florida Rising: would you

10073
06:27:58,948 --> 06:28:02,118
further agree that if the comet

10074
06:28:02,118 --> 06:28:04,200
were to change it would shift

10075
06:28:04,200 --> 06:28:06,210
the baseline around which that

10076
06:28:06,210 --> 06:28:06,289
variation would call weather is

10077
06:28:06,289 --> 06:28:08,190
occurring?

10078
06:28:08,190 --> 06:28:10,260
>> teco Witness: it is possible

10079
06:28:10,260 --> 06:28:14,226
but for the period of time I've

10080
06:28:19,869 --> 06:28:21,671
been doing this it has not

10081
06:28:21,671 --> 06:28:22,805
moved 65b0 is the base.

10082
06:28:22,805 --> 06:28:24,674
>> Florida Rising: I'm not

10083
06:28:24,674 --> 06:28:25,875
referring to that number

10084
06:28:25,875 --> 06:28:27,710
specifically just in general

10085
06:28:27,710 --> 06:28:29,879
terms if we talk about the

10086
06:28:29,879 --> 06:28:31,848
weather as inter-day inter-week

10087
06:28:31,848 --> 06:28:33,783
and inter-seasonal variation

10088
06:28:33,783 --> 06:28:35,685
around general baseline would

10089
06:28:35,685 --> 06:28:37,186
you agree that climate change

10090
06:28:37,186 --> 06:28:38,688
or changing the climate would

10091
06:28:38,688 --> 06:28:40,690
move the baseline in any

10092
06:28:40,690 --> 06:28:40,957
direction it would move that

10093
06:28:40,957 --> 06:28:41,691
baseline?

10094
06:28:41,691 --> 06:28:42,858
> teco Witness: i

10095
06:28:42,858 --> 06:28:44,326
believe it would be a gradual

10096
06:28:44,326 --> 06:28:45,561
change over time.

10097
06:28:45,561 --> 06:28:47,430
>> Florida Rising: there enough

10098
06:28:47,430 --> 06:28:51,300
if you go to master number

10099
06:29:09,251 --> 06:29:11,251
3.2-3815.

10100
06:29:14,457 --> 06:29:15,691
Do you have it up?

10101
06:29:15,691 --> 06:29:17,593
>> teco Witness: yes if it is

10102
06:29:17,593 --> 06:29:21,193
one that we have seen already?

10103
06:29:21,597 --> 06:29:24,597
>> Florida Rising: yes this is

10104
06:29:25,868 --> 06:29:27,870
one that opc pulled up.

10105
06:29:27,870 --> 06:29:31,107
I will ask you questions around

10106
06:29:31,107 --> 06:29:33,108
this but just to confirm this

10107
06:29:33,108 --> 06:29:35,144
document provides build first

10108
06:29:35,144 --> 06:29:38,144
projected energy versus use per

10109
06:29:39,182 --> 06:29:39,277
class for APRIL 24

10110
06:29:39,277 --> 06:29:40,583
.

10111
06:29:40,583 --> 06:29:40,691
>> teco Witness: yes

10112
06:29:40,691 --> 06:29:42,691
.

10113
06:29:43,180 --> 06:29:44,887
>> opc:

10114
06:29:44,887 --> 06:29:48,487
>> Florida Rising: if we go to

10115
06:29:48,657 --> 06:29:52,940
pages down does this page show

10116
06:29:52,940 --> 06:29:54,494
narrative explanations for the

10117
06:29:57,699 --> 06:29:58,340
variance between predicted and

10118
06:29:58,340 --> 06:29:59,835
actual sales.

10119
06:29:59,835 --> 06:30:01,871
>> teco Witness: yes it does.

10120
06:30:01,871 --> 06:30:04,271
>> Florida Rising: under the

10121
06:30:05,107 --> 06:30:06,241
heading peak demand section

10122
06:30:06,241 --> 06:30:08,144
does it note that predict

10123
06:30:08,144 --> 06:30:09,412
winter peak months are now

10124
06:30:09,412 --> 06:30:10,379
being driven by hunters rather

10125
06:30:10,379 --> 06:30:12,281
than cold weather?

10126
06:30:12,281 --> 06:30:14,681
>> teco Witness: I'm reading

10127
06:30:15,584 --> 06:30:17,584
it.

10128
06:30:17,987 --> 06:30:20,987
>> Florida Rising: it would be

10129
06:30:25,795 --> 06:30:25,928
cel h 15

10130
06:30:25,928 --> 06:30:27,960
.

10131
06:30:27,960 --> 06:30:28,998
>> teco Witness: for that

10132
06:30:28,998 --> 06:30:30,165
specific period but that is not

10133
06:30:30,165 --> 06:30:31,934
consistent all winter months.

10134
06:30:31,934 --> 06:30:33,936
For that period it was.

10135
06:30:33,936 --> 06:30:35,838
>> Florida Rising: it is your

10136
06:30:35,838 --> 06:30:37,739
testimony that the winter peaks

10137
06:30:37,739 --> 06:30:38,941
on the teco system are driven

10138
06:30:38,941 --> 06:30:39,841
by heating needs rather than

10139
06:30:39,841 --> 06:30:41,841
cooling needs?

10140
06:30:41,877 --> 06:30:42,478
>> teco Witness: can you repeat

10141
06:30:42,478 --> 06:30:42,578
that

10142
06:30:42,578 --> 06:30:44,578
.

10143
06:30:45,581 --> 06:30:46,682
>> Florida Rising: the variance

10144
06:30:46,682 --> 06:30:49,820
explanation on this page

10145
06:30:56,559 --> 06:30:58,270
attributes winter peak to

10146
06:30:58,270 --> 06:30:59,695
effectively it attributes them

10147
06:30:59,695 --> 06:31:01,497
to cooling needs rather than

10148
06:31:01,497 --> 06:31:03,532
heating needs because it is

10149
06:31:03,532 --> 06:31:04,734
saying there happening and hot

10150
06:31:04,734 --> 06:31:06,602
peak days and you're saying

10151
06:31:06,602 --> 06:31:07,670
that explanation applies in

10152
06:31:07,670 --> 06:31:09,605
this context to this time

10153
06:31:09,605 --> 06:31:11,574
period that do not agree that

10154
06:31:11,574 --> 06:31:12,875
it is representative of the

10155
06:31:12,875 --> 06:31:14,610
peak on teco systems.

10156
06:31:14,610 --> 06:31:16,512
>> teco Witness: I don't agree

10157
06:31:16,512 --> 06:31:17,713
I feel still think heating

10158
06:31:17,713 --> 06:31:19,515
degree will drive the winter

10159
06:31:19,515 --> 06:31:20,750
peak at times but sometimes

10160
06:31:20,750 --> 06:31:22,718
it's a cooling degree day. I

10161
06:31:22,718 --> 06:31:24,620
will say this first quarter of

10162
06:31:24,620 --> 06:31:26,555
it this year which is kind of

10163
06:31:26,555 --> 06:31:29,291
overlaps into. Was the mildest

10164
06:31:29,291 --> 06:31:30,593
period of time for those months

10165
06:31:30,593 --> 06:31:32,394
in the past 50 years.

10166
06:31:32,394 --> 06:31:34,394
Very mild.

10167
06:31:35,197 --> 06:31:37,197
>> Florida Rising: okay.

10168
06:31:41,402 --> 06:31:45,602
If we can go three pages down.

10169
06:32:01,230 --> 06:32:02,191
Master number ending 3820.

10170
06:32:02,191 --> 06:32:05,191
Looking at this page the

10171
06:32:05,861 --> 06:32:06,961
production for non-peak demand

10172
06:32:06,961 --> 06:32:09,798
shows a clear spike between

10173
06:32:09,798 --> 06:32:11,667
DECEMBER non-peak demand shows

10174
06:32:11,667 --> 06:32:12,768
a clear spike between DECEMBER

10175
06:32:12,768 --> 06:32:14,737
2023 and FEBRUARY 2024?

10176
06:32:14,737 --> 06:32:18,337
>> teco Witness: I need to see

10177
06:32:19,141 --> 06:32:21,110
that.

10178
06:32:21,110 --> 06:32:21,644
>> Florida Rising: the orange

10179
06:32:21,644 --> 06:32:22,444
line in the graph is the

10180
06:32:22,444 --> 06:32:23,445
predicted.

10181
06:32:23,445 --> 06:32:25,445
>> teco Witness: yes.

10182
06:32:28,117 --> 06:32:29,318
>> Florida Rising: I'm sorry.

10183
06:32:29,318 --> 06:32:31,120
You agree there is a predicted

10184
06:32:31,120 --> 06:32:33,120
spike there?

10185
06:32:36,292 --> 06:32:38,127
>> teco Witness: yes we predict

10186
06:32:38,127 --> 06:32:38,327
our winter peaks to be 31b0

10187
06:32:38,327 --> 06:32:39,561
days.

10188
06:32:39,561 --> 06:32:41,297
>> Florida Rising: that spike

10189
06:32:41,297 --> 06:32:41,763
does coincide with the teco is

10190
06:32:41,763 --> 06:32:42,298
winter

10191
06:32:42,298 --> 06:32:44,298
season.

10192
06:32:45,200 --> 06:32:47,200
>> teco Witness: yes.

10193
06:32:47,769 --> 06:32:50,973
It is evident that graph our

10194
06:32:50,973 --> 06:32:52,207
first quarter was very mild.

10195
06:32:52,207 --> 06:32:54,109
>> Florida Rising: would agree

10196
06:32:54,109 --> 06:32:56,509
the predicted forecaster winter

10197
06:32:58,614 --> 06:32:58,880
peak did not for materialize as

10198
06:32:58,880 --> 06:33:00,816
expected.

10199
06:33:00,816 --> 06:33:02,785
>> teco Witness: it did not.

10200
06:33:02,785 --> 06:33:05,185
>> Florida Rising: for FEBRUARY

10201
06:33:05,254 --> 06:33:09,454
this is looking up this will be

10202
06:33:12,494 --> 06:33:14,596
cel number 5k 5 looking at the

10203
06:33:14,596 --> 06:33:16,650
variance directory highlighted

10204
06:33:16,650 --> 06:33:18,465
cel for FEBRUARY 2024 the

10205
06:33:20,469 --> 06:33:21,436
actual peak was most 29% below

10206
06:33:21,436 --> 06:33:23,436
the expected.

10207
06:33:25,441 --> 06:33:26,642
>> teco Witness:

10208
06:33:26,642 --> 06:33:28,143
yes again that was a very mild

10209
06:33:28,143 --> 06:33:28,240
quarter

10210
06:33:28,240 --> 06:33:30,240
.

10211
06:33:30,379 --> 06:33:31,380
>> Florida Rising: for DECEMBER

10212
06:33:31,380 --> 06:33:32,581
it was 30% below?

10213
06:33:32,581 --> 06:33:34,850
>> teco Witness: for which

10214
06:33:34,850 --> 06:33:34,945
month

10215
06:33:34,945 --> 06:33:36,819
.

10216
06:33:36,819 --> 06:33:38,254
>> Florida Rising: sorry for

10217
06:33:38,254 --> 06:33:39,454
DECEMBER 2023.

10218
06:33:39,454 --> 06:33:41,854
>> teco Witness: it was 4.4%.

10219
06:33:43,792 --> 06:33:45,594
>> Florida Rising: I'm looking

10220
06:33:45,594 --> 06:33:45,861
at the percent variance my

10221
06:33:45,861 --> 06:33:47,861
apologies.

10222
06:33:50,565 --> 06:33:53,565
This is cell I five.

10223
06:33:56,271 --> 06:33:56,405
>> teco Witness: I see that

10224
06:33:56,405 --> 06:33:57,706
.

10225
06:33:57,706 --> 06:33:59,541
>> Florida Rising: simply for

10226
06:33:59,541 --> 06:34:01,410
JANUARY 2020 fourth the peak

10227
06:34:01,410 --> 06:34:02,478
was 52% lower than expected.

10228
06:34:02,478 --> 06:34:04,478
>> teco Witness: yes.

10229
06:34:06,681 --> 06:34:07,882
Can we go to master number

10230
06:34:07,882 --> 06:34:10,180
before we move on can I add

10231
06:34:10,180 --> 06:34:11,120
something if we were to extend

10232
06:34:11,120 --> 06:34:13,521
this this ends in MARCH if we

10233
06:34:13,521 --> 06:34:17,121
go through last month our JUNE

10234
06:34:18,260 --> 06:34:20,295
and JULY summer peak I just

10235
06:34:20,295 --> 06:34:21,930
want to point out the rolloff

10236
06:34:21,930 --> 06:34:23,832
by 8 mw.

10237
06:34:23,832 --> 06:34:24,399
In both JUNE and JULY. The peak

10238
06:34:24,399 --> 06:34:25,501
demand forecast and at the

10239
06:34:25,501 --> 06:34:28,237
forecast in this proceeding are

10240
06:34:28,237 --> 06:34:31,837
basically dead on I would like

10241
06:34:32,808 --> 06:34:37,800
to point out that we raised the

10242
06:34:37,179 --> 06:34:38,447
forecast for this proceeding by

10243
06:34:38,447 --> 06:34:40,847
almost 1% because we realized

10244
06:34:41,115 --> 06:34:42,151
residential forecast had been

10245
06:34:42,151 --> 06:34:43,619
on the low side.

10246
06:34:43,619 --> 06:34:45,420
The residential forecast year

10247
06:34:45,420 --> 06:34:47,188
to date in JULY is actually

10248
06:34:47,188 --> 06:34:50,188
3/10 of a percent below our

10249
06:34:52,260 --> 06:34:53,662
budget.

10250
06:34:53,662 --> 06:34:55,297
This forecast in this

10251
06:34:55,297 --> 06:34:56,364
proceeding that leads into the

10252
06:34:56,364 --> 06:34:58,990
test year is very very

10253
06:34:58,990 --> 06:35:00,990
accurate.

10254
06:35:00,135 --> 06:35:01,336
On a weather normalize basis

10255
06:35:01,336 --> 06:35:02,170
which no I like to talk about

10256
06:35:02,170 --> 06:35:04,170
it that way.

10257
06:35:05,307 --> 06:35:07,420
We are 1/10 of a percent above

10258
06:35:07,420 --> 06:35:11,242
because we had a hot JULY and

10259
06:35:12,948 --> 06:35:14,816
we also had an upside with an

10260
06:35:14,816 --> 06:35:17,216
industrial customer if we

10261
06:35:17,619 --> 06:35:19,530
remove the impact of that

10262
06:35:19,530 --> 06:35:21,453
customer we are actually

10263
06:35:22,858 --> 06:35:24,759
forecast through JULY is 0.0%.

10264
06:35:24,759 --> 06:35:24,959
We are below our budget by 3 gw

10265
06:35:24,959 --> 06:35:26,959
hours.

10266
06:35:28,530 --> 06:35:30,432
That's a very very good

10267
06:35:30,432 --> 06:35:31,600
statistic for a forecast any

10268
06:35:31,600 --> 06:35:33,569
proceeding.

10269
06:35:33,569 --> 06:35:36,205
>> Florida Rising: I think you

10270
06:35:36,205 --> 06:35:38,139
indicated but the reform or to

10271
06:35:38,139 --> 06:35:41,139
confirm your talk about the

10272
06:35:44,546 --> 06:35:44,713
weather normalized

10273
06:35:44,713 --> 06:35:45,848
.

10274
06:35:45,848 --> 06:35:47,715
>> teco Witness: both not

10275
06:35:47,715 --> 06:35:48,984
innate weather normalized our

10276
06:35:48,984 --> 06:35:50,819
presidential forecast is 3/10

10277
06:35:50,819 --> 06:35:51,887
of a percent below our budget.

10278
06:35:51,887 --> 06:35:53,922
Our budget is too high.

10279
06:35:53,922 --> 06:35:55,791
In total because we had hotter

10280
06:35:55,791 --> 06:35:56,958
weather last month as well as

10281
06:35:56,958 --> 06:35:58,860
an industrial upside if we

10282
06:35:58,860 --> 06:36:01,260
remove that industrial upside

10283
06:36:02,970 --> 06:36:03,932
our non-weather normalized

10284
06:36:03,932 --> 06:36:07,532
forecast is just off by 2/10 of

10285
06:36:08,770 --> 06:36:10,772
a percent if you weather

10286
06:36:10,772 --> 06:36:12,673
normalized at 2/10 of a percent

10287
06:36:12,673 --> 06:36:13,508
we are 0.0% off on our

10288
06:36:13,508 --> 06:36:14,743
forecast.

10289
06:36:14,743 --> 06:36:17,946
That is 3 gw hours below our

10290
06:36:17,946 --> 06:36:18,213
budget is where the actual

10291
06:36:18,213 --> 06:36:20,115
comes in.

10292
06:36:20,115 --> 06:36:21,950
>> Florida Rising: thank you

10293
06:36:21,950 --> 06:36:26,150
for the can we move on to

10294
06:36:27,188 --> 06:36:29,224
master number f16-89.

10295
06:36:29,224 --> 06:36:32,224
this is from hearing exhibit

10296
06:36:51,880 --> 06:36:53,880
831.

10297
06:36:53,882 --> 06:36:55,383
>> Mike La Rosa,CHAIRMAN: how

10298
06:36:55,383 --> 06:36:56,184
many more questions do think

10299
06:36:56,184 --> 06:36:56,278
you have for this witness

10300
06:36:56,278 --> 06:36:58,219
.

10301
06:36:58,219 --> 06:36:59,420
>> Florida Rising: I have a

10302
06:36:59,420 --> 06:37:01,820
fairly significant amount of

10303
06:37:04,559 --> 06:37:05,760
questions if it's time for a

10304
06:37:05,760 --> 06:37:06,728
break this would be a good time

10305
06:37:06,728 --> 06:37:08,663
for break.

10306
06:37:08,663 --> 06:37:09,798
>> Mike La Rosa,CHAIRMAN: let's

10307
06:37:09,798 --> 06:37:13,398
do that let's take a break

10308
06:37:25,447 --> 06:37:27,447
until 3:45 pm.

10309
06:50:59,526 --> 06:51:02,526
>> Mike La Rosa,CHAIRMAN: we

10310
06:51:06,767 --> 06:51:09,536
can jump back in are you ready.

10311
06:51:09,536 --> 06:51:10,738
>> Florida Rising: thank you

10312
06:51:10,738 --> 06:51:12,380
MR. CHAIRMAN MS. Fuentes to

10313
06:51:12,380 --> 06:51:14,438
recognize that document pulled

10314
06:51:15,242 --> 06:51:15,375
up

10315
06:51:15,375 --> 06:51:16,543
.

10316
06:51:16,543 --> 06:51:19,512
>> teco Witness: yes I do.

10317
06:51:19,512 --> 06:51:21,415
>> Florida Rising: this is a

10318
06:51:21,415 --> 06:51:21,681
report from the peak demand

10319
06:51:21,681 --> 06:51:22,649
from 2019.

10320
06:51:22,649 --> 06:51:24,649
>> teco Witness: yes.

10321
06:51:26,253 --> 06:51:28,653
>> Florida Rising: I apologize.

10322
06:51:40,733 --> 06:51:41,868
One second.

10323
06:51:41,868 --> 06:51:44,868
For context this is master

10324
06:51:47,274 --> 06:51:49,674
number f-16-89 comprehensive

10325
06:51:52,312 --> 06:51:53,346
exhibit 831.

10326
06:51:53,346 --> 06:51:54,414
This report is from

10327
06:51:54,414 --> 06:51:56,249
2019.

10328
06:51:56,249 --> 06:51:59,849
We will also go to separate

10329
06:52:04,424 --> 06:52:06,459
documents you have from 2020

10330
06:52:06,459 --> 06:52:07,794
-2023 will be as efficient as

10331
06:52:07,794 --> 06:52:09,529
possible going through these

10332
06:52:09,529 --> 06:52:10,197
all of these documents these

10333
06:52:10,197 --> 06:52:11,465
are

10334
06:52:11,465 --> 06:52:12,965
workpapers from the

10335
06:52:12,965 --> 06:52:13,633
development of your testimony

10336
06:52:13,633 --> 06:52:14,468
and mfr.

10337
06:52:14,468 --> 06:52:15,302
> teco Witness: I

10338
06:52:15,302 --> 06:52:15,400
believe they are

10339
06:52:15,400 --> 06:52:17,204
.

10340
06:52:17,204 --> 06:52:18,672
>> Florida Rising: please

10341
06:52:18,672 --> 06:52:20,273
scroll down to the section

10342
06:52:20,273 --> 06:52:23,873
which l peak demand this will

10343
06:52:25,645 --> 06:52:27,381
be role 109.

10344
06:52:27,381 --> 06:52:30,381
This section includes the real

10345
06:52:30,650 --> 06:52:33,650
actual and forecasted for each

10346
06:52:34,120 --> 06:52:35,288
month of 2019?

10347
06:52:35,288 --> 06:52:36,156
>> teco Witness: that is

10348
06:52:36,156 --> 06:52:38,156
correct.

10349
06:52:38,792 --> 06:52:40,727
>> Florida Rising: for instance

10350
06:52:40,727 --> 06:52:42,862
in 2019 JANUARY was forecast to

10351
06:52:42,862 --> 06:52:42,958
have a peak of 4337 mw

10352
06:52:42,958 --> 06:52:44,958
.

10353
06:52:45,232 --> 06:52:46,990
>> teco Witness: that is

10354
06:52:46,990 --> 06:52:47,601
correct.

10355
06:52:47,601 --> 06:52:50,100
>> Florida Rising: the actual

10356
06:52:56,943 --> 06:52:57,177
peak demand for JANUARY was

10357
06:52:57,177 --> 06:52:58,945
3091 mw.

10358
06:52:58,945 --> 06:52:59,178
>> teco Witness: that is

10359
06:52:59,178 --> 06:53:01,148
correct.

10360
06:53:01,148 --> 06:53:01,481
>> Florida Rising: looking at

10361
06:53:01,481 --> 06:53:02,949
the cell

10362
06:53:02,949 --> 06:53:04,949
below the forecast

10363
06:53:04,951 --> 06:53:06,352
number that represents a

10364
06:53:06,352 --> 06:53:07,870
variance of-29%.

10365
06:53:07,870 --> 06:53:07,988
>> teco Witness: that is

10366
06:53:07,988 --> 06:53:09,189
correct.

10367
06:53:09,189 --> 06:53:09,422
>> Florida Rising: put another

10368
06:53:09,422 --> 06:53:11,570
way

10369
06:53:11,570 --> 06:53:12,191
teco's forecast was 25%

10370
06:53:12,191 --> 06:53:14,270
higher than the natural for

10371
06:53:14,270 --> 06:53:15,195
JANUARY teco's forecast was 25%

10372
06:53:15,195 --> 06:53:16,960
higher than the natural for

10373
06:53:16,960 --> 06:53:18,960
JANUARY 2014.

10374
06:53:18,131 --> 06:53:20,333
>> teco Witness: just to remind

10375
06:53:20,333 --> 06:53:21,534
our winter forecast we

10376
06:53:21,534 --> 06:53:23,536
requested 31b0 peak at the time

10377
06:53:23,536 --> 06:53:25,338
to ensure we have the capacity

10378
06:53:25,338 --> 06:53:26,572
to meet a winter load. We do

10379
06:53:26,572 --> 06:53:28,441
have a occasional winter load

10380
06:53:28,441 --> 06:53:31,277
and in fact we don't have the

10381
06:53:31,277 --> 06:53:31,877
2010 peak report but if we did

10382
06:53:31,877 --> 06:53:35,477
that would show that peak in

10383
06:53:36,816 --> 06:53:38,819
2010 we had 14 consecutive days

10384
06:53:38,819 --> 06:53:39,852
of cold weather that peak is

10385
06:53:39,852 --> 06:53:43,452
actually only 50 mw or so off

10386
06:53:48,610 --> 06:53:49,429
our 2024 and 2025 winter peak.

10387
06:53:49,429 --> 06:53:51,640
If we have a winter peak we

10388
06:53:51,640 --> 06:53:53,833
will have a pretty sharp spike

10389
06:53:53,833 --> 06:53:55,833
in the demand.

10390
06:53:55,835 --> 06:53:57,103
I just want to explain broken

10391
06:53:57,103 --> 06:53:58,872
forecast for 31b0 and we don't

10392
06:53:58,872 --> 06:54:00,390
meet that every year.

10393
06:54:00,390 --> 06:54:03,976
Like I said when we have our

10394
06:54:03,976 --> 06:54:04,277
winter we will meet it and then

10395
06:54:04,277 --> 06:54:06,145
surpass it.

10396
06:54:06,145 --> 06:54:08,470
>> Florida Rising: if I can

10397
06:54:08,470 --> 06:54:09,248
draw your attention back to the

10398
06:54:09,248 --> 06:54:11,510
forecast rope we look across

10399
06:54:11,510 --> 06:54:12,986
the forecast role that has 4337

10400
06:54:12,986 --> 06:54:14,854
for JANUARY if you look across

10401
06:54:14,854 --> 06:54:15,822
that for the rest of the year

10402
06:54:15,822 --> 06:54:18,822
JANUARY is actually forecast to

10403
06:54:24,497 --> 06:54:25,798
be the peak for 2019.

10404
06:54:25,798 --> 06:54:27,667
JANUARY 2019 was forecast to be

10405
06:54:27,667 --> 06:54:31,103
the retail system peak for the

10406
06:54:31,103 --> 06:54:31,236
year

10407
06:54:31,236 --> 06:54:32,305
.

10408
06:54:32,305 --> 06:54:34,207
>> teco Witness: yes.

10409
06:54:34,207 --> 06:54:35,441
>> Florida Rising: the actual

10410
06:54:35,441 --> 06:54:36,409
retail peak for that year was

10411
06:54:36,409 --> 06:54:38,311
4298 mw in JUNE?

10412
06:54:38,311 --> 06:54:38,544
>> teco Witness: that is

10413
06:54:38,544 --> 06:54:40,544
correct.

10414
06:54:43,650 --> 06:54:45,552
>> Florida Rising: if we look

10415
06:54:45,552 --> 06:54:49,152
at the actual peak demand for

10416
06:54:49,456 --> 06:54:51,458
JANUARY, 2091 mw number we look

10417
06:54:51,458 --> 06:54:55,580
across the rest of that row

10418
06:54:57,664 --> 06:54:59,365
would you agree that the actual

10419
06:54:59,365 --> 06:55:01,200
peak was higher than the actual

10420
06:55:01,200 --> 06:55:02,801
peak in JANUARY for the months

10421
06:55:02,801 --> 06:55:04,770
of FEBRUARY, MARCH, APRIL,

10422
06:55:04,770 --> 06:55:07,170
MAY, JUNE, JULY, AUGUST,

10423
06:55:08,440 --> 06:55:10,440
SEPTEMBER, OCTOBER, NOVEMBER

10424
06:55:15,481 --> 06:55:15,648
NOVEMBER 2019

10425
06:55:15,648 --> 06:55:16,849
.

10426
06:55:16,849 --> 06:55:18,752
>> teco Witness: I would agree.

10427
06:55:18,752 --> 06:55:20,752
>> Florida Rising: putting

10428
06:55:20,819 --> 06:55:22,822
aside the months of JUNE-august

10429
06:55:22,822 --> 06:55:24,791
that is seven months outside of

10430
06:55:24,791 --> 06:55:26,826
the number four cp months that

10431
06:55:26,826 --> 06:55:26,926
the code uses higher than

10432
06:55:26,926 --> 06:55:28,128
.

10433
06:55:28,128 --> 06:55:31,128
>> teco Witness: I don't want

10434
06:55:32,698 --> 06:55:34,667
to speak about number four cp

10435
06:55:34,667 --> 06:55:37,136
that's a question for jordan

10436
06:55:37,136 --> 06:55:38,371
williams.

10437
06:55:38,371 --> 06:55:40,172
>> Florida Rising: it is your

10438
06:55:40,172 --> 06:55:43,172
forecast data that goes into

10439
06:55:44,644 --> 06:55:45,879
MR. Williams models.

10440
06:55:45,879 --> 06:55:47,780
>> teco Witness: yes they do.

10441
06:55:47,780 --> 06:55:49,649
>> Florida Rising: it is the

10442
06:55:49,649 --> 06:55:50,883
peak from those months the

10443
06:55:50,883 --> 06:55:51,751
drive the cost of service that

10444
06:55:51,751 --> 06:55:53,751
he uses.

10445
06:55:58,910 --> 06:55:59,993
>> teco Witness: that as well

10446
06:55:59,993 --> 06:56:01,861
as a number of other things.

10447
06:56:01,861 --> 06:56:02,895
>> Florida Rising: as we sit

10448
06:56:02,895 --> 06:56:04,630
here today is your

10449
06:56:04,630 --> 06:56:05,932
understanding that the peaks

10450
06:56:05,932 --> 06:56:07,433
using the 4 cp bottle is

10451
06:56:07,433 --> 06:56:08,330
JANUARY JUNE JULY and AUGUST is

10452
06:56:08,330 --> 06:56:09,968
that correct.

10453
06:56:09,968 --> 06:56:11,170
>> teco Witness: that would be

10454
06:56:11,170 --> 06:56:12,906
correct JUNE JULY and AUGUST

10455
06:56:12,906 --> 06:56:14,908
the peak was that on.

10456
06:56:14,908 --> 06:56:16,750
Can we go to the section net

10457
06:56:16,750 --> 06:56:16,942
integrated retail firm peak

10458
06:56:16,942 --> 06:56:18,277
data.

10459
06:56:18,277 --> 06:56:20,277
Alone ron line 129.

10460
06:56:20,579 --> 06:56:22,579
This

10461
06:56:23,416 --> 06:56:25,451
section includes for each month

10462
06:56:25,451 --> 06:56:27,420
total that was available for

10463
06:56:27,420 --> 06:56:28,587
interruption.

10464
06:56:28,587 --> 06:56:30,220
>> teco Witness: I'm sorry

10465
06:56:30,220 --> 06:56:30,123
where are we looking

10466
06:56:30,123 --> 06:56:32,123
.

10467
06:56:34,193 --> 06:56:34,293
>> Florida Rising: on line 129

10468
06:56:34,293 --> 06:56:36,293
.

10469
06:56:38,665 --> 06:56:38,757
>> teco Witness: okay

10470
06:56:38,757 --> 06:56:40,735
.

10471
06:56:40,735 --> 06:56:42,735
>> Florida Rising: that line

10472
06:56:42,735 --> 06:56:45,135
represent the monthly total

10473
06:56:45,138 --> 06:56:45,437
available megawatts they can be

10474
06:56:45,437 --> 06:56:47,306
interrupted?

10475
06:56:47,306 --> 06:56:47,540
>> teco Witness: that's

10476
06:56:47,540 --> 06:56:49,309
correct.

10477
06:56:49,309 --> 06:56:51,577
>> Florida Rising: the actual

10478
06:56:51,577 --> 06:56:53,613
the total megawatts actually

10479
06:56:53,613 --> 06:56:55,114
curtailed for that months is

10480
06:56:55,114 --> 06:56:57,514
represented by line 123 which

10481
06:56:59,180 --> 06:56:59,352
is called curtailed megawatts

10482
06:56:59,352 --> 06:57:01,154
interruptible.

10483
06:57:01,154 --> 06:57:03,554
>> teco Witness: yes 123 and

10484
06:57:04,230 --> 06:57:04,290
128.

10485
06:57:04,290 --> 06:57:06,226
123 york).

10486
06:57:06,226 --> 06:57:08,930
>> Florida Rising: subject to

10487
06:57:08,930 --> 06:57:11,930
check looking across the row

10488
06:57:16,402 --> 06:57:17,637
for potentially curtailed will

10489
06:57:17,637 --> 06:57:19,439
that line 123 range is roughly

10490
06:57:19,439 --> 06:57:19,639
180-260 mw depending on the

10491
06:57:19,639 --> 06:57:21,441
month.

10492
06:57:21,441 --> 06:57:22,575
>> teco Witness: that is

10493
06:57:22,575 --> 06:57:23,543
correct.

10494
06:57:23,543 --> 06:57:25,511
>> Florida Rising: those

10495
06:57:25,511 --> 06:57:27,446
potential portable megawatts or

10496
06:57:27,446 --> 06:57:28,647
the basis for credits for

10497
06:57:28,647 --> 06:57:30,583
interruptible customers.

10498
06:57:30,583 --> 06:57:33,583
>> teco Witness: I'm not sure

10499
06:57:34,320 --> 06:57:37,920
for these purposes it is we

10500
06:57:44,263 --> 06:57:46,466
produce to get the firm load to

10501
06:57:46,466 --> 06:57:48,400
do reserve margin calculations.

10502
06:57:48,400 --> 06:57:50,269
As far as credits to customers

10503
06:57:50,269 --> 06:57:50,502
I don't know if the same

10504
06:57:50,502 --> 06:57:52,272
amount.

10505
06:57:52,272 --> 06:57:53,405
>> Florida Rising: questions

10506
06:57:53,405 --> 06:57:55,275
about how retail how the

10507
06:57:55,275 --> 06:57:57,275
credits articulate for

10508
06:57:57,276 --> 06:57:58,744
interruptible customers will be

10509
06:57:58,744 --> 06:57:59,412
best directed to another

10510
06:57:59,412 --> 06:58:00,346
witness.

10511
06:58:00,346 --> 06:58:00,646
>> teco Witness: yes.

10512
06:58:00,646 --> 06:58:02,348
>> Florida

10513
06:58:02,348 --> 06:58:03,516
Rising: you agree if

10514
06:58:03,516 --> 06:58:05,351
you look across the road the

10515
06:58:05,351 --> 06:58:07,287
teco did not interrupt or

10516
06:58:07,287 --> 06:58:08,821
curtail any load from those

10517
06:58:08,821 --> 06:58:09,355
customers at any point over the

10518
06:58:09,355 --> 06:58:10,556
year.

10519
06:58:10,556 --> 06:58:12,458
>> teco Witness: at any time of

10520
06:58:12,458 --> 06:58:14,293
the peak there could have been

10521
06:58:14,293 --> 06:58:15,428
another hour there was not

10522
06:58:15,428 --> 06:58:17,296
reported monthly peak that

10523
06:58:17,296 --> 06:58:17,630
could have been an

10524
06:58:17,630 --> 06:58:19,432
interruption.

10525
06:58:19,432 --> 06:58:20,366
This was one point in time for

10526
06:58:20,366 --> 06:58:22,268
each month.

10527
06:58:22,268 --> 06:58:23,402
>> Florida Rising: sure. Do

10528
06:58:23,402 --> 06:58:25,802
your knowledge does teco

10529
06:58:27,673 --> 06:58:28,941
interrupt its curtail book

10530
06:58:28,941 --> 06:58:29,808
customers a time other than the

10531
06:58:29,808 --> 06:58:31,644
peak periods.

10532
06:58:31,644 --> 06:58:32,779
>> teco Witness: I cannot

10533
06:58:32,779 --> 06:58:35,779
answer that I'm not sure.

10534
06:58:40,286 --> 06:58:41,454
I would think they could.

10535
06:58:41,454 --> 06:58:43,355
>> Florida Rising: you don't

10536
06:58:43,355 --> 06:58:45,358
have any evidence that they do.

10537
06:58:45,358 --> 06:58:47,293
>> teco Witness: what would say

10538
06:58:47,293 --> 06:58:48,494
if they did interrupt that

10539
06:58:48,494 --> 06:58:50,497
would reduce the peak it MAY

10540
06:58:50,497 --> 06:58:52,298
not show up as the monthly peak

10541
06:58:52,298 --> 06:58:53,766
does that make sense?

10542
06:58:53,766 --> 06:58:55,301
>> Florida Rising: if they

10543
06:58:55,301 --> 06:58:56,535
interrupted it would show up as

10544
06:58:56,535 --> 06:58:57,403
reducing the firm load is that

10545
06:58:57,403 --> 06:58:59,305
not true?

10546
06:58:59,305 --> 06:59:00,806
>> teco Witness: it would

10547
06:59:00,806 --> 06:59:02,374
produce the firm load I don't

10548
06:59:02,374 --> 06:59:04,310
know if it would reduce the

10549
06:59:04,310 --> 06:59:04,577
actual peak load on these

10550
06:59:04,577 --> 06:59:06,512
reports.

10551
06:59:06,512 --> 06:59:08,481
>> Florida Rising: fair enough.

10552
06:59:08,481 --> 06:59:10,316
We will move on now to the same

10553
06:59:10,316 --> 06:59:12,716
report for 2020. The number

10554
06:59:13,419 --> 06:59:15,819
there is f16-90.

10555
06:59:17,390 --> 06:59:18,558
We did some groundwork on that

10556
06:59:18,558 --> 06:59:20,426
first one I think we can move

10557
06:59:20,426 --> 06:59:22,561
through the following years

10558
06:59:22,561 --> 06:59:23,662
quickly.

10559
06:59:23,662 --> 06:59:25,662
>> teco Witness: okay.

10560
06:59:36,942 --> 06:59:38,811
>> Florida Rising: if we can go

10561
06:59:38,811 --> 06:59:41,981
back down to the retail peak

10562
06:59:41,981 --> 06:59:44,381
section beginning with row 115.

10563
06:59:44,683 --> 06:59:47,830
Thank you. Four 2020 JANUARY

10564
06:59:54,226 --> 06:59:54,460
was forecast to the peak of

10565
06:59:54,460 --> 06:59:56,162
4384 mw?

10566
06:59:56,162 --> 06:59:56,662
>> teco Witness: that is

10567
06:59:56,662 --> 06:59:58,430
correct.

10568
06:59:58,430 --> 07:00:00,399
>> Florida Rising: three row

10569
07:00:00,399 --> 07:00:01,534
above that the actual peak for

10570
07:00:01,534 --> 07:00:03,269
JANUARY is 3538?

10571
07:00:03,269 --> 07:00:04,470
>> teco Witness: that is

10572
07:00:04,470 --> 07:00:08,700
correct it was 37b0 peak versus

10573
07:00:09,641 --> 07:00:10,776
31.

10574
07:00:10,776 --> 07:00:12,644
>> Florida Rising: that

10575
07:00:12,644 --> 07:00:12,878
forecast was 90% higher than

10576
07:00:12,878 --> 07:00:14,646
actual.

10577
07:00:14,646 --> 07:00:15,781
>> teco Witness: correct.

10578
07:00:15,781 --> 07:00:17,781
>> Florida Rising: looking

10579
07:00:17,817 --> 07:00:19,918
across the rest of the forecast

10580
07:00:19,918 --> 07:00:20,886
row JANUARY was expected to be

10581
07:00:20,886 --> 07:00:22,886
the peak for 2020?

10582
07:00:22,888 --> 07:00:23,656
>> teco Witness: JANUARY was

10583
07:00:23,656 --> 07:00:24,890
yes.

10584
07:00:24,890 --> 07:00:26,692
>> Florida Rising: the actual

10585
07:00:26,692 --> 07:00:26,959
p4 2020 was 4255 mw for

10586
07:00:26,959 --> 07:00:28,694
SEPTEMBER.

10587
07:00:28,694 --> 07:00:28,928
>> teco Witness: that is

10588
07:00:28,928 --> 07:00:30,928
correct.

10589
07:00:30,929 --> 07:00:32,765
>> Florida Rising: SEPTEMBER is

10590
07:00:32,765 --> 07:00:33,866
not one of the fortune one

10591
07:00:33,866 --> 07:00:35,866
months we discussed?

10592
07:00:36,869 --> 07:00:38,700
>> teco Witness: no it is not.

10593
07:00:38,700 --> 07:00:40,600
>> Florida Rising: looking at

10594
07:00:40,600 --> 07:00:42,800
the actual peak for january

10595
07:00:42,800 --> 07:00:43,976
3538 mw actual peak was higher

10596
07:00:43,976 --> 07:00:47,576
in MARCH APRIL MAY JUNE JULY

10597
07:00:51,851 --> 07:00:52,985
AUGUST SEPTEMBER and OCTOBER.

10598
07:00:52,985 --> 07:00:53,852
>> teco Witness: that is

10599
07:00:53,852 --> 07:00:55,321
correct.

10600
07:00:55,321 --> 07:00:56,856
>> Florida Rising: putting

10601
07:00:56,856 --> 07:00:58,390
aside the month of JUNE until

10602
07:00:58,390 --> 07:00:59,325
AUGUST that is high months with

10603
07:00:59,325 --> 07:00:59,925
higher demand than JANUARY

10604
07:00:59,925 --> 07:01:00,225
is

10605
07:01:00,225 --> 07:01:00,392
4cp months.

10606
07:01:00,392 --> 07:01:02,270
>>

10607
07:01:02,270 --> 07:01:02,160
teco Witness: that would be)

10608
07:01:02,160 --> 07:01:03,328
.

10609
07:01:03,328 --> 07:01:05,196
>> Florida Rising: if we go to

10610
07:01:05,196 --> 07:01:06,432
the net integrated retail firm

10611
07:01:06,432 --> 07:01:09,432
peak data looking across line

10612
07:01:12,171 --> 07:01:14,171
130.

10613
07:01:14,206 --> 07:01:17,206
Teco did not interrupt or

10614
07:01:18,277 --> 07:01:18,777
curtail any load for many of

10615
07:01:18,777 --> 07:01:19,477
the interruptible

10616
07:01:19,477 --> 07:01:21,313
curtailed

10617
07:01:21,313 --> 07:01:22,447
customers during the year.

10618
07:01:22,447 --> 07:01:24,847
>> teco Witness: that is

10619
07:01:25,684 --> 07:01:26,853
correct.

10620
07:01:26,853 --> 07:01:28,754
>> Florida Rising: we are

10621
07:01:28,754 --> 07:01:29,988
flying we go to the report for

10622
07:01:29,988 --> 07:01:33,588
2021 the number on that is f16-

10623
07:01:36,280 --> 07:01:37,262
91.

10624
07:01:37,262 --> 07:01:39,198
When that is open we will go

10625
07:01:39,198 --> 07:01:42,798
back to the retail peak demand

10626
07:02:09,261 --> 07:02:11,261
on row 126.

10627
07:02:23,475 --> 07:02:25,377
If you look on row one 31

10628
07:02:25,377 --> 07:02:26,545
JANUARY 2021 was forecast of a

10629
07:02:26,545 --> 07:02:27,513
peak of 4400 mw?

10630
07:02:27,513 --> 07:02:29,481
>> teco Witness: yes.

10631
07:02:29,481 --> 07:02:31,881
>> Florida Rising: actual peak

10632
07:02:40,459 --> 07:02:40,892
demand for JANUARY is 2195 mw

10633
07:02:40,892 --> 07:02:42,460
.

10634
07:02:42,460 --> 07:02:44,630
>> Florida Rising: trench was

10635
07:02:44,630 --> 07:02:44,864
forecast with 31% higher than

10636
07:02:44,864 --> 07:02:45,931
actual.

10637
07:02:45,931 --> 07:02:47,931
> teco Witness: yes.

10638
07:02:47,933 --> 07:02:49,670
>> Florida Rising: JANUARY was

10639
07:02:49,670 --> 07:02:50,200
forecast to be the annual peak

10640
07:02:50,200 --> 07:02:51,269
for 2021.

10641
07:02:51,269 --> 07:02:53,380
>> teco Witness: yes.

10642
07:02:53,380 --> 07:02:54,205
>> Florida Rising: actual peak

10643
07:02:54,205 --> 07:02:54,973
for 2021 was 4293 mw in

10644
07:02:54,973 --> 07:02:56,842
AUGUST?

10645
07:02:56,842 --> 07:02:57,109
>> teco Witness: that is

10646
07:02:57,109 --> 07:02:58,978
correct.

10647
07:02:58,978 --> 07:03:00,879
>> Florida Rising: looking

10648
07:03:00,879 --> 07:03:01,980
official pay for JANUARY >>

10649
07:03:01,980 --> 07:03:03,949
Florida Rising: looking

10650
07:03:03,949 --> 07:03:05,885
official pay for JANUARY 2000

10651
07:03:05,885 --> 07:03:07,119
905 mw the peak was higher in

10652
07:03:07,119 --> 07:03:07,318
every single other month of the

10653
07:03:07,318 --> 07:03:08,987
year.

10654
07:03:08,987 --> 07:03:10,422
> teco Witness: that

10655
07:03:10,422 --> 07:03:12,900
is usually the case in JANUARY

10656
07:03:12,900 --> 07:03:13,992
if we don't have a winter peak.

10657
07:03:13,992 --> 07:03:15,940
JUNE JULY and AUGUST the peaks

10658
07:03:15,940 --> 07:03:16,995
are typically higher ones.

10659
07:03:16,995 --> 07:03:17,997
Like I said we forecast for a

10660
07:03:17,997 --> 07:03:19,970
cold winter peak.

10661
07:03:19,970 --> 07:03:21,497
We cannot avoid that.

10662
07:03:21,901 --> 07:03:23,200
>> Florida Rising: once again

10663
07:03:23,200 --> 07:03:24,903
putting aside the month of JUNE

10664
07:03:24,903 --> 07:03:26,905
-AUGUST is eight months higher

10665
07:03:26,905 --> 07:03:28,908
than JANUARY outside of their

10666
07:03:28,908 --> 07:03:30,800
4cp months if we go to the net

10667
07:03:30,800 --> 07:03:31,877
integrated firm data.

10668
07:03:31,877 --> 07:03:33,879
On line 41 shows teco did not

10669
07:03:33,879 --> 07:03:35,413
interrupt or curtail any load

10670
07:03:35,413 --> 07:03:36,949
from interruptible or curtail

10671
07:03:36,949 --> 07:03:38,851
book customers during any

10672
07:03:38,851 --> 07:03:39,985
monthly peaks of the year.

10673
07:03:39,985 --> 07:03:40,218
>> teco Witness: thumbs

10674
07:03:40,218 --> 07:03:42,530
correct.

10675
07:03:42,530 --> 07:03:44,453
>> Florida Rising: let's move

10676
07:03:51,763 --> 07:03:54,163
on to 2020 2f.6-92.

10677
07:03:54,966 --> 07:03:57,966
Retail peak demand row 131 in

10678
07:04:03,408 --> 07:04:05,408
this document.

10679
07:04:10,949 --> 07:04:12,851
Okay a few lines below that

10680
07:04:12,851 --> 07:04:14,119
JANUARY 2022 was forecast of a

10681
07:04:14,119 --> 07:04:14,953
peak of 4461 mw?

10682
07:04:14,953 --> 07:04:16,855
>> teco Witness: yes.

10683
07:04:16,855 --> 07:04:18,223
>> Florida Rising: actual peak

10684
07:04:18,223 --> 07:04:18,390
demand was 3731 mw.

10685
07:04:18,390 --> 07:04:19,230
> teco

10686
07:04:19,230 --> 07:04:19,157
Witness:

10687
07:04:19,157 --> 07:04:20,592
yes.

10688
07:04:20,592 --> 07:04:22,592
>> Florida Rising: teco's

10689
07:04:23,361 --> 07:04:25,761
forecast was 3% higher than

10690
07:04:27,666 --> 07:04:29,101
actual if you look across the

10691
07:04:29,101 --> 07:04:31,501
forecast bro general response

10692
07:04:32,437 --> 07:04:32,704
to bp for JANUARY 2022

10693
07:04:32,704 --> 07:04:33,705
annually.

10694
07:04:33,705 --> 07:04:35,705
>> teco Witness: yes.

10695
07:04:39,100 --> 07:04:40,212
>> Florida Rising: actual peak

10696
07:04:40,212 --> 07:04:42,130
for 2022 was 4385 mw in JUNE.

10697
07:04:42,130 --> 07:04:43,215
>> teco Witness: yes.

10698
07:04:43,215 --> 07:04:45,830
>> Florida Rising: looking at

10699
07:04:45,830 --> 07:04:46,585
the actual peak demand for

10700
07:04:46,585 --> 07:04:49,585
JANUARY the actual peak was

10701
07:04:50,488 --> 07:04:51,523
higher in MAY-september?

10702
07:04:51,523 --> 07:04:53,491
>> teco Witness: yes.

10703
07:04:53,491 --> 07:04:54,960
>> Florida Rising: that is two

10704
07:04:54,960 --> 07:04:56,280
months with higher peak in

10705
07:04:56,280 --> 07:04:56,728
JANUARY outside of the 4cp

10706
07:04:56,728 --> 07:04:58,396
months.

10707
07:04:58,396 --> 07:04:58,491
>> teco Witness: correct

10708
07:04:58,491 --> 07:05:00,398
.

10709
07:05:00,398 --> 07:05:02,798
>> Florida Rising: at line 146

10710
07:05:06,604 --> 07:05:07,506
confirming teco did not

10711
07:05:07,506 --> 07:05:08,607
interrupt or

10712
07:05:08,607 --> 07:05:09,808
curtail any

10713
07:05:09,808 --> 07:05:11,610
customers during any of the

10714
07:05:11,610 --> 07:05:11,710
monthly peaks of the year.

10715
07:05:11,710 --> 07:05:12,430
>

10716
07:05:12,430 --> 07:05:13,612
teco Witness:

10717
07:05:13,612 --> 07:05:15,113
that is correct.

10718
07:05:15,113 --> 07:05:16,748
>> Florida Rising: moving onto

10719
07:05:16,748 --> 07:05:18,616
the last one in the special

10720
07:05:18,616 --> 07:05:22,216
that is f16-93 the 2023 peak

10721
07:05:43,342 --> 07:05:44,576
demand.

10722
07:05:44,576 --> 07:05:47,576
JANUARY 2020 was forecast of a

10723
07:05:51,883 --> 07:05:52,817
peak of 4004 61 mw actual peak

10724
07:05:52,817 --> 07:05:53,585
with 3247 mw.

10725
07:05:53,585 --> 07:05:53,918
>> teco

10726
07:05:53,918 --> 07:05:55,918
Witness: gas.

10727
07:05:56,722 --> 07:05:58,189
>> Florida Rising: which was a

10728
07:05:58,189 --> 07:05:59,324
variance 25% higher than

10729
07:05:59,324 --> 07:06:01,324
actual.

10730
07:06:01,493 --> 07:06:01,593
>> teco Witness: yes

10731
07:06:01,593 --> 07:06:03,593
.

10732
07:06:03,595 --> 07:06:05,995
>> Florida Rising: JANUARY was

10733
07:06:07,732 --> 07:06:09,635
expected to do peak for 2023.

10734
07:06:09,635 --> 07:06:10,935
>> teco Witness: JANUARY is

10735
07:06:10,935 --> 07:06:12,637
always the peak.

10736
07:06:12,637 --> 07:06:13,404
>> Florida Rising: actual peak

10737
07:06:13,404 --> 07:06:15,207
was AUGUST for 4659 mw.

10738
07:06:15,207 --> 07:06:16,408
>> teco Witness: yes.

10739
07:06:16,408 --> 07:06:18,808
>> Florida Rising: looking at

10740
07:06:20,479 --> 07:06:21,480
the monthly peaks were higher

10741
07:06:21,480 --> 07:06:22,847
in MARCH through NOVEMBER.

10742
07:06:22,847 --> 07:06:24,483
>> teco Witness: yes.

10743
07:06:24,483 --> 07:06:26,485
>> Florida Rising: that is six

10744
07:06:26,485 --> 07:06:28,190
months with therapies outside

10745
07:06:28,190 --> 07:06:28,152
of teco is 4cp months

10746
07:06:28,152 --> 07:06:29,488
.

10747
07:06:29,488 --> 07:06:31,156
>> teco Witness: yes.

10748
07:06:31,156 --> 07:06:32,324
>> Florida Rising: if we go to

10749
07:06:32,324 --> 07:06:34,724
line 143 looking across at

10750
07:06:36,595 --> 07:06:37,696
NOVEMBER teco curtailed 109 mw

10751
07:06:37,696 --> 07:06:39,696
of interruptible customers.

10752
07:06:40,832 --> 07:06:43,232
>> teco Witness: in NOVEMBER.

10753
07:06:50,800 --> 07:06:51,243
That was the only instance of

10754
07:06:51,243 --> 07:06:53,144
curtailment we seen in the five

10755
07:06:53,144 --> 07:06:54,212
years of annual review we have

10756
07:06:54,212 --> 07:06:55,213
two review.

10757
07:06:55,213 --> 07:06:57,613
>> teco Witness: within five

10758
07:06:58,160 --> 07:06:58,616
years I thought we reported one

10759
07:06:58,616 --> 07:07:00,251
more don't know when that was.

10760
07:07:00,251 --> 07:07:02,987
It did not fall obviously on

10761
07:07:02,987 --> 07:07:04,222
any of the peak times.

10762
07:07:04,222 --> 07:07:07,222
>> Florida Rising: you might be

10763
07:07:09,527 --> 07:07:13,127
right I think you are right.

10764
07:07:17,535 --> 07:07:20,139
If we can also look in row 130

10765
07:07:20,139 --> 07:07:22,539
and 131 I'm looking at

10766
07:07:22,741 --> 07:07:24,741
NOVEMBER.

10767
07:07:27,979 --> 07:07:29,982
There peak for the month of

10768
07:07:29,982 --> 07:07:30,983
NOVEMBER occurred in the hour

10769
07:07:30,983 --> 07:07:32,983
ending in 5 pm?

10770
07:07:36,870 --> 07:07:36,235
>> teco Witness: in NOVEMBER

10771
07:07:36,235 --> 07:07:38,156
.

10772
07:07:38,156 --> 07:07:40,556
>> Florida Rising: I'm looking

10773
07:07:45,730 --> 07:07:47,632
at the cells and 130 I'm sorry

10774
07:07:47,632 --> 07:07:48,700
that is the hour ending at 4

10775
07:07:48,700 --> 07:07:51,100
pm. You are right.

10776
07:07:54,639 --> 07:07:54,973
The mint temperature at the

10777
07:07:54,973 --> 07:07:55,773
time was 87b0.

10778
07:07:55,773 --> 07:07:56,708
>> teco Witness: that is

10779
07:07:56,708 --> 07:07:58,143
correct.

10780
07:07:58,143 --> 07:07:59,811
>> Florida Rising: I left one

10781
07:07:59,811 --> 07:08:01,646
thing out in the 2022 report if

10782
07:08:01,646 --> 07:08:01,880
we can go back to that really

10783
07:08:01,880 --> 07:08:03,880
quickly.

10784
07:08:06,985 --> 07:08:08,985
F16-92.

10785
07:08:12,824 --> 07:08:14,250
Thank you.

10786
07:08:14,250 --> 07:08:15,927
There if we can go to the same

10787
07:08:15,927 --> 07:08:17,829
place looking at the peak for

10788
07:08:17,829 --> 07:08:20,229
NOVEMBER the time and

10789
07:08:21,867 --> 07:08:23,867
temperature. For NOVEMBER 2022

10790
07:08:23,869 --> 07:08:26,337
at the peak occurred in the

10791
07:08:26,337 --> 07:08:26,438
hour ending in 5 pm

10792
07:08:26,438 --> 07:08:28,407
.

10793
07:08:28,407 --> 07:08:29,474
>> teco Witness: I don't have

10794
07:08:29,474 --> 07:08:31,874
between two up yet.

10795
07:08:34,612 --> 07:08:36,612
2022 up

10796
07:08:36,982 --> 07:08:38,950
yet. I cannot see (.

10797
07:08:38,950 --> 07:08:41,350
>> Florida Rising: that is

10798
07:08:59,504 --> 07:09:00,972
fair.

10799
07:09:00,972 --> 07:09:03,372
>> teco Witness: thank you.

10800
07:09:05,176 --> 07:09:07,112
>> Florida Rising: I apologize

10801
07:09:07,112 --> 07:09:08,813
for missing this when we were

10802
07:09:08,813 --> 07:09:10,140
on the document.

10803
07:09:10,140 --> 07:09:11,516
>> teco Witness: what are we

10804
07:09:11,516 --> 07:09:11,615
looking at again

10805
07:09:11,615 --> 07:09:13,615
.

10806
07:09:13,618 --> 07:09:16,180
>> Florida Rising: looking at

10807
07:09:18,122 --> 07:09:21,122
the NOVEMBER peak row 133 and

10808
07:09:21,860 --> 07:09:23,610
134.

10809
07:09:23,610 --> 07:09:24,929
The peak for the month of

10810
07:09:24,929 --> 07:09:26,564
NOVEMBER occurred in at the

10811
07:09:26,564 --> 07:09:26,651
hour ending at 5 pm

10812
07:09:26,651 --> 07:09:27,765
.

10813
07:09:27,765 --> 07:09:30,165
>> teco Witness: that is

10814
07:09:30,235 --> 07:09:30,334
correct

10815
07:09:30,334 --> 07:09:31,236
.

10816
07:09:31,236 --> 07:09:32,304
>> Florida

10817
07:09:32,304 --> 07:09:33,537
Rising: the ambient

10818
07:09:33,537 --> 07:09:34,306
temperature at the time was 86b0

10819
07:09:34,306 --> 07:09:34,773
.

10820
07:09:34,773 --> 07:09:35,373
>> teco Witness: yes.

10821
07:09:35,373 --> 07:09:36,507
>

10822
07:09:36,507 --> 07:09:39,507
Florida Rising: we are done.

10823
07:09:39,510 --> 07:09:41,513
>> teco Witness: you don't have

10824
07:09:41,513 --> 07:09:42,714
the 2024 peak demand report I

10825
07:09:42,714 --> 07:09:45,714
want to reiterate in our

10826
07:09:46,818 --> 07:09:48,820
JANUARY peak I'm not talking

10827
07:09:48,820 --> 07:09:50,210
4cp I'm just talking in general

10828
07:09:50,210 --> 07:09:51,789
are generally peaks are always

10829
07:09:51,789 --> 07:09:53,240
going to be our highest peak

10830
07:09:53,240 --> 07:09:56,624
because with the plan for the

10831
07:09:56,795 --> 07:09:59,697
31b0 winter peak we need to make

10832
07:09:59,697 --> 07:10:01,699
sure we have enough capacity

10833
07:10:01,699 --> 07:10:02,700
underground to serve a winter

10834
07:10:02,700 --> 07:10:03,734
peak.

10835
07:10:03,734 --> 07:10:05,269
We don't have one every year

10836
07:10:05,269 --> 07:10:06,700
but we still have the plan for

10837
07:10:06,700 --> 07:10:07,338
that.

10838
07:10:07,338 --> 07:10:09,274
I just want to point out again

10839
07:10:09,274 --> 07:10:11,108
our JUNE and JULY are less two

10840
07:10:11,108 --> 07:10:12,276
months the peaks are within 8

10841
07:10:12,276 --> 07:10:15,480
mw that is 2/10 of a percent

10842
07:10:15,480 --> 07:10:17,348
our current forecast are used

10843
07:10:17,348 --> 07:10:20,348
in this proceeding are very

10844
07:10:22,153 --> 07:10:24,153
accurate.

10845
07:10:24,488 --> 07:10:28,880
>> Florida Rising: can we go to

10846
07:10:42,340 --> 07:10:45,940
f1 6-97 exhibit 831 we will go

10847
07:11:08,767 --> 07:11:09,100
to the tab total retail.

10848
07:11:09,100 --> 07:11:10,835
Are you there.

10849
07:11:10,835 --> 07:11:13,835
>> teco Witness: I am here.

10850
07:11:16,741 --> 07:11:18,609
>> Florida Rising: this

10851
07:11:18,609 --> 07:11:19,777
document with establishing the

10852
07:11:19,777 --> 07:11:22,177
historical retail peak from

10853
07:11:26,519 --> 07:11:27,652
1973 until 2023?

10854
07:11:27,652 --> 07:11:28,520
>> teco Witness: this

10855
07:11:28,520 --> 07:11:29,587
is one of

10856
07:11:29,587 --> 07:11:31,456
our working files.

10857
07:11:31,456 --> 07:11:33,357
>> Florida Rising: the bold

10858
07:11:33,357 --> 07:11:34,492
blue numbers in this chart

10859
07:11:34,492 --> 07:11:36,427
represents summer peaks.

10860
07:11:36,427 --> 07:11:37,494
>> teco Witness: I think that

10861
07:11:37,494 --> 07:11:39,330
was the intent.

10862
07:11:39,330 --> 07:11:41,330
>> Florida Rising: presumably

10863
07:11:42,660 --> 07:11:43,267
the blue is for cooling

10864
07:11:43,267 --> 07:11:45,203
compared to the red for heating

10865
07:11:45,203 --> 07:11:47,205
for the other bullet numbers.

10866
07:11:47,205 --> 07:11:48,273
>> teco Witness: it is called

10867
07:11:48,273 --> 07:11:50,673
peak versus hot peak.

10868
07:11:59,650 --> 07:12:01,486
>> Florida Rising: generally

10869
07:12:01,486 --> 07:12:02,753
speaking called peaks and

10870
07:12:02,753 --> 07:12:04,588
heartbeats are interchangeable

10871
07:12:04,588 --> 07:12:06,590
the summer and winter peaks.

10872
07:12:06,590 --> 07:12:07,492
Amanda flipped those but that

10873
07:12:07,492 --> 07:12:08,926
is the idea.

10874
07:12:08,926 --> 07:12:09,727
>> teco Witness: yes. I get

10875
07:12:09,727 --> 07:12:11,727
what you're saying.

10876
07:12:11,729 --> 07:12:14,129
>> Florida Rising: started with

10877
07:12:14,498 --> 07:12:15,566
the blue bullet numbers one

10878
07:12:15,566 --> 07:12:17,935
year had looking at the role we

10879
07:12:17,935 --> 07:12:19,700
will look at MAY.

10880
07:12:19,700 --> 07:12:22,670
Are you on the tab total

10881
07:12:25,576 --> 07:12:26,844
retail?

10882
07:12:26,844 --> 07:12:28,679
>> Florida Rising: if you go to

10883
07:12:28,679 --> 07:12:30,614
the column for MAY you would

10884
07:12:30,614 --> 07:12:33,614
agree scrolling down that there

10885
07:12:35,253 --> 07:12:35,552
is one year for which the

10886
07:12:35,552 --> 07:12:36,387
summer peak

10887
07:12:36,387 --> 07:12:38,189
fell in MAY?

10888
07:12:38,189 --> 07:12:38,293
>> teco Witness: yes.

10889
07:12:38,293 --> 07:12:39,456
>

10890
07:12:39,456 --> 07:12:42,293
Florida Rising: if we look over

10891
07:12:42,293 --> 07:12:45,229
at SEPTEMBER and count five

10892
07:12:45,229 --> 07:12:48,532
years the summer peak fell in

10893
07:12:48,532 --> 07:12:49,634
SEPTEMBER?

10894
07:12:49,634 --> 07:12:51,568
>> teco Witness: yes.

10895
07:12:51,568 --> 07:12:52,970
>> Florida Rising: looking at

10896
07:12:52,970 --> 07:12:55,606
the red numbers going first to

10897
07:12:55,606 --> 07:12:57,508
the column for FEBRUARY would

10898
07:12:57,508 --> 07:13:00,311
you agree there are 13 years

10899
07:13:00,311 --> 07:13:01,512
with a winter peak in FEBRUARY?

10900
07:13:01,512 --> 07:13:02,646
I will give you a second to

10901
07:13:02,646 --> 07:13:04,646
count.

10902
07:13:06,950 --> 07:13:07,818
>> teco Witness: how many did

10903
07:13:07,818 --> 07:13:09,487
you say.

10904
07:13:09,487 --> 07:13:11,487
>> Florida Rising: 13?

10905
07:13:13,900 --> 07:13:14,291
>> teco Witness: I counted 15?

10906
07:13:14,291 --> 07:13:17,291
>> Florida Rising: we can take

10907
07:13:18,729 --> 07:13:19,964
15.

10908
07:13:19,964 --> 07:13:21,865
>> teco Witness: now I counted

10909
07:13:21,865 --> 07:13:25,465
12 I will go with your number.

10910
07:13:26,360 --> 07:13:27,872
>> Florida Rising: I genuinely

10911
07:13:27,872 --> 07:13:29,140
believe it is 13 but it's

10912
07:13:29,140 --> 07:13:30,374
entirely possible I miscounted.

10913
07:13:30,374 --> 07:13:32,744
Looking now at the column for

10914
07:13:32,744 --> 07:13:33,944
MARCH.

10915
07:13:33,944 --> 07:13:36,647
There are five printer peak

10916
07:13:36,647 --> 07:13:37,881
spring with the winter peak

10917
07:13:37,881 --> 07:13:39,881
occurring in MARCH?

10918
07:13:42,987 --> 07:13:44,889
Then moving to the column for

10919
07:13:44,889 --> 07:13:46,157
NOVEMBER there were four with

10920
07:13:46,157 --> 07:13:48,157
printer peak NOVEMBER?

10921
07:13:49,660 --> 07:13:51,596
>> teco Witness: yes.

10922
07:13:51,596 --> 07:13:52,863
>> Florida Rising: looking at

10923
07:13:52,863 --> 07:13:55,299
the column for DECEMBER there

10924
07:13:55,299 --> 07:13:55,767
were three years with a winter

10925
07:13:55,767 --> 07:13:55,899
peak in DECEMBER

10926
07:13:55,899 --> 07:13:57,100
.

10927
07:13:57,100 --> 07:13:58,870
>> teco Witness: yes.

10928
07:13:58,870 --> 07:14:00,872
>> Florida Rising: you would

10929
07:14:00,872 --> 07:14:02,874
agree that MARCH MAY SEPTEMBER

10930
07:14:02,874 --> 07:14:03,874
NOVEMBER and DECEMBER or onset

10931
07:14:03,874 --> 07:14:05,142
of the 4cp months?

10932
07:14:05,142 --> 07:14:06,878
>> teco Witness: can you repeat

10933
07:14:06,878 --> 07:14:06,977
that

10934
07:14:06,977 --> 07:14:08,946
.

10935
07:14:08,946 --> 07:14:09,680
>> Florida Rising: MARCH MAY

10936
07:14:09,680 --> 07:14:10,113
SEPTEMBER DECEMBER

10937
07:14:10,113 --> 07:14:11,983
are not

10938
07:14:11,983 --> 07:14:12,350
within the 4cp months we are

10939
07:14:12,350 --> 07:14:14,218
talking about.

10940
07:14:14,218 --> 07:14:16,253
>> teco Witness: correct if you

10941
07:14:16,253 --> 07:14:18,121
will accept my representation

10942
07:14:18,121 --> 07:14:21,721
on the separation that would be

10943
07:14:23,294 --> 07:14:24,795
25 years with which at least

10944
07:14:24,795 --> 07:14:25,529
one seasonal peak occurred

10945
07:14:25,529 --> 07:14:28,332
outside of the 4cp month

10946
07:14:28,332 --> 07:14:28,433
subject to check

10947
07:14:28,433 --> 07:14:30,670
.

10948
07:14:30,670 --> 07:14:32,467
>> teco Witness: subject check.

10949
07:14:32,570 --> 07:14:33,737
>> Florida Rising: that is 25

10950
07:14:33,737 --> 07:14:34,472
years out of 50 years of data

10951
07:14:34,472 --> 07:14:34,572
shown

10952
07:14:34,572 --> 07:14:35,707
.

10953
07:14:35,707 --> 07:14:37,241
>> teco Witness: if your

10954
07:14:37,241 --> 07:14:37,341
numbers are correct

10955
07:14:37,341 --> 07:14:39,341
.

10956
07:14:39,477 --> 07:14:40,712
>> Florida Rising: roughly 50%?

10957
07:14:40,712 --> 07:14:42,712
>> teco Witness: yes.

10958
07:14:45,116 --> 07:14:46,384
>> Florida Rising:

10959
07:14:46,384 --> 07:14:49,384
>> teco Witness: want to point

10960
07:14:51,355 --> 07:14:53,224
out JANUARY we see all the red

10961
07:14:53,224 --> 07:14:55,126
in JANUARY we have numerous

10962
07:14:55,126 --> 07:14:56,260
winter peaks.

10963
07:14:56,260 --> 07:15:00,531
When we do have one it is a

10964
07:15:00,531 --> 07:15:01,766
pretty high peak. Looking at

10965
07:15:01,766 --> 07:15:03,000
2010. That's been our highest

10966
07:15:03,000 --> 07:15:06,600
one of our highest peaks winter

10967
07:15:07,271 --> 07:15:09,271
peaks ever.

10968
07:15:09,306 --> 07:15:10,875
I just want to point that out

10969
07:15:10,875 --> 07:15:13,411
JANUARY is we have a winter in

10970
07:15:13,411 --> 07:15:14,711
JANUARY the peaks they are very

10971
07:15:14,711 --> 07:15:16,711
high.

10972
07:15:17,215 --> 07:15:19,830
>> Florida Rising: can we

10973
07:15:19,830 --> 07:15:21,752
scroll down to six can we

10974
07:15:21,752 --> 07:15:23,687
scroll down to 6l 52.

10975
07:15:23,687 --> 07:15:27,887
You will see that if you click

10976
07:15:28,959 --> 07:15:32,496
on that row or hover over it

10977
07:15:32,496 --> 07:15:35,499
there is a note that pops up.

10978
07:15:35,499 --> 07:15:37,634
MR. Schultz you might have to

10979
07:15:37,634 --> 07:15:37,734
enable it

10980
07:15:37,734 --> 07:15:38,969
.

10981
07:15:38,969 --> 07:15:41,969
>> teco Witness: I just enabled

10982
07:15:42,439 --> 07:15:44,439
it.

10983
07:15:48,245 --> 07:15:50,214
>> Florida Rising: MS. Fuentes

10984
07:15:50,214 --> 07:15:51,820
are you able to read without

10985
07:15:51,820 --> 07:15:52,282
notes as.

10986
07:15:52,282 --> 07:15:54,850
>> teco Witness: not yet I'm

10987
07:15:54,850 --> 07:15:55,850
trying to make it bigger.

10988
07:15:55,850 --> 07:15:55,285
Give me one minute.

10989
07:15:55,285 --> 07:15:57,285
> Florida

10990
07:16:00,825 --> 07:16:03,825
Rising: I'm in no rush.

10991
07:16:08,532 --> 07:16:09,767
Okay.

10992
07:16:09,767 --> 07:16:10,534
Can you make out what the note

10993
07:16:10,534 --> 07:16:12,534
says?

10994
07:16:12,803 --> 07:16:14,803
> teco Witness: I'm

10995
07:16:15,539 --> 07:16:16,807
trying to read it now.

10996
07:16:16,807 --> 07:16:18,750
>> Florida Rising: you can read

10997
07:16:18,750 --> 07:16:19,210
it.

10998
07:16:19,210 --> 07:16:20,243
>> teco Witness: yes I

10999
07:16:20,243 --> 07:16:22,460
understand the note.

11000
07:16:22,460 --> 07:16:24,460
>> Florida Rising: essentially

11001
07:16:24,470 --> 07:16:27,647
the note is indicating that the

11002
07:16:27,718 --> 07:16:29,786
peak for that winter occurred

11003
07:16:29,786 --> 07:16:31,789
on hot tape that was televised

11004
07:16:31,789 --> 07:16:34,558
megawatts usage in the NOVEMBER

11005
07:16:34,558 --> 07:16:36,600
MARCH season the counted and

11006
07:16:36,600 --> 07:16:36,162
winter for the 18/19 peak

11007
07:16:36,162 --> 07:16:37,940
.

11008
07:16:37,940 --> 07:16:37,395
>> teco Witness:

11009
07:16:37,395 --> 07:16:38,128
that is correct

11010
07:16:38,128 --> 07:16:39,130
.

11011
07:16:39,130 --> 07:16:42,130
>> Florida Rising: can we hover

11012
07:16:44,368 --> 07:16:48,305
over the row for d 54 it should

11013
07:16:48,305 --> 07:16:49,507
be a red bold.

11014
07:16:49,507 --> 07:16:53,176
Is that the same idea for the

11015
07:16:53,176 --> 07:16:55,179
peak for the winter of

11016
07:16:55,179 --> 07:16:56,313
2019-2020 fell on hot day?

11017
07:16:56,313 --> 07:16:58,713
>> teco Witness: that is

11018
07:16:59,416 --> 07:17:01,416
correct.

11019
07:17:04,822 --> 07:17:06,757
>> Florida Rising: for the cell

11020
07:17:06,757 --> 07:17:07,992
directly below that there is

11021
07:17:07,992 --> 07:17:08,859
another note to indicate the

11022
07:17:08,859 --> 07:17:10,859
same thing.

11023
07:17:10,995 --> 07:17:12,896
>> teco Witness: the same thing

11024
07:17:12,896 --> 07:17:14,765
we tend to mark those we need

11025
07:17:14,765 --> 07:17:16,767
to separate cold and hot peaks.

11026
07:17:16,767 --> 07:17:18,269
>> Florida Rising: for the two

11027
07:17:18,269 --> 07:17:19,570
bold peaks for 2020 2022 and

11028
07:17:19,570 --> 07:17:23,170
2023 there is not a note on

11029
07:17:27,178 --> 07:17:28,345
those days will be in column l.

11030
07:17:28,345 --> 07:17:28,545
Neither of those has a note

11031
07:17:28,545 --> 07:17:28,637
from

11032
07:17:28,637 --> 07:17:30,637
.

11033
07:17:31,715 --> 07:17:32,816
>> teco Witness: that would be

11034
07:17:32,816 --> 07:17:35,816
because it was a cold

11035
07:17:37,554 --> 07:17:38,789
temperature.

11036
07:17:38,789 --> 07:17:40,724
>> Florida Rising: can I recall

11037
07:17:40,724 --> 07:17:44,924
or focus on the never peaks on

11038
07:17:47,464 --> 07:17:49,499
the 2022 and 2023 demand report

11039
07:17:49,499 --> 07:17:50,500
we can go back to establish my

11040
07:17:50,500 --> 07:17:51,602
representation we

11041
07:17:51,602 --> 07:17:53,503
establishedoccurred on an

11042
07:17:53,503 --> 07:17:53,770
afternoon with the

11043
07:17:53,770 --> 07:17:55,639
temperatures

11044
07:17:55,639 --> 07:17:56,540
in the high upper 80s or in the

11045
07:17:56,540 --> 07:17:57,708
upper 80s.

11046
07:17:57,708 --> 07:17:59,543
>> teco Witness: I do recall

11047
07:17:59,543 --> 07:18:00,878
that we just did not put a

11048
07:18:00,878 --> 07:18:01,780
footnote for those.

11049
07:18:01,780 --> 07:18:02,646
> Florida

11050
07:18:02,646 --> 07:18:03,647
Rising: that's perfectly fine

11051
07:18:03,647 --> 07:18:05,616
that is not a track.

11052
07:18:05,616 --> 07:18:07,617
Just trying to confirm for 4/5

11053
07:18:07,617 --> 07:18:10,321
years for which that has been

11054
07:18:10,321 --> 07:18:12,956
provided 4cp's winter peaks are

11055
07:18:12,956 --> 07:18:14,591
driven by air conditioning use

11056
07:18:14,591 --> 07:18:17,494
on holidays rather than heating

11057
07:18:17,494 --> 07:18:19,494
on cold days.

11058
07:18:19,496 --> 07:18:19,697
>> teco Witness: can you repeat

11059
07:18:19,697 --> 07:18:21,499
that.

11060
07:18:21,499 --> 07:18:22,699
>> Florida Rising: looking at

11061
07:18:22,699 --> 07:18:25,703
the three notes we just looked

11062
07:18:25,703 --> 07:18:29,172
at then the other 2 notes the

11063
07:18:29,172 --> 07:18:30,674
other two that did not have the

11064
07:18:30,674 --> 07:18:32,674
notes.

11065
07:18:40,484 --> 07:18:42,452
This is actually it is 5/6 of

11066
07:18:42,452 --> 07:18:44,421
the most recent years to which

11067
07:18:44,421 --> 07:18:47,478
we have data that the winter

11068
07:18:47,478 --> 07:18:47,584
peak is driven by air

11069
07:18:47,584 --> 07:18:48,391
conditioning use?

11070
07:18:48,391 --> 07:18:49,526
>> teco Witness: it doesn't

11071
07:18:49,526 --> 07:18:51,328
look like that.

11072
07:18:51,328 --> 07:18:54,300
>> Florida Rising: can we go to

11073
07:18:54,300 --> 07:18:56,300
c 10 b

11074
07:19:01,939 --> 07:19:03,173
-six 112 this is your

11075
07:19:03,173 --> 07:19:06,173
exhibit lc 1 is document number

11076
07:19:27,665 --> 07:19:30,567
h. 8. Do you have the document

11077
07:19:30,567 --> 07:19:31,634
up?

11078
07:19:31,634 --> 07:19:34,634
>> teco Witness: I have to

11079
07:19:35,306 --> 07:19:37,306
scroll it.

11080
07:19:40,243 --> 07:19:41,412
Which one are you at?

11081
07:19:41,412 --> 07:19:43,812
>> Florida Rising: I'm on

11082
07:20:06,269 --> 07:20:08,172
document number eight 's this

11083
07:20:08,172 --> 07:20:09,473
shows an increase in the

11084
07:20:09,473 --> 07:20:10,307
expected winter peak beginning

11085
07:20:10,307 --> 07:20:12,209
in 2024?

11086
07:20:12,209 --> 07:20:13,343
>> teco Witness: correct.

11087
07:20:13,343 --> 07:20:15,379
>> Florida Rising: it also

11088
07:20:15,379 --> 07:20:17,214
shows a decrease in the summer

11089
07:20:17,214 --> 07:20:18,349
peak beginning in 2024.

11090
07:20:18,349 --> 07:20:19,349
>> teco Witness: that is

11091
07:20:19,349 --> 07:20:20,284
correct.

11092
07:20:20,284 --> 07:20:21,518
>> Florida Rising: you

11093
07:20:21,518 --> 07:20:23,320
attributed the projected growth

11094
07:20:23,320 --> 07:20:26,223
in the winter peaks to which

11095
07:20:26,223 --> 07:20:26,456
you characterize as recent mild

11096
07:20:26,456 --> 07:20:28,291
winters?

11097
07:20:28,291 --> 07:20:30,194
>> teco Witness: yes you can

11098
07:20:30,194 --> 07:20:31,461
see 2023 was a mild winter is

11099
07:20:31,461 --> 07:20:33,330
transitioning to 2024 which is

11100
07:20:33,330 --> 07:20:35,299
based on 31b0 winter peaks.

11101
07:20:35,299 --> 07:20:37,234
In the summer of 2023 it was

11102
07:20:37,234 --> 07:20:38,369
very hot summer we had our hair

11103
07:20:38,369 --> 07:20:40,270
higher summer peak number

11104
07:20:40,270 --> 07:20:41,405
versus 2024 we are

11105
07:20:41,405 --> 07:20:42,238
transitioning back to normal

11106
07:20:42,238 --> 07:20:43,640
weather.

11107
07:20:43,640 --> 07:20:45,242
That is why is lower.

11108
07:20:45,242 --> 07:20:47,642
>> Florida Rising: think you

11109
07:20:52,850 --> 07:20:57,500
can we go to number f16-100.

11110
07:21:21,912 --> 07:21:23,460
We will go to tab cp.

11111
07:21:23,460 --> 07:21:25,181
>> Florida Rising: this tab

11112
07:21:25,181 --> 07:21:28,781
shows the console data for the

11113
07:21:36,393 --> 07:21:37,927
peak in 2023.

11114
07:21:37,927 --> 07:21:38,428
>> teco Witness: yes this is

11115
07:21:38,428 --> 07:21:40,428
2023.

11116
07:21:40,431 --> 07:21:41,640
>> Florida Rising: for JANUARY

11117
07:21:41,640 --> 07:21:44,640
2023 there was a peak of 3347

11118
07:21:46,970 --> 07:21:49,573
mw the resident coincident peak

11119
07:21:49,573 --> 07:21:49,707
was 1845 mw

11120
07:21:49,707 --> 07:21:50,807
.

11121
07:21:50,807 --> 07:21:51,675
>> teco Witness: that is

11122
07:21:51,675 --> 07:21:52,376
correct.

11123
07:21:52,376 --> 07:21:54,776
>> Florida Rising: subject to

11124
07:21:57,948 --> 07:21:59,883
check you would divide if the

11125
07:21:59,883 --> 07:22:01,883
residential coincident peak

11126
07:22:03,219 --> 07:22:05,222
into the overall peak would you

11127
07:22:05,222 --> 07:22:07,791
agree that number is roughly

11128
07:22:07,791 --> 07:22:09,590
55% does that sound right I

11129
07:22:09,590 --> 07:22:10,294
have a calculator.

11130
07:22:10,294 --> 07:22:11,295
>> teco Witness: that looks

11131
07:22:11,295 --> 07:22:13,295
about right.

11132
07:22:17,734 --> 07:22:19,734
>> Florida Rising: okay.

11133
07:22:19,770 --> 07:22:20,104
That is the percentage is the

11134
07:22:20,104 --> 07:22:21,400
amount of the

11135
07:22:21,400 --> 07:22:22,773
JANUARY retail

11136
07:22:22,773 --> 07:22:24,741
peak attributable to the

11137
07:22:24,741 --> 07:22:25,943
residential customer demand.

11138
07:22:25,943 --> 07:22:26,843
>> teco Witness: subject to

11139
07:22:26,843 --> 07:22:27,944
check yes.

11140
07:22:27,944 --> 07:22:29,944
>> teco Witness:

11141
07:22:29,946 --> 07:22:31,810
>> Florida Rising: would you

11142
07:22:31,810 --> 07:22:33,149
accept my representation that

11143
07:22:33,149 --> 07:22:35,219
if you did that same

11144
07:22:35,219 --> 07:22:38,819
calculation for each row of the

11145
07:22:42,125 --> 07:22:43,326
year that none of the

11146
07:22:43,326 --> 07:22:44,595
percentages for the residential

11147
07:22:44,595 --> 07:22:46,595
classes above 60%?

11148
07:22:46,830 --> 07:22:46,997
Does that sound

11149
07:22:46,997 --> 07:22:48,197
.

11150
07:22:48,197 --> 07:22:51,197
>> teco Witness: I would have

11151
07:22:52,636 --> 07:22:53,770
to do the math I don't know.

11152
07:22:53,770 --> 07:22:55,638
>> Florida Rising: in the

11153
07:22:55,638 --> 07:22:59,238
interest of doing or moving us

11154
07:23:00,344 --> 07:23:02,312
along I will not ask.

11155
07:23:02,312 --> 07:23:03,280
>> teco Witness: subject to

11156
07:23:03,280 --> 07:23:05,680
check I will agree.

11157
07:23:06,820 --> 07:23:08,118
>> Florida Rising: as we sit

11158
07:23:08,118 --> 07:23:09,319
here today although residential

11159
07:23:09,319 --> 07:23:11,121
customers are being given 60%

11160
07:23:11,121 --> 07:23:12,823
of system cost under the 4cp

11161
07:23:12,823 --> 07:23:14,391
model being driven permanently

11162
07:23:14,391 --> 07:23:17,391
by the JANUARY peak the

11163
07:23:17,861 --> 07:23:20,497
forecast peak you are not aware

11164
07:23:20,497 --> 07:23:23,366
of any month for which in the

11165
07:23:23,366 --> 07:23:25,766
actual data the residential

11166
07:23:29,806 --> 07:23:30,807
class resented 60% of the

11167
07:23:30,807 --> 07:23:32,807
coincident peak?

11168
07:23:32,842 --> 07:23:33,430
>> teco Witness: can you repeat

11169
07:23:33,430 --> 07:23:34,811
that.

11170
07:23:34,811 --> 07:23:36,120
>> Florida Rising: residential

11171
07:23:36,120 --> 07:23:37,947
customers are 60% responsible

11172
07:23:37,947 --> 07:23:40,683
for the peaks cost wise under

11173
07:23:40,683 --> 07:23:41,317
teco 4cp cost of service

11174
07:23:41,317 --> 07:23:43,317
methodology.

11175
07:23:46,390 --> 07:23:48,225
>> teco Witness: you are

11176
07:23:48,225 --> 07:23:49,459
starting to get out of my areas

11177
07:23:49,459 --> 07:23:50,627
of expertise I think this

11178
07:23:50,627 --> 07:23:51,728
should be directed at the

11179
07:23:51,728 --> 07:23:53,728
witness williams.

11180
07:23:53,730 --> 07:23:55,298
>> Florida Rising: we will move

11181
07:23:55,298 --> 07:23:57,298
past this.

11182
07:23:57,634 --> 07:24:01,234
We can go to master number

11183
07:24:29,232 --> 07:24:30,901
f16-96.

11184
07:24:30,901 --> 07:24:33,503
We are going to go to the tab

11185
07:24:33,503 --> 07:24:35,503
request forecast.

11186
07:24:41,110 --> 07:24:45,211
Let me know when you are there.

11187
07:24:48,452 --> 07:24:49,953
>> teco Witness: I am there.

11188
07:24:49,953 --> 07:24:51,555
>> Florida Rising: this shows

11189
07:24:51,555 --> 07:24:52,689
teco forecast for the 2025

11190
07:24:52,689 --> 07:24:53,557
energy sales by class and

11191
07:24:53,557 --> 07:24:54,491
month?

11192
07:24:54,491 --> 07:24:56,491
>> teco Witness: yes.

11193
07:24:57,427 --> 07:24:59,463
>> Florida Rising: so with the

11194
07:24:59,463 --> 07:25:02,463
exception of the lighting class

11195
07:25:03,330 --> 07:25:05,350
which is presumably varies in

11196
07:25:05,350 --> 07:25:05,602
the length and gsl d all of the

11197
07:25:05,602 --> 07:25:06,269
classes shown here

11198
07:25:06,269 --> 07:25:07,304
objected to

11199
07:25:07,304 --> 07:25:09,304
peak in SEPTEMBER.

11200
07:25:10,741 --> 07:25:12,642
>> teco Witness: I'm trying to

11201
07:25:12,642 --> 07:25:16,842
make it so I can see better

11202
07:25:17,413 --> 07:25:19,413
hold on.

11203
07:25:19,850 --> 07:25:19,942
You said with the exception of

11204
07:25:19,942 --> 07:25:21,942
.

11205
07:25:23,820 --> 07:25:26,220
>> Florida Rising: of lighting

11206
07:25:27,924 --> 07:25:30,961
and gsl d or all of the other

11207
07:25:30,961 --> 07:25:33,961
classes pictured here are the

11208
07:25:35,650 --> 07:25:38,650
remaining do the residential gs

11209
07:25:38,602 --> 07:25:40,604
and gst classes are they

11210
07:25:40,604 --> 07:25:43,604
projected to peak in SEPTEMBER?

11211
07:25:45,509 --> 07:25:46,709
>> teco Witness: we are talking

11212
07:25:46,709 --> 07:25:47,644
megawatts hours in energy not

11213
07:25:47,644 --> 07:25:49,546
peak demand?

11214
07:25:49,546 --> 07:25:51,848
>> Florida Rising: is the peak

11215
07:25:51,848 --> 07:25:51,949
usage here

11216
07:25:51,949 --> 07:25:53,949
.

11217
07:25:56,720 --> 07:25:58,588
>> teco Witness: there are

11218
07:25:58,588 --> 07:25:59,790
reasons for the schools and

11219
07:25:59,790 --> 07:26:02,592
universities are out part of

11220
07:26:02,592 --> 07:26:04,561
those summer months JULY and

11221
07:26:04,561 --> 07:26:04,761
AUGUST. SEPTEMBER everybody is

11222
07:26:04,761 --> 07:26:06,663
back.

11223
07:26:06,663 --> 07:26:10,263
That's what we have more energy

11224
07:26:13,670 --> 07:26:14,905
in at those months.

11225
07:26:14,905 --> 07:26:17,305
>> Florida Rising: looking at

11226
07:26:19,843 --> 07:26:21,144
the numbers the gst class usage

11227
07:26:21,144 --> 07:26:22,178
from 25 ranges from a low in

11228
07:26:22,178 --> 07:26:24,914
FEBRUARY from about half give

11229
07:26:24,914 --> 07:26:29,114
go what do I in SEPTEMBER from

11230
07:26:29,853 --> 07:26:33,453
a high of 6 kwh would you

11231
07:26:34,156 --> 07:26:35,258
accept my map that is roughly

11232
07:26:35,258 --> 07:26:36,392
35% increase.

11233
07:26:36,392 --> 07:26:38,194
>> teco Witness: I will accept

11234
07:26:38,194 --> 07:26:40,194
your math.

11235
07:26:43,967 --> 07:26:45,835
>> Florida Rising: if we look

11236
07:26:45,835 --> 07:26:47,700
at the gsl d class there

11237
07:26:47,700 --> 07:26:49,706
productive use ranges from a

11238
07:26:49,706 --> 07:26:51,641
low in FEBRUARY we look at the

11239
07:26:51,641 --> 07:26:54,444
gsl d class there productive

11240
07:26:54,444 --> 07:26:55,770
use ranges from a low in

11241
07:26:55,770 --> 07:26:56,278
FEBRUARY 2.15 gw hours to high

11242
07:26:56,278 --> 07:26:57,514
in JULY of.18 kwh.

11243
07:26:57,514 --> 07:27:01,714
Would you accept my map that is

11244
07:27:02,852 --> 07:27:04,852
about a 15% increase.

11245
07:27:04,855 --> 07:27:06,823
>> teco Witness: apple etc.

11246
07:27:06,823 --> 07:27:08,858
(*speaker14* you would agree to

11247
07:27:08,858 --> 07:27:10,326
large industrial and commercial

11248
07:27:10,326 --> 07:27:12,280
customers are not projected

11249
07:27:12,280 --> 07:27:13,129
toward fat consumption across

11250
07:27:13,129 --> 07:27:14,631
the year.

11251
07:27:14,631 --> 07:27:15,632
>> teco Witness: these are by

11252
07:27:15,632 --> 07:27:17,632
rate schedules.

11253
07:27:17,633 --> 07:27:19,633
There is nonindustrial

11254
07:27:20,636 --> 07:27:22,438
customers in all of these rate

11255
07:27:22,438 --> 07:27:23,639
classes.

11256
07:27:23,639 --> 07:27:27,239
This is just not an industrial

11257
07:27:28,178 --> 07:27:28,278
rate

11258
07:27:28,278 --> 07:27:30,247
.

11259
07:27:30,247 --> 07:27:30,847
>> Florida Rising: you would

11260
07:27:30,847 --> 07:27:33,850
agree that the gs d and gsl d

11261
07:27:33,850 --> 07:27:36,219
classes are associated with

11262
07:27:36,219 --> 07:27:38,219
larger commercial and

11263
07:27:40,991 --> 07:27:41,910
industrial customers

11264
07:27:41,910 --> 07:27:42,259
.

11265
07:27:42,259 --> 07:27:43,626
>> teco Witness: the gsl d

11266
07:27:43,626 --> 07:27:45,626
would be larger.

11267
07:27:47,731 --> 07:27:49,733
>> Florida Rising: that class

11268
07:27:49,733 --> 07:27:50,233
does not have flat consumption

11269
07:27:50,233 --> 07:27:50,867
for each of the year

11270
07:27:50,867 --> 07:27:51,701
but has

11271
07:27:51,701 --> 07:27:53,403
variation.

11272
07:27:53,403 --> 07:27:55,403
> teco Witness:

11273
07:28:00,410 --> 07:28:02,412
no it is not completely flat.

11274
07:28:02,412 --> 07:28:05,412
You have other things that

11275
07:28:07,150 --> 07:28:08,385
influence it.

11276
07:28:08,385 --> 07:28:10,287
Like seasonal weather the

11277
07:28:10,287 --> 07:28:12,755
number of days in the typical

11278
07:28:12,755 --> 07:28:14,190
billing period that fluctuate.

11279
07:28:14,190 --> 07:28:15,758
You will see differences

11280
07:28:15,758 --> 07:28:17,761
because of that not just

11281
07:28:17,761 --> 07:28:20,161
because of their consumption

11282
07:28:20,530 --> 07:28:21,665
pattern.

11283
07:28:21,665 --> 07:28:23,600
>> Florida Rising: you are

11284
07:28:23,600 --> 07:28:24,634
aware of the are we the teco is

11285
07:28:24,634 --> 07:28:25,302
seeking in this case.

11286
07:28:25,302 --> 07:28:26,569
>> teco

11287
07:28:26,569 --> 07:28:28,538
Witness: I'm aware.

11288
07:28:28,538 --> 07:28:28,738
>> Florida Rising: that is

11289
07:28:28,738 --> 07:28:29,772
11.5%.

11290
07:28:29,772 --> 07:28:31,772
>> teco Witness: yes.

11291
07:28:32,875 --> 07:28:34,778
>> Florida Rising: you are

11292
07:28:34,778 --> 07:28:36,746
where the teco is justifying

11293
07:28:36,746 --> 07:28:37,914
this requested 11.5% are we in

11294
07:28:37,914 --> 07:28:39,749
part on the basis that high

11295
07:28:39,749 --> 07:28:42,149
prices from present future

11296
07:28:44,721 --> 07:28:46,122
inflation estate higher return

11297
07:28:46,122 --> 07:28:49,122
you need to speak with.

11298
07:28:51,861 --> 07:28:53,129
[Listing names] Can we turn to

11299
07:28:53,129 --> 07:28:55,529
the confidential exhibit that

11300
07:28:56,398 --> 07:28:58,401
is been passed out.

11301
07:28:58,401 --> 07:29:02,100
This is hearing exhibit this is

11302
07:29:04,140 --> 07:29:07,140
hearing exhibit 766 it is fll

11303
07:30:01,564 --> 07:30:03,564
-306c.

11304
07:30:08,471 --> 07:30:08,637
>> teco Witness: I have it

11305
07:30:08,637 --> 07:30:10,637
.

11306
07:30:10,639 --> 07:30:11,808
>> Florida Rising: do you

11307
07:30:11,808 --> 07:30:13,643
recognize this document.

11308
07:30:13,643 --> 07:30:14,811
>> teco Witness: yes I do.

11309
07:30:14,811 --> 07:30:16,813
>> Florida Rising: this was

11310
07:30:16,813 --> 07:30:19,213
produced from your workpapers.

11311
07:30:19,282 --> 07:30:20,650
This is a confidential document

11312
07:30:20,650 --> 07:30:21,851
that shows the parts on this

11313
07:30:21,851 --> 07:30:23,786
document that are confidential

11314
07:30:23,786 --> 07:30:26,186
are highlighted in yellow?

11315
07:30:26,222 --> 07:30:27,256
>> teco Witness: yes, those

11316
07:30:27,256 --> 07:30:29,192
were productions.

11317
07:30:29,192 --> 07:30:31,270
>> Florida Rising: in general

11318
07:30:31,270 --> 07:30:33,620
terms, this document shows

11319
07:30:33,620 --> 07:30:34,396
patient escalation rates for

11320
07:30:34,396 --> 07:30:36,396
nonproduction cpi and

11321
07:30:41,271 --> 07:30:41,537
production hwi

11322
07:30:41,537 --> 07:30:42,605
.

11323
07:30:42,605 --> 07:30:44,540
>> teco Witness: yes.

11324
07:30:44,540 --> 07:30:45,942
>> Florida Rising: just to

11325
07:30:45,942 --> 07:30:47,610
clarify for the record cpi is

11326
07:30:47,610 --> 07:30:49,512
the consumer price index.

11327
07:30:49,512 --> 07:30:49,746
>> teco Witness: that is

11328
07:30:49,746 --> 07:30:51,681
correct.

11329
07:30:51,681 --> 07:30:53,716
>> Florida Rising: h wi is the

11330
07:30:53,716 --> 07:30:55,585
handy equipment index according

11331
07:30:55,585 --> 07:30:57,553
to this memo teco uses the cpa

11332
07:30:57,553 --> 07:30:59,589
to guide escalation cost of

11333
07:30:59,589 --> 07:31:00,823
expenses.

11334
07:31:00,823 --> 07:31:02,625
>> teco Witness: what I can

11335
07:31:02,625 --> 07:31:03,826
speak to is we provide this

11336
07:31:03,826 --> 07:31:06,826
memo we get these projections

11337
07:31:09,165 --> 07:31:10,500
from moody's analytics. We

11338
07:31:10,500 --> 07:31:12,101
prepared this memo and

11339
07:31:12,101 --> 07:31:14,101
submitted throughout the

11340
07:31:14,103 --> 07:31:15,271
company in four areas of the

11341
07:31:15,271 --> 07:31:17,206
company that do not have any

11342
07:31:17,206 --> 07:31:20,206
other indices to protect their

11343
07:31:24,380 --> 07:31:26,249
o&m expenses by praying it is

11344
07:31:26,249 --> 07:31:27,383
not used I don't know who uses

11345
07:31:27,383 --> 07:31:29,251
it. Like I said it is just

11346
07:31:29,251 --> 07:31:30,452
available for them as a guide

11347
07:31:30,452 --> 07:31:31,621
if they need value to escalate

11348
07:31:31,621 --> 07:31:32,789
their expenses by.

11349
07:31:32,789 --> 07:31:34,991
>> Florida Rising: if I can

11350
07:31:34,991 --> 07:31:36,125
return to my question.

11351
07:31:36,125 --> 07:31:38,160
The cpi is used by teco to

11352
07:31:38,160 --> 07:31:40,160
escalate content cost?

11353
07:31:40,295 --> 07:31:42,295
As a guide.

11354
07:31:43,232 --> 07:31:43,332
Would it be helpful

11355
07:31:43,332 --> 07:31:45,332
.

11356
07:31:47,379 --> 07:31:47,526
>> teco Witness: it would not

11357
07:31:47,526 --> 07:31:52,326
be all o&m cost I don't know

11358
07:31:52,442 --> 07:31:52,608
which o&m cost apply to the

11359
07:31:52,608 --> 07:31:54,444
cpi?

11360
07:31:54,444 --> 07:31:56,412
>> Florida Rising: if we look

11361
07:31:56,412 --> 07:31:58,313
at the first page of this memo

11362
07:31:58,313 --> 07:32:00,750
the uc under the chart do see

11363
07:32:00,750 --> 07:32:02,151
that all that is bold consumer

11364
07:32:02,151 --> 07:32:04,151
price index?

11365
07:32:04,153 --> 07:32:04,253
>> teco Witness: yes I do

11366
07:32:04,253 --> 07:32:06,253
.

11367
07:32:06,322 --> 07:32:08,957
>> Florida Rising: can you read

11368
07:32:08,957 --> 07:32:11,957
the sentence below that heading

11369
07:32:13,290 --> 07:32:14,931
the cpi at the most widely used

11370
07:32:14,931 --> 07:32:17,667
measure of inflation is a guide

11371
07:32:17,667 --> 07:32:18,768
use when escalating o&m temp

11372
07:32:18,768 --> 07:32:20,570
electric company.

11373
07:32:20,570 --> 07:32:22,570
>> Florida Rising:

11374
07:32:25,641 --> 07:32:27,476
>> teco Witness: it is a guide

11375
07:32:27,476 --> 07:32:29,411
there is many areas of the

11376
07:32:29,411 --> 07:32:30,846
company that haven't thrown

11377
07:32:30,846 --> 07:32:32,414
indices that they use to

11378
07:32:32,414 --> 07:32:33,649
escalate the roof o&m expenses.

11379
07:32:33,649 --> 07:32:35,551
>> Florida Rising: my question

11380
07:32:35,551 --> 07:32:37,519
is whether it was used as a

11381
07:32:37,519 --> 07:32:38,753
guide at teco for escalating

11382
07:32:38,753 --> 07:32:40,656
close expenses. Similarly does

11383
07:32:40,656 --> 07:32:42,357
teco use the handy equipment

11384
07:32:42,357 --> 07:32:45,127
index to escalate costs for

11385
07:32:45,127 --> 07:32:47,630
capital projects to guide the

11386
07:32:47,630 --> 07:32:50,630
escalation of cost for capital

11387
07:32:53,936 --> 07:32:55,104
projects?

11388
07:32:55,104 --> 07:32:56,905
>> teco Witness: we provided

11389
07:32:56,905 --> 07:32:58,908
whether it is used or not I'm

11390
07:32:58,908 --> 07:33:00,810
not sure I would assume some

11391
07:33:00,810 --> 07:33:02,440
areas MAY use it.

11392
07:33:02,440 --> 07:33:04,460
>> Florida Rising: can you read

11393
07:33:04,460 --> 07:33:05,914
the two sentences on the second

11394
07:33:05,914 --> 07:33:08,914
page below the heading that

11395
07:33:12,555 --> 07:33:14,557
reads and equipment index?

11396
07:33:14,557 --> 07:33:15,758
>> teco Witness: the h wi is a

11397
07:33:15,758 --> 07:33:17,693
widely used utility closet next

11398
07:33:17,693 --> 07:33:19,695
the trucks cause based on the

11399
07:33:19,695 --> 07:33:21,563
uniform consistent and related

11400
07:33:21,563 --> 07:33:23,566
plant items for the purposes of

11401
07:33:23,566 --> 07:33:25,134
peak it's a guide to use when

11402
07:33:25,134 --> 07:33:27,134
escalating projects associated

11403
07:33:28,360 --> 07:33:29,238
with our assets.

11404
07:33:29,238 --> 07:33:31,720
Again if they have no other

11405
07:33:31,720 --> 07:33:32,341
indices I don't know who is

11406
07:33:32,341 --> 07:33:34,310
using it or not.

11407
07:33:34,310 --> 07:33:37,310
>> Florida Rising: this is a

11408
07:33:37,579 --> 07:33:38,713
guidance memo that is issued to

11409
07:33:38,713 --> 07:33:40,715
departments at teco to use.

11410
07:33:40,715 --> 07:33:42,840
>> teco Witness: we issue this

11411
07:33:42,840 --> 07:33:42,171
annually

11412
07:33:42,171 --> 07:33:43,252
.

11413
07:33:43,252 --> 07:33:46,852
>> teco Witness: if we can go

11414
07:33:47,155 --> 07:33:49,158
back to the first page.

11415
07:33:49,158 --> 07:33:50,359
Without verbalizing any of the

11416
07:33:50,359 --> 07:33:52,359
highlighted numbers.

11417
07:33:54,764 --> 07:33:58,364
Can you confirm that this chart

11418
07:34:00,202 --> 07:34:04,402
for forecast both the cpi and h

11419
07:34:11,413 --> 07:34:13,415
wi numbers for the next period?

11420
07:34:13,415 --> 07:34:14,550
Basically, it begins in 21, 22,

11421
07:34:14,550 --> 07:34:16,419
23 the highlighted numbers

11422
07:34:16,419 --> 07:34:17,820
represent the forecast for

11423
07:34:17,820 --> 07:34:19,820
24-2030?

11424
07:34:19,822 --> 07:34:22,525
>> teco Witness: what was the

11425
07:34:22,525 --> 07:34:22,658
specific question

11426
07:34:22,658 --> 07:34:24,658
.

11427
07:34:24,694 --> 07:34:25,928
>> Florida Rising: making if it

11428
07:34:25,928 --> 07:34:27,796
is a correct characterization

11429
07:34:27,796 --> 07:34:29,632
of the highlighted values on

11430
07:34:29,632 --> 07:34:30,232
this page are the projected

11431
07:34:30,232 --> 07:34:34,432
values for that cpi and h wi

11432
07:34:37,390 --> 07:34:37,373
over that time period between

11433
07:34:37,373 --> 07:34:39,241
2024 and 2030?

11434
07:34:39,241 --> 07:34:41,176
>> teco Witness: yes those were

11435
07:34:41,176 --> 07:34:42,545
the projections of the time

11436
07:34:42,545 --> 07:34:44,945
that this was prepared 2023.

11437
07:34:48,284 --> 07:34:49,285
>> Florida Rising: and without

11438
07:34:49,285 --> 07:34:51,285
without verbalizing

11439
07:34:51,287 --> 07:34:53,287
confidential information could

11440
07:34:54,657 --> 07:34:58,257
you give an indication of the

11441
07:34:59,962 --> 07:35:00,229
general trend of those

11442
07:35:00,229 --> 07:35:02,229
forecasts?

11443
07:35:05,167 --> 07:35:07,136
I am actually this is also to

11444
07:35:07,136 --> 07:35:08,337
the council please let me know

11445
07:35:08,337 --> 07:35:09,271
if we're getting anywhere we

11446
07:35:09,271 --> 07:35:11,207
should not be?

11447
07:35:11,207 --> 07:35:13,207
>> understood thank you.

11448
07:35:20,516 --> 07:35:22,516
>> teco Witness: for 2024

11449
07:35:23,119 --> 07:35:25,519
inflation is actually higher

11450
07:35:28,756 --> 07:35:30,726
than what we have on this memo.

11451
07:35:30,726 --> 07:35:32,862
>> Florida Rising: I am just

11452
07:35:32,862 --> 07:35:34,620
asking what the memo is

11453
07:35:34,620 --> 07:35:36,832
referring to what does this

11454
07:35:36,832 --> 07:35:37,832
memo forecast in terms of

11455
07:35:37,832 --> 07:35:39,335
inflation. Does it dissipate

11456
07:35:39,335 --> 07:35:40,435
inflation increasing or

11457
07:35:40,435 --> 07:35:41,937
decreasing by these metrics?

11458
07:35:41,937 --> 07:35:44,473
>> teco Witness: we can see in

11459
07:35:44,473 --> 07:35:48,673
2022 we had a high it has been

11460
07:35:49,111 --> 07:35:50,278
coming down and the production

11461
07:35:50,278 --> 07:35:52,678
period for 2024 and 2025 and

11462
07:35:54,350 --> 07:35:57,350
beyond we expect 2024 to come

11463
07:36:00,489 --> 07:36:02,889
down. We expect 2025 inflation

11464
07:36:03,259 --> 07:36:04,326
to also come down some. Then we

11465
07:36:04,326 --> 07:36:05,327
expect 26-30 to remain at the

11466
07:36:05,327 --> 07:36:05,528
same level as 2025.

11467
07:36:05,528 --> 07:36:06,629
> Florida

11468
07:36:06,629 --> 07:36:06,715
Rising: thank you

11469
07:36:06,715 --> 07:36:08,715
.

11470
07:36:09,899 --> 07:36:11,734
>> teco Witness: I believe

11471
07:36:11,734 --> 07:36:14,169
inflation has been higher in

11472
07:36:14,169 --> 07:36:15,304
2024.

11473
07:36:15,304 --> 07:36:17,172
>> Florida Rising: are you

11474
07:36:17,172 --> 07:36:19,572
familiar with any documents

11475
07:36:22,144 --> 07:36:23,178
that cooperate that on this

11476
07:36:23,178 --> 07:36:23,345
record that you can point me

11477
07:36:23,345 --> 07:36:25,345
to?

11478
07:36:27,115 --> 07:36:29,985
>> teco Witness: not that I can

11479
07:36:29,985 --> 07:36:30,850
think of

11480
07:36:30,850 --> 07:36:32,540
.

11481
07:36:32,540 --> 07:36:34,454
>> Florida Rising: thank you

11482
07:36:59,748 --> 07:37:00,949
can we move on to f16-9h.

11483
07:37:00,949 --> 07:37:02,685
Just give me a nod when you're

11484
07:37:02,685 --> 07:37:03,886
ready.

11485
07:37:03,886 --> 07:37:06,288
>> teco Witness: I am there.

11486
07:37:06,288 --> 07:37:08,288
>> Florida Rising: okay.

11487
07:37:15,964 --> 07:37:17,650
Do you recognize this document.

11488
07:37:17,650 --> 07:37:18,200
The teco uses a 20 year

11489
07:37:18,200 --> 07:37:20,600
historical to forecast its

11490
07:37:22,237 --> 07:37:23,405
load.

11491
07:37:23,405 --> 07:37:25,407
That 20 year period is also

11492
07:37:25,407 --> 07:37:26,641
used for the predictive period

11493
07:37:26,641 --> 07:37:28,276
for normal weather.

11494
07:37:28,276 --> 07:37:29,411
Teco's normal weather is

11495
07:37:29,411 --> 07:37:31,312
developed by I want to make

11496
07:37:31,312 --> 07:37:35,617
sure I have this right it is by

11497
07:37:35,617 --> 07:37:37,118
averaging them monte carlo

11498
07:37:37,118 --> 07:37:38,721
simulation for the weather in

11499
07:37:38,721 --> 07:37:40,589
those years that directly from

11500
07:37:40,589 --> 07:37:41,857
the 20 years of actual usage

11501
07:37:41,857 --> 07:37:43,758
rather of actual weather data?

11502
07:37:43,758 --> 07:37:45,627
>> teco Witness: we are not

11503
07:37:45,627 --> 07:37:47,629
averaging anything from the

11504
07:37:47,629 --> 07:37:49,598
monte carlo simulation using

11505
07:37:49,598 --> 07:37:50,833
numbers directly from the monte

11506
07:37:50,833 --> 07:37:53,833
carlo simulation on the summary

11507
07:37:55,837 --> 07:37:57,739
tab to 50% probability is what

11508
07:37:57,739 --> 07:37:59,908
we are using to assume as

11509
07:37:59,908 --> 07:38:01,908
normal.

11510
07:38:02,144 --> 07:38:05,744
That is very similar to an

11511
07:38:08,784 --> 07:38:10,180
average of over the 20 years.

11512
07:38:10,180 --> 07:38:12,200
>> Florida Rising: I appreciate

11513
07:38:12,200 --> 07:38:13,822
the clarification. Let's talk

11514
07:38:13,822 --> 07:38:15,124
about the monte carlo

11515
07:38:15,124 --> 07:38:17,524
simulation for the moment.

11516
07:38:19,595 --> 07:38:21,463
Can you explain in general

11517
07:38:21,463 --> 07:38:23,432
terms how they work and are

11518
07:38:23,432 --> 07:38:23,699
used to establish teco's

11519
07:38:23,699 --> 07:38:25,699
baseline?

11520
07:38:27,350 --> 07:38:30,350
>> teco Witness: years back we

11521
07:38:31,907 --> 07:38:33,809
just did a simple average like

11522
07:38:33,809 --> 07:38:35,811
many utilities do. We started

11523
07:38:35,811 --> 07:38:37,120
incorporating the monte carlo

11524
07:38:37,120 --> 07:38:38,914
assimilation so we could get a

11525
07:38:38,914 --> 07:38:41,914
range of possible degree days.

11526
07:38:42,384 --> 07:38:44,119
What them monte carlo

11527
07:38:44,119 --> 07:38:45,287
assimilation do the run through

11528
07:38:45,287 --> 07:38:47,687
numerous iterations and they

11529
07:38:58,901 --> 07:39:00,903
will give you a chart like this

11530
07:39:00,903 --> 07:39:02,404
that says okay there is zero

11531
07:39:02,404 --> 07:39:04,173
probability of having degree

11532
07:39:04,173 --> 07:39:06,410
days at this level present a 5%

11533
07:39:06,410 --> 07:39:08,176
at this level etc. All the way

11534
07:39:08,176 --> 07:39:10,450
to hundred percent probability.

11535
07:39:10,450 --> 07:39:11,947
We used the 50% point that is

11536
07:39:11,947 --> 07:39:12,313
basically minimizing the risk

11537
07:39:12,313 --> 07:39:14,490
of the company.

11538
07:39:14,490 --> 07:39:15,951
It is saying there is a 50%

11539
07:39:15,951 --> 07:39:17,118
chance it is going to be harder

11540
07:39:17,118 --> 07:39:18,286
or there is a 50% chance it

11541
07:39:18,286 --> 07:39:20,550
will be not as hot.

11542
07:39:20,550 --> 07:39:21,156
That is how we use the monte

11543
07:39:21,156 --> 07:39:23,125
carlo simulation.

11544
07:39:23,125 --> 07:39:24,726
The reason we use the software

11545
07:39:24,726 --> 07:39:25,860
versus a simple average is we

11546
07:39:25,860 --> 07:39:26,962
are asked to do different

11547
07:39:26,962 --> 07:39:28,962
scenarios whether scenarios

11548
07:39:30,666 --> 07:39:32,634
which I have provided several

11549
07:39:32,634 --> 07:39:34,336
of those. What we can do is say

11550
07:39:34,336 --> 07:39:38,536
okay what kind of risks are we

11551
07:39:41,376 --> 07:39:42,476
looking at kara we want as

11552
07:39:42,476 --> 07:39:43,945
winterson does only a 5%

11553
07:39:43,945 --> 07:39:45,513
probability of this occurrence

11554
07:39:45,513 --> 07:39:47,549
that we have the numbers

11555
07:39:47,549 --> 07:39:49,451
already we don't have to figure

11556
07:39:49,451 --> 07:39:50,452
out a way like some utilities

11557
07:39:50,452 --> 07:39:51,653
have to do.

11558
07:39:51,653 --> 07:39:53,622
What is a 5% probability.

11559
07:39:53,622 --> 07:39:55,524
We have that available.

11560
07:39:55,524 --> 07:39:58,293
It is just convenient to use

11561
07:39:58,293 --> 07:39:59,494
the monte carlo simulations.

11562
07:39:59,494 --> 07:40:01,463
>> Florida Rising: would be a

11563
07:40:01,463 --> 07:40:02,631
fair comparison to the if you

11564
07:40:02,631 --> 07:40:04,532
want to know the distribution

11565
07:40:04,532 --> 07:40:05,734
of outcomes for rolling to dice

11566
07:40:05,734 --> 07:40:08,134
1000 times to get that

11567
07:40:12,107 --> 07:40:13,308
distribution curve of the

11568
07:40:13,308 --> 07:40:15,109
possible outcomes.

11569
07:40:15,109 --> 07:40:15,444
>> teco Witness: I don't think

11570
07:40:15,444 --> 07:40:16,245
I will relate

11571
07:40:16,245 --> 07:40:17,780
it to rolling

11572
07:40:17,780 --> 07:40:18,460
dice.

11573
07:40:18,460 --> 07:40:18,247
> Florida Rising: by

11574
07:40:18,247 --> 07:40:20,247
not.

11575
07:40:22,951 --> 07:40:24,952
>> teco Witness: I think I

11576
07:40:24,952 --> 07:40:26,188
can't explain exactly why. I

11577
07:40:26,188 --> 07:40:29,788
don't believe that it is the

11578
07:40:33,195 --> 07:40:34,396
same thing.

11579
07:40:34,396 --> 07:40:36,197
>> Florida Rising: I'm not an

11580
07:40:36,197 --> 07:40:38,200
expert in forecasting I'm

11581
07:40:38,200 --> 07:40:39,401
trying to have something to

11582
07:40:39,401 --> 07:40:41,303
compare it to. That is totally

11583
07:40:41,303 --> 07:40:42,504
fine.

11584
07:40:42,504 --> 07:40:44,439
Looking across the tabs for

11585
07:40:44,439 --> 07:40:47,439
this spreadsheet as a whole.

11586
07:40:49,711 --> 07:40:50,878
There are runs for each month

11587
07:40:50,878 --> 07:40:52,948
which are indicated by the

11588
07:40:52,948 --> 07:40:53,181
number following the simulation

11589
07:40:53,181 --> 07:40:54,816
results.

11590
07:40:54,816 --> 07:40:56,717
> teco Witness: that

11591
07:40:56,717 --> 07:40:58,186
is correct automatically

11592
07:40:58,186 --> 07:40:59,888
created by the software.

11593
07:40:59,888 --> 07:41:01,756
>> Florida Rising: the months

11594
07:41:01,756 --> 07:41:03,580
where teco can experience

11595
07:41:03,580 --> 07:41:04,526
heating or cooling those there

11596
07:41:04,526 --> 07:41:05,961
is an hcd and sed run.

11597
07:41:05,961 --> 07:41:06,695
>> teco Witness: that is

11598
07:41:06,695 --> 07:41:06,784
correct

11599
07:41:06,784 --> 07:41:08,630
.

11600
07:41:08,630 --> 07:41:09,865
>> Florida Rising: for the

11601
07:41:09,865 --> 07:41:10,980
summer months there is one run

11602
07:41:10,980 --> 07:41:12,980
for cdd?

11603
07:41:16,104 --> 07:41:18,104
> teco Witness: yes.

11604
07:41:27,515 --> 07:41:31,715
If we can turn to f3.1-3150

11605
07:41:40,462 --> 07:41:42,462
or fll 51.

11606
07:41:44,499 --> 07:41:46,668
You recognize this exhibit?

11607
07:41:46,668 --> 07:41:48,360
When it comes up?

11608
07:41:48,360 --> 07:41:51,360
>> teco Witness: yes I do.

11609
07:41:51,973 --> 07:41:53,909
>> Florida Rising: the attached

11610
07:41:53,909 --> 07:41:57,509
table on this exhibit shows per

11611
07:41:58,980 --> 07:42:00,215
table for 2022 countries

11612
07:42:00,215 --> 07:42:03,215
forecast or stated the heating

11613
07:42:04,252 --> 07:42:04,373
degree days by 50% on average

11614
07:42:04,373 --> 07:42:05,420
.

11615
07:42:05,420 --> 07:42:07,322
>> teco Witness: yes.

11616
07:42:07,322 --> 07:42:08,490
>> Florida Rising: it

11617
07:42:08,490 --> 07:42:10,890
understated cooling degree days

11618
07:42:13,328 --> 07:42:13,461
by roughly 20% on average

11619
07:42:13,461 --> 07:42:14,563
.

11620
07:42:14,563 --> 07:42:15,430
>> teco Witness: that is

11621
07:42:15,430 --> 07:42:16,631
correct.

11622
07:42:16,631 --> 07:42:18,533
>> Florida Rising: for JANUARY

11623
07:42:18,533 --> 07:42:20,335
but teco expected the annual

11624
07:42:20,335 --> 07:42:21,469
retail peak demand heating

11625
07:42:21,469 --> 07:42:22,704
degrees world fleet 80% and

11626
07:42:22,704 --> 07:42:25,104
cooling is roughly hundred 10%

11627
07:42:30,111 --> 07:42:30,230
higher than charges forecast

11628
07:42:30,230 --> 07:42:31,346
.

11629
07:42:31,346 --> 07:42:33,181
>> teco Witness: that is

11630
07:42:33,181 --> 07:42:36,781
correct the weather is very hot

11631
07:42:36,885 --> 07:42:37,520
in 2022

11632
07:42:37,520 --> 07:42:39,200
.

11633
07:42:39,200 --> 07:42:40,288
>> Florida Rising: that was my

11634
07:42:40,288 --> 07:42:42,190
next question to attribute this

11635
07:42:42,190 --> 07:42:44,920
to the record-breaking weather.

11636
07:42:44,920 --> 07:42:44,325
>> teco Witness: some of the

11637
07:42:44,325 --> 07:42:46,195
months.

11638
07:42:46,195 --> 07:42:48,950
>> Florida Rising: if we can go

11639
07:42:48,950 --> 07:42:49,290
to e >> Florida Rising: if we

11640
07:42:49,290 --> 07:42:51,429
can go to e268.

11641
07:43:00,875 --> 07:43:02,177
It is exhibit 216.

11642
07:43:02,177 --> 07:43:06,377
I gave the wrong number. Can we

11643
07:43:20,270 --> 07:43:21,830
go to e 8 271.

11644
07:43:21,830 --> 07:43:24,830
Do you recognize this document?

11645
07:43:25,867 --> 07:43:27,867
>> teco Witness: yes.

11646
07:43:29,804 --> 07:43:32,673
>> Florida Rising: this is late

11647
07:43:32,673 --> 07:43:34,875
filed exhibit from your desk

11648
07:43:34,875 --> 07:43:36,711
the person this is comparing

11649
07:43:36,711 --> 07:43:39,711
the expected energy sales based

11650
07:43:42,818 --> 07:43:44,752
on degree days for teco is twin

11651
07:43:44,752 --> 07:43:44,986
near-normal versus tenure

11652
07:43:44,986 --> 07:43:46,754
normal.

11653
07:43:46,754 --> 07:43:48,156
>> teco Witness: that is

11654
07:43:48,156 --> 07:43:49,356
correct.

11655
07:43:49,356 --> 07:43:51,259
>> Florida Rising: this chart

11656
07:43:51,259 --> 07:43:53,228
shows that if weather is in

11657
07:43:53,228 --> 07:43:54,429
line with the 10 year normal as

11658
07:43:54,429 --> 07:43:56,498
compared to the 20 year normal

11659
07:43:56,498 --> 07:43:58,898
teco should expect JANUARY

11660
07:44:02,360 --> 07:44:02,166
weather usage to be 20% low

11661
07:44:02,166 --> 07:44:04,138
.

11662
07:44:04,138 --> 07:44:04,339
>> teco Witness: can you repeat

11663
07:44:04,339 --> 07:44:06,339
that.

11664
07:44:09,243 --> 07:44:11,111
>> Florida Rising: if the

11665
07:44:11,111 --> 07:44:12,380
weather for the year is in line

11666
07:44:12,380 --> 07:44:14,215
with the 10 year normal instead

11667
07:44:14,215 --> 07:44:16,615
of the 20 near-normal that

11668
07:44:18,352 --> 07:44:19,520
would be associated with

11669
07:44:19,520 --> 07:44:20,555
roughly 1% decrease in energy

11670
07:44:20,555 --> 07:44:22,490
use is for JANUARY.

11671
07:44:22,490 --> 07:44:24,359
>> teco Witness: for JANUARY

11672
07:44:24,359 --> 07:44:25,590
I'm sorry I was looking at the

11673
07:44:25,590 --> 07:44:25,160
total

11674
07:44:25,160 --> 07:44:27,128
.

11675
07:44:27,128 --> 07:44:28,329
>> Florida Rising: for APRIL

11676
07:44:28,329 --> 07:44:31,929
and MAY sales would be about 2%

11677
07:44:35,203 --> 07:44:36,371
higher given use a 20

11678
07:44:36,371 --> 07:44:38,272
near-normal as reference

11679
07:44:38,272 --> 07:44:40,672
chemical that the reference?

11680
07:44:41,409 --> 07:44:42,176
>> teco Witness: I'm following

11681
07:44:42,176 --> 07:44:43,277
you.

11682
07:44:43,277 --> 07:44:45,180
> Florida Rising: for

11683
07:44:45,180 --> 07:44:45,613
APRIL and MAY it would be about

11684
07:44:45,613 --> 07:44:46,347
2% higher than the

11685
07:44:46,347 --> 07:44:47,415
reference.

11686
07:44:47,415 --> 07:44:49,350
>> teco Witness: yes.

11687
07:44:49,350 --> 07:44:51,185
>> Florida Rising: for NOVEMBER

11688
07:44:51,185 --> 07:44:52,420
would be to percent higher.

11689
07:44:52,420 --> 07:44:54,322
So similarly the effects of a

11690
07:44:54,322 --> 07:44:56,290
one year of weather that is

11691
07:44:56,290 --> 07:44:57,559
more in line with the 10 year

11692
07:44:57,559 --> 07:44:58,459
normal than the 20 near-normal

11693
07:44:58,459 --> 07:45:01,620
will be associated with an

11694
07:45:01,620 --> 07:45:03,398
additional 204 gw hours of

11695
07:45:03,398 --> 07:45:05,398
energy sales.

11696
07:45:06,467 --> 07:45:09,637
Looking at the summary row at

11697
07:45:09,637 --> 07:45:10,705
the bottom?

11698
07:45:10,705 --> 07:45:12,507
For the difference?

11699
07:45:12,507 --> 07:45:13,774
>> teco

11700
07:45:13,774 --> 07:45:14,442
Witness: which month were

11701
07:45:14,442 --> 07:45:15,376
you

11702
07:45:15,376 --> 07:45:17,376
referring to.

11703
07:45:20,682 --> 07:45:21,816
>> teco Witness: this would be

11704
07:45:21,816 --> 07:45:22,750
row 13 the total annual

11705
07:45:22,750 --> 07:45:24,520
difference yes.

11706
07:45:24,520 --> 07:45:27,520
>> Florida Rising: thank you if

11707
07:45:29,824 --> 07:45:31,125
we could just scroll down to it

11708
07:45:31,125 --> 07:45:35,325
this is late filed 4 does if we

11709
07:45:38,299 --> 07:45:41,899
can scroll to late filed 6 this

11710
07:45:45,106 --> 07:45:47,106
is 8/02/06 I'm sorry 8275.

11711
07:45:47,108 --> 07:45:48,376
>> teco Witness: want to point

11712
07:45:48,376 --> 07:45:49,476
something out before we move

11713
07:45:49,476 --> 07:45:50,645
on.

11714
07:45:50,645 --> 07:45:53,645
We talk about the 20 years

11715
07:45:54,480 --> 07:45:56,480
versus 10 years.

11716
07:45:59,220 --> 07:46:01,122
If we look at things other than

11717
07:46:01,122 --> 07:46:04,722
the last 10 years it has been

11718
07:46:05,192 --> 07:46:06,361
hot.

11719
07:46:06,361 --> 07:46:08,363
I mentioned earlier today 20

11720
07:46:08,363 --> 07:46:11,963
years is kind of the industry

11721
07:46:13,334 --> 07:46:15,334
standard.

11722
07:46:15,336 --> 07:46:16,537
It is actually for standard in

11723
07:46:16,537 --> 07:46:19,307
florida. There is no utility

11724
07:46:19,307 --> 07:46:20,341
using tenures or anything lower

11725
07:46:20,341 --> 07:46:21,609
than 20 years. There is a

11726
07:46:21,609 --> 07:46:24,345
reason for that person sample

11727
07:46:24,345 --> 07:46:25,346
size is the reason when you use

11728
07:46:25,346 --> 07:46:28,346
20 years you have a large

11729
07:46:28,549 --> 07:46:30,517
sample of it degree days. You

11730
07:46:30,517 --> 07:46:32,120
have 20 years. 10 years we

11731
07:46:32,120 --> 07:46:34,122
consider a small sample. Let's

11732
07:46:34,122 --> 07:46:35,389
import about a large sample is

11733
07:46:35,389 --> 07:46:37,258
stability. Every year when we

11734
07:46:37,258 --> 07:46:40,258
update our normals it's a

11735
07:46:40,828 --> 07:46:41,995
rolling lock.

11736
07:46:41,995 --> 07:46:43,865
Would dropping off your all

11737
07:46:43,865 --> 07:46:44,999
this year and adding your

11738
07:46:44,999 --> 07:46:46,833
newest year. Those two years

11739
07:46:46,833 --> 07:46:47,101
that are changing are very

11740
07:46:47,101 --> 07:46:49,370
different.

11741
07:46:49,370 --> 07:46:50,710
It is going to impact your new

11742
07:46:50,710 --> 07:46:52,600
normal degree days.

11743
07:46:52,600 --> 07:46:55,600
When you've assembled that is

11744
07:46:56,540 --> 07:46:59,540
20 years old it's a stable

11745
07:46:59,947 --> 07:47:01,949
transition from year to year

11746
07:47:01,949 --> 07:47:03,151
which is very important for the

11747
07:47:03,151 --> 07:47:05,151
company's long-term planning.

11748
07:47:05,986 --> 07:47:07,989
Which like you said before our

11749
07:47:07,989 --> 07:47:09,570
forecasts are not just used for

11750
07:47:09,570 --> 07:47:10,992
revenue it is used for

11751
07:47:10,992 --> 07:47:12,992
long-term planning of

11752
07:47:12,993 --> 07:47:14,262
generation of transmission

11753
07:47:14,262 --> 07:47:16,163
distribution infrastructure

11754
07:47:16,163 --> 07:47:18,650
also used for estate planning

11755
07:47:18,650 --> 07:47:20,100
at the florida liability court

11756
07:47:20,100 --> 07:47:21,135
and counsel this transition of

11757
07:47:21,135 --> 07:47:23,710
our normals is important.

11758
07:47:23,710 --> 07:47:25,390
When you go to attend your

11759
07:47:25,390 --> 07:47:26,974
simple regardless of what has

11760
07:47:26,974 --> 07:47:28,976
been happening with the weather

11761
07:47:28,976 --> 07:47:30,244
when it tenure simple there is

11762
07:47:30,244 --> 07:47:32,647
more instability when you drop

11763
07:47:32,647 --> 07:47:33,981
one year and add your new year

11764
07:47:33,981 --> 07:47:35,383
they are very different

11765
07:47:35,383 --> 07:47:37,383
near-normal will change.

11766
07:47:38,190 --> 07:47:39,287
It MAY change significantly.

11767
07:47:39,287 --> 07:47:41,189
That impacts expansion plans

11768
07:47:41,189 --> 07:47:42,230
the company's infra structure

11769
07:47:42,230 --> 07:47:43,240
planning.

11770
07:47:43,240 --> 07:47:44,910
Ou don't when you

11771
07:47:44,910 --> 07:47:47,910
plan you don't want these

11772
07:47:50,932 --> 07:47:52,166
sudden changes we need to add a

11773
07:47:52,166 --> 07:47:54,680
lot of generation not for sure

11774
07:47:54,680 --> 07:47:55,269
where to take it away. That is

11775
07:47:55,269 --> 07:47:57,710
why we use 20 years.

11776
07:47:57,710 --> 07:47:58,206
That's why am opposed to moving

11777
07:47:58,206 --> 07:48:02,406
to a 10 year look even if it

11778
07:48:04,845 --> 07:48:06,130
has been harder.

11779
07:48:06,130 --> 07:48:07,915
Our normal over 20 years the

11780
07:48:07,915 --> 07:48:09,884
gap is closing between 20 and

11781
07:48:09,884 --> 07:48:10,618
10 because we have these 10 hot

11782
07:48:10,618 --> 07:48:11,152
years in our 20

11783
07:48:11,152 --> 07:48:13,540
years. That gap

11784
07:48:13,540 --> 07:48:15,289
is closing our normals are very

11785
07:48:15,289 --> 07:48:16,490
very hot and warm here is.

11786
07:48:16,490 --> 07:48:19,293
I illustrate that I've said

11787
07:48:19,293 --> 07:48:21,863
that in my late filed exhibit

11788
07:48:21,863 --> 07:48:25,463
number six bullet it is the

11789
07:48:27,401 --> 07:48:29,370
exhibit number 16 this last

11790
07:48:29,370 --> 07:48:31,238
nine years not that it's just a

11791
07:48:31,238 --> 07:48:34,238
small sample it is anomalous

11792
07:48:34,875 --> 07:48:36,430
compared to the 40 or 50 years

11793
07:48:36,430 --> 07:48:37,845
our. I want to make that

11794
07:48:37,845 --> 07:48:39,460
point. Yes it has been hot

11795
07:48:39,460 --> 07:48:41,480
these past 10 years it is not

11796
07:48:41,480 --> 07:48:43,448
good forecasting practice to

11797
07:48:45,886 --> 07:48:47,888
just look at that back in time.

11798
07:48:47,888 --> 07:48:49,356
>> Florida Rising: it is your

11799
07:48:49,356 --> 07:48:52,356
testimony for the last nine

11800
07:48:53,928 --> 07:48:55,129
years are anomalous.

11801
07:48:55,129 --> 07:48:57,310
>> Florida Rising: compared to

11802
07:48:57,310 --> 07:48:57,198
what we see historically they

11803
07:48:57,198 --> 07:48:59,198
are.

11804
07:48:59,667 --> 07:49:01,200
>> Florida Rising: you would I

11805
07:49:01,200 --> 07:49:04,200
don't think anybody knows that.

11806
07:49:07,675 --> 07:49:09,610
But because there have been

11807
07:49:09,610 --> 07:49:11,479
some number of anomalies during

11808
07:49:11,479 --> 07:49:13,130
that period of time I just

11809
07:49:13,130 --> 07:49:14,481
don't believe that it's a good

11810
07:49:14,481 --> 07:49:15,549
period of time to use as

11811
07:49:15,549 --> 07:49:18,549
normals and to plan the

11812
07:49:19,119 --> 07:49:21,119
company's future with.

11813
07:49:21,188 --> 07:49:23,290
A lot of uncertainty there and

11814
07:49:23,290 --> 07:49:25,125
is not any utilities in florida

11815
07:49:25,125 --> 07:49:25,358
that are willing to do that

11816
07:49:25,358 --> 07:49:27,161
either.

11817
07:49:27,161 --> 07:49:28,295
>> Florida Rising: if I can

11818
07:49:28,295 --> 07:49:31,295
redirect you to my question.

11819
07:49:34,635 --> 07:49:36,536
You would agree that I will

11820
07:49:36,536 --> 07:49:38,238
withdraw the question and move

11821
07:49:38,238 --> 07:49:39,472
on.

11822
07:49:39,472 --> 07:49:41,410
If we can look at the document

11823
07:49:41,410 --> 07:49:43,441
we pulled up next.

11824
07:49:50,784 --> 07:49:51,919
This is e 8 275 this shows the

11825
07:49:51,919 --> 07:49:53,887
cooling degree days in the

11826
07:49:53,887 --> 07:49:57,487
total three days in the cooling

11827
07:49:59,427 --> 07:50:00,595
degree days from 1990-2023.

11828
07:50:00,595 --> 07:50:01,362
I apologize I think it should

11829
07:50:01,362 --> 07:50:03,362
be 1970.

11830
07:50:03,597 --> 07:50:05,597
-2023.

11831
07:50:06,834 --> 07:50:08,350
>> teco Witness: yes.

11832
07:50:08,350 --> 07:50:09,937
>> Florida Rising: looking at

11833
07:50:09,937 --> 07:50:12,937
the heating degree day chart

11834
07:50:13,641 --> 07:50:17,241
which should be I believe the

11835
07:50:18,913 --> 07:50:20,913
second.

11836
07:50:27,288 --> 07:50:28,489
The average 40 monte carlo is

11837
07:50:28,489 --> 07:50:31,225
it the average or the 20 year

11838
07:50:31,225 --> 07:50:31,525
normal for the monte carlo

11839
07:50:31,525 --> 07:50:33,525
simulation.

11840
07:50:36,130 --> 07:50:36,464
>> teco Witness: it is the 50%

11841
07:50:36,464 --> 07:50:38,199
probability.

11842
07:50:38,199 --> 07:50:40,134
>> Florida Rising: the 50%

11843
07:50:40,134 --> 07:50:41,302
probability which we called the

11844
07:50:41,302 --> 07:50:43,702
20 near-normal that number is

11845
07:50:45,205 --> 07:50:45,300
431 heating degree days

11846
07:50:45,300 --> 07:50:46,373
.

11847
07:50:46,373 --> 07:50:46,467
>> teco Witness: yes

11848
07:50:46,467 --> 07:50:48,467
.

11849
07:50:49,377 --> 07:50:52,377
>> Florida Rising: if we look

11850
07:50:56,517 --> 07:50:58,519
at this chart it shows that the

11851
07:50:58,519 --> 07:51:00,521
heating degree days have gone

11852
07:51:00,521 --> 07:51:01,622
down dramatically over time not

11853
07:51:01,622 --> 07:51:03,591
just in the last nine years.

11854
07:51:03,591 --> 07:51:06,591
>> teco Witness: they have gone

11855
07:51:07,428 --> 07:51:09,363
down. If we scroll to a few

11856
07:51:09,363 --> 07:51:09,697
more it is illustrated much

11857
07:51:09,697 --> 07:51:10,598
easier to see?

11858
07:51:10,598 --> 07:51:13,598
>> Florida Rising: we will get

11859
07:51:16,300 --> 07:51:17,404
there.

11860
07:51:17,404 --> 07:51:20,404
Would you accept subject to

11861
07:51:21,740 --> 07:51:24,674
check for the 54 years of data

11862
07:51:25,412 --> 07:51:27,281
that are shown here there are

11863
07:51:27,281 --> 07:51:28,449
23 years for which the total

11864
07:51:28,449 --> 07:51:31,449
heating degree days were fewer

11865
07:51:32,190 --> 07:51:32,119
than teco is 20 near-normal

11866
07:51:32,119 --> 07:51:33,286
.

11867
07:51:33,286 --> 07:51:34,154
>> teco Witness: subject to

11868
07:51:34,154 --> 07:51:36,890
check yes.

11869
07:51:36,890 --> 07:51:37,724
>> Florida Rising: subject to

11870
07:51:37,724 --> 07:51:39,326
check their work tenures with

11871
07:51:39,326 --> 07:51:42,326
fewer heating degree days lower

11872
07:51:44,965 --> 07:51:47,233
than the current 20 near-normal

11873
07:51:47,233 --> 07:51:49,633
in the 34 years between 1970

11874
07:51:50,871 --> 07:51:52,871
and 2003.

11875
07:51:52,873 --> 07:51:53,720
>> teco Witness: subject to

11876
07:51:53,720 --> 07:51:54,474
check.

11877
07:51:54,474 --> 07:51:56,874
>> Florida Rising: 10 out of

11878
07:52:04,885 --> 07:52:06,860
10/24 hours is roughly 1/3

11879
07:52:06,860 --> 07:52:08,689
subject to check this chart

11880
07:52:08,689 --> 07:52:09,890
shows there were 13 years with

11881
07:52:09,890 --> 07:52:11,358
fewer heating degree days than

11882
07:52:11,358 --> 07:52:12,125
the current 20 near-normal

11883
07:52:12,125 --> 07:52:13,894
between 2004 and 2023?

11884
07:52:13,894 --> 07:52:14,495
>> teco Witness: yes.

11885
07:52:14,495 --> 07:52:15,562
>> Florida Rising: would you

11886
07:52:15,562 --> 07:52:16,363
accept my map that 13/20 is

11887
07:52:16,363 --> 07:52:17,898
roughly 2/3.

11888
07:52:17,898 --> 07:52:19,898
>> teco Witness: yes.

11889
07:52:20,340 --> 07:52:23,340
>> Florida Rising: this one I

11890
07:52:24,338 --> 07:52:26,240
don't think we have to subject

11891
07:52:26,240 --> 07:52:29,840
to check there are fewer of

11892
07:52:32,346 --> 07:52:32,979
them none of tenures had a

11893
07:52:32,979 --> 07:52:33,480
fewer heating to read days the

11894
07:52:33,480 --> 07:52:33,847
20b0 normal.

11895
07:52:33,847 --> 07:52:35,349
>> teco

11896
07:52:35,349 --> 07:52:35,716
Witness: subject to

11897
07:52:35,716 --> 07:52:37,551
check aspirin.

11898
07:52:37,551 --> 07:52:39,951
>> Florida Rising: that would

11899
07:52:40,487 --> 07:52:40,721
be a rate of 90%

11900
07:52:40,721 --> 07:52:41,888
.

11901
07:52:41,888 --> 07:52:42,923
>> teco Witness: subject to

11902
07:52:42,923 --> 07:52:44,958
check your math yes.

11903
07:52:44,958 --> 07:52:46,727
>> Florida Rising: it's looking

11904
07:52:46,727 --> 07:52:48,728
at the next sheet cooling

11905
07:52:48,728 --> 07:52:48,995
degree days go through the same

11906
07:52:48,995 --> 07:52:50,864
exercise.

11907
07:52:50,864 --> 07:52:51,932
Again there is 54 years of data

11908
07:52:51,932 --> 07:52:54,332
shown on this chart.

11909
07:52:57,236 --> 07:52:59,106
I by my count there are 16

11910
07:52:59,106 --> 07:53:00,307
years for which the total

11911
07:53:00,307 --> 07:53:02,242
cooling degree days were higher

11912
07:53:02,242 --> 07:53:04,642
than teco 20 year normal.

11913
07:53:08,882 --> 07:53:10,882
Would you agree.

11914
07:53:10,884 --> 07:53:12,151
Would you accept there just six

11915
07:53:12,151 --> 07:53:15,151
years with more cooling degree

11916
07:53:15,222 --> 07:53:16,390
days than the current 20

11917
07:53:16,390 --> 07:53:18,790
near-normal in the 34 years

11918
07:55:33,693 --> 07:55:34,928
between 1970 and 2003.

11919
07:55:34,928 --> 07:55:36,763
>> teco Witness: the top left

11920
07:55:36,763 --> 07:55:37,898
is the heating degree days you

11921
07:55:37,898 --> 07:55:39,700
can see that I drafted the

11922
07:55:39,700 --> 07:55:41,100
solid red line is a 20

11923
07:55:41,100 --> 07:55:42,200
near-normal the dotted line is

11924
07:55:42,200 --> 07:55:43,904
the 10 year normal.

11925
07:55:43,904 --> 07:55:45,839
To do the degree days have been

11926
07:55:45,839 --> 07:55:47,741
going down the graph next to it

11927
07:55:47,741 --> 07:55:49,242
is cooling degree days you can

11928
07:55:49,242 --> 07:55:49,909
see it has been higher in the

11929
07:55:49,909 --> 07:55:51,845
last 10 years.

11930
07:55:51,845 --> 07:55:55,445
The point I want to make

11931
07:56:02,555 --> 07:56:04,458
customers are using more energy

11932
07:56:04,458 --> 07:56:06,359
and at the heating degree days

11933
07:56:06,359 --> 07:56:07,761
when it's the heating degree

11934
07:56:07,761 --> 07:56:09,362
date; degree day. In other

11935
07:56:09,362 --> 07:56:10,530
words 10 heating degree days

11936
07:56:10,530 --> 07:56:12,499
customers are going to use a

11937
07:56:12,499 --> 07:56:12,699
lot more than 10 cooling degree

11938
07:56:12,699 --> 07:56:14,699
days.

11939
07:56:18,671 --> 07:56:20,607
Door heating appliances just

11940
07:56:20,607 --> 07:56:21,808
use more electricity vendor

11941
07:56:21,808 --> 07:56:23,743
cooling appliances. We would be

11942
07:56:23,743 --> 07:56:25,645
losing some load on the heating

11943
07:56:25,645 --> 07:56:26,646
site. We are making it up on

11944
07:56:26,646 --> 07:56:27,814
the cooling side.

11945
07:56:27,814 --> 07:56:29,716
if you look at it together

11946
07:56:29,716 --> 07:56:30,916
which is important was on the

11947
07:56:30,916 --> 07:56:32,619
bottom two graphs.

11948
07:56:32,619 --> 07:56:34,620
The bottom left to start with

11949
07:56:34,620 --> 07:56:35,822
you can see the solid red line

11950
07:56:35,822 --> 07:56:37,624
which is my 20 near-normal.

11951
07:56:37,624 --> 07:56:40,624
It is way above those

11952
07:56:42,229 --> 07:56:43,395
historical values.

11953
07:56:43,395 --> 07:56:45,365
All the way back to 1970. We

11954
07:56:45,365 --> 07:56:46,333
are hovering over the highest

11955
07:56:46,333 --> 07:56:48,333
hottest years.

11956
07:56:55,208 --> 07:56:57,110
During that period yes we are

11957
07:56:57,110 --> 07:56:58,345
below the past nine which is a

11958
07:56:58,345 --> 07:57:01,810
are anomalous. Which leads me

11959
07:57:01,810 --> 07:57:02,820
to the second graph. The bottom

11960
07:57:02,820 --> 07:57:03,249
graph on the right. That has

11961
07:57:03,249 --> 07:57:05,552
buxton you see I've put a box

11962
07:57:05,552 --> 07:57:06,786
between 1970 and 2014.

11963
07:57:06,786 --> 07:57:08,655
That looks pretty stable if you

11964
07:57:08,655 --> 07:57:10,556
were to draw a trend line

11965
07:57:10,556 --> 07:57:13,556
through that it would be

11966
07:57:16,290 --> 07:57:17,931
relatively flat and maybe take

11967
07:57:17,931 --> 07:57:19,132
up a little bit one of those

11968
07:57:19,132 --> 07:57:21,340
years in their 2010 which was a

11969
07:57:21,340 --> 07:57:22,969
cold winter not even in a hot

11970
07:57:22,969 --> 07:57:24,170
year. It was a cold year which

11971
07:57:24,170 --> 07:57:26,710
made those total degree days

11972
07:57:26,710 --> 07:57:27,307
spike. That is a stable trend.

11973
07:57:27,307 --> 07:57:28,441
Now boxed in the past nine

11974
07:57:28,441 --> 07:57:28,642
years that we keep talking

11975
07:57:28,642 --> 07:57:30,642
about.

11976
07:57:41,154 --> 07:57:43,156
O me anomalous means

11977
07:57:43,156 --> 07:57:44,390
different than what you expect

11978
07:57:44,390 --> 07:57:46,226
different than what you've seen

11979
07:57:46,226 --> 07:57:48,194
in the past. That is why I'm

11980
07:57:48,194 --> 07:57:50,196
saying those tenures are

11981
07:57:50,196 --> 07:57:51,298
anomalous to me david been

11982
07:57:51,298 --> 07:57:53,332
extremely hot I agree.

11983
07:57:53,332 --> 07:57:55,201
It is nothing like what we have

11984
07:57:55,201 --> 07:57:56,770
seen. To say that those nine

11985
07:57:56,770 --> 07:57:58,371
years there are going to be our

11986
07:57:58,371 --> 07:57:59,405
new normal no utilities ready

11987
07:57:59,405 --> 07:58:01,207
to say that.

11988
07:58:01,207 --> 07:58:01,541
This to me is an important

11989
07:58:01,541 --> 07:58:03,442
illustration.

11990
07:58:03,442 --> 07:58:07,420
I work 20 years is somewhere we

11991
07:58:09,415 --> 07:58:11,284
have those nine years in that

11992
07:58:11,284 --> 07:58:12,485
box area then we have the 10

11993
07:58:12,485 --> 07:58:14,487
years prior to it. Our normals

11994
07:58:14,487 --> 07:58:16,356
are right in between there. Our

11995
07:58:16,356 --> 07:58:16,590
normals are getting harder and

11996
07:58:16,590 --> 07:58:18,590
harder.

11997
07:58:19,325 --> 07:58:20,727
I believe that is just the best

11998
07:58:20,727 --> 07:58:22,295
representation for future

11999
07:58:22,295 --> 07:58:23,530
weather for load forecasting.

12000
07:58:23,530 --> 07:58:25,465
>> Florida Rising: looking at

12001
07:58:25,465 --> 07:58:27,367
these illustrations as you note

12002
07:58:27,367 --> 07:58:28,501
you have your tenure or your 20

12003
07:58:28,501 --> 07:58:29,769
near-normal and retain your

12004
07:58:29,769 --> 07:58:32,769
normal as flatlands you would

12005
07:58:33,540 --> 07:58:34,674
agree that those are not best

12006
07:58:34,674 --> 07:58:36,543
lines for the date on this

12007
07:58:36,543 --> 07:58:40,143
chart on any of these charts.

12008
07:58:43,716 --> 07:58:44,918
>> teco Witness: albert 20 year

12009
07:58:44,918 --> 07:58:46,853
monte carlo 20 year average in

12010
07:58:46,853 --> 07:58:48,722
our monte carlo tenure average.

12011
07:58:48,722 --> 07:58:49,922
>> teco Witness: the data

12012
07:58:49,922 --> 07:58:52,191
points in this chart are not

12013
07:58:52,191 --> 07:58:55,791
monte carlo they are not monte

12014
07:58:56,763 --> 07:58:57,597
carlo numbers correct those are

12015
07:58:57,597 --> 07:58:58,765
actuals.

12016
07:58:58,765 --> 07:59:00,800
>> Florida Rising: you agree

12017
07:59:00,800 --> 07:59:01,434
that tenant 20 year monte carlo

12018
07:59:01,434 --> 07:59:01,534
lines

12019
07:59:01,534 --> 07:59:03,503
.

12020
07:59:03,503 --> 07:59:06,503
>> teco Witness: they are only

12021
07:59:07,307 --> 07:59:10,307
bested for the 20 year period

12022
07:59:11,344 --> 07:59:12,578
not for this entire period.

12023
07:59:12,578 --> 07:59:15,578
>> Florida Rising: even for the

12024
07:59:15,882 --> 07:59:16,850
20 year period if I understand

12025
07:59:16,850 --> 07:59:18,850
the cancellation.

12026
07:59:21,988 --> 07:59:23,122
>> teco Witness: is an average.

12027
07:59:23,122 --> 07:59:24,990
>> Florida Rising: to your

12028
07:59:24,990 --> 07:59:26,993
point if you draw a neat box

12029
07:59:26,993 --> 07:59:29,728
around the last nine years and

12030
07:59:29,728 --> 07:59:30,964
disaggregate that.

12031
07:59:30,964 --> 07:59:34,567
You would agree if you have one

12032
07:59:34,567 --> 07:59:36,503
year that is an outlier perhaps

12033
07:59:36,503 --> 07:59:37,604
it is not worth changing how

12034
07:59:37,604 --> 07:59:38,804
the system operates.

12035
07:59:38,804 --> 07:59:39,906
Is that fair to say?

12036
07:59:39,906 --> 07:59:41,407
>> teco Witness: that is fair

12037
07:59:41,407 --> 07:59:41,508
to say

12038
07:59:41,508 --> 07:59:43,508
.

12039
07:59:43,609 --> 07:59:46,609
>> Florida Rising: this is nine

12040
07:59:47,614 --> 07:59:47,710
years in a row

12041
07:59:47,710 --> 07:59:48,470
.

12042
07:59:48,470 --> 07:59:50,470
[Unclear audio].

12043
07:59:50,783 --> 07:59:52,719
>> teco

12044
07:59:52,719 --> 07:59:54,187
Witness: that's correct it is

12045
07:59:54,187 --> 07:59:58,358
still anomalous we had a lot of

12046
07:59:58,358 --> 07:59:58,691
winter or the weather events

12047
07:59:58,691 --> 08:00:00,927
such as el nic

12048
08:00:00,927 --> 08:00:02,528
a number of

12049
08:00:02,528 --> 08:00:04,528
those.

12050
08:00:05,565 --> 08:00:07,534
During that period that we do

12051
08:00:07,534 --> 08:00:11,134
not have in the period before

12052
08:00:11,971 --> 08:00:13,971
it.

12053
08:00:13,973 --> 08:00:15,975
I just don't believe those

12054
08:00:15,975 --> 08:00:18,375
tenures should represent our

12055
08:00:18,378 --> 08:00:19,412
future.

12056
08:00:19,412 --> 08:00:21,347
If we did obviously guess our

12057
08:00:21,347 --> 08:00:23,850
retail energy cells would go up

12058
08:00:23,850 --> 08:00:25,919
and all revenues would go up it

12059
08:00:25,919 --> 08:00:27,190
does not viscerally mean that

12060
08:00:27,190 --> 08:00:29,789
the income would go up.

12061
08:00:29,789 --> 08:00:32,789
We would have duet additional

12062
08:00:33,593 --> 08:00:35,461
infrastructure. That costs

12063
08:00:35,461 --> 08:00:37,330
money. There are two sides you

12064
08:00:37,330 --> 08:00:38,498
have to look at.

12065
08:00:38,498 --> 08:00:42,980
Not just the story on energy

12066
08:00:44,170 --> 08:00:45,371
cells.

12067
08:00:45,371 --> 08:00:47,207
>> Florida Rising: recognizing

12068
08:00:47,207 --> 08:00:50,207
we've been talking about up

12069
08:00:52,245 --> 08:00:53,880
time and again 2023 now we are

12070
08:00:53,880 --> 08:00:54,213
in 2024 has 2024 been

12071
08:00:54,213 --> 08:00:56,490
returned

12072
08:00:56,490 --> 08:00:57,283
to normal for teco system.

12073
08:00:57,283 --> 08:00:59,319
>> teco Witness: through JUNE

12074
08:00:59,319 --> 08:00:59,685
we were below our normal degree

12075
08:00:59,685 --> 08:01:01,685
days.

12076
08:01:09,662 --> 08:01:10,863
Through JUNE.

12077
08:01:10,863 --> 08:01:12,665
>> Florida Rising: I think we

12078
08:01:12,665 --> 08:01:13,900
have good document to

12079
08:01:13,900 --> 08:01:15,768
illustrate this to me go to the

12080
08:01:15,768 --> 08:01:18,768
late filed number five this

12081
08:01:25,912 --> 08:01:27,146
will be e 8 274.

12082
08:01:27,146 --> 08:01:31,346
Do you by any chance have a

12083
08:01:32,618 --> 08:01:33,820
copy of your late file that you

12084
08:01:33,820 --> 08:01:35,722
can look at I think it would be

12085
08:01:35,722 --> 08:01:37,623
helpful to go back and forth

12086
08:01:37,623 --> 08:01:40,623
between the heating and cooling

12087
08:03:11,284 --> 08:03:11,418
degree days on the

12088
08:03:11,418 --> 08:03:13,351
.

12089
08:03:13,351 --> 08:03:16,351
>> Florida Rising: it is just

12090
08:03:20,493 --> 08:03:21,494
for heating degree days about

12091
08:03:21,494 --> 08:03:22,962
the tenure normal.

12092
08:03:22,962 --> 08:03:23,496
>> teco Witness: that is

12093
08:03:23,496 --> 08:03:24,730
correct.

12094
08:03:24,730 --> 08:03:26,131
>> Florida Rising: for MARCH it

12095
08:03:26,131 --> 08:03:27,500
is 40 heating degree days

12096
08:03:27,500 --> 08:03:29,500
written aspirin.

12097
08:03:29,502 --> 08:03:31,370
>> teco Witness: that is pure

12098
08:03:31,370 --> 08:03:31,704
heating to read is about the 10

12099
08:03:31,704 --> 08:03:33,704
and 20 near-normal.

12100
08:03:33,706 --> 08:03:35,608
>> teco Witness: I'm sorry what

12101
08:03:35,608 --> 08:03:37,430
was the last thing you said.

12102
08:03:37,430 --> 08:03:38,678
>> Florida Rising: 40 heating

12103
08:03:38,678 --> 08:03:40,613
degree days will be below the

12104
08:03:40,613 --> 08:03:41,814
40 and 10 near-normal spread.

12105
08:03:41,814 --> 08:03:44,814
> teco Witness: you are in

12106
08:03:45,170 --> 08:03:46,918
MARCH looking at APRIL there

12107
08:03:46,918 --> 08:03:49,918
were three heating degree days

12108
08:03:50,456 --> 08:03:51,590
in APRIL 2024?

12109
08:03:51,590 --> 08:03:53,990
>> teco Witness: that is

12110
08:03:55,636 --> 08:03:55,772
correct.

12111
08:03:55,772 --> 08:03:55,863
>> Florida Rising: that is

12112
08:03:55,863 --> 08:03:55,955
below the 20 near-normal and

12113
08:03:55,955 --> 08:03:56,470
the 10 near-normal fred

12114
08:03:56,470 --> 08:03:57,290
.

12115
08:03:57,290 --> 08:03:59,290
>> teco Witness: yes.

12116
08:04:00,499 --> 08:04:02,468
>> Florida Rising: then of

12117
08:04:02,468 --> 08:04:04,337
course we don't expect heating

12118
08:04:04,337 --> 08:04:05,771
degree days in MAY and JUNE.

12119
08:04:05,771 --> 08:04:07,473
>> teco Witness: that is

12120
08:04:07,473 --> 08:04:10,576
correct if we go to the cooling

12121
08:04:10,576 --> 08:04:11,810
degree days.

12122
08:04:11,810 --> 08:04:14,210
There were 43 cooling degree

12123
08:04:15,281 --> 08:04:17,283
days in JANUARY there were 43

12124
08:04:17,283 --> 08:04:17,483
cooling degree days in JANUARY

12125
08:04:17,483 --> 08:04:18,718
2024.

12126
08:04:18,718 --> 08:04:20,353
>> teco Witness: that is

12127
08:04:20,353 --> 08:04:21,454
correct that is below the 20

12128
08:04:21,454 --> 08:04:23,454
and 10 year normal.

12129
08:04:23,689 --> 08:04:24,957
>> Florida Rising: yes.

12130
08:04:24,957 --> 08:04:27,357
There were 46 cooling degree

12131
08:04:29,428 --> 08:04:29,561
days in FEBRUARY

12132
08:04:29,561 --> 08:04:30,662
.

12133
08:04:30,662 --> 08:04:32,631
>> teco Witness: that is

12134
08:04:32,631 --> 08:04:33,532
correct again below the 10 and

12135
08:04:33,532 --> 08:04:33,732
20 near-normal.

12136
08:04:33,732 --> 08:04:35,732
> Florida

12137
08:04:36,235 --> 08:04:38,304
Rising: MARCH there were 122

12138
08:04:38,304 --> 08:04:40,105
cooling degree days and that is

12139
08:04:40,105 --> 08:04:40,202
above the 20 year normal.

12140
08:04:40,202 --> 08:04:42,202
>

12141
08:04:42,273 --> 08:04:43,442
teco Witness: that is.

12142
08:04:43,442 --> 08:04:45,842
>> Florida Rising: for APRIL

12143
08:04:46,278 --> 08:04:48,800
there was 212 cooling degree

12144
08:04:48,800 --> 08:04:50,800
days.

12145
08:04:50,820 --> 08:04:53,820
>> teco Witness: I believe that

12146
08:04:54,620 --> 08:04:54,820
is normal

12147
08:04:54,820 --> 08:04:56,789
.

12148
08:04:56,789 --> 08:04:58,290
>> Florida Rising: that is

12149
08:04:58,290 --> 08:04:59,959
exactly the 20 near-normal.

12150
08:04:59,959 --> 08:05:01,927
>> teco Witness: correct.

12151
08:05:01,927 --> 08:05:03,662
>> Florida Rising: for me to

12152
08:05:03,662 --> 08:05:04,290
work hundred 82 cooling degree

12153
08:05:04,290 --> 08:05:05,630
days.

12154
08:05:05,630 --> 08:05:06,999
>> teco Witness: yes.

12155
08:05:06,999 --> 08:05:09,340
>> Florida Rising: which is

12156
08:05:09,340 --> 08:05:09,835
above the 20 and 10 near-normal

12157
08:05:09,835 --> 08:05:11,303
spread.

12158
08:05:11,303 --> 08:05:12,838
> teco Witness: for

12159
08:05:12,838 --> 08:05:14,106
JUNE the most recent month for

12160
08:05:14,106 --> 08:05:16,800
which you have degree data at

12161
08:05:16,800 --> 08:05:17,843
the time this was produced

12162
08:05:17,843 --> 08:05:18,430
there were 5178 cooling degree

12163
08:05:18,430 --> 08:05:19,411
days.

12164
08:05:19,411 --> 08:05:20,111
That is above the 20 year

12165
08:05:20,111 --> 08:05:21,113
normal.

12166
08:05:21,113 --> 08:05:22,214
>> teco Witness: yes.

12167
08:05:22,214 --> 08:05:23,150
>> Florida Rising: and

12168
08:05:23,150 --> 08:05:23,882
the 10

12169
08:05:23,882 --> 08:05:25,882
for normal.

12170
08:05:25,885 --> 08:05:26,885
>> teco Witness: if we take a

12171
08:05:26,885 --> 08:05:27,219
moment to scroll up through

12172
08:05:27,219 --> 08:05:29,540
that column.

12173
08:05:29,540 --> 08:05:30,989
>> teco Witness: I can tell you

12174
08:05:30,989 --> 08:05:32,124
the total even the 1383 that is

12175
08:05:32,124 --> 08:05:32,625
the lowest we'd seen in 10

12176
08:05:32,625 --> 08:05:34,260
years.

12177
08:05:34,260 --> 08:05:35,928
>> teco Witness: 1383.

12178
08:05:35,928 --> 08:05:37,960
>> Florida Rising: I'm sorry

12179
08:05:37,960 --> 08:05:40,960
I'm on cooling degree days.

12180
08:05:40,366 --> 08:05:42,301
For JUNE I'm comparing that to

12181
08:05:42,301 --> 08:05:46,501
your late filed if we look up

12182
08:06:26,378 --> 08:06:26,545
through JUNE

12183
08:06:26,545 --> 08:06:27,646
.

12184
08:06:27,646 --> 08:06:29,481
>> teco Witness: we are

12185
08:06:29,481 --> 08:06:30,649
planning for the whole theorem

12186
08:06:30,649 --> 08:06:32,518
1383 is the lowest cooling

12187
08:06:32,518 --> 08:06:32,918
degree days with seen in

12188
08:06:32,918 --> 08:06:34,918
tenures.

12189
08:06:34,920 --> 08:06:37,320
>> Florida Rising: a 10 year

12190
08:06:38,257 --> 08:06:40,391
period which you have 10 year

12191
08:06:40,391 --> 08:06:40,559
period which you characterize

12192
08:06:40,559 --> 08:06:40,654
as

12193
08:06:40,654 --> 08:06:40,992
.

12194
08:06:40,992 --> 08:06:42,992
[Unclear audio].

12195
08:06:43,462 --> 08:06:45,462
>> teco

12196
08:06:50,169 --> 08:06:52,169
Witness:

12197
08:06:52,171 --> 08:06:52,838
>> Florida Rising: it's lowest

12198
08:06:52,838 --> 08:06:54,139
in the 10 year

12199
08:06:54,139 --> 08:06:55,441
period that you

12200
08:06:55,441 --> 08:06:56,175
characterize as higher elevated

12201
08:06:56,175 --> 08:06:57,409
.

12202
08:06:57,409 --> 08:06:59,345
>> teco Witness: that is lower

12203
08:06:59,345 --> 08:07:02,345
than the anomalous period we

12204
08:07:11,290 --> 08:07:12,491
are moving I'm just saying it

12205
08:07:12,491 --> 08:07:16,910
is lower than what we've seen

12206
08:07:26,706 --> 08:07:27,940
in the past 10 years.

12207
08:07:27,940 --> 08:07:29,808
>> Florida Rising: give me a

12208
08:07:29,808 --> 08:07:34,120
moment and try to see if I can

12209
08:07:34,120 --> 08:07:36,412
find a few questions.

12210
08:07:37,583 --> 08:07:40,919
If you can go to your late

12211
08:07:40,919 --> 08:07:42,954
filed number seven this should

12212
08:07:42,954 --> 08:07:44,189
be just a few pages that is not

12213
08:07:44,189 --> 08:07:47,189
included in the staff exhibit

12214
08:07:49,994 --> 08:07:51,630
that is 3.F 3.1-3152

12215
08:07:51,630 --> 08:07:53,630
comprehensive exhibit

12216
08:07:56,701 --> 08:07:58,701
comprehensive exhibit 512.

12217
08:08:11,383 --> 08:08:13,383
Thank you.

12218
08:08:15,888 --> 08:08:20,688
If we can go to page 10 of this

12219
08:08:53,425 --> 08:08:55,425
document.

12220
08:08:55,427 --> 08:08:56,895
I believe it is consistent with

12221
08:08:56,895 --> 08:08:59,895
earlier testimony I want to

12222
08:09:00,232 --> 08:09:01,200
confirm that teco still just on

12223
08:09:01,200 --> 08:09:03,200
point.

12224
08:09:05,437 --> 08:09:08,473
Even though many of the more

12225
08:09:08,473 --> 08:09:09,841
recent years they are being

12226
08:09:09,841 --> 08:09:10,976
driven by cooling not heating.

12227
08:09:10,976 --> 08:09:13,376
>> teco Witness: that is

12228
08:09:13,445 --> 08:09:15,247
correct like I said we need to

12229
08:09:15,247 --> 08:09:18,847
plan for the winter peak for

12230
08:09:30,629 --> 08:09:31,730
capacity planning.

12231
08:09:31,730 --> 08:09:34,130
>> Florida Rising: we are

12232
08:09:43,608 --> 08:09:45,608
getting very close.

12233
08:09:50,916 --> 08:09:52,917
>> Florida Rising: I would like

12234
08:09:52,917 --> 08:09:54,920
to follow up on something as

12235
08:09:54,920 --> 08:09:55,821
true in our conversations

12236
08:09:55,821 --> 08:09:57,821
during

12237
08:09:57,856 --> 08:09:58,590
your deposition as we sit here

12238
08:09:58,590 --> 08:09:59,791
today

12239
08:09:59,791 --> 08:10:01,693
everywhere if emera has

12240
08:10:01,693 --> 08:10:01,927
taken a position on climate

12241
08:10:01,927 --> 08:10:03,828
change.

12242
08:10:03,828 --> 08:10:04,763
>> teco Witness: I'm not aware

12243
08:10:04,763 --> 08:10:05,731
.

12244
08:10:05,731 --> 08:10:06,765
>> Florida Rising: the same

12245
08:10:06,765 --> 08:10:07,966
question for teco.

12246
08:10:07,966 --> 08:10:09,901
>> teco Witness: I don't know.

12247
08:10:09,901 --> 08:10:11,737
>> Florida Rising: in directing

12248
08:10:11,737 --> 08:10:13,738
the activities of local

12249
08:10:13,738 --> 08:10:14,206
researching forecasting for

12250
08:10:14,206 --> 08:10:14,973
temporal letter

12251
08:10:14,973 --> 08:10:16,875
company your

12252
08:10:16,875 --> 08:10:18,744
team acknowledge the coming

12253
08:10:18,744 --> 08:10:19,911
change is consistently

12254
08:10:19,911 --> 08:10:21,780
increasing the average

12255
08:10:21,780 --> 08:10:22,800
temperature of the teco service

12256
08:10:22,800 --> 08:10:24,800
territory.

12257
08:10:24,783 --> 08:10:25,984
>> teco Witness: whether it is

12258
08:10:25,984 --> 08:10:27,918
climate change or not I don't

12259
08:10:27,918 --> 08:10:29,787
know but I would agree it has

12260
08:10:29,787 --> 08:10:30,540
been hotter as we just

12261
08:10:30,540 --> 08:10:31,790
discussed.

12262
08:10:31,790 --> 08:10:34,760
Climate change is a gradual

12263
08:10:34,760 --> 08:10:35,861
change I've seen sudden changes

12264
08:10:35,861 --> 08:10:38,861
as far as I'm concerned.

12265
08:10:38,964 --> 08:10:40,866
>> Florida Rising: does

12266
08:10:40,866 --> 08:10:42,567
temperature increase as the

12267
08:10:42,567 --> 08:10:44,967
demand for air conditioning

12268
08:10:46,104 --> 08:10:46,237
increases

12269
08:10:46,237 --> 08:10:47,439
.

12270
08:10:47,439 --> 08:10:48,206
>> teco Witness: say that one

12271
08:10:48,206 --> 08:10:49,307
time.

12272
08:10:49,307 --> 08:10:51,243
>> Florida Rising: as to

12273
08:10:51,243 --> 08:10:53,145
average temperature grison is

12274
08:10:53,145 --> 08:10:54,245
it fair to say demand for air

12275
08:10:54,245 --> 08:10:56,810
conditioning increases.

12276
08:10:56,810 --> 08:10:57,282
>> teco Witness: the demand

12277
08:10:57,282 --> 08:10:57,549
will increase in the winter

12278
08:10:57,549 --> 08:10:59,251
months

12279
08:10:59,251 --> 08:10:59,384
it can actually decrease

12280
08:10:59,384 --> 08:11:01,319
.

12281
08:11:01,319 --> 08:11:03,255
>> Florida Rising: that is fair

12282
08:11:03,255 --> 08:11:05,189
I guess let's say given the

12283
08:11:05,189 --> 08:11:07,920
data that we look out for last

12284
08:11:07,920 --> 08:11:08,326
number of years which was

12285
08:11:08,326 --> 08:11:09,428
available we were seeing peaks

12286
08:11:09,428 --> 08:11:10,528
in the summer.

12287
08:11:10,528 --> 08:11:12,528
>> teco Witness: yes.

12288
08:11:16,670 --> 08:11:17,969
>> Florida Rising: as the

12289
08:11:17,969 --> 08:11:18,937
temperature in the summer

12290
08:11:18,937 --> 08:11:19,971
increased we would

12291
08:11:19,971 --> 08:11:21,971
expect to see

12292
08:11:22,730 --> 08:11:23,341
higher air-conditioning usage

12293
08:11:23,341 --> 08:11:25,760
during those months.

12294
08:11:25,760 --> 08:11:25,310
>> teco Witness: yes just based

12295
08:11:25,310 --> 08:11:27,780
on that.

12296
08:11:27,780 --> 08:11:28,947
But consumers to change their

12297
08:11:28,947 --> 08:11:30,382
behavior and do conserve at

12298
08:11:30,382 --> 08:11:32,382
times.

12299
08:11:36,855 --> 08:11:38,560
But in general guess.

12300
08:11:38,560 --> 08:11:40,456
>> Florida Rising: because I

12301
08:11:43,327 --> 08:11:45,163
will put it this way we spoke

12302
08:11:45,163 --> 08:11:46,298
about that breakpoint at 65b0

12303
08:11:46,298 --> 08:11:48,698
breakpoint brain that is

12304
08:11:50,535 --> 08:11:51,336
embedded in teco's forecasting

12305
08:11:51,336 --> 08:11:52,437
model.

12306
08:11:52,437 --> 08:11:53,538
> teco Witness: that

12307
08:11:53,538 --> 08:11:54,506
is correct.

12308
08:11:54,506 --> 08:11:56,441
>> Florida Rising: that does

12309
08:11:56,441 --> 08:11:57,142
not assume customers will

12310
08:11:57,142 --> 08:11:57,509
change their

12311
08:11:57,509 --> 08:11:59,444
behavior.

12312
08:11:59,444 --> 08:11:59,644
>> teco Witness: the 65b0 does

12313
08:11:59,644 --> 08:12:01,512
not.

12314
08:12:01,512 --> 08:12:03,912
>> Florida Rising: I recognize

12315
08:12:04,316 --> 08:12:06,350
you make model adjustments for

12316
08:12:06,350 --> 08:12:08,253
energy efficiency and other

12317
08:12:08,253 --> 08:12:10,540
behavioral changes looking at

12318
08:12:10,540 --> 08:12:11,889
just the model itself you would

12319
08:12:11,889 --> 08:12:13,910
agree that if the ambient

12320
08:12:13,910 --> 08:12:14,926
temperature is increasing

12321
08:12:14,926 --> 08:12:16,127
further away from 65b0 there

12322
08:12:16,127 --> 08:12:18,396
would be more load associated

12323
08:12:18,396 --> 08:12:19,530
with returning climate

12324
08:12:19,530 --> 08:12:21,466
controlled spaces to 65b0.

12325
08:12:21,466 --> 08:12:23,268
>> teco Witness: I would say

12326
08:12:23,268 --> 08:12:24,603
because our normal heating

12327
08:12:24,603 --> 08:12:27,603
degree days are increasing then

12328
08:12:30,442 --> 08:12:34,642
I would say even if the 65b0

12329
08:12:34,980 --> 08:12:36,114
points do not change for

12330
08:12:36,114 --> 08:12:37,916
calculating the heating and

12331
08:12:37,916 --> 08:12:39,117
cooling degree days on

12332
08:12:39,117 --> 08:12:41,517
historical basis the future

12333
08:12:49,930 --> 08:12:51,930
normal has changed.

12334
08:12:51,960 --> 08:12:51,696
>> Florida Rising: to clarify

12335
08:12:51,696 --> 08:12:52,264
something I might

12336
08:12:52,264 --> 08:12:54,232
have been

12337
08:12:54,232 --> 08:12:56,101
served I thank you said heating

12338
08:12:56,101 --> 08:12:57,235
degree days increasing did you

12339
08:12:57,235 --> 08:12:59,104
mean cooling degrees.

12340
08:12:59,104 --> 08:13:00,105
>> teco Witness: I meant

12341
08:13:00,105 --> 08:13:01,673
cooling probably.

12342
08:13:01,673 --> 08:13:03,273
>> Florida Rising: I just want

12343
08:13:03,273 --> 08:13:04,109
to make sure I am not cracking

12344
08:13:04,109 --> 08:13:05,276
up.

12345
08:13:05,276 --> 08:13:07,111
recalling our earlier

12346
08:13:07,111 --> 08:13:08,246
discussion on the accuracy of

12347
08:13:08,246 --> 08:13:10,248
load forecasting and its

12348
08:13:10,248 --> 08:13:12,183
potential impacts for revenue.

12349
08:13:12,183 --> 08:13:13,251
Could ignoring the change in

12350
08:13:13,251 --> 08:13:14,619
weather baseline in teco

12351
08:13:14,619 --> 08:13:17,190
service territory benefit teco

12352
08:13:20,425 --> 08:13:21,626
by allowing for higher revenue

12353
08:13:21,626 --> 08:13:24,626
recovery and what is forecasted

12354
08:13:24,763 --> 08:13:24,863
for the year

12355
08:13:24,863 --> 08:13:26,131
.

12356
08:13:26,131 --> 08:13:29,131
>> teco Witness: can you repeat

12357
08:13:30,177 --> 08:13:30,304
that

12358
08:13:30,304 --> 08:13:32,304
again.

12359
08:13:33,371 --> 08:13:36,371
>> Florida Rising: if teco is

12360
08:13:36,741 --> 08:13:39,741
forecast do not take into

12361
08:13:40,412 --> 08:13:42,812
account potentially the new

12362
08:13:44,282 --> 08:13:47,282
normal or you acknowledged the

12363
08:13:48,860 --> 08:13:49,353
temperatures leased and left

12364
08:13:49,353 --> 08:13:51,256
tenures have been elevated for

12365
08:13:51,256 --> 08:13:52,124
what you consider to be at the

12366
08:13:52,124 --> 08:13:53,758
baseline?

12367
08:13:53,758 --> 08:13:56,158
If teco is forecast

12368
08:13:56,861 --> 08:13:58,861
forward-looking forecast treats

12369
08:14:00,565 --> 08:14:02,734
those years anomalies and

12370
08:14:02,734 --> 08:14:04,369
continues to expect lower load

12371
08:14:04,369 --> 08:14:05,570
than his actual could it teco

12372
08:14:05,570 --> 08:14:07,970
be benefiting by recovering

12373
08:14:09,674 --> 08:14:10,842
more energy sales then is

12374
08:14:10,842 --> 08:14:13,242
forecast through the commission

12375
08:14:15,846 --> 08:14:17,810
as part of this rate.

12376
08:14:17,810 --> 08:14:17,282
>> teco Witness: save the last

12377
08:14:17,282 --> 08:14:18,983
part

12378
08:14:18,983 --> 08:14:19,851
of the question I got the

12379
08:14:19,851 --> 08:14:20,185
beginning.

12380
08:14:20,185 --> 08:14:22,185
> Florida Rising:

12381
08:14:25,256 --> 08:14:27,258
diego is making a forecast

12382
08:14:27,258 --> 08:14:29,260
through this commission about

12383
08:14:29,260 --> 08:14:30,428
the amount of energy it expects

12384
08:14:30,428 --> 08:14:32,429
to sell to customers.

12385
08:14:32,429 --> 08:14:34,365
That forecast as we discussed

12386
08:14:34,365 --> 08:14:36,501
as part of the predicate from

12387
08:14:36,501 --> 08:14:38,436
which the ultimate tariff sheet

12388
08:14:38,436 --> 08:14:42,636
and drive to make sure that the

12389
08:14:43,908 --> 08:14:45,110
company can recover its revenue

12390
08:14:45,110 --> 08:14:46,978
requirements. That is based on

12391
08:14:46,978 --> 08:14:47,311
an expected percentage of

12392
08:14:47,311 --> 08:14:49,311
sales.

12393
08:14:49,848 --> 08:14:50,470
>> teco Witness: yes

12394
08:14:50,470 --> 08:14:52,160
.

12395
08:14:52,160 --> 08:14:53,118
>> Florida Rising: rather an

12396
08:14:53,118 --> 08:14:55,190
expected total sales.

12397
08:14:55,190 --> 08:14:56,221
>> teco Witness: correct.

12398
08:14:56,221 --> 08:14:58,220
>> Florida Rising: if teco is

12399
08:14:58,220 --> 08:14:59,189
actual sales or above that

12400
08:14:59,189 --> 08:15:02,189
number it can over recover.

12401
08:15:03,728 --> 08:15:05,663
>> teco Witness: as of this

12402
08:15:05,663 --> 08:15:07,565
before you're looking at just

12403
08:15:07,565 --> 08:15:08,700
one part of the equation. You

12404
08:15:08,700 --> 08:15:10,602
need to look at the expense

12405
08:15:10,602 --> 08:15:11,669
side to if energy sales will

12406
08:15:11,669 --> 08:15:12,837
increase there will be

12407
08:15:12,837 --> 08:15:14,739
increases in the expense side.

12408
08:15:14,739 --> 08:15:15,600
I don't know what that net

12409
08:15:15,600 --> 08:15:16,574
impact is.

12410
08:15:16,574 --> 08:15:18,574
Hen you say

12411
08:15:18,576 --> 08:15:19,744
increase on the expense side

12412
08:15:19,744 --> 08:15:21,579
premium if energy sales are

12413
08:15:21,579 --> 08:15:23,979
higher there could be

12414
08:15:25,820 --> 08:15:27,820
additional content expenses

12415
08:15:27,850 --> 08:15:28,253
maintenance for operational

12416
08:15:28,253 --> 08:15:30,188
purposes. Things like that.

12417
08:15:30,188 --> 08:15:32,900
We are not looking at that burn

12418
08:15:32,900 --> 08:15:33,291
if you are talking long-term

12419
08:15:33,291 --> 08:15:35,590
there could be additional

12420
08:15:35,590 --> 08:15:36,127
capital infrastructure

12421
08:15:36,127 --> 08:15:38,127
expenses.

12422
08:15:41,310 --> 08:15:42,200
You can't just look at the

12423
08:15:42,200 --> 08:15:44,769
impact on energy sales and

12424
08:15:44,769 --> 08:15:45,470
revenue you have to look at the

12425
08:15:45,470 --> 08:15:47,372
big picture to determine what

12426
08:15:47,372 --> 08:15:48,606
the impact would be on the

12427
08:15:48,606 --> 08:15:50,441
revenue requirements.

12428
08:15:50,441 --> 08:15:51,642
>> Florida Rising: for the

12429
08:15:51,642 --> 08:15:55,460
three year rate period that is

12430
08:15:55,460 --> 08:15:59,246
at issue in this case you would

12431
08:16:00,652 --> 08:16:02,586
agree that that we are not

12432
08:16:02,586 --> 08:16:04,589
talking about long-term impacts

12433
08:16:04,589 --> 08:16:07,325
we are talking about the things

12434
08:16:07,325 --> 08:16:07,625
that are forecast for the next

12435
08:16:07,625 --> 08:16:08,359
three years.

12436
08:16:08,359 --> 08:16:10,161
>> teco Witness: it was either

12437
08:16:10,161 --> 08:16:11,562
late filed exhibit or my

12438
08:16:11,562 --> 08:16:12,363
rebuttal testimony were

12439
08:16:12,363 --> 08:16:14,298
actually did a scenario 10

12440
08:16:14,298 --> 08:16:16,167
years and yes revenues went up

12441
08:16:16,167 --> 08:16:17,368
8/10 of a percent energy went

12442
08:16:17,368 --> 08:16:21,568
up peak demand went up by close

12443
08:16:22,840 --> 08:16:24,800
to 170 mw.

12444
08:16:24,800 --> 08:16:25,610
In the test year of 2025. I

12445
08:16:25,610 --> 08:16:27,645
would think there would be some

12446
08:16:27,645 --> 08:16:29,814
additional cost associated with

12447
08:16:29,814 --> 08:16:31,814
that.

12448
08:16:32,783 --> 08:16:34,685
>> Florida Rising: do you

12449
08:16:34,685 --> 08:16:35,887
recall we looked that peak

12450
08:16:35,887 --> 08:16:38,122
demand charts the general range

12451
08:16:38,122 --> 08:16:40,158
that was offered the

12452
08:16:40,158 --> 08:16:42,558
interruptible and curtail bull

12453
08:16:43,628 --> 08:16:46,628
customers subject to check the

12454
08:16:53,371 --> 08:16:54,772
mid 160-280 I forget what it

12455
08:16:54,772 --> 08:16:57,800
was is it fair to say that

12456
08:16:57,800 --> 08:16:57,742
there was 200 mw that teco can:

12457
08:16:57,742 --> 08:16:58,142
for

12458
08:16:58,142 --> 08:16:59,677
curtailment.

12459
08:16:59,677 --> 08:16:59,777
>> teco Witness: yes

12460
08:16:59,777 --> 08:17:01,777
.

12461
08:17:01,846 --> 08:17:04,846
>> Florida Rising: to the other

12462
08:17:05,783 --> 08:17:07,852
just briefly mentioned increase

12463
08:17:07,852 --> 08:17:09,553
energy sales can be associated

12464
08:17:09,553 --> 08:17:09,820
with increased trend

12465
08:17:09,820 --> 08:17:10,655
that o&m

12466
08:17:10,655 --> 08:17:11,722
expense.

12467
08:17:11,722 --> 08:17:14,122
>> teco Witness: I would

12468
08:17:17,828 --> 08:17:19,830
believe it has an impact.

12469
08:17:19,830 --> 08:17:21,650
>> Florida Rising: that is not

12470
08:17:21,650 --> 08:17:21,899
recovered as part of the base

12471
08:17:21,899 --> 08:17:22,660
rate

12472
08:17:22,660 --> 08:17:23,534
.

12473
08:17:23,534 --> 08:17:25,236
>> teco Witness: I'm getting

12474
08:17:25,236 --> 08:17:26,737
out of my area of expertise I

12475
08:17:26,737 --> 08:17:28,706
will save the current 24 peak

12476
08:17:28,706 --> 08:17:29,907
demand forecast over the past

12477
08:17:29,907 --> 08:17:32,307
two months we've been 8

12478
08:17:33,978 --> 08:17:35,912
megawatts lower than forecast

12479
08:17:35,912 --> 08:17:38,382
2/10 of a percent or forecast

12480
08:17:38,382 --> 08:17:40,551
based on these 20 year

12481
08:17:40,551 --> 08:17:43,551
forecasts are very much in

12482
08:17:43,654 --> 08:17:44,889
line.

12483
08:17:44,889 --> 08:17:46,924
>> Florida Rising: based on the

12484
08:17:46,924 --> 08:17:48,793
weather normalization.

12485
08:17:48,793 --> 08:17:50,761
>> teco Witness: we don't

12486
08:17:50,761 --> 08:17:51,996
delete weather normalized to

12487
08:17:51,996 --> 08:17:53,798
the men it is more complicated

12488
08:17:53,798 --> 08:17:54,932
on an actual basis the peak

12489
08:17:54,932 --> 08:17:57,567
demands over the past two

12490
08:17:57,567 --> 08:17:59,503
months we've been the actuals

12491
08:17:59,503 --> 08:18:01,903
have been 8 megawatts lower

12492
08:18:03,841 --> 08:18:05,142
2/10 of a percent or forecast

12493
08:18:05,142 --> 08:18:07,845
the mid forecast online as well

12494
08:18:07,845 --> 08:18:08,779
as the energy forecast for this

12495
08:18:08,779 --> 08:18:09,981
proceeding.

12496
08:18:09,981 --> 08:18:11,849
>> Florida Rising: I have one

12497
08:18:11,849 --> 08:18:15,449
more thing for you can we

12498
08:18:30,735 --> 08:18:32,970
please go to f16-99.

12499
08:18:32,970 --> 08:18:37,770
We are going to go to tab ma

12500
08:19:49,747 --> 08:19:51,747
price.

12501
08:20:30,854 --> 08:20:32,220
[Unclear audio].

12502
08:20:32,220 --> 08:20:33,823
>> Florida Rising: that will

12503
08:20:33,823 --> 08:20:35,859
get you close we are just

12504
08:20:35,859 --> 08:20:39,459
looking for the graph that is

12505
08:20:41,498 --> 08:20:43,498
there.

12506
08:20:57,715 --> 08:20:58,949
[Unclear audio].

12507
08:20:58,949 --> 08:21:02,549
>> teco Witness: I can try to

12508
08:21:09,893 --> 08:21:11,893
scroll to it.

12509
08:21:12,630 --> 08:21:15,300
>> Florida Rising: I figured

12510
08:21:16,673 --> 08:21:17,234
out the cell hoping I can

12511
08:21:17,234 --> 08:21:18,468
figure out and save some time

12512
08:21:18,468 --> 08:21:20,468
from scrolling.

12513
08:21:26,109 --> 08:21:27,645
I apologize.

12514
08:21:27,645 --> 08:21:29,246
>> teco Witness: are you on the

12515
08:21:29,246 --> 08:21:31,246
moving average price.

12516
08:21:31,915 --> 08:21:33,817
>> Florida Rising: moving

12517
08:21:33,817 --> 08:21:35,190
average price it should be

12518
08:21:35,190 --> 08:21:38,190
delete 700 spring you will need

12519
08:21:42,920 --> 08:21:43,327
to go over to the right.

12520
08:21:43,327 --> 08:21:46,327
>> teco Witness: we are getting

12521
08:21:49,867 --> 08:21:51,867
there slowly.

12522
08:21:55,839 --> 08:21:57,839
Got it.

12523
08:21:58,842 --> 08:22:00,510
I am there.

12524
08:22:00,510 --> 08:22:01,711
>> Florida Rising: thank you.

12525
08:22:01,711 --> 08:22:05,311
This is one of your workpapers?

12526
08:22:05,949 --> 08:22:07,818
>> teco Witness: this is done

12527
08:22:07,818 --> 08:22:08,919
under my guidance. I did not

12528
08:22:08,919 --> 08:22:10,120
prepare it myself.

12529
08:22:10,120 --> 08:22:12,520
>> Florida Rising: this track

12530
08:22:15,626 --> 08:22:17,594
we are looking at tracks the

12531
08:22:17,594 --> 08:22:18,762
moving average price of

12532
08:22:18,762 --> 08:22:19,829
electricity per customer).

12533
08:22:19,829 --> 08:22:21,829
>> teco Witness: yes.

12534
08:22:21,831 --> 08:22:23,701
>> Florida Rising: really quick

12535
08:22:23,701 --> 08:22:27,301
about that while we talk about

12536
08:22:29,173 --> 08:22:31,750
ma does replace me and it is

12537
08:22:31,750 --> 08:22:32,176
adjusted for inflation.

12538
08:22:32,176 --> 08:22:34,770
>> teco Witness: correct this

12539
08:22:34,770 --> 08:22:37,770
the total price of inflation

12540
08:22:37,581 --> 08:22:40,581
not the base rate portion.

12541
08:22:49,626 --> 08:22:51,562
>> Florida Rising: I know you

12542
08:22:51,562 --> 08:22:53,497
are not here during MR. Collins

12543
08:22:53,497 --> 08:22:55,432
testimony you MAY not know the

12544
08:22:55,432 --> 08:22:56,700
answer to this. I don't know if

12545
08:22:56,700 --> 08:22:58,602
you're able to listen in but

12546
08:22:58,602 --> 08:23:00,471
MR. Collins testified earlier

12547
08:23:00,471 --> 08:23:01,638
this week when adjusted for

12548
08:23:01,638 --> 08:23:03,474
inflation teco is great not

12549
08:23:03,474 --> 08:23:05,476
increase in left tenures.

12550
08:23:05,476 --> 08:23:05,842
Would you agree with that

12551
08:23:05,842 --> 08:23:07,842
representation.

12552
08:23:08,245 --> 08:23:11,245
>> teco Witness: do you know

12553
08:23:13,116 --> 08:23:16,116
what he was talking about.

12554
08:23:16,987 --> 08:23:18,922
>> Florida Rising: he set in

12555
08:23:18,922 --> 08:23:20,924
this commission he said they

12556
08:23:20,924 --> 08:23:21,991
are not increased in the last

12557
08:23:21,991 --> 08:23:22,926
10 years.

12558
08:23:22,926 --> 08:23:23,127
I assume he's talking about

12559
08:23:23,127 --> 08:23:24,862
today.

12560
08:23:24,862 --> 08:23:26,862
And years ago.

12561
08:23:30,834 --> 08:23:33,570
>> teco Witness: 2023 if I put

12562
08:23:33,570 --> 08:23:36,106
my cursor on the residential

12563
08:23:36,106 --> 08:23:38,106
aqua colored line

12564
08:23:38,475 --> 08:23:40,475
.

12565
08:23:41,545 --> 08:23:43,460
>> Florida Rising: I'm assuming

12566
08:23:43,460 --> 08:23:43,134
he was talking 2024

12567
08:23:43,134 --> 08:23:45,134
.

12568
08:23:47,750 --> 08:23:49,753
>> teco Witness: I don't know

12569
08:23:49,753 --> 08:23:51,255
if this is the appropriate

12570
08:23:51,255 --> 08:23:52,756
comparison. This is done to

12571
08:23:52,756 --> 08:23:53,957
come up with a price of

12572
08:23:53,957 --> 08:23:55,659
electricity trying to put into

12573
08:23:55,659 --> 08:23:58,659
our consumption models it MAY

12574
08:24:00,664 --> 08:24:03,533
not really be what MR. Collins

12575
08:24:03,533 --> 08:24:04,735
was using.

12576
08:24:04,735 --> 08:24:06,670
>> Florida Rising: let's talk

12577
08:24:06,670 --> 08:24:09,506
about that trend for second.

12578
08:24:09,506 --> 08:24:12,876
The rockwell plan that is the

12579
08:24:12,876 --> 08:24:12,976
residential)

12580
08:24:12,976 --> 08:24:14,144
.

12581
08:24:14,144 --> 08:24:15,946
>> teco Witness: I will say

12582
08:24:15,946 --> 08:24:16,280
this is a 12 month moving

12583
08:24:16,280 --> 08:24:17,513
average.

12584
08:24:17,513 --> 08:24:19,716
The peak that we have because

12585
08:24:19,716 --> 08:24:20,917
of the fuel would be pushed

12586
08:24:20,917 --> 08:24:23,520
would be seen out into the

12587
08:24:23,520 --> 08:24:25,520
future.

12588
08:24:25,522 --> 08:24:26,623
One year or so. That is why I'm

12589
08:24:26,623 --> 08:24:30,223
saying it is not a good

12590
08:24:33,196 --> 08:24:34,331
comparison.

12591
08:24:34,331 --> 08:24:36,300
>> Florida Rising: is a 12

12592
08:24:36,300 --> 08:24:37,401
month moving average this chart

12593
08:24:37,401 --> 08:24:38,302
would flatten the highest

12594
08:24:38,302 --> 08:24:39,202
peaks.

12595
08:24:39,202 --> 08:24:41,204
you might see on a

12596
08:24:41,204 --> 08:24:42,205
month-to-month basis.

12597
08:24:42,205 --> 08:24:44,207
>> teco Witness: it would

12598
08:24:44,207 --> 08:24:44,507
smooth out the month-to-month

12599
08:24:44,507 --> 08:24:46,410
variations.

12600
08:24:46,410 --> 08:24:48,810
>> Florida Rising: looking at

12601
08:24:50,580 --> 08:24:52,582
that blueline you would agree

12602
08:24:52,582 --> 08:24:53,749
that residential prices on this

12603
08:24:53,749 --> 08:24:55,719
chart are shown to be the

12604
08:24:55,719 --> 08:24:56,286
highest they've been in about

12605
08:24:56,286 --> 08:24:58,286
15 years.

12606
08:24:58,622 --> 08:24:59,790
The moving average price for

12607
08:24:59,790 --> 08:25:01,790
residential customers.

12608
08:25:01,892 --> 08:25:03,727
>> teco Witness: again, I would

12609
08:25:03,727 --> 08:25:07,130
have to recall how we came up

12610
08:25:07,130 --> 08:25:08,365
with all of these numbers.

12611
08:25:08,365 --> 08:25:10,367
>> Florida Rising: looking at

12612
08:25:10,367 --> 08:25:12,169
the documents you provided us.

12613
08:25:12,169 --> 08:25:13,370
That is what it shows?

12614
08:25:13,370 --> 08:25:14,338
>> teco Witness: that is what

12615
08:25:14,338 --> 08:25:16,139
it looks like.

12616
08:25:16,139 --> 08:25:17,374
>> Florida Rising:

12617
08:25:17,374 --> 08:25:19,943
>> teco Witness: that MAY not

12618
08:25:19,943 --> 08:25:21,110
be reality.

12619
08:25:21,110 --> 08:25:22,979
>> Florida Rising: that is

12620
08:25:22,979 --> 08:25:25,482
because of the big spikes

12621
08:25:25,482 --> 08:25:27,482
starting in 2022?

12622
08:25:28,618 --> 08:25:29,720
>> teco Witness: possibly with

12623
08:25:29,720 --> 08:25:30,453
the fuel increases that

12624
08:25:30,453 --> 08:25:31,321
we

12625
08:25:31,321 --> 08:25:33,321
celebrated.

12626
08:25:37,728 --> 08:25:39,595
>> Florida Rising: there is a

12627
08:25:39,595 --> 08:25:41,531
note the one we had to move so

12628
08:25:41,531 --> 08:25:42,766
we can see the blue line. That

12629
08:25:42,766 --> 08:25:44,701
note indicates the spike is due

12630
08:25:44,701 --> 08:25:46,736
to the rate increases following

12631
08:25:46,736 --> 08:25:48,736
the 2021 settlement agreement.

12632
08:25:48,772 --> 08:25:48,972
>> teco Witness: I would assume

12633
08:25:48,972 --> 08:25:50,972
that

12634
08:25:51,400 --> 08:25:51,808
does include the 2022 rate

12635
08:25:51,808 --> 08:25:52,609
increases.

12636
08:25:52,609 --> 08:25:54,544
Speed 14.

12637
08:25:54,544 --> 08:25:55,545
>> Florida Rising: the note.

12638
08:25:55,545 --> 08:25:56,780
[Unclear audio].

12639
08:25:56,780 --> 08:25:56,913
It does not mention fuel prices

12640
08:25:56,913 --> 08:25:58,913
.

12641
08:26:11,928 --> 08:26:13,928
>> teco Witness: no.

12642
08:26:13,930 --> 08:26:15,265
It could be including the fuel

12643
08:26:15,265 --> 08:26:17,100
prices we just don't specify

12644
08:26:17,100 --> 08:26:17,500
these are comments for our own

12645
08:26:17,500 --> 08:26:18,635
use.

12646
08:26:18,635 --> 08:26:20,570
>> Florida Rising: you would

12647
08:26:20,570 --> 08:26:24,170
agree that the aqua blue line

12648
08:26:27,477 --> 08:26:29,479
is higher than the lines for

12649
08:26:29,479 --> 08:26:30,814
industrial and commercial

12650
08:26:30,814 --> 08:26:31,181
commercials which are

12651
08:26:31,181 --> 08:26:32,482
represented by

12652
08:26:32,482 --> 08:26:32,682
purple and dark

12653
08:26:32,682 --> 08:26:34,483
blue.

12654
08:26:34,483 --> 08:26:36,483
>> teco Witness: guess.

12655
08:26:36,486 --> 08:26:37,721
>> Florida Rising: would agree

12656
08:26:37,721 --> 08:26:40,523
following the rate case in 2021

12657
08:26:40,523 --> 08:26:42,492
the residential line increase

12658
08:26:42,492 --> 08:26:43,693
proportionally higher and more

12659
08:26:43,693 --> 08:26:47,293
sharply than the lines for the

12660
08:26:47,731 --> 08:26:48,965
cna classes.

12661
08:26:48,965 --> 08:26:50,867
>> teco Witness: that is what

12662
08:26:50,867 --> 08:26:55,670
it looks like unless it is a

12663
08:27:02,445 --> 08:27:04,445
skill.

12664
08:27:04,447 --> 08:27:05,415
This shows the 12 month moving

12665
08:27:05,415 --> 08:27:07,316
average.

12666
08:27:07,316 --> 08:27:09,219
This is looking only at

12667
08:27:09,219 --> 08:27:10,420
residential.

12668
08:27:10,420 --> 08:27:12,288
And commercial customers.

12669
08:27:12,288 --> 08:27:13,657
>> teco Witness: that is

12670
08:27:13,657 --> 08:27:13,789
correct

12671
08:27:13,789 --> 08:27:15,789
.

12672
08:27:15,792 --> 08:27:16,960
>> Florida Rising: to your

12673
08:27:16,960 --> 08:27:18,862
knowledge does not commercial

12674
08:27:18,862 --> 08:27:20,764
include industrial is it meant

12675
08:27:20,764 --> 08:27:22,766
to be business versus

12676
08:27:22,766 --> 08:27:23,660
residential was that strictly

12677
08:27:23,660 --> 08:27:24,935
commercial.

12678
08:27:24,935 --> 08:27:26,970
>> teco Witness: I am not sure.

12679
08:27:26,970 --> 08:27:28,905
>> Florida Rising: would agree

12680
08:27:28,905 --> 08:27:30,730
at every point on this graph

12681
08:27:30,730 --> 08:27:30,907
blue line is higher than the

12682
08:27:30,907 --> 08:27:32,907
red line?

12683
08:27:34,211 --> 08:27:36,120
>> teco Witness: the rate in

12684
08:27:36,120 --> 08:27:38,140
general is higher for

12685
08:27:38,140 --> 08:27:39,115
residential. So yes.

12686
08:27:39,115 --> 08:27:41,510
>> Florida Rising: when we look

12687
08:27:41,510 --> 08:27:42,819
you see the data plans to come

12688
08:27:42,819 --> 08:27:46,122
up in the key under the x axis

12689
08:27:46,122 --> 08:27:48,240
describes those as residential

12690
08:27:48,240 --> 08:27:49,893
last year and commercial last

12691
08:27:49,893 --> 08:27:52,762
year those represent a forecast

12692
08:27:52,762 --> 08:27:54,664
of what prices would do that

12693
08:27:54,664 --> 08:27:57,664
was made years before this

12694
08:27:59,235 --> 08:28:00,503
document was produced.

12695
08:28:00,503 --> 08:28:02,372
>> teco Witness: those would've

12696
08:28:02,372 --> 08:28:05,972
been the assumption that we had

12697
08:28:06,743 --> 08:28:07,744
used in the prior forecast.

12698
08:28:07,744 --> 08:28:08,778
If this was updated

12699
08:28:08,778 --> 08:28:09,879
correctly

12700
08:28:09,879 --> 08:28:10,814
sometimes we don't update every

12701
08:28:10,814 --> 08:28:12,814
graph friend.

12702
08:28:12,849 --> 08:28:14,784
>> Florida Rising: assuming the

12703
08:28:14,784 --> 08:28:16,520
teco document is correct this

12704
08:28:16,520 --> 08:28:18,452
forecast shows that following

12705
08:28:18,655 --> 08:28:21,550
2022 prices would decrease for

12706
08:28:21,858 --> 08:28:23,858
customers.

12707
08:28:23,893 --> 08:28:26,893
At least the residential and

12708
08:28:27,731 --> 08:28:28,932
commercial classes shown here.

12709
08:28:28,932 --> 08:28:30,767
>> teco Witness: in real terms

12710
08:28:30,767 --> 08:28:32,769
that is what it looks like.

12711
08:28:32,769 --> 08:28:34,771
>> Florida Rising: the fact

12712
08:28:34,771 --> 08:28:35,972
they increased pretty

12713
08:28:35,972 --> 08:28:38,700
significantly from that point.

12714
08:28:38,700 --> 08:28:39,242
>> teco Witness: again it could

12715
08:28:39,242 --> 08:28:44,420
be the cpi we were using we had

12716
08:28:48,418 --> 08:28:49,618
8% inflation at some point.

12717
08:28:49,618 --> 08:28:51,554
>> Florida Rising: I am just

12718
08:28:51,554 --> 08:28:53,456
asking what the graph shows.

12719
08:28:53,456 --> 08:28:53,857
You agree with that

12720
08:28:53,857 --> 08:28:55,857
characterization?

12721
08:28:55,858 --> 08:28:56,860
>> teco Witness: repeat your

12722
08:28:56,860 --> 08:28:58,360
characterization.

12723
08:28:58,360 --> 08:29:00,290
>> Florida Rising: instead of

12724
08:29:00,290 --> 08:29:01,264
the client after 2022 prices

12725
08:29:01,264 --> 08:29:03,264
have increased?

12726
08:29:08,704 --> 08:29:10,640
I'm sorry after from 2022

12727
08:29:10,640 --> 08:29:10,840
prices have increased on this

12728
08:29:10,840 --> 08:29:12,750
chart?

12729
08:29:12,750 --> 08:29:14,844
>> teco Witness: that is what

12730
08:29:14,844 --> 08:29:16,780
the graph shows.

12731
08:29:16,780 --> 08:29:18,948
>> Florida Rising: I think this

12732
08:29:18,948 --> 08:29:20,950
gives us a better definition of

12733
08:29:20,950 --> 08:29:22,818
what I was trying to ask on the

12734
08:29:22,818 --> 08:29:23,887
other chart you would agree

12735
08:29:23,887 --> 08:29:25,321
looking at the two lines

12736
08:29:25,321 --> 08:29:27,824
following the last rate case

12737
08:29:27,824 --> 08:29:30,590
the line for the blue class the

12738
08:29:30,590 --> 08:29:31,995
presidential class is a much

12739
08:29:31,995 --> 08:29:34,395
steeper slope associated with

12740
08:29:37,934 --> 08:29:39,335
it.

12741
08:29:39,335 --> 08:29:41,360
>> teco Witness: it does look

12742
08:29:41,360 --> 08:29:42,380
like it there is a foot note

12743
08:29:42,380 --> 08:29:43,940
talking about the.

12744
08:29:43,940 --> 08:29:45,141
[Listing names] I'm not

12745
08:29:45,141 --> 08:29:46,943
familiar with those components

12746
08:29:46,943 --> 08:29:48,110
and what would drive the

12747
08:29:48,110 --> 08:29:50,110
residential higher.

12748
08:29:50,800 --> 08:29:51,948
>> teco

12749
08:29:51,948 --> 08:29:52,147
Witness: is it fair to say

12750
08:29:52,147 --> 08:29:53,950
that.

12751
08:29:53,950 --> 08:29:55,950
[Listing names] Increases

12752
08:29:55,952 --> 08:29:57,952
general rate-based adjustment

12753
08:29:59,389 --> 08:30:00,590
increases is a modification to

12754
08:30:00,590 --> 08:30:02,926
the rate made in the context of

12755
08:30:02,926 --> 08:30:04,926
rate case?

12756
08:30:04,961 --> 08:30:08,561
Are you familiar with the term.

12757
08:30:09,565 --> 08:30:11,565
[Listing names]

12758
08:30:11,568 --> 08:30:13,360
>> teco Witness: guess I'm just

12759
08:30:13,360 --> 08:30:14,637
saying these step increases

12760
08:30:14,637 --> 08:30:16,573
that are being reflected in the

12761
08:30:16,573 --> 08:30:19,708
graphs I don't know if that is

12762
08:30:19,708 --> 08:30:20,910
what is causing the steeper

12763
08:30:20,910 --> 08:30:22,779
increase in the residential

12764
08:30:22,779 --> 08:30:24,714
there MAY be a difference in

12765
08:30:24,714 --> 08:30:27,684
those step increases from the

12766
08:30:27,684 --> 08:30:28,785
different classes.

12767
08:30:28,785 --> 08:30:30,720
This is not my area of

12768
08:30:30,720 --> 08:30:31,540
expertise. When it comes to the

12769
08:30:31,540 --> 08:30:31,954
actual rate.

12770
08:30:31,954 --> 08:30:33,890
>> teco Witness:

12771
08:30:33,890 --> 08:30:34,957
>> Florida Rising: looking at

12772
08:30:34,957 --> 08:30:36,159
this document which was

12773
08:30:36,159 --> 08:30:38,270
produced under your direction

12774
08:30:38,270 --> 08:30:42,227
you would agree that if we look

12775
08:30:42,398 --> 08:30:45,398
at the data point for 2024

12776
08:30:46,703 --> 08:30:48,604
doesn't look cute like there

12777
08:30:48,604 --> 08:30:50,606
has ever been a time in this

12778
08:30:50,606 --> 08:30:52,606
chart when reverential

12779
08:30:53,309 --> 08:30:54,477
customers were further apart

12780
08:30:54,477 --> 08:30:56,779
from the commercial class in

12781
08:30:56,779 --> 08:30:58,314
terms of the higher price that

12782
08:30:58,314 --> 08:30:59,582
they were paying?

12783
08:30:59,582 --> 08:31:01,517
>> teco Witness: not looking at

12784
08:31:01,517 --> 08:31:03,453
this chart but again this chart

12785
08:31:03,453 --> 08:31:07,530
MAY not reflect the same things

12786
08:31:16,320 --> 08:31:16,999
that the witness collins was

12787
08:31:16,999 --> 08:31:18,101
looking at.

12788
08:31:18,101 --> 08:31:20,200
>> Florida Rising: I'm not

12789
08:31:20,200 --> 08:31:21,237
concerned with MR. Collins

12790
08:31:21,237 --> 08:31:23,105
testimony we will keep it to

12791
08:31:23,105 --> 08:31:25,740
this since you are not here.

12792
08:31:25,740 --> 08:31:26,542
You would agree on this chart I

12793
08:31:26,542 --> 08:31:28,211
will ask it this way. Is there

12794
08:31:28,211 --> 08:31:31,130
any point in the history of

12795
08:31:31,130 --> 08:31:32,181
this chart where reverential

12796
08:31:32,181 --> 08:31:34,170
customers have paid a higher

12797
08:31:34,170 --> 08:31:36,180
have been further above the

12798
08:31:36,180 --> 08:31:36,285
commercial class than they are

12799
08:31:36,285 --> 08:31:38,153
currently?

12800
08:31:38,153 --> 08:31:40,122
In terms of the real average.

12801
08:31:40,122 --> 08:31:40,323
The moving average the real

12802
08:31:40,323 --> 08:31:42,158
price?

12803
08:31:42,158 --> 08:31:43,250
>> teco Witness: not on this

12804
08:31:43,250 --> 08:31:44,227
graph.

12805
08:31:44,227 --> 08:31:46,620
>> Florida Rising: thank you

12806
08:31:46,620 --> 08:31:47,797
very much for your patience

12807
08:31:47,797 --> 08:31:48,264
that's all the questions that I

12808
08:31:48,264 --> 08:31:50,166
have.

12809
08:31:50,166 --> 08:31:50,767
>> Mike La Rosa,CHAIRMAN: let's

12810
08:31:50,767 --> 08:31:52,767
move to.

12811
08:31:56,806 --> 08:31:58,741
>> fipug: I have a question for

12812
08:31:58,741 --> 08:31:59,742
you I think I need

12813
08:31:59,742 --> 08:32:00,944
clarification on an answer you

12814
08:32:00,944 --> 08:32:02,879
gave to previously you were

12815
08:32:02,879 --> 08:32:04,780
asked a lot of questions about

12816
08:32:04,780 --> 08:32:05,915
a lot of things and

12817
08:32:05,915 --> 08:32:07,850
temperatures the peak and

12818
08:32:07,850 --> 08:32:09,852
everything that I hear you just

12819
08:32:09,852 --> 08:32:12,622
say the cultists they that has

12820
08:32:12,622 --> 08:32:13,756
ever occurred I assume that

12821
08:32:13,756 --> 08:32:16,156
translates into the highest

12822
08:32:18,127 --> 08:32:19,295
peak was in JANUARY the day is

12823
08:32:19,295 --> 08:32:22,895
that ever since you been with

12824
08:32:33,576 --> 08:32:35,576
the company?

12825
08:32:35,611 --> 08:32:36,912
>> teco Witness: the coldest

12826
08:32:36,912 --> 08:32:37,680
temperature occultist cement

12827
08:32:37,680 --> 08:32:38,581
but

12828
08:32:38,581 --> 08:32:39,748
be different.

12829
08:32:39,748 --> 08:32:41,584
>> Florida Rising: you just

12830
08:32:41,584 --> 08:32:43,619
made a reference he said

12831
08:32:43,619 --> 08:32:44,787
JANUARY was the coldest day I

12832
08:32:44,787 --> 08:32:45,822
remember.

12833
08:32:45,822 --> 08:32:46,756
>> teco Witness: I was speaking

12834
08:32:46,756 --> 08:32:47,890
to JANUARY 2010.

12835
08:32:47,890 --> 08:32:48,658
That is been

12836
08:32:48,658 --> 08:32:48,858
our coldest winter

12837
08:32:48,858 --> 08:32:50,660
peak.

12838
08:32:50,660 --> 08:32:51,827
>> Florida Rising: how long

12839
08:32:51,827 --> 08:32:51,961
have you been with the company

12840
08:32:51,961 --> 08:32:53,961
.

12841
08:32:58,768 --> 08:33:00,768
>> teco Witness: 37 years.

12842
08:33:03,939 --> 08:33:05,975
Thank you that is all I have.

12843
08:33:05,975 --> 08:33:07,975
>> fea: no questions.

12844
08:33:09,612 --> 08:33:10,513
>> Sierra Club: no questions

12845
08:33:10,513 --> 08:33:12,415
thank you.

12846
08:33:12,415 --> 08:33:12,748
>> Florida Retail Federation:

12847
08:33:12,748 --> 08:33:14,748
no questions.

12848
08:33:21,357 --> 08:33:23,357
>> Walmart: no questions.

12849
08:33:31,867 --> 08:33:32,101
>> all right good afternoon MS.

12850
08:33:32,101 --> 08:33:33,868
Fuentes.

12851
08:33:33,868 --> 08:33:34,869
>> teco Witness: good

12852
08:33:34,869 --> 08:33:35,971
afternoon.

12853
08:33:35,971 --> 08:33:37,139
>> has teco's calculated its

12854
08:33:37,139 --> 08:33:39,875
cooling degree days for JULY

12855
08:33:39,875 --> 08:33:41,110
2020 fourth using international

12856
08:33:41,110 --> 08:33:41,911
airports recorded temperature

12857
08:33:41,911 --> 08:33:43,145
data?

12858
08:33:43,145 --> 08:33:45,470
>> teco Witness: for JULY this

12859
08:33:45,470 --> 08:33:46,215
past month yes we have.

12860
08:33:46,215 --> 08:33:48,183
>> what is that number.

12861
08:33:48,183 --> 08:33:49,819
>> teco Witness: I don't have

12862
08:33:49,819 --> 08:33:52,819
that in front of me.

12863
08:33:55,458 --> 08:33:56,692
>> are you able to locate it.

12864
08:33:56,692 --> 08:34:02,920
I'm going to look to see if I I

12865
08:34:03,199 --> 08:34:05,599
know I had JUNE.

12866
08:34:06,335 --> 08:34:08,804
I will say it was hot.

12867
08:34:08,804 --> 08:34:12,404
It was probably about or about

12868
08:34:15,411 --> 08:34:19,110
our normals I'm sure earlier I

12869
08:34:20,649 --> 08:34:21,851
believe I heard you indicate

12870
08:34:21,851 --> 08:34:23,752
that no florida utility is

12871
08:34:23,752 --> 08:34:25,688
using less than 20 years of

12872
08:34:25,688 --> 08:34:26,989
historical temperatures to

12873
08:34:26,989 --> 08:34:29,989
determine normal weather that I

12874
08:34:30,192 --> 08:34:32,192
hear you correctly.

12875
08:34:35,331 --> 08:34:36,532
>> would it surprise you to

12876
08:34:36,532 --> 08:34:38,401
learn on AUGUST 22 of this year

12877
08:34:38,401 --> 08:34:40,236
for a public utility company

12878
08:34:40,236 --> 08:34:42,636
filed testimony with his

12879
08:34:43,939 --> 08:34:45,207
commission basing its energy

12880
08:34:45,207 --> 08:34:47,760
use per customer forecast on 10

12881
08:34:47,760 --> 08:34:49,111
year normals for cooling degree

12882
08:34:49,111 --> 08:34:50,980
days in docket no: 2024 basing

12883
08:34:50,980 --> 08:34:51,647
its energy use per customer

12884
08:34:51,647 --> 08:34:52,181
forecast on 10 year

12885
08:34:52,181 --> 08:34:54,181
normals for

12886
08:34:54,984 --> 08:34:55,384
cooling degree days in docket

12887
08:34:55,384 --> 08:34:55,484
no: 2020 40099 b

12888
08:34:55,484 --> 08:34:57,860
ei.

12889
08:34:57,860 --> 08:34:58,988
>> teco Witness: that would

12890
08:34:58,988 --> 08:34:59,488
surprise me as of MAY 1 all the

12891
08:34:59,488 --> 08:35:00,188
utilities met there

12892
08:35:00,188 --> 08:35:01,991
was not any

12893
08:35:01,991 --> 08:35:03,920
I'm not sure if they were

12894
08:35:03,920 --> 08:35:04,192
represented at the florida

12895
08:35:04,192 --> 08:35:05,127
reliability coordinating

12896
08:35:05,127 --> 08:35:05,261
council

12897
08:35:05,261 --> 08:35:07,129
.

12898
08:35:07,129 --> 08:35:08,964
>> when you testified earlier

12899
08:35:08,964 --> 08:35:09,265
today and you were unaware of

12900
08:35:09,265 --> 08:35:11,265
that fact.

12901
08:35:12,968 --> 08:35:14,203
>> teco Witness: yes I was.

12902
08:35:14,203 --> 08:35:18,403
>> I would like to go back to

12903
08:35:20,342 --> 08:35:21,577
the monte carlo simulation

12904
08:35:21,577 --> 08:35:24,577
probabilities if we could. Did

12905
08:35:25,414 --> 08:35:26,615
I understand correctly that

12906
08:35:26,615 --> 08:35:28,417
teco's production of annual

12907
08:35:28,417 --> 08:35:29,685
cooling does have a 15%

12908
08:35:29,685 --> 08:35:31,587
probability of being higher

12909
08:35:31,587 --> 08:35:31,787
than actual cooling degree

12910
08:35:31,787 --> 08:35:33,522
days.

12911
08:35:33,522 --> 08:35:33,756
>> teco Witness: that is

12912
08:35:33,756 --> 08:35:35,756
correct.

12913
08:35:38,994 --> 08:35:40,994
>> also the converse 50%

12914
08:35:40,996 --> 08:35:43,499
probability of being lower than

12915
08:35:43,499 --> 08:35:44,733
actual cooling days.

12916
08:35:44,733 --> 08:35:46,535
>> that's basically the same as

12917
08:35:46,535 --> 08:35:46,631
using the simple average.

12918
08:35:46,631 --> 08:35:48,631
>

12919
08:35:49,605 --> 08:35:53,750
for the last nine years or

12920
08:35:53,750 --> 08:35:54,276
2015-2023 every year teco's

12921
08:35:54,276 --> 08:35:56,676
projected cooling degree days

12922
08:35:57,460 --> 08:35:58,848
that were lower than actual

12923
08:35:58,848 --> 08:35:59,248
cooling degree days is that

12924
08:35:59,248 --> 08:36:00,416
correct.

12925
08:36:00,416 --> 08:36:02,816
>> teco Witness: that is

12926
08:36:04,820 --> 08:36:05,987
correct.

12927
08:36:05,987 --> 08:36:08,230
>> can you explain the method

12928
08:36:08,230 --> 08:36:09,825
for calculating the probability

12929
08:36:09,825 --> 08:36:10,893
of that occurrence.

12930
08:36:10,893 --> 08:36:12,795
>> teco Witness: it's an

12931
08:36:12,795 --> 08:36:15,195
automatic regulation by the

12932
08:36:16,650 --> 08:36:18,660
monte carlo demolition and

12933
08:36:18,660 --> 08:36:19,201
software. We provide the 20

12934
08:36:19,201 --> 08:36:21,203
years worth of data monthly.

12935
08:36:21,203 --> 08:36:24,803
And we have it go through 500

12936
08:36:25,707 --> 08:36:27,707
or 1000 iterations of

12937
08:36:28,143 --> 08:36:31,143
distribution and it comes up

12938
08:36:33,115 --> 08:36:35,515
with the probabilities from

12939
08:36:37,286 --> 08:36:38,487
0-100 automatically.

12940
08:36:38,487 --> 08:36:40,522
>> I'm asking about the

12941
08:36:40,522 --> 08:36:41,523
specific sequence that occurred

12942
08:36:41,523 --> 08:36:43,459
of those nine years.

12943
08:36:43,459 --> 08:36:44,927
Do you know how to calculate

12944
08:36:44,927 --> 08:36:45,794
the probability of that

12945
08:36:45,794 --> 08:36:46,395
occurring?

12946
08:36:46,395 --> 08:36:47,620
The nine years of

12947
08:36:47,620 --> 08:36:47,796
data from 2015

12948
08:36:47,796 --> 08:36:49,598
.

12949
08:36:49,598 --> 08:36:53,198
>> teco Witness: we did do a

12950
08:37:00,943 --> 08:37:02,111
scenario where we used they

12951
08:37:02,111 --> 08:37:03,979
told us to use I'm not sure if

12952
08:37:03,979 --> 08:37:05,948
it was the staff or another

12953
08:37:05,948 --> 08:37:09,548
intervener had us run the monte

12954
08:37:09,994 --> 08:37:10,127
carlo simulation for a tenure

12955
08:37:10,127 --> 08:37:11,853
scenario. We did that and we

12956
08:37:11,853 --> 08:37:12,821
look at that earlier increased

12957
08:37:12,821 --> 08:37:13,922
our sales by 1%.

12958
08:37:13,922 --> 08:37:15,240
Increased revenues by

12959
08:37:15,240 --> 08:37:15,824
approximately 8/10 of a

12960
08:37:15,824 --> 08:37:17,250
percent.

12961
08:37:17,250 --> 08:37:18,961
We have done that scenario.

12962
08:37:18,961 --> 08:37:20,162
>> let me ask you this would

12963
08:37:20,162 --> 08:37:23,162
you agree that nine straight

12964
08:37:23,332 --> 08:37:24,933
years of actual cooling degree

12965
08:37:24,933 --> 08:37:26,802
days being above the 50%

12966
08:37:26,802 --> 08:37:28,802
probability level is

12967
08:37:34,843 --> 08:37:36,779
represented by the no meal of

12968
08:37:36,779 --> 08:37:39,248
one over two to the ninth power

12969
08:37:39,248 --> 08:37:40,449
or 1/512 which would be 0.2%.

12970
08:37:40,449 --> 08:37:42,384
>> teco Witness: I will trust

12971
08:37:42,384 --> 08:37:43,385
your mouth I cannot do that in

12972
08:37:43,385 --> 08:37:44,753
my head.

12973
08:37:44,753 --> 08:37:45,954
>> thank you very much MS.

12974
08:37:45,954 --> 08:37:47,923
Fuentes I know it was a long

12975
08:37:47,923 --> 08:37:48,990
day I appreciate you answering

12976
08:37:48,990 --> 08:37:50,159
my questions.

12977
08:37:50,159 --> 08:37:50,959
We have nothing further for

12978
08:37:50,959 --> 08:37:52,959
her.

12979
08:37:57,499 --> 08:37:58,833
>> Mike La Rosa,CHAIRMAN: thank

12980
08:37:58,833 --> 08:37:59,568
you commissioners any

12981
08:37:59,568 --> 08:38:01,568
questions?

12982
08:38:02,404 --> 08:38:03,405
Seeing no questions let's send

12983
08:38:03,405 --> 08:38:03,539
it back to teco's for redirect

12984
08:38:03,539 --> 08:38:05,539
.

12985
08:38:05,541 --> 08:38:07,509
>> teco Attorney: no redirect.

12986
08:38:07,509 --> 08:38:09,411
>> Mike La Rosa,CHAIRMAN: let's

12987
08:38:09,411 --> 08:38:10,612
talk about the exhibits and

12988
08:38:10,612 --> 08:38:12,648
entering them into the organ

12989
08:38:12,648 --> 08:38:14,516
spent tampa electric would like

12990
08:38:14,516 --> 08:38:16,451
to move exhibits 25 and 146 and

12991
08:38:16,451 --> 08:38:16,751
the newly identified 138 into

12992
08:38:16,751 --> 08:38:18,751
the record.

12993
08:38:19,488 --> 08:38:19,755
>> Mike La Rosa,CHAIRMAN: any

12994
08:38:19,755 --> 08:38:21,590
objection?

12995
08:38:21,590 --> 08:38:23,325
seeing none I show them entered

12996
08:38:23,325 --> 08:38:25,325
into the record.

12997
08:38:30,699 --> 08:38:30,828
Porter rising would move into

12998
08:38:30,828 --> 08:38:31,132
.

12999
08:38:31,132 --> 08:38:33,132
[Unclear audio].

13000
08:38:33,435 --> 08:38:35,435
>> Mike La

13001
08:38:36,438 --> 08:38:37,606
Rosa,CHAIRMAN: objection no

13002
08:38:37,606 --> 08:38:38,574
objection show that entered

13003
08:38:38,574 --> 08:38:40,574
into the record.

13004
08:38:41,876 --> 08:38:44,276
>> Florida Rising: we would

13005
08:38:46,882 --> 08:38:49,282
move in hearing exhibit 511,

13006
08:38:50,519 --> 08:38:52,519
512, 766.

13007
08:38:57,526 --> 08:38:59,526
, 663.

13008
08:39:01,463 --> 08:39:04,800
, I don't know how we want to

13009
08:39:04,800 --> 08:39:07,200
approach the step exhibit

13010
08:39:08,703 --> 08:39:10,639
number three which is 831 do

13011
08:39:10,639 --> 08:39:11,773
you want to move those and by

13012
08:39:11,773 --> 08:39:12,807
attachment or move in the

13013
08:39:12,807 --> 08:39:14,807
entire document?

13014
08:39:17,712 --> 08:39:17,945
Or the entire exhibit

13015
08:39:17,945 --> 08:39:19,945
.

13016
08:39:19,948 --> 08:39:21,917
>> Mike La Rosa,CHAIRMAN: I'm

13017
08:39:21,917 --> 08:39:23,151
not familiar with what else is

13018
08:39:23,151 --> 08:39:23,352
attached to it I will look to

13019
08:39:23,352 --> 08:39:24,953
staff.

13020
08:39:24,953 --> 08:39:26,922
> Staff: I would

13021
08:39:26,922 --> 08:39:28,156
recommend just making it a

13022
08:39:28,156 --> 08:39:29,958
competent exhibit it's already

13023
08:39:29,958 --> 08:39:31,293
been numbered as a 31.

13024
08:39:31,293 --> 08:39:32,794
>> Mike La Rosa,CHAIRMAN: the

13025
08:39:32,794 --> 08:39:34,950
whole exhibit.

13026
08:39:34,950 --> 08:39:35,197
>> Florida Rising: I didn't

13027
08:39:35,197 --> 08:39:36,398
want to draw an objection

13028
08:39:36,398 --> 08:39:36,732
bringing in too many things I

13029
08:39:36,732 --> 08:39:37,366
will

13030
08:39:37,366 --> 08:39:39,366
bring 831.

13031
08:39:40,168 --> 08:39:42,170
>> Mike La Rosa,CHAIRMAN: is

13032
08:39:42,170 --> 08:39:42,437
that all anything else is there

13033
08:39:42,437 --> 08:39:44,272
objection?

13034
08:39:44,272 --> 08:39:44,840
Seeing no objection I show that

13035
08:39:44,840 --> 08:39:44,937
entered

13036
08:39:44,937 --> 08:39:46,937
.

13037
08:39:50,412 --> 08:39:52,347
>> Staff: MR. CHAIRMAN when you

13038
08:39:52,347 --> 08:39:55,250
said the last exhibit did you

13039
08:39:55,250 --> 08:39:55,345
same 838 or 138

13040
08:39:55,345 --> 08:39:57,345
.

13041
08:39:58,220 --> 08:39:58,312
>> opc: I said 838

13042
08:39:58,312 --> 08:40:00,312
.

13043
08:40:02,560 --> 08:40:03,958
>> Mike La Rosa,CHAIRMAN: let's

13044
08:40:03,958 --> 08:40:05,193
move 838 if there are no

13045
08:40:05,193 --> 08:40:07,620
objections and exhibit that

13046
08:40:07,620 --> 08:40:07,963
porter rising his offered into

13047
08:40:07,963 --> 08:40:09,300
the record.

13048
08:40:09,300 --> 08:40:09,756
Anything else.

13049
08:40:09,756 --> 08:40:11,756
Any other exhibits.

13050
08:40:13,426 --> 08:40:16,426
Seeing none MS. Fuentes. Your

13051
08:40:19,932 --> 08:40:21,932
excuse.

13052
08:40:25,638 --> 08:40:26,905
I'm sorry you are excused.

13053
08:40:26,905 --> 08:40:27,773
>> she wants to stay longer if

13054
08:40:27,773 --> 08:40:29,641
she could.

13055
08:40:29,641 --> 08:40:30,809
>> Mike La Rosa,CHAIRMAN:

13056
08:40:30,809 --> 08:40:31,610
normally a witness does not

13057
08:40:31,610 --> 08:40:32,911
deny that.

13058
08:40:32,911 --> 08:40:34,911
>> teco Witness: I

13059
08:40:34,947 --> 08:40:36,515
thought you asked if I had any

13060
08:40:36,515 --> 08:40:36,611
questions

13061
08:40:36,611 --> 08:40:38,418
.

13062
08:40:38,418 --> 08:40:39,618
>> Florida Rising: MS. Fuentes

13063
08:40:39,618 --> 08:40:43,818
if you want to do any more

13064
08:40:49,628 --> 08:40:49,862
questions we can do this all

13065
08:40:49,862 --> 08:40:51,664
night.

13066
08:40:51,664 --> 08:40:53,666
>> Mike La Rosa,CHAIRMAN: as

13067
08:40:53,666 --> 08:40:54,867
long as there is not a 30 year

13068
08:40:54,867 --> 08:40:56,769
comparison we are all) Thank

13069
08:40:56,769 --> 08:40:58,671
you for your testimony I will

13070
08:40:58,671 --> 08:40:59,772
kick this over to diego for the

13071
08:40:59,772 --> 08:41:00,390
introduction of the next

13072
08:41:00,390 --> 08:41:01,774
witness.

13073
08:41:01,774 --> 08:41:03,774
>> teco Attorney: tampa

13074
08:41:10,183 --> 08:41:12,184
electric calls ned ellis.

13075
08:41:12,184 --> 08:41:15,184
>> Mike La Rosa,CHAIRMAN: do

13076
08:41:16,922 --> 08:41:18,957
not believe you had been

13077
08:41:18,957 --> 08:41:20,920
administered euros if you mind

13078
08:41:20,920 --> 08:41:21,927
standing in raising the right

13079
08:41:21,927 --> 08:41:23,162
handprint do swear or affirm

13080
08:41:23,162 --> 08:41:25,970
that this is money you're about

13081
08:41:25,970 --> 08:41:27,990
to give will be the truth the

13082
08:41:27,990 --> 08:41:27,300
whole truth and nothing but the

13083
08:41:27,300 --> 08:41:28,233
truth?

13084
08:41:28,233 --> 08:41:30,233
>> teco Witness: yes.

13085
08:41:30,269 --> 08:41:32,204
>> Mike La Rosa,CHAIRMAN: as he

13086
08:41:32,204 --> 08:41:35,373
gets settled still the plan is

13087
08:41:35,373 --> 08:41:37,309
to take a break at 6 pm we are

13088
08:41:37,309 --> 08:41:38,544
still on target we will see how

13089
08:41:38,544 --> 08:41:41,247
this line of questioning goes

13090
08:41:41,247 --> 08:41:41,714
we will break halfway in the

13091
08:41:41,714 --> 08:41:44,714
middle if we need to.

13092
08:41:48,688 --> 08:41:49,822
I will send it over to teco's.

13093
08:41:49,822 --> 08:41:50,890
>> teco Attorney: good

13094
08:41:50,890 --> 08:41:52,725
afternoon are you settled.

13095
08:41:52,725 --> 08:41:53,292
>> teco Witness: yes.

13096
08:41:53,292 --> 08:41:54,126
>> teco Attorney: will you

13097
08:41:54,126 --> 08:41:55,930
state your full name for the

13098
08:41:55,930 --> 08:41:57,930
record.

13099
08:41:58,397 --> 08:41:58,493
>> teco Witness: my name is

13100
08:41:58,493 --> 08:42:00,493
.

13101
08:42:02,235 --> 08:42:03,436
[Listing names]

13102
08:42:03,436 --> 08:42:05,304
>> teco Attorney: who is your

13103
08:42:05,304 --> 08:42:06,372
current employer and what is

13104
08:42:06,372 --> 08:42:08,340
your business address.

13105
08:42:08,340 --> 08:42:09,308
>> teco Witness: smith at smith

13106
08:42:09,308 --> 08:42:11,308
at 207 senate ave.

13107
08:42:14,680 --> 08:42:14,847
MS. Mac

13108
08:42:14,847 --> 08:42:16,816
.

13109
08:42:16,816 --> 08:42:18,160
>> teco Attorney: did you

13110
08:42:18,160 --> 08:42:19,551
prepare and cause to be filed

13111
08:42:19,551 --> 08:42:19,919
in this docket on APRIL 2,

13112
08:42:19,919 --> 08:42:21,820
2024

13113
08:42:21,820 --> 08:42:22,955
prepare direct testimony

13114
08:42:22,955 --> 08:42:24,900
consisting of 46 pages.

13115
08:42:24,900 --> 08:42:25,891
>> teco Witness: yes.

13116
08:42:25,891 --> 08:42:27,827
>> teco Attorney: did you

13117
08:42:27,827 --> 08:42:31,230
prepare or cause to be filed

13118
08:42:31,230 --> 08:42:33,165
this document on JULY 22 22

13119
08:42:33,165 --> 08:42:35,167
four prepare for battle because

13120
08:42:35,167 --> 08:42:36,301
many consisting of 43 pages.

13121
08:42:36,301 --> 08:42:38,237
>> teco Witness: yes.

13122
08:42:38,237 --> 08:42:40,390
>> teco Attorney: you have any

13123
08:42:40,390 --> 08:42:41,240
additions or corrections to

13124
08:42:41,240 --> 08:42:42,241
your prepared direct or

13125
08:42:42,241 --> 08:42:44,760
rebuttal testimony.

13126
08:42:44,760 --> 08:42:47,760
>> teco Witness: I do not.

13127
08:42:49,448 --> 08:42:51,383
>> teco Attorney: if I were to

13128
08:42:51,383 --> 08:42:52,684
ask you the questions contained

13129
08:42:52,684 --> 08:42:54,520
in your prepared direct and

13130
08:42:54,520 --> 08:42:56,288
rebuttal testimony today would

13131
08:42:56,288 --> 08:42:57,356
your answers be the same as

13132
08:42:57,356 --> 08:42:58,457
those contained therein.

13133
08:42:58,457 --> 08:43:00,457
>> teco Witness: yes.

13134
08:43:01,193 --> 08:43:02,294
>> teco Attorney: MR. CHAIRMAN

13135
08:43:02,294 --> 08:43:03,395
tampa electric request the

13136
08:43:03,395 --> 08:43:04,463
prepared direct rebuttal

13137
08:43:04,463 --> 08:43:06,231
testimony of.

13138
08:43:06,231 --> 08:43:07,433
[Listing names] Be inserted

13139
08:43:07,433 --> 08:43:09,367
into the record as the red did

13140
08:43:09,367 --> 08:43:11,237
you prepare and caused to be

13141
08:43:11,237 --> 08:43:12,538
filed with your direct

13142
08:43:12,538 --> 08:43:14,406
testimony and exhibit marked na

13143
08:43:14,406 --> 08:43:15,608
1 consisting of four documents.

13144
08:43:15,608 --> 08:43:17,409
>> teco Witness: yes.

13145
08:43:17,409 --> 08:43:19,345
>> teco Attorney: did you also

13146
08:43:19,345 --> 08:43:21,246
prepare and cause to be filed

13147
08:43:21,246 --> 08:43:22,348
with your rebuttal testimony

13148
08:43:22,348 --> 08:43:24,250
and exhibit marked na 2

13149
08:43:24,250 --> 08:43:25,317
consisting of three documents.

13150
08:43:25,317 --> 08:43:27,317
>> teco Witness: yes.

13151
08:43:27,419 --> 08:43:29,355
>> teco Attorney: MR. CHAIRMAN

13152
08:43:29,355 --> 08:43:30,555
tampa electric would note for

13153
08:43:30,555 --> 08:43:32,491
the record that exhibits na one

13154
08:43:32,491 --> 08:43:34,360
in any 2 have been identified

13155
08:43:34,360 --> 08:43:34,526
under ce l as exhibits 26 and

13156
08:43:34,526 --> 08:43:36,295
147.

13157
08:43:36,295 --> 08:43:38,297
>> teco Attorney: would you

13158
08:43:38,297 --> 08:43:39,498
summarize your prepared and

13159
08:43:39,498 --> 08:43:40,466
summarize your direct and

13160
08:43:40,466 --> 08:43:42,434
rebuttal testimony.

13161
08:43:42,434 --> 08:43:44,369
>> teco Witness: good afternoon

13162
08:43:44,369 --> 08:43:45,304
CHAIRMAN And commissioners my

13163
08:43:45,304 --> 08:43:47,304
name is.

13164
08:44:14,566 --> 08:44:16,535
[Listing names] I performed the

13165
08:44:16,535 --> 08:44:17,703
depreciation study on behalf of

13166
08:44:17,703 --> 08:44:19,705
temperature company my direct

13167
08:44:19,705 --> 08:44:21,773
testimony presents and explains

13168
08:44:21,773 --> 08:44:24,173
that study. The depreciation

13169
08:44:24,543 --> 08:44:26,545
study was conducted based on

13170
08:44:26,545 --> 08:44:27,746
industry-standard methods and

13171
08:44:27,746 --> 08:44:29,681
procedures that are consistent

13172
08:44:29,681 --> 08:44:31,516
with prior depreciation studies

13173
08:44:31,516 --> 08:44:32,718
performed for utilities in

13174
08:44:32,718 --> 08:44:34,586
florida. The study equipment

13175
08:44:34,586 --> 08:44:35,754
service life and salvage as

13176
08:44:35,754 --> 08:44:37,623
misplaced property account as

13177
08:44:37,623 --> 08:44:39,591
well as lifespan estimates for

13178
08:44:39,591 --> 08:44:41,626
each of the companies

13179
08:44:41,626 --> 08:44:42,761
generating facilities those are

13180
08:44:42,761 --> 08:44:44,597
then used along with the

13181
08:44:44,597 --> 08:44:46,597
current company's current

13182
08:44:46,598 --> 08:44:47,766
balance is to catholic

13183
08:44:47,766 --> 08:44:49,568
depreciation rates for each of

13184
08:44:49,568 --> 08:44:51,568
these property groups.

13185
08:44:51,570 --> 08:44:53,572
Estimates that are recommended

13186
08:44:53,572 --> 08:44:55,572
incorporate statistical

13187
08:44:55,574 --> 08:44:57,576
analysis of historical data

13188
08:44:57,576 --> 08:44:59,578
information obtained from site

13189
08:44:59,578 --> 08:45:01,130
visits meetings with company

13190
08:45:01,130 --> 08:45:02,715
personnel. As well as the

13191
08:45:02,715 --> 08:45:04,583
overall experience of myself

13192
08:45:04,583 --> 08:45:06,585
and my staff which includes

13193
08:45:06,585 --> 08:45:08,585
conducting similar depreciation

13194
08:45:08,587 --> 08:45:09,788
studies for utilities across

13195
08:45:09,788 --> 08:45:10,722
the country.

13196
08:45:10,722 --> 08:45:11,890
Including other florida

13197
08:45:11,890 --> 08:45:13,592
utilities as well.

13198
08:45:13,592 --> 08:45:15,594
The study results and overall

13199
08:45:15,594 --> 08:45:17,594
increase in depreciation

13200
08:45:17,595 --> 08:45:19,595
expense of approximately $40.7

13201
08:45:19,598 --> 08:45:20,833
million. As of DECEMBER 31 2024

13202
08:45:20,833 --> 08:45:22,667
does overall increase the

13203
08:45:22,667 --> 08:45:24,570
result of several factors the

13204
08:45:24,570 --> 08:45:26,571
largest of which is actually

13205
08:45:26,571 --> 08:45:27,973
just the mechanical updating of

13206
08:45:27,973 --> 08:45:29,575
depreciation rates to

13207
08:45:29,575 --> 08:45:30,809
incorporate current balances

13208
08:45:30,809 --> 08:45:32,678
that accounts for about 36 of

13209
08:45:32,678 --> 08:45:34,612
the $40 million increase. The

13210
08:45:34,612 --> 08:45:36,715
recommended service life and

13211
08:45:36,715 --> 08:45:38,617
that some adjustments are made

13212
08:45:38,617 --> 08:45:40,617
study for transmission

13213
08:45:40,619 --> 08:45:41,820
distribution accounts result in

13214
08:45:41,820 --> 08:45:43,722
increased offset by a decrease

13215
08:45:43,722 --> 08:45:45,658
in due to longer service life

13216
08:45:45,658 --> 08:45:46,792
for generation accounts net to

13217
08:45:46,792 --> 08:45:48,827
about a $4 million increase.

13218
08:45:48,827 --> 08:45:50,763
My rebuttal testimony response

13219
08:45:50,763 --> 08:45:52,631
to the depreciation blended

13220
08:45:52,631 --> 08:45:52,865
testimony of opc related

13221
08:45:52,865 --> 08:45:54,633
witness.

13222
08:45:54,633 --> 08:45:55,867
[Listing names] MR. Collins

13223
08:45:55,867 --> 08:45:57,802
proposed adjustment to lifespan

13224
08:45:57,802 --> 08:45:59,771
the sewer facilities as well as

13225
08:45:59,771 --> 08:46:00,939
to the average solvers life

13226
08:46:00,939 --> 08:46:02,841
energy storage which anderson

13227
08:46:02,841 --> 08:46:04,743
has been for the belated we

13228
08:46:04,743 --> 08:46:06,712
propose longer lifespans for

13229
08:46:06,712 --> 08:46:08,747
cycle facilities as well as

13230
08:46:08,747 --> 08:46:10,649
different interim survivor for

13231
08:46:10,649 --> 08:46:12,684
production plan accounts longer

13232
08:46:12,684 --> 08:46:14,653
service life for underground

13233
08:46:14,653 --> 08:46:16,655
dissolution conductors and less

13234
08:46:16,655 --> 08:46:18,657
negative that salvage estimates

13235
08:46:18,657 --> 08:46:19,858
for several) That this customer

13236
08:46:19,858 --> 08:46:21,660
bottle has money does agree

13237
08:46:21,660 --> 08:46:22,828
with each of these

13238
08:46:22,828 --> 08:46:24,663
recommendations opc and that

13239
08:46:24,663 --> 08:46:25,831
the proposal for longer

13240
08:46:25,831 --> 08:46:27,666
lifespans for solar and cycle

13241
08:46:27,666 --> 08:46:28,801
plans do not in my opinion

13242
08:46:28,801 --> 08:46:30,669
adequately consider factors

13243
08:46:30,669 --> 08:46:32,370
will contribute to the

13244
08:46:32,370 --> 08:46:33,705
retirement of these facilities

13245
08:46:33,705 --> 08:46:35,705
just changing technology

13246
08:46:35,708 --> 08:46:37,708
changes the operating

13247
08:46:37,710 --> 08:46:38,911
environment and other economic

13248
08:46:38,911 --> 08:46:40,845
factors that I believe are

13249
08:46:40,845 --> 08:46:42,715
likely to limit the overall

13250
08:46:42,715 --> 08:46:43,982
lifespan of these facilities.

13251
08:46:43,982 --> 08:46:46,382
The proposed survivor curves

13252
08:46:46,718 --> 08:46:47,853
are a set of best practices and

13253
08:46:47,853 --> 08:46:49,855
typical estimates in the

13254
08:46:49,855 --> 08:46:51,857
industry example the estimate

13255
08:46:51,857 --> 08:46:53,758
of no three survivor curve is

13256
08:46:53,758 --> 08:46:55,693
very unusual and does not

13257
08:46:55,693 --> 08:46:56,695
really suit the property study

13258
08:46:56,695 --> 08:46:58,695
particularly well.

13259
08:46:58,730 --> 08:47:00,732
Additionally I think MR. Enders

13260
08:47:00,732 --> 08:47:02,000
testimony did not interpret

13261
08:47:02,000 --> 08:47:03,869
historical data is also true

13262
08:47:03,869 --> 08:47:05,771
with the net salvage estimates

13263
08:47:05,771 --> 08:47:06,938
and made in general I think my

13264
08:47:06,938 --> 08:47:08,707
recommendations are better

13265
08:47:08,707 --> 08:47:10,709
aligned with the data was

13266
08:47:10,709 --> 08:47:12,177
properly interpreted and

13267
08:47:12,177 --> 08:47:13,745
analyzed prints in summary

13268
08:47:13,745 --> 08:47:15,714
think the other party's

13269
08:47:15,714 --> 08:47:17,716
proposals are based on limited

13270
08:47:17,716 --> 08:47:18,830
information analysis and failed

13271
08:47:18,830 --> 08:47:19,718
to consider the

13272
08:47:19,718 --> 08:47:20,919
many ways the

13273
08:47:20,919 --> 08:47:22,721
company and really the entire

13274
08:47:22,721 --> 08:47:24,722
industry will change in the

13275
08:47:24,722 --> 08:47:26,724
coming decades. I think my

13276
08:47:26,724 --> 08:47:27,925
regulations for each of these

13277
08:47:27,925 --> 08:47:29,895
accounts reflect the future

13278
08:47:29,895 --> 08:47:31,963
life and that salvage estimates

13279
08:47:31,963 --> 08:47:33,765
life net salvage expectations

13280
08:47:33,765 --> 08:47:35,700
based on the information and

13281
08:47:35,700 --> 08:47:36,835
data we have today. Thank you I

13282
08:47:36,835 --> 08:47:38,770
concludes my summary.

13283
08:47:38,770 --> 08:47:39,370
>> teco Attorney: we tender the

13284
08:47:39,370 --> 08:47:40,706
spec for

13285
08:47:40,706 --> 08:47:42,174
cross-examination.

13286
08:47:42,174 --> 08:47:43,709
>> opc: thank you MR. Chair

13287
08:47:43,709 --> 08:47:45,711
hello MR. [Listing names] If

13288
08:47:45,711 --> 08:47:46,912
you don't mind milliken jumped

13289
08:47:46,912 --> 08:47:48,814
right into questioning.

13290
08:47:48,814 --> 08:47:49,281
You recommended a 30 year

13291
08:47:49,281 --> 08:47:50,816
average

13292
08:47:50,816 --> 08:47:51,116
service life for solar

13293
08:47:51,116 --> 08:47:51,883
facilities

13294
08:47:51,883 --> 08:47:52,951
correct.

13295
08:47:52,951 --> 08:47:54,885
>> teco Witness: yes.

13296
08:47:54,885 --> 08:47:56,888
>> opc: isn't true that the

13297
08:47:56,888 --> 08:47:57,823
teco service life as officers

13298
08:47:57,823 --> 08:47:59,823
is 35 years.

13299
08:47:59,858 --> 08:48:01,793
>> teco Witness: not exactly.

13300
08:48:01,793 --> 08:48:02,894
Based on the settlement of the

13301
08:48:02,894 --> 08:48:03,729
prior case if there is a b

13302
08:48:03,729 --> 08:48:04,830
35

13303
08:48:04,830 --> 08:48:06,731
lifespan and the company

13304
08:48:06,731 --> 08:48:08,734
proposed a 30 year lifespan of

13305
08:48:08,734 --> 08:48:09,835
the prior depreciation study.

13306
08:48:09,835 --> 08:48:11,770
>> Florida Rising:

13307
08:48:11,770 --> 08:48:13,705
>> opc: thank you and 2021 you

13308
08:48:13,705 --> 08:48:15,707
testified on behalf of florida

13309
08:48:15,707 --> 08:48:16,741
power & light companies

13310
08:48:16,741 --> 08:48:17,809
depreciation study.

13311
08:48:17,809 --> 08:48:18,843
>> teco Witness: yes.

13312
08:48:18,843 --> 08:48:19,778
>> Florida Rising:

13313
08:48:19,778 --> 08:48:20,712
>> opc: ur b

13314
08:48:20,712 --> 08:48:22,140
35 lifespan for

13315
08:48:22,140 --> 08:48:23,715
solar facilities.

13316
08:48:23,715 --> 08:48:24,916
>> teco Witness: I don't make a

13317
08:48:24,916 --> 08:48:26,785
cushion at the request of

13318
08:48:26,785 --> 08:48:28,720
witness ferguson ever was a 30

13319
08:48:28,720 --> 08:48:29,210
year lifespan for solar

13320
08:48:29,210 --> 08:48:31,210
facilities.

13321
08:48:31,723 --> 08:48:32,824
>> opc: fpl current levels all

13322
08:48:32,824 --> 08:48:34,760
facilities in 35 years.

13323
08:48:34,760 --> 08:48:36,695
>> teco Witness: based on the

13324
08:48:36,695 --> 08:48:37,696
result of that case.

13325
08:48:37,696 --> 08:48:39,798
>> opc: in this case you

13326
08:48:39,798 --> 08:48:40,932
provided calculations for a 35

13327
08:48:40,932 --> 08:48:42,834
year average service life.

13328
08:48:42,834 --> 08:48:44,836
>> teco Witness: I did in my

13329
08:48:44,836 --> 08:48:46,738
rebuttal testimony want to make

13330
08:48:46,738 --> 08:48:48,774
sure that dk collated

13331
08:48:48,774 --> 08:48:50,776
depreciation rates from other

13332
08:48:50,776 --> 08:48:51,910
proposals were performed

13333
08:48:51,910 --> 08:48:53,912
consistent with how we have

13334
08:48:53,912 --> 08:48:55,912
done depreciation studies

13335
08:48:56,781 --> 08:48:56,981
everywhere that mary bottle has

13336
08:48:56,981 --> 08:48:57,882
money.

13337
08:48:57,882 --> 08:48:58,317
>> opc: that's on exhibit any 2

13338
08:48:58,317 --> 08:48:58,883
page 1 of

13339
08:48:58,883 --> 08:49:00,786
two.

13340
08:49:00,786 --> 08:49:02,786
>> teco Witness: correct.

13341
08:49:02,787 --> 08:49:04,790
>> opc: your calculations are

13342
08:49:04,790 --> 08:49:06,791
not original in support of a 35

13343
08:49:06,791 --> 08:49:07,992
year overall service life for

13344
08:49:07,992 --> 08:49:09,992
solar generation facilities.

13345
08:49:09,994 --> 08:49:11,962
>> teco Witness: I'm not sure I

13346
08:49:11,962 --> 08:49:14,320
fully understand the question.

13347
08:49:14,320 --> 08:49:16,432
>> opc: are your calculations

13348
08:49:16,768 --> 08:49:17,235
for a 35 year service life for

13349
08:49:17,235 --> 08:49:18,803
tampa electric solar

13350
08:49:18,803 --> 08:49:20,500
generation

13351
08:49:20,500 --> 08:49:21,973
facilities reasonable.

13352
08:49:21,973 --> 08:49:24,373
>> teco Witness: I've proposed

13353
08:49:24,842 --> 08:49:25,811
30 your life I would expect I

13354
08:49:25,811 --> 08:49:26,978
believe that to be the most

13355
08:49:26,978 --> 08:49:28,847
reasonable. 35 is appose

13356
08:49:28,847 --> 08:49:30,815
outside the range of

13357
08:49:30,815 --> 08:49:32,851
possibilities I think a 30 year

13358
08:49:32,851 --> 08:49:34,820
lifespan is more reasonable

13359
08:49:34,820 --> 08:49:35,120
regarding a 35 year lifespan is

13360
08:49:35,120 --> 08:49:36,988
reasonable.

13361
08:49:36,988 --> 08:49:38,824
>> teco Witness: that is not

13362
08:49:38,824 --> 08:49:40,826
what it said it is within range

13363
08:49:40,826 --> 08:49:42,260
of potential more reasonable

13364
08:49:42,260 --> 08:49:42,193
possibilities for the future.

13365
08:49:42,193 --> 08:49:44,290
>>

13366
08:49:44,290 --> 08:49:44,896
opc: thank you that's all

13367
08:49:44,896 --> 08:49:46,831
from opc.

13368
08:49:46,831 --> 08:49:47,999
>> Florida Rising: I just have

13369
08:49:47,999 --> 08:49:49,999
very short questions.

13370
08:49:50,100 --> 08:49:51,102
Thank you CHAIRMAN Brintnall

13371
08:49:51,102 --> 08:49:52,300
good afternoon good

13372
08:49:52,300 --> 08:49:53,939
evening.

13373
08:49:53,939 --> 08:49:55,840
[Listing names] Generally would

13374
08:49:55,840 --> 08:49:57,750
you agree it makes sense as a

13375
08:49:57,750 --> 08:49:58,760
practice to match depreciation

13376
08:49:58,760 --> 08:49:59,844
with service life?

13377
08:49:59,844 --> 08:50:01,450
>> teco Witness: yes.

13378
08:50:01,450 --> 08:50:03,140
>> Florida Rising: thank you so

13379
08:50:03,140 --> 08:50:03,147
much of those are my questions

13380
08:50:03,147 --> 08:50:04,950
.

13381
08:50:04,950 --> 08:50:05,817
>> fipug: I just have a few

13382
08:50:05,817 --> 08:50:07,180
questions.

13383
08:50:07,180 --> 08:50:08,820
In response to the question

13384
08:50:08,820 --> 08:50:10,855
about the combined cycle she

13385
08:50:10,855 --> 08:50:11,990
said there is a range that is

13386
08:50:11,990 --> 08:50:13,892
reasonable what is the range?

13387
08:50:13,892 --> 08:50:14,993
>> teco Witness: he asked me

13388
08:50:14,993 --> 08:50:17,280
about the solar lifespans.

13389
08:50:17,280 --> 08:50:18,830
>> fipug: what was your range

13390
08:50:18,830 --> 08:50:19,300
when you said there was a

13391
08:50:19,300 --> 08:50:20,899
range.

13392
08:50:20,899 --> 08:50:22,834
>> teco Witness: for solar we

13393
08:50:22,834 --> 08:50:23,601
typically seen lifespans in the

13394
08:50:23,601 --> 08:50:24,836
25-35 year range

13395
08:50:24,836 --> 08:50:25,837
kind of the

13396
08:50:25,837 --> 08:50:27,400
midpoint of that.

13397
08:50:27,400 --> 08:50:29,841
>> fipug: have you looked do

13398
08:50:29,841 --> 08:50:30,842
have knowledge a lot of leases

13399
08:50:30,842 --> 08:50:33,842
being dealt with solar or 35

13400
08:50:39,217 --> 08:50:40,251
years with five years options

13401
08:50:40,251 --> 08:50:42,186
those type of things.

13402
08:50:42,186 --> 08:50:44,121
>> teco Witness: I'm not sure

13403
08:50:44,121 --> 08:50:46,900
if you are referring to any

13404
08:50:46,900 --> 08:50:47,291
specific ones I know some solar

13405
08:50:47,291 --> 08:50:48,226
cells have leases in the map

13406
08:50:48,226 --> 08:50:50,950
during terms.

13407
08:50:50,950 --> 08:50:52,970
>> fipug: I'm just asking you

13408
08:50:52,970 --> 08:50:52,430
do this pretty regularly with

13409
08:50:52,430 --> 08:50:54,131
solar rights?

13410
08:50:54,131 --> 08:50:56,670
>> teco Witness: I'm not

13411
08:50:56,670 --> 08:50:57,268
familiar with every lease term

13412
08:50:57,268 --> 08:50:59,203
until their lease terms and

13413
08:50:59,203 --> 08:51:01,106
things like that but I been

13414
08:51:01,106 --> 08:51:03,740
involved in the studies that

13415
08:51:03,740 --> 08:51:03,374
had hundreds of different solar

13416
08:51:03,374 --> 08:51:05,309
facilities.

13417
08:51:05,309 --> 08:51:08,790
>> fipug: in europe and he said

13418
08:51:08,790 --> 08:51:08,480
the entire industry will change

13419
08:51:08,480 --> 08:51:09,281
materially in the

13420
08:51:09,281 --> 08:51:10,315
future what

13421
08:51:10,315 --> 08:51:12,250
did you mean by that.

13422
08:51:12,250 --> 08:51:13,151
>> teco Witness: there is quite

13423
08:51:13,151 --> 08:51:15,860
a bit to it.

13424
08:51:15,860 --> 08:51:16,321
First of all technology.

13425
08:51:16,321 --> 08:51:18,223
Technology has changed a lot.

13426
08:51:18,223 --> 08:51:20,158
I look back to when I started

13427
08:51:20,158 --> 08:51:21,559
about 18 years ago when most of

13428
08:51:21,559 --> 08:51:24,462
the generating fleet was a

13429
08:51:24,462 --> 08:51:26,431
coal-fired generation and

13430
08:51:26,431 --> 08:51:27,599
things in the past 18 years we

13431
08:51:27,599 --> 08:51:28,700
saw that turnover a lot sooner

13432
08:51:28,700 --> 08:51:30,700
than people expected.

13433
08:51:37,108 --> 08:51:39,110
That is been driven by new gas

13434
08:51:39,110 --> 08:51:40,344
fire cycle technology that is

13435
08:51:40,344 --> 08:51:42,213
gotten much more efficient and

13436
08:51:42,213 --> 08:51:44,115
solar and other things like

13437
08:51:44,115 --> 08:51:45,282
that. I think in the future we

13438
08:51:45,282 --> 08:51:47,118
will see a lot more of those

13439
08:51:47,118 --> 08:51:49,120
type of changes that will

13440
08:51:49,120 --> 08:51:50,288
potentially impact the existing

13441
08:51:50,288 --> 08:51:52,190
generation might be there new

13442
08:51:52,190 --> 08:51:54,124
things without thought of yet.

13443
08:51:54,124 --> 08:51:56,127
I think were seeing changes in

13444
08:51:56,127 --> 08:51:57,629
load growth electrification and

13445
08:51:57,629 --> 08:51:59,230
things like that will have an

13446
08:51:59,230 --> 08:52:01,132
impact obviously there is need

13447
08:52:01,132 --> 08:52:02,200
to make system resilient and

13448
08:52:02,200 --> 08:52:03,301
reliable does a lot of

13449
08:52:03,301 --> 08:52:05,136
investments going on.

13450
08:52:05,136 --> 08:52:06,338
Really for my experience I

13451
08:52:06,338 --> 08:52:08,272
think there is a lot that is

13452
08:52:08,272 --> 08:52:08,573
going to change in the coming

13453
08:52:08,573 --> 08:52:10,141
two decades.

13454
08:52:10,141 --> 08:52:11,342
Hat will impact

13455
08:52:11,342 --> 08:52:13,244
public just about everything.

13456
08:52:13,244 --> 08:52:13,511
>> fipug: that's all I have

13457
08:52:13,511 --> 08:52:15,413
thank you.

13458
08:52:15,413 --> 08:52:17,148
>> Mike La Rosa,CHAIRMAN:

13459
08:52:17,148 --> 08:52:19,148
>> fea: no questions.

13460
08:52:23,788 --> 08:52:24,856
>> Sierra Club: no questions.

13461
08:52:24,856 --> 08:52:25,122
>> Fuel Retailors: no

13462
08:52:25,122 --> 08:52:26,958
questions.

13463
08:52:26,958 --> 08:52:28,958
>> Walmart: no questions.

13464
08:52:32,263 --> 08:52:34,263
>> yes MR. CHAIRMAN.

13465
08:52:36,101 --> 08:52:39,101
MR. [Listing names] Is it

13466
08:52:44,842 --> 08:52:46,644
correct that teco recently

13467
08:52:46,644 --> 08:52:48,645
filed an updated revenue

13468
08:52:48,645 --> 08:52:49,781
requirement which includes an

13469
08:52:49,781 --> 08:52:51,683
increase of battery storage

13470
08:52:51,683 --> 08:52:54,251
life from your proposal of

13471
08:52:54,251 --> 08:52:55,320
b,10-20 years?

13472
08:52:55,320 --> 08:52:57,121
>> teco Witness: I don't know

13473
08:52:57,121 --> 08:52:58,823
exactly what was filed my

13474
08:52:58,823 --> 08:52:59,991
understanding is that yes they

13475
08:52:59,991 --> 08:53:00,992
stipulated to a 20 your life

13476
08:53:00,992 --> 08:53:02,992
for energy storage.

13477
08:53:03,528 --> 08:53:04,829
>> will that increase in

13478
08:53:04,829 --> 08:53:08,429
service life have any impact on

13479
08:53:10,680 --> 08:53:12,680
teco's theoretical reserve

13480
08:53:14,606 --> 08:53:14,806
balance as of DECEMBER 21 of

13481
08:53:14,806 --> 08:53:16,707
2024.

13482
08:53:16,707 --> 08:53:18,610
>> teco Witness: yes it will

13483
08:53:18,610 --> 08:53:22,210
although was a fairly masses I

13484
08:53:26,500 --> 08:53:28,853
would not have it fairly big

13485
08:53:28,853 --> 08:53:29,988
impact brian box when you say

13486
08:53:29,988 --> 08:53:31,856
you don't expected to have that

13487
08:53:31,856 --> 08:53:33,858
much of an impact you have any

13488
08:53:33,858 --> 08:53:34,893
sort of estimate or number that

13489
08:53:34,893 --> 08:53:36,126
you can give me roughly?

13490
08:53:36,126 --> 08:53:37,896
>> teco Witness: that might be

13491
08:53:37,896 --> 08:53:39,970
in the I think we did

13492
08:53:39,970 --> 08:53:40,899
calculations with the 20 year

13493
08:53:40,899 --> 08:53:43,299
period in my rebuttal

13494
08:53:49,400 --> 08:53:50,141
testimony.

13495
08:53:50,141 --> 08:53:52,430
i don't know I have that

13496
08:53:52,430 --> 08:53:53,411
information it is certainly

13497
08:53:53,411 --> 08:53:53,678
something that we can

13498
08:53:53,678 --> 08:53:55,480
calculate.

13499
08:53:55,480 --> 08:53:59,680
>> also want to ask you is it

13500
08:54:00,351 --> 08:54:02,186
correct that opc proposed use

13501
08:54:02,186 --> 08:54:04,188
35 year service life for the

13502
08:54:04,188 --> 08:54:04,355
sole facilities and set up your

13503
08:54:04,355 --> 08:54:06,291
30?

13504
08:54:06,291 --> 08:54:08,292
>> teco Witness: yes 35 year

13505
08:54:08,292 --> 08:54:09,661
average service life instead of

13506
08:54:09,661 --> 08:54:11,661
three years.

13507
08:54:11,696 --> 08:54:14,696
>> if the commission approved a

13508
08:54:15,165 --> 08:54:17,680
b,35 service life what would be

13509
08:54:17,680 --> 08:54:18,869
the impact again on the reserve

13510
08:54:18,869 --> 08:54:20,104
balance?

13511
08:54:20,104 --> 08:54:22,504
>> teco Witness: similarly it

13512
08:54:23,975 --> 08:54:25,975
would change.

13513
08:54:26,100 --> 08:54:27,545
I don't know thereby have been

13514
08:54:27,545 --> 08:54:28,120
discovery that we responded to

13515
08:54:28,120 --> 08:54:30,120
that.

13516
08:54:31,916 --> 08:54:32,984
>> teco Witness: up or down

13517
08:54:32,984 --> 08:54:34,952
with a longer life the

13518
08:54:34,952 --> 08:54:36,952
theoretical reserve would

13519
08:54:37,822 --> 08:54:39,923
decrease which would it would

13520
08:54:39,923 --> 08:54:43,523
make the reserve in balance it

13521
08:54:49,166 --> 08:54:49,633
depends on whether positive or

13522
08:54:49,633 --> 08:54:50,401
negative number. It

13523
08:54:50,401 --> 08:54:52,270
would change

13524
08:54:52,270 --> 08:54:54,171
the theoretical reserve which

13525
08:54:54,171 --> 08:54:54,472
might make it larger or smaller

13526
08:54:54,472 --> 08:54:56,307
depending.

13527
08:54:56,307 --> 08:54:57,441
>> thank you I have nothing

13528
08:54:57,441 --> 08:54:59,577
further for that witness.

13529
08:54:59,577 --> 08:55:01,479
>> Mike La Rosa,CHAIRMAN: thank

13530
08:55:01,479 --> 08:55:02,790
you commissioners. Any

13531
08:55:02,790 --> 08:55:03,281
questions.

13532
08:55:03,281 --> 08:55:04,449
Seeing none I sent it back to

13533
08:55:04,449 --> 08:55:04,544
you for redirect

13534
08:55:04,544 --> 08:55:06,544
.

13535
08:55:08,190 --> 08:55:08,111
>> teco Attorney: no redirect

13536
08:55:08,111 --> 08:55:10,111
.

13537
08:55:10,188 --> 08:55:12,900
>> Mike La Rosa,CHAIRMAN: let's

13538
08:55:12,900 --> 08:55:12,322
talk about exhibits on the

13539
08:55:12,322 --> 08:55:14,580
record.

13540
08:55:14,580 --> 08:55:15,226
>> teco Attorney: tampa

13541
08:55:15,226 --> 08:55:17,261
electric like to move exhibit

13542
08:55:17,261 --> 08:55:19,661
26 and 147 into the record.

13543
08:55:21,309 --> 08:55:21,437
>> Mike La Rosa,CHAIRMAN: any

13544
08:55:21,437 --> 08:55:21,531
objection?

13545
08:55:21,531 --> 08:55:25,131
seeing none I sure them entered

13546
08:55:25,903 --> 08:55:27,370
into the record.

13547
08:55:27,370 --> 08:55:28,106
Opc any of the units.

13548
08:55:28,106 --> 08:55:30,700
>> opc: no exhibits.

13549
08:55:30,700 --> 08:55:31,942
>> Mike La Rosa,CHAIRMAN: any

13550
08:55:31,942 --> 08:55:33,177
other parties have exhibits.

13551
08:55:33,177 --> 08:55:34,145
Seeing none thank you for being

13552
08:55:34,145 --> 08:55:35,613
here today.

13553
08:55:35,613 --> 08:55:37,613
You are excused.

13554
08:55:40,170 --> 08:55:43,170
All rights it's about seven

13555
08:55:44,221 --> 08:55:46,123
minutes before 6 o'clock I said

13556
08:55:46,123 --> 08:55:47,258
we will take a break at 6

13557
08:55:47,258 --> 08:55:49,227
o'clock let's take a break

13558
08:55:49,227 --> 08:55:50,194
early we can reconvene at 6:30

13559
08:55:50,194 --> 08:55:52,194
pm.

13560
08:55:56,434 --> 08:56:00,340
We will see you guys then.

13561
09:33:53,173 --> 09:33:54,240
>> Mike La Rosa,CHAIRMAN: I

13562
09:33:54,240 --> 09:33:57,240
think we are ready to

13563
09:34:03,150 --> 09:34:05,850
reconvene.

13564
09:34:05,850 --> 09:34:08,850
Where we have left off.

13565
09:34:09,723 --> 09:34:12,225
It is now back in teco's hand

13566
09:34:12,225 --> 09:34:14,227
to introduce the next witness.

13567
09:34:14,227 --> 09:34:17,227
>> teco Attorney: thank you MR.

13568
09:34:17,431 --> 09:34:19,399
CHAIRMAN tampa electric called.

13569
09:34:19,399 --> 09:34:21,334
[Listing names] To the stand.

13570
09:34:21,334 --> 09:34:22,435
>> Mike La Rosa,CHAIRMAN: do

13571
09:34:22,435 --> 09:34:24,838
you mind standing up to

13572
09:34:24,838 --> 09:34:26,807
administer the oath to swear or

13573
09:34:26,807 --> 09:34:28,742
affirm the testimony you're

13574
09:34:28,742 --> 09:34:30,744
about to give will be the truth

13575
09:34:30,744 --> 09:34:31,712
the whole truth and nothing but

13576
09:34:31,712 --> 09:34:32,179
the truth.

13577
09:34:32,179 --> 09:34:34,179
Thank you.

13578
09:34:34,214 --> 09:34:35,381
>> teco Attorney: good evening.

13579
09:34:35,381 --> 09:34:37,384
[Listing names] Would you

13580
09:34:37,384 --> 09:34:38,351
please state your full name for

13581
09:34:38,351 --> 09:34:40,253
the record.

13582
09:34:40,253 --> 09:34:41,254
>> teco Witness: [Listing

13583
09:34:41,254 --> 09:34:42,254
names]

13584
09:34:42,254 --> 09:34:44,257
>> Mike La Rosa,CHAIRMAN: I

13585
09:34:44,257 --> 09:34:44,424
think your microphone might be

13586
09:34:44,424 --> 09:34:45,391
off.

13587
09:34:45,391 --> 09:34:47,294
The green light?

13588
09:34:47,294 --> 09:34:49,294
>> teco Witness: [Listing

13589
09:34:52,365 --> 09:34:53,567
names].

13590
09:34:53,567 --> 09:34:53,799
>> teco Attorney: who is your

13591
09:34:53,799 --> 09:34:55,469
current

13592
09:34:55,469 --> 09:34:56,536
employer what is your

13593
09:34:56,536 --> 09:34:58,371
business address.

13594
09:34:58,371 --> 09:35:00,371
>> teco Witness: [Listing

13595
09:35:18,491 --> 09:35:20,427
names] Address 1400 1400 merck

13596
09:35:20,427 --> 09:35:22,429
pkwy., kansas city, mo. Spinner

13597
09:35:22,429 --> 09:35:24,331
did you prepare and cause to be

13598
09:35:24,331 --> 09:35:25,431
filed in this docket and APRIL

13599
09:35:25,431 --> 09:35:27,334
2, 2024 prepared direct

13600
09:35:27,334 --> 09:35:27,534
testimony consisting of 19

13601
09:35:27,534 --> 09:35:29,435
pages.

13602
09:35:29,435 --> 09:35:31,337
>> teco Witness: kisha davis.

13603
09:35:31,337 --> 09:35:32,272
>> teco Attorney: did you

13604
09:35:32,272 --> 09:35:32,639
prepare and caused

13605
09:35:32,639 --> 09:35:34,474
to be filed

13606
09:35:34,474 --> 09:35:36,343
in this docket on JULY 2, 2024

13607
09:35:36,343 --> 09:35:37,476
prepared rebuttal testimony

13608
09:35:37,476 --> 09:35:38,578
consisting of 16 pages.

13609
09:35:38,578 --> 09:35:40,514
>> teco Witness: yes.

13610
09:35:40,514 --> 09:35:42,649
>> teco Attorney: do you have

13611
09:35:42,649 --> 09:35:42,916
any additions or corrections to

13612
09:35:42,916 --> 09:35:44,516
your

13613
09:35:44,516 --> 09:35:45,418
prepared direct or rebuttal

13614
09:35:45,418 --> 09:35:46,419
testimony.

13615
09:35:46,419 --> 09:35:48,419
>> teco Witness: no.

13616
09:35:48,422 --> 09:35:50,356
>> teco Attorney: if I were to

13617
09:35:50,356 --> 09:35:51,591
ask you the questions prepared

13618
09:35:51,591 --> 09:35:53,359
in your direct and rebuttal

13619
09:35:53,359 --> 09:35:54,494
testimony today would your

13620
09:35:54,494 --> 09:35:56,229
answers be the same as your

13621
09:35:56,229 --> 09:35:56,429
answers contained therein.

13622
09:35:56,429 --> 09:35:57,596
>

13623
09:35:57,596 --> 09:35:59,432
teco Attorney: MR. CHAIRMAN

13624
09:35:59,432 --> 09:36:01,368
tampa electric would like to

13625
09:36:01,368 --> 09:36:02,369
prepared direct and rebuttal

13626
09:36:02,369 --> 09:36:03,570
testimony of.

13627
09:36:03,570 --> 09:36:05,437
[Listing names] To be inserted

13628
09:36:05,437 --> 09:36:07,374
into the record is so red.

13629
09:36:07,374 --> 09:36:09,376
Did you also prepare and cause

13630
09:36:09,376 --> 09:36:11,377
to be filed with your direct

13631
09:36:11,377 --> 09:36:11,778
testimony and exhibits marked j

13632
09:36:11,778 --> 09:36:12,512
kate 1 consisting

13633
09:36:12,512 --> 09:36:13,380
of three

13634
09:36:13,380 --> 09:36:14,414
documents.

13635
09:36:14,414 --> 09:36:16,349
>> teco Witness: yes.

13636
09:36:16,349 --> 09:36:17,484
>> teco Attorney: tampa

13637
09:36:17,484 --> 09:36:19,352
electric would note for the

13638
09:36:19,352 --> 09:36:20,553
record that exhibit jk one has

13639
09:36:20,553 --> 09:36:21,421
been identified in the ctl as

13640
09:36:21,421 --> 09:36:23,421
exhibit 27.

13641
09:36:23,490 --> 09:36:25,391
Would you please summarize your

13642
09:36:25,391 --> 09:36:25,692
prepared direct and rebuttal

13643
09:36:25,692 --> 09:36:27,594
testimony.

13644
09:36:27,594 --> 09:36:29,594
>> teco Witness: commissioners

13645
09:36:29,629 --> 09:36:31,397
i provided direct testimony in

13646
09:36:31,397 --> 09:36:32,598
this case regarding the

13647
09:36:32,598 --> 09:36:34,998
dismantlement study prepared by

13648
09:36:44,243 --> 09:36:46,312
me and my team at 1898 for

13649
09:36:46,312 --> 09:36:48,147
electric company. As outlined

13650
09:36:48,147 --> 09:36:49,382
in my direct estimate the

13651
09:36:49,382 --> 09:36:51,250
purpose of the study was to

13652
09:36:51,250 --> 09:36:53,186
review tampa electric's fleet

13653
09:36:53,186 --> 09:36:55,188
of generating assets and make

13654
09:36:55,188 --> 09:36:56,322
recommendations to the company

13655
09:36:56,322 --> 09:36:58,191
regarding the total cost of

13656
09:36:58,191 --> 09:36:59,426
this metal the facilities at

13657
09:36:59,426 --> 09:37:01,394
the end of their useful life.

13658
09:37:01,394 --> 09:37:03,195
My team and I previously

13659
09:37:03,195 --> 09:37:04,397
prepared a similar study for

13660
09:37:04,397 --> 09:37:06,432
the company in 2020 in support

13661
09:37:06,432 --> 09:37:08,200
of the company's depreciation

13662
09:37:08,200 --> 09:37:09,669
filing the qantas military

13663
09:37:09,669 --> 09:37:11,236
service to update the cost

13664
09:37:11,236 --> 09:37:13,173
presented in the 2020 study for

13665
09:37:13,173 --> 09:37:14,340
changes to market conditions

13666
09:37:14,340 --> 09:37:16,209
physical changes that have

13667
09:37:16,209 --> 09:37:17,410
occurred at the plants and

13668
09:37:17,410 --> 09:37:19,410
incorporating new facilities

13669
09:37:20,213 --> 09:37:21,448
that have been constructed or

13670
09:37:21,448 --> 09:37:23,316
acquired since 2020. My team

13671
09:37:23,316 --> 09:37:25,251
and I relied upon our vast

13672
09:37:25,251 --> 09:37:26,352
experience and in-house data as

13673
09:37:26,352 --> 09:37:28,752
well as information from

13674
09:37:29,222 --> 09:37:30,223
electric company to perform the

13675
09:37:30,223 --> 09:37:32,225
study. The total dismantling

13676
09:37:32,225 --> 09:37:33,760
cost is determined by 1898 and

13677
09:37:33,760 --> 09:37:35,328
reflected in the dismantlement

13678
09:37:35,328 --> 09:37:37,230
study are net of salvage value

13679
09:37:37,230 --> 09:37:38,431
for scrap materials at each

13680
09:37:38,431 --> 09:37:40,333
plant. This mental exhaustion

13681
09:37:40,333 --> 09:37:42,234
study brutalize as an input

13682
09:37:42,234 --> 09:37:43,336
into killing dismantlement

13683
09:37:43,336 --> 09:37:45,736
approvals in this case.

13684
09:37:46,500 --> 09:37:47,307
The estimates of dismantlement

13685
09:37:47,307 --> 09:37:49,242
cost were repaired with the

13686
09:37:49,242 --> 09:37:51,244
intent of most accurately

13687
09:37:51,244 --> 09:37:53,244
representing what 1898 wooden

13688
09:37:53,246 --> 09:37:54,480
displayed contractors bidding

13689
09:37:54,480 --> 09:37:56,382
to dismantle the equipment

13690
09:37:56,382 --> 09:37:58,251
address environmental issues

13691
09:37:58,251 --> 09:38:00,252
and restore the site through a

13692
09:38:00,252 --> 09:38:01,387
competitive bidding process.

13693
09:38:01,387 --> 09:38:03,355
Site-specific cost estimates

13694
09:38:03,355 --> 09:38:05,225
were developed using a bottom

13695
09:38:05,225 --> 09:38:06,459
up cost estimating approach

13696
09:38:06,459 --> 09:38:08,227
request estimates are developed

13697
09:38:08,227 --> 09:38:10,230
from scratch through the

13698
09:38:10,230 --> 09:38:12,230
development of site-specific

13699
09:38:12,231 --> 09:38:13,366
quantity estimates and that the

13700
09:38:13,366 --> 09:38:15,235
application of unit pricing

13701
09:38:15,235 --> 09:38:15,501
rates to the quantity

13702
09:38:15,501 --> 09:38:17,303
estimates.

13703
09:38:17,303 --> 09:38:18,471
The dismantlement study is

13704
09:38:18,471 --> 09:38:20,239
consistent with the rule 25-

13705
09:38:20,239 --> 09:38:21,407
6.0436 four of the florida

13706
09:38:21,407 --> 09:38:23,407
administrative code regarding

13707
09:38:23,475 --> 09:38:25,244
electric utilities

13708
09:38:25,244 --> 09:38:26,412
dismantlement study's inc.'s

13709
09:38:26,412 --> 09:38:28,214
methodologies used in prior

13710
09:38:28,214 --> 09:38:29,349
studies we are prepared that

13711
09:38:29,349 --> 09:38:31,217
have been approved by this

13712
09:38:31,217 --> 09:38:33,252
commission and other utility

13713
09:38:33,252 --> 09:38:35,252
commissions throughout the

13714
09:38:35,254 --> 09:38:36,456
country. And incorporates

13715
09:38:36,456 --> 09:38:38,291
industry-standard data. The

13716
09:38:38,291 --> 09:38:40,293
study results and cost

13717
09:38:40,293 --> 09:38:41,560
estimates are reasonable

13718
09:38:41,560 --> 09:38:43,363
estimates and appropriate for

13719
09:38:43,363 --> 09:38:44,564
the company to rely on their

13720
09:38:44,564 --> 09:38:46,466
dismantlement preserve needs.

13721
09:38:46,466 --> 09:38:48,866
My rebuttal testimony addresses

13722
09:38:49,268 --> 09:38:50,435
three issues raised by the

13723
09:38:50,435 --> 09:38:52,305
direct testimony of florida

13724
09:38:52,305 --> 09:38:53,439
office of public counsel

13725
09:38:53,439 --> 09:38:55,308
witness was back witness

13726
09:38:55,308 --> 09:38:57,308
recommends dismantlement

13727
09:38:57,310 --> 09:38:58,378
expense should exclude all

13728
09:38:58,378 --> 09:39:00,313
forecasts growth in the

13729
09:39:00,313 --> 09:39:01,581
dismantlement cost and expense

13730
09:39:01,581 --> 09:39:03,483
beyond the end of the test year

13731
09:39:03,483 --> 09:39:05,317
over rule 25-6.0436 four of the

13732
09:39:05,317 --> 09:39:07,317
florida administrative code

13733
09:39:07,319 --> 09:39:09,319
regarding electric utilities

13734
09:39:09,321 --> 09:39:10,489
dismantlement study's

13735
09:39:10,489 --> 09:39:12,325
specifically includes

13736
09:39:12,325 --> 09:39:13,760
escalation rates used in

13737
09:39:13,760 --> 09:39:15,428
converting the current

13738
09:39:15,428 --> 09:39:16,896
estimated dismantlement cost to

13739
09:39:16,896 --> 09:39:18,431
future estimated dismantlement

13740
09:39:18,431 --> 09:39:20,366
cost. It is reasonable and

13741
09:39:20,366 --> 09:39:21,600
appropriate that the 2023 cost

13742
09:39:21,600 --> 09:39:23,403
I provided my dismantlement

13743
09:39:23,403 --> 09:39:25,371
study should be escalated to

13744
09:39:25,371 --> 09:39:26,539
future years to account for the

13745
09:39:26,539 --> 09:39:28,440
impact of inflation to put them

13746
09:39:28,440 --> 09:39:30,342
in the year dollars in which

13747
09:39:30,342 --> 09:39:31,578
they will be expended and to

13748
09:39:31,578 --> 09:39:33,379
most accurately reflect the

13749
09:39:33,379 --> 09:39:35,348
actual cost to be incurred

13750
09:39:35,348 --> 09:39:37,350
consistent with this role.

13751
09:39:37,350 --> 09:39:39,352
Witness: recommend the of the

13752
09:39:39,352 --> 09:39:40,887
dismantlement cost on the solar

13753
09:39:40,887 --> 09:39:43,287
generating assets because he

13754
09:39:43,355 --> 09:39:44,356
suggest removing or for site

13755
09:39:44,356 --> 09:39:46,756
restoration activities each of

13756
09:39:48,403 --> 09:39:48,533
these facilities. Rule 25-

13757
09:39:48,533 --> 09:39:48,626
6.0436 four of the four

13758
09:39:48,626 --> 09:39:50,363
admission of code regarding

13759
09:39:50,363 --> 09:39:52,363
electric utilities

13760
09:39:52,365 --> 09:39:54,365
dismantlement study's

13761
09:39:54,367 --> 09:39:55,868
specifically includes site

13762
09:39:55,868 --> 09:39:57,903
restoration and its definition

13763
09:39:57,903 --> 09:39:59,906
of dismantling cost. These are

13764
09:39:59,906 --> 09:40:01,908
reasonable and appropriate cost

13765
09:40:01,908 --> 09:40:03,910
that should be included in the

13766
09:40:03,910 --> 09:40:05,445
garden for the solar generating

13767
09:40:05,445 --> 09:40:07,914
asset facilities. Just as they

13768
09:40:07,914 --> 09:40:08,214
are at the other generating

13769
09:40:08,214 --> 09:40:10,150
facilities.

13770
09:40:10,150 --> 09:40:11,917
Lastly MR. Collins states that

13771
09:40:11,917 --> 09:40:13,886
the company's contingency

13772
09:40:13,886 --> 09:40:15,688
assumptions are extremely

13773
09:40:15,688 --> 09:40:16,789
speculative and not known and

13774
09:40:16,789 --> 09:40:18,691
measurable. Again rule

13775
09:40:18,691 --> 09:40:19,859
25-6.0436 four of the florida

13776
09:40:19,859 --> 09:40:21,694
mission of code regarding

13777
09:40:21,694 --> 09:40:23,694
electric utilities

13778
09:40:23,696 --> 09:40:25,697
dismantlement study is also

13779
09:40:25,697 --> 09:40:27,667
specifically addressed this

13780
09:40:27,667 --> 09:40:29,135
contingency is a component of

13781
09:40:29,135 --> 09:40:30,703
dismantlement study spread

13782
09:40:30,703 --> 09:40:31,771
furthermore the application of

13783
09:40:31,771 --> 09:40:33,673
contingency is not only

13784
09:40:33,673 --> 09:40:35,708
appropriate but also entered

13785
09:40:35,708 --> 09:40:36,909
industry practice which is been

13786
09:40:36,909 --> 09:40:38,811
approved by this commission on

13787
09:40:38,811 --> 09:40:39,712
prior cases electric and other

13788
09:40:39,712 --> 09:40:40,413
utilities.

13789
09:40:40,413 --> 09:40:40,847
This concludes my

13790
09:40:40,847 --> 09:40:42,847
summary.

13791
09:40:42,881 --> 09:40:43,749
>> teco Attorney: MR. CHAIRMAN

13792
09:40:43,749 --> 09:40:45,717
we tender.

13793
09:40:45,717 --> 09:40:46,718
Listing names] For

13794
09:40:46,718 --> 09:40:46,885
cross-examination.

13795
09:40:46,885 --> 09:40:48,821
> opc:

13796
09:40:48,821 --> 09:40:49,755
thank you MR. CHAIRMAN and good

13797
09:40:49,755 --> 09:40:51,755
evening.

13798
09:40:52,491 --> 09:40:53,726
[Listing names]

13799
09:40:53,726 --> 09:40:56,126
>> teco Witness: good evening.

13800
09:40:57,771 --> 09:40:57,892
>> opc: I will go and

13801
09:40:57,892 --> 09:40:57,978
get into

13802
09:40:57,978 --> 09:40:59,532
the questioning would you agree

13803
09:40:59,532 --> 09:41:00,899
that a lease agreement

13804
09:41:00,899 --> 09:41:02,535
typically states the

13805
09:41:02,535 --> 09:41:04,537
requirements for the lease land

13806
09:41:04,537 --> 09:41:04,836
which the solar facilities

13807
09:41:04,836 --> 09:41:06,539
constructed.

13808
09:41:06,539 --> 09:41:08,539
>> teco Witness: ps.

13809
09:41:08,541 --> 09:41:10,543
>> opc: those requirements MAY

13810
09:41:10,543 --> 09:41:11,577
impact decommissioning

13811
09:41:11,577 --> 09:41:12,545
assumptions.

13812
09:41:12,545 --> 09:41:13,913
>> teco Witness: ps.

13813
09:41:13,913 --> 09:41:14,747
>> opc: MAY impact

13814
09:41:14,747 --> 09:41:16,549
decommissioning obligations.

13815
09:41:16,549 --> 09:41:18,549
>> teco Witness: ps.

13816
09:41:18,618 --> 09:41:19,752
>> opc: requirements such as

13817
09:41:19,752 --> 09:41:21,553
environmental remediation.

13818
09:41:21,553 --> 09:41:21,954
>> teco Witness: test

13819
09:41:21,954 --> 09:41:22,755
that can

13820
09:41:22,755 --> 09:41:24,690
be one components.

13821
09:41:24,690 --> 09:41:25,591
>> opc: requirements are set

13822
09:41:25,591 --> 09:41:26,626
restoration.

13823
09:41:26,626 --> 09:41:28,560
>> teco Witness: yes.

13824
09:41:28,560 --> 09:41:30,563
>> opc: is it true that you do

13825
09:41:30,563 --> 09:41:30,863
not review the lease at 25/35

13826
09:41:30,863 --> 09:41:32,698
solar sites.

13827
09:41:32,698 --> 09:41:34,567
>> teco Witness: some of the

13828
09:41:34,567 --> 09:41:35,934
lease agreements were not

13829
09:41:35,934 --> 09:41:37,669
available for review.

13830
09:41:37,669 --> 09:41:39,805
>> opc: new do not build the

13831
09:41:39,805 --> 09:41:40,773
rimadyl remediation performance

13832
09:41:40,773 --> 09:41:42,708
for the 25 sites.

13833
09:41:42,708 --> 09:41:45,708
>> teco Witness: I don't know

13834
09:41:48,914 --> 09:41:49,281
if there were any additional

13835
09:41:49,281 --> 09:41:50,515
.

13836
09:41:50,515 --> 09:41:52,418
>> opc: can you please answer

13837
09:41:52,418 --> 09:41:53,718
the question with a yes or not

13838
09:41:53,718 --> 09:41:55,488
then answer the question.

13839
09:41:55,488 --> 09:41:58,291
>> teco Witness: yes no I don't

13840
09:41:58,291 --> 09:41:59,759
know if there any requirements

13841
09:41:59,759 --> 09:42:01,294
specifically stated in those

13842
09:42:01,294 --> 09:42:02,428
leases but typically those

13843
09:42:02,428 --> 09:42:04,297
requirements are above and

13844
09:42:04,297 --> 09:42:05,397
beyond our standards

13845
09:42:05,397 --> 09:42:07,266
assumptions for site

13846
09:42:07,266 --> 09:42:07,767
restoration would typically

13847
09:42:07,767 --> 09:42:09,268
include a minimum

13848
09:42:09,268 --> 09:42:10,536
level of site

13849
09:42:10,536 --> 09:42:12,438
restoration that is appropriate

13850
09:42:12,438 --> 09:42:14,273
and we reviewed those leases to

13851
09:42:14,273 --> 09:42:15,374
see if there is additional

13852
09:42:15,374 --> 09:42:16,508
requirements beyond those

13853
09:42:16,508 --> 09:42:18,444
minimal requirements.

13854
09:42:18,444 --> 09:42:19,145
>> opc: thank you for your time

13855
09:42:19,145 --> 09:42:20,446
today opc

13856
09:42:20,446 --> 09:42:22,448
has no more questions.

13857
09:42:22,448 --> 09:42:23,682
>> Florida Rising: thank you

13858
09:42:23,682 --> 09:42:25,418
CHAIRMAN Good evening.

13859
09:42:25,418 --> 09:42:26,118
I have one question for you

13860
09:42:26,118 --> 09:42:27,386
generally

13861
09:42:27,386 --> 09:42:28,621
speaking do you teco

13862
09:42:28,621 --> 09:42:29,421
future projected peaks

13863
09:42:29,421 --> 09:42:30,389
affect

13864
09:42:30,389 --> 09:42:31,457
dismantling cost.

13865
09:42:31,457 --> 09:42:33,457
>> teco Witness:?

13866
09:42:33,459 --> 09:42:34,293
>> Florida Rising: that's my

13867
09:42:34,293 --> 09:42:35,294
question.

13868
09:42:35,294 --> 09:42:35,560
> fipug: good

13869
09:42:35,560 --> 09:42:37,296
evening.

13870
09:42:37,296 --> 09:42:39,331
[Listing names] For the.

13871
09:42:39,331 --> 09:42:40,599
[Listing names] You mention you

13872
09:42:40,599 --> 09:42:42,434
reviewed some places do recall

13873
09:42:42,434 --> 09:42:44,436
if those were 35 year leases.

13874
09:42:44,436 --> 09:42:46,305
>> teco Witness: I don't recall

13875
09:42:46,305 --> 09:42:48,307
it is not looking for the

13876
09:42:48,307 --> 09:42:49,408
duration of lease just the site

13877
09:42:49,408 --> 09:42:51,310
requirements or site

13878
09:42:51,310 --> 09:42:51,577
restoration performance were

13879
09:42:51,577 --> 09:42:53,312
included.

13880
09:42:53,312 --> 09:42:54,513
>> fipug: you have any

13881
09:42:54,513 --> 09:42:56,315
information with respect to

13882
09:42:56,315 --> 09:42:57,516
property owners possibly not

13883
09:42:57,516 --> 09:42:59,385
wanting to solar facilities

13884
09:42:59,385 --> 09:43:01,420
removed from their property if

13885
09:43:01,420 --> 09:43:04,420
they are continuing to produce

13886
09:43:04,423 --> 09:43:06,358
energy. If that was the case

13887
09:43:06,358 --> 09:43:07,560
there would not be any

13888
09:43:07,560 --> 09:43:08,594
dismantlement cost associated

13889
09:43:08,594 --> 09:43:10,529
with that correct.

13890
09:43:10,529 --> 09:43:12,331
>> teco Witness: are not aware

13891
09:43:12,331 --> 09:43:13,566
of any of the leases I guess

13892
09:43:13,566 --> 09:43:14,500
I'm not quite sure I understand

13893
09:43:14,500 --> 09:43:16,402
the question.

13894
09:43:16,402 --> 09:43:18,337
>> fipug: if you own the

13895
09:43:18,337 --> 09:43:20,339
property and lease it for 30 or

13896
09:43:20,339 --> 09:43:21,540
35 years to a utility utility

13897
09:43:21,540 --> 09:43:23,409
comes in and put a bunch of

13898
09:43:23,409 --> 09:43:24,877
solar assets on it but say

13899
09:43:24,877 --> 09:43:26,478
after 15 years they said you

13900
09:43:26,478 --> 09:43:28,381
know what there are no more

13901
09:43:28,381 --> 09:43:29,648
efficient solar and they put

13902
09:43:29,648 --> 09:43:31,550
solar assets on it have another

13903
09:43:31,550 --> 09:43:33,118
15 years on the lease at the

13904
09:43:33,118 --> 09:43:35,200
end if the landowner had the

13905
09:43:35,200 --> 09:43:35,354
option to say thank you the

13906
09:43:35,354 --> 09:43:37,890
lease is over.

13907
09:43:37,890 --> 09:43:39,240
Go about your business you

13908
09:43:39,240 --> 09:43:43,224
don't need to get the solar off

13909
09:43:43,696 --> 09:43:44,897
the property.

13910
09:43:44,897 --> 09:43:46,832
Just leave it here I will take

13911
09:43:46,832 --> 09:43:47,733
it over I will sell the energy

13912
09:43:47,733 --> 09:43:48,934
from it.

13913
09:43:48,934 --> 09:43:50,903
And operate the solar field

13914
09:43:50,903 --> 09:43:51,137
have you ever seen that or her

13915
09:43:51,137 --> 09:43:52,971
of that.

13916
09:43:52,971 --> 09:43:54,806
>> teco Witness: I've heard of

13917
09:43:54,806 --> 09:43:55,574
it being an option in the

13918
09:43:55,574 --> 09:43:56,675
lease.

13919
09:43:56,675 --> 09:43:58,677
Our studies are all looking at

13920
09:43:58,677 --> 09:44:00,646
the liability at the end of the

13921
09:44:00,646 --> 09:44:02,547
useful life of the facility.

13922
09:44:02,547 --> 09:44:05,284
This is what is the cost for

13923
09:44:05,284 --> 09:44:07,118
restoring the site and that

13924
09:44:07,118 --> 09:44:08,320
obligation is still typically

13925
09:44:08,320 --> 09:44:12,900
on the utility at the end of

13926
09:44:12,900 --> 09:44:13,291
the life to take it out.

13927
09:44:13,291 --> 09:44:15,294
>> fipug: if you're looking at

13928
09:44:15,294 --> 09:44:17,129
a lease and saw that provision

13929
09:44:17,129 --> 09:44:17,396
would you make an adjustment

13930
09:44:17,396 --> 09:44:19,197
for that?

13931
09:44:19,197 --> 09:44:20,398
Or would you assume that they

13932
09:44:20,398 --> 09:44:21,367
will come get this up and have

13933
09:44:21,367 --> 09:44:23,335
to take it out?

13934
09:44:23,335 --> 09:44:25,236
>> teco Witness: I haven't seen

13935
09:44:25,236 --> 09:44:26,939
leases that include the option

13936
09:44:26,939 --> 09:44:28,974
for the owner to make their

13937
09:44:28,974 --> 09:44:31,644
decision about living in things

13938
09:44:31,644 --> 09:44:32,978
like

13939
09:44:32,978 --> 09:44:34,780
, roads at a windfarm or

13940
09:44:34,780 --> 09:44:36,281
things like that. But the

13941
09:44:36,281 --> 09:44:38,217
obligation is still always on

13942
09:44:38,217 --> 09:44:39,285
the lessor I'm sorry to lessee

13943
09:44:39,285 --> 09:44:40,653
the utility to take out

13944
09:44:40,653 --> 09:44:44,253
everything at the end of life.

13945
09:44:47,260 --> 09:44:50,260
>> fipug: that's all I have.

13946
09:44:51,130 --> 09:44:51,230
>> fea: no question thank you

13947
09:44:51,230 --> 09:44:52,430
.

13948
09:44:52,430 --> 09:44:54,830
>> Sierra Club: no questions

13949
09:44:54,966 --> 09:44:55,670
MR. CHAIRMAN

13950
09:44:55,670 --> 09:44:57,360
.

13951
09:44:57,360 --> 09:44:57,402
>> Florida Retail Federation:

13952
09:44:57,402 --> 09:44:58,671
no questions.

13953
09:44:58,671 --> 09:44:58,836
>> Walmart: no question thank

13954
09:44:58,836 --> 09:45:00,836
you.

13955
09:45:04,610 --> 09:45:04,739
>> no question thank you

13956
09:45:04,739 --> 09:45:06,645
.

13957
09:45:06,645 --> 09:45:07,813
>> Mike La Rosa,CHAIRMAN:

13958
09:45:07,813 --> 09:45:09,681
commissioners see none teco

13959
09:45:09,681 --> 09:45:12,618
back in your hands for

13960
09:45:12,618 --> 09:45:13,819
redirects.

13961
09:45:13,819 --> 09:45:16,219
>> teco Attorney: no redirects.

13962
09:45:16,721 --> 09:45:18,591
>> Mike La Rosa,CHAIRMAN: let's

13963
09:45:18,591 --> 09:45:19,758
talk about exhibits teco any

13964
09:45:19,758 --> 09:45:22,758
exhibits to enter into the

13965
09:45:23,161 --> 09:45:23,329
record

13966
09:45:23,329 --> 09:45:25,296
.

13967
09:45:25,296 --> 09:45:26,565
>> teco Attorney: yes MR.

13968
09:45:26,565 --> 09:45:28,434
CHAIRMAN we would move exhibit

13969
09:45:28,434 --> 09:45:30,369
27 into the record please.

13970
09:45:30,369 --> 09:45:32,304
>> Mike La Rosa,CHAIRMAN: any

13971
09:45:32,304 --> 09:45:33,672
objection I show that entered

13972
09:45:33,672 --> 09:45:35,607
into the record opc none any

13973
09:45:35,607 --> 09:45:36,842
other parties that have

13974
09:45:36,842 --> 09:45:37,875
objections seeing non-excellent

13975
09:45:37,875 --> 09:45:40,875
. Thank you for being here

13976
09:45:43,381 --> 09:45:44,550
today you are excused.

13977
09:45:44,550 --> 09:45:45,784
Teco back in your hands to

13978
09:45:45,784 --> 09:45:48,184
produce your next witness.

13979
09:46:01,667 --> 09:46:03,569
>> teco Attorney: I will do the

13980
09:46:03,569 --> 09:46:05,471
oath if you don't mind stand

13981
09:46:05,471 --> 09:46:06,705
and raise your hand to affirm

13982
09:46:06,705 --> 09:46:08,640
that this is the money you're

13983
09:46:08,640 --> 09:46:10,609
about to give is the truth the

13984
09:46:10,609 --> 09:46:11,210
whole truth and nothing but the

13985
09:46:11,210 --> 09:46:12,277
truth.

13986
09:46:12,277 --> 09:46:14,277
>> teco Witness: yes.

13987
09:46:14,312 --> 09:46:14,513
>> Mike La Rosa,CHAIRMAN: thank

13988
09:46:14,513 --> 09:46:15,747
you.

13989
09:46:15,747 --> 09:46:16,381
>> teco Attorney: good

13990
09:46:16,381 --> 09:46:18,350
evening.

13991
09:46:18,350 --> 09:46:20,219
>> teco Witness: good evening

13992
09:46:20,219 --> 09:46:21,387
spinning can you state your

13993
09:46:21,387 --> 09:46:23,221
full name for the record.

13994
09:46:23,221 --> 09:46:25,221
>> teco Witness: [Listing

13995
09:46:29,861 --> 09:46:31,630
names]

13996
09:46:31,630 --> 09:46:32,364
>> teco Attorney: who is your

13997
09:46:32,364 --> 09:46:32,931
current employer and what

13998
09:46:32,931 --> 09:46:34,320
is

13999
09:46:34,320 --> 09:46:35,868
your business address.

14000
09:46:35,868 --> 09:46:37,350
>> teco Witness: it is.

14001
09:46:37,350 --> 09:46:39,435
[Listing names] My business

14002
09:46:45,143 --> 09:46:46,345
address is 3000 atrium way

14003
09:46:46,345 --> 09:46:46,578
suite 200 in mount laurel new

14004
09:46:46,578 --> 09:46:48,213
jersey.

14005
09:46:48,213 --> 09:46:49,381
> teco Attorney: did

14006
09:46:49,381 --> 09:46:51,249
you prepare and caused to be

14007
09:46:51,249 --> 09:46:53,284
filed in this docket and APRIL

14008
09:46:53,284 --> 09:46:55,154
2, 2020 fourth prepare direct

14009
09:46:55,154 --> 09:46:57,154
testimony consisting of 92

14010
09:47:18,110 --> 09:47:18,944
pages

14011
09:47:18,944 --> 09:47:20,110
.

14012
09:47:20,110 --> 09:47:22,110
>> teco Witness: yes.

14013
09:47:22,790 --> 09:47:23,949
>> Fuel Retailors: you prepare

14014
09:47:23,949 --> 09:47:25,917
and cause to be filed in this

14015
09:47:25,917 --> 09:47:27,119
docket on JULY 2, 2024 prepare

14016
09:47:27,119 --> 09:47:28,190
rebuttal testimony consisting

14017
09:47:28,190 --> 09:47:29,154
of 135 pages.

14018
09:47:29,154 --> 09:47:31,122
>> teco Witness: yes.

14019
09:47:31,122 --> 09:47:32,925
>> teco Attorney: you have any

14020
09:47:32,925 --> 09:47:34,920
additions or corrections to

14021
09:47:34,920 --> 09:47:35,960
your prepared direct or

14022
09:47:35,960 --> 09:47:36,428
rebuttal testimony?

14023
09:47:36,428 --> 09:47:38,960
>> teco Witness: no.

14024
09:47:38,960 --> 09:47:39,965
>> teco Attorney: if I were to

14025
09:47:39,965 --> 09:47:41,133
ask you the questions contained

14026
09:47:41,133 --> 09:47:43,680
in your prepared direct or

14027
09:47:43,680 --> 09:47:44,969
rebuttal testimony today would

14028
09:47:44,969 --> 09:47:46,371
your answers be the same as

14029
09:47:46,371 --> 09:47:48,730
those contained therein.

14030
09:47:48,730 --> 09:47:50,141
>> teco Witness: they would.

14031
09:47:50,141 --> 09:47:52,143
>> teco Attorney: MR. CHAIRMAN

14032
09:47:52,143 --> 09:47:54,120
electric requests that prepared

14033
09:47:54,120 --> 09:47:55,247
and direct and rebuttal

14034
09:47:55,247 --> 09:47:56,215
testimony of.

14035
09:47:56,215 --> 09:47:58,160
[Listing names] Be inserted

14036
09:47:58,160 --> 09:47:58,217
into the record as though

14037
09:47:58,217 --> 09:48:00,118
ready.

14038
09:48:00,118 --> 09:48:02,200
Did you also prepare and cause

14039
09:48:02,200 --> 09:48:03,521
to be filed with your direct

14040
09:48:03,521 --> 09:48:05,900
testimony and exhibits marked

14041
09:48:05,900 --> 09:48:05,356
dw d 1 consisting of 15

14042
09:48:05,356 --> 09:48:07,192
documents.

14043
09:48:07,192 --> 09:48:09,127
>> teco Witness: ps spinning

14044
09:48:09,127 --> 09:48:11,290
did you also prepare and cause

14045
09:48:11,290 --> 09:48:12,130
to be filed with your testimony

14046
09:48:12,130 --> 09:48:14,320
and exhibits marked dw d 2

14047
09:48:14,320 --> 09:48:15,133
consisting of 19 documents.

14048
09:48:15,133 --> 09:48:17,133
>> teco Witness: yes.

14049
09:48:17,234 --> 09:48:19,104
>> teco Attorney: MR. CHAIRMAN

14050
09:48:19,104 --> 09:48:20,338
tampa electric would note for

14051
09:48:20,338 --> 09:48:23,740
the record that exhibits dw d 1

14052
09:48:23,740 --> 09:48:24,209
2 have been identified on the

14053
09:48:24,209 --> 09:48:26,177
cl as exhibit 28 and 148.

14054
09:48:26,177 --> 09:48:28,112
Would you please summarize your

14055
09:48:28,112 --> 09:48:28,380
prepared direct and rebuttal

14056
09:48:28,380 --> 09:48:30,380
testimony.

14057
09:48:31,820 --> 09:48:33,850
>> teco Witness: good evening

14058
09:48:33,850 --> 09:48:35,870
commissioners thank you for the

14059
09:48:35,870 --> 09:48:35,319
opportunity to appear today. My

14060
09:48:35,319 --> 09:48:37,222
name is.

14061
09:48:37,222 --> 09:48:39,910
[Listing names] I'm a partner

14062
09:48:39,910 --> 09:48:41,920
at scott madden inc. The

14063
09:48:41,920 --> 09:48:43,950
purpose of my testimony is to

14064
09:48:43,950 --> 09:48:45,950
provide a recommendation

14065
09:48:45,960 --> 09:48:46,264
regarding the return on common

14066
09:48:46,264 --> 09:48:48,199
equity referred to as are we

14067
09:48:48,199 --> 09:48:49,234
our cost of equity. For tampa

14068
09:48:49,234 --> 09:48:51,103
electric company.

14069
09:48:51,103 --> 09:48:53,105
Which I also referred to as

14070
09:48:53,105 --> 09:48:54,272
teco. As well as provide an

14071
09:48:54,272 --> 09:48:56,207
assessment of the company's

14072
09:48:56,207 --> 09:48:58,900
capital structure is to be used

14073
09:48:58,900 --> 09:48:59,770
for ratemaking purposes.

14074
09:48:59,770 --> 09:49:00,312
Please note I felt direct

14075
09:49:00,312 --> 09:49:02,114
testimony and exhibits on

14076
09:49:02,114 --> 09:49:04,115
behalf of teco as well as

14077
09:49:04,115 --> 09:49:05,350
submitted rebuttal testimony to

14078
09:49:05,350 --> 09:49:07,151
respond to the florida office

14079
09:49:07,151 --> 09:49:07,786
of public counsel or opc

14080
09:49:07,786 --> 09:49:09,488
witness.

14081
09:49:09,488 --> 09:49:11,890
[Listing names] Federal

14082
09:49:11,890 --> 09:49:12,257
executive agencies or fea

14083
09:49:12,257 --> 09:49:14,192
witness christopher walters

14084
09:49:14,192 --> 09:49:16,128
florida retail federation or

14085
09:49:16,128 --> 09:49:18,528
afar witness stephen chris.

14086
09:49:23,401 --> 09:49:26,401
[Listing names] With respect to

14087
09:49:27,939 --> 09:49:29,775
the companies roe in this case

14088
09:49:29,775 --> 09:49:31,643
I will refer to those parties

14089
09:49:31,643 --> 09:49:32,978
as the intervener roe

14090
09:49:32,978 --> 09:49:34,978
witnesses.

14091
09:49:36,148 --> 09:49:38,830
In a few of current markets and

14092
09:49:38,830 --> 09:49:39,151
the results of my analytical

14093
09:49:39,151 --> 09:49:41,551
models presented in my

14094
09:49:42,253 --> 09:49:44,222
testimony the reasonable range

14095
09:49:44,222 --> 09:49:47,822
of roe applicable to teco is

14096
09:49:48,593 --> 09:49:49,761
between 10.31% and 11.93%.

14097
09:49:49,761 --> 09:49:51,595
Within that range I recommend

14098
09:49:51,595 --> 09:49:53,995
that the commission to

14099
09:49:57,669 --> 09:49:59,671
authorize and roe of 11.50%.

14100
09:49:59,671 --> 09:50:01,139
My recommended roe considers of

14101
09:50:01,139 --> 09:50:02,274
various factors to get sitter

14102
09:50:02,274 --> 09:50:04,176
the required return to the

14103
09:50:04,176 --> 09:50:04,409
equity investors of the

14104
09:50:04,409 --> 09:50:06,409
company.

14105
09:50:08,914 --> 09:50:10,115
My testimony discusses the

14106
09:50:10,115 --> 09:50:12,170
multiple analytical approaches

14107
09:50:12,170 --> 09:50:15,170
that were evaluated to develop

14108
09:50:15,886 --> 09:50:17,856
my roe recommendations my

14109
09:50:17,856 --> 09:50:19,591
testimony explains that no

14110
09:50:19,591 --> 09:50:22,591
single model is inherently so

14111
09:50:29,601 --> 09:50:31,470
precise that it can be allowed

14112
09:50:31,470 --> 09:50:32,604
on to the exclusion of other

14113
09:50:32,604 --> 09:50:34,505
theoretically sound models.

14114
09:50:34,505 --> 09:50:35,639
Using multiple models as a

14115
09:50:35,639 --> 09:50:37,576
liability to the estimated

14116
09:50:37,576 --> 09:50:39,511
common equity cost ratio and

14117
09:50:39,511 --> 09:50:41,513
supported both the financial

14118
09:50:41,513 --> 09:50:42,848
literature and regulatory

14119
09:50:42,848 --> 09:50:44,848
precedent.

14120
09:50:44,850 --> 09:50:46,851
My testimony explains how the

14121
09:50:46,851 --> 09:50:48,420
analysis to determine an

14122
09:50:48,420 --> 09:50:49,954
appropriate roe is affected by

14123
09:50:49,954 --> 09:50:51,890
the various business and

14124
09:50:51,890 --> 09:50:52,123
financial risk faced by the

14125
09:50:52,123 --> 09:50:53,858
company.

14126
09:50:53,858 --> 09:50:55,893
My roe recommendation also

14127
09:50:55,893 --> 09:50:57,128
considers factors as effective

14128
09:50:57,128 --> 09:50:58,964
rotation cost of the company's

14129
09:50:58,964 --> 09:51:00,899
bond rating. As well as the

14130
09:51:00,899 --> 09:51:02,901
company's high level customer

14131
09:51:02,901 --> 09:51:04,102
growth whether risk and capital

14132
09:51:04,102 --> 09:51:06,360
investment plans relative to

14133
09:51:06,360 --> 09:51:08,500
the companies in the proxy.

14134
09:51:08,500 --> 09:51:10,750
The analysis presented in my

14135
09:51:10,750 --> 09:51:11,910
testimony support the company's

14136
09:51:11,910 --> 09:51:13,578
requested ratemaking capital

14137
09:51:13,578 --> 09:51:15,130
structure which includes a

14138
09:51:15,130 --> 09:51:16,915
common equity ratio of 54%.

14139
09:51:16,915 --> 09:51:18,950
That common equity ration is

14140
09:51:18,950 --> 09:51:20,151
consistent with equity ratio

14141
09:51:20,151 --> 09:51:22,920
maintained by the proxy groups

14142
09:51:22,920 --> 09:51:24,880
and their operating utilities

14143
09:51:24,880 --> 09:51:26,880
subsidiary companies.

14144
09:51:26,910 --> 09:51:28,590
Finally my testimony response

14145
09:51:28,590 --> 09:51:29,928
to the issues raised by the and

14146
09:51:29,928 --> 09:51:31,928
addresses the shortcomings

14147
09:51:31,930 --> 09:51:33,931
within the intervening roe

14148
09:51:33,931 --> 09:51:35,166
witness testimony none of the

14149
09:51:35,166 --> 09:51:37,100
arguments changed by conclusion

14150
09:51:37,100 --> 09:51:38,169
that the company should be

14151
09:51:38,169 --> 09:51:40,105
authorized an opportunity to

14152
09:51:40,105 --> 09:51:43,105
earn a roe of 11.50% likewise

14153
09:51:44,542 --> 09:51:46,578
the analysis should not

14154
09:51:46,578 --> 09:51:48,790
persuade the commission to

14155
09:51:48,790 --> 09:51:50,548
approve a roe for teco up below

14156
09:51:50,548 --> 09:51:50,815
my regulation. That includes my

14157
09:51:50,815 --> 09:51:52,716
summary.

14158
09:51:52,716 --> 09:51:52,984
>> teco Attorney: we tender.

14159
09:51:52,984 --> 09:51:54,619
[Listing

14160
09:51:54,619 --> 09:51:55,220
names] For

14161
09:51:55,220 --> 09:51:55,754
cross-examination.

14162
09:51:55,754 --> 09:51:56,754
> opc:

14163
09:51:56,754 --> 09:51:58,754
good evening.

14164
09:51:58,857 --> 09:51:59,691
[Listing names] How are you

14165
09:51:59,691 --> 09:52:00,859
doing.

14166
09:52:00,859 --> 09:52:02,894
>> teco Witness: doing well.

14167
09:52:02,894 --> 09:52:07,940
>> opc: I would ask you to take

14168
09:52:09,199 --> 09:52:10,468
a look at let me start with

14169
09:52:10,468 --> 09:52:12,536
this, you have testified or

14170
09:52:12,536 --> 09:52:13,404
filed testimony in a proximally

14171
09:52:13,404 --> 09:52:15,239
150 predatory

14172
09:52:15,239 --> 09:52:15,473
proceedings

14173
09:52:15,473 --> 09:52:16,607
correct.

14174
09:52:16,607 --> 09:52:18,576
>> teco Witness: yes.

14175
09:52:18,576 --> 09:52:19,944
>> opc: it would be true to say

14176
09:52:19,944 --> 09:52:23,448
in all of those cases you

14177
09:52:23,448 --> 09:52:23,814
testified on behalf of of

14178
09:52:23,814 --> 09:52:24,549
utilities right.

14179
09:52:24,549 --> 09:52:25,449
> teco

14180
09:52:25,449 --> 09:52:27,385
Witness: yes.

14181
09:52:27,385 --> 09:52:29,387
>> opc: let me direct your

14182
09:52:29,387 --> 09:52:32,387
attention to page 19 of your

14183
09:52:36,930 --> 09:52:38,620
testimony.

14184
09:52:38,620 --> 09:52:38,150
>> teco Witness: yes ma'am

14185
09:52:38,150 --> 09:52:40,150
.

14186
09:52:44,836 --> 09:52:46,360
>> opc: it looks like we are

14187
09:52:46,360 --> 09:52:47,772
there as well. In this section

14188
09:52:47,772 --> 09:52:50,575
of your testimony this is where

14189
09:52:50,575 --> 09:52:51,576
you start your discussion about

14190
09:52:51,576 --> 09:52:53,576
capital structure.

14191
09:52:53,811 --> 09:52:54,945
>> teco Witness: yes the bottom

14192
09:52:54,945 --> 09:52:55,713
of page 19 starting at line

14193
09:52:55,713 --> 09:52:57,713
22.

14194
09:52:58,316 --> 09:52:59,417
>> opc: okay.

14195
09:52:59,417 --> 09:53:01,352
am I correct that tampa

14196
09:53:01,352 --> 09:53:03,752
electric is requesting a

14197
09:53:06,570 --> 09:53:08,570
capital structure of 41.57%

14198
09:53:08,590 --> 09:53:10,610
long-term debt and 54% equity?

14199
09:53:10,610 --> 09:53:10,228
>> teco Witness: common equity

14200
09:53:10,228 --> 09:53:12,228
yes.

14201
09:53:17,969 --> 09:53:19,971
>> opc: you use a proxy group

14202
09:53:19,971 --> 09:53:21,873
to be representative of teco

14203
09:53:21,873 --> 09:53:22,440
and the equity ratio and the

14204
09:53:22,440 --> 09:53:23,700
return on equity it

14205
09:53:23,700 --> 09:53:24,800
should

14206
09:53:24,800 --> 09:53:25,910
receive correct.

14207
09:53:25,910 --> 09:53:27,878
>> teco Witness: yes ma'am.

14208
09:53:27,878 --> 09:53:29,460
>> opc: in looking at page 23

14209
09:53:29,460 --> 09:53:32,460
of that testimony of your

14210
09:53:36,553 --> 09:53:37,822
testimony, [Unclear audio].

14211
09:53:37,822 --> 09:53:37,989
I'm assuming you are looking at

14212
09:53:37,989 --> 09:53:39,989
918.

14213
09:53:40,358 --> 09:53:42,358
Of that portion?

14214
09:53:43,194 --> 09:53:46,194
>> teco Witness: you mean lines

14215
09:53:49,701 --> 09:53:50,901
9-18?

14216
09:53:50,901 --> 09:53:52,700
>> opc: let me get there just

14217
09:53:52,700 --> 09:53:54,700
one second?

14218
09:53:55,773 --> 09:53:56,975
I'm specifically looking at the

14219
09:53:56,975 --> 09:53:59,975
sentence that starts at line

14220
09:54:00,311 --> 09:54:01,512
18.

14221
09:54:01,512 --> 09:54:03,514
It says the equity ratios of

14222
09:54:03,514 --> 09:54:06,514
your proxy group of companies

14223
09:54:09,287 --> 09:54:11,687
range from 28.9%-56-56.13%

14224
09:54:13,391 --> 09:54:16,391
for the fiscal year 2022 as

14225
09:54:18,496 --> 09:54:20,465
shown in pages three and four

14226
09:54:20,465 --> 09:54:23,465
of your document number three

14227
09:54:24,507 --> 09:54:24,626
is that correct.

14228
09:54:24,626 --> 09:54:25,270
>> teco Witness: that is right.

14229
09:54:25,270 --> 09:54:26,404
>> opc: would you agree the

14230
09:54:26,404 --> 09:54:27,571
simple average for the 14

14231
09:54:27,571 --> 09:54:30,571
companies in your proxy group

14232
09:54:32,900 --> 09:54:34,440
is a 33 is a 33.46% equity

14233
09:54:34,440 --> 09:54:34,132
ratio subject to check

14234
09:54:34,132 --> 09:54:34,345
.

14235
09:54:34,345 --> 09:54:36,345
>> opc:

14236
09:54:38,316 --> 09:54:39,751
>> teco Witness: if you look at

14237
09:54:39,751 --> 09:54:42,751
document number three page 4 of

14238
09:54:51,529 --> 09:54:53,564
five there is the simple

14239
09:54:53,564 --> 09:54:56,100
average of the proxy group

14240
09:54:56,100 --> 09:54:58,100
companies.

14241
09:55:03,441 --> 09:55:04,609
That is there.

14242
09:55:04,609 --> 09:55:06,577
The common equity ratio the

14243
09:55:06,577 --> 09:55:08,413
simple average is 41.49 but my

14244
09:55:08,413 --> 09:55:08,980
testimony faith that the 54%

14245
09:55:08,980 --> 09:55:10,915
equity ratio is within the

14246
09:55:10,915 --> 09:55:13,315
range of capital structures

14247
09:55:14,685 --> 09:55:15,887
,

14248
09:55:15,887 --> 09:55:17,688
maintained by the proxy group

14249
09:55:17,688 --> 09:55:19,590
person and their operating

14250
09:55:19,590 --> 09:55:21,526
subsidiaries. Like I said it's

14251
09:55:21,526 --> 09:55:23,926
appropriate because it is

14252
09:55:25,263 --> 09:55:26,230
representative of an electric

14253
09:55:26,230 --> 09:55:28,230
utility company.

14254
09:55:30,100 --> 09:55:33,601
>> opc: just want to make sure

14255
09:55:34,972 --> 09:55:36,507
heard you correctly.

14256
09:55:36,507 --> 09:55:38,142
This simple average which you

14257
09:55:38,142 --> 09:55:38,309
said you calculated is actually

14258
09:55:38,309 --> 09:55:40,100
44%?

14259
09:55:40,100 --> 09:55:41,678
For the proxy group.

14260
09:55:41,678 --> 09:55:43,214
>> teco Witness: no it would be

14261
09:55:43,214 --> 09:55:44,915
bates number I guess 107.

14262
09:55:44,915 --> 09:55:46,150
>>

14263
09:55:46,150 --> 09:55:49,750
opc: I'm sorry which page are

14264
09:55:50,787 --> 09:55:51,923
you looking at it and if you're

14265
09:55:51,923 --> 09:55:53,791
looking at document number

14266
09:55:53,791 --> 09:55:54,992
three page number four go to

14267
09:55:54,992 --> 09:55:56,994
the bottom it says proxy group

14268
09:55:56,994 --> 09:55:58,994
14 electric utility companies.

14269
09:55:59,960 --> 09:56:01,980
You will see the average of the

14270
09:56:01,980 --> 09:56:03,498
14 utility companies it is 55%

14271
09:56:04,669 --> 09:56:06,669
or 55.3% long-term debt.

14272
09:56:07,370 --> 09:56:09,370
2.72% short-term debt.

14273
09:56:12,676 --> 09:56:13,811
0.49% preferred stock and 41.49

14274
09:56:13,811 --> 09:56:15,713
common equities do you see

14275
09:56:15,713 --> 09:56:16,981
that?

14276
09:56:16,981 --> 09:56:19,283
>> opc: that is what I'm trying

14277
09:56:19,283 --> 09:56:20,384
to say.

14278
09:56:20,384 --> 09:56:20,717
>> teco Witness: it is up

14279
09:56:20,717 --> 09:56:22,717
there.

14280
09:56:27,825 --> 09:56:29,327
>> opc: I'm seeing that now.

14281
09:56:29,327 --> 09:56:30,261
That is divided by years

14282
09:56:30,261 --> 09:56:30,361
correct

14283
09:56:30,361 --> 09:56:32,361
.

14284
09:56:33,931 --> 09:56:37,531
>> teco Witness: if you look at

14285
09:56:37,869 --> 09:56:41,469
the top row of that schedule

14286
09:56:41,838 --> 09:56:43,274
you will see it is 2022 /2021.

14287
09:56:43,274 --> 09:56:46,874
What I was looking at their

14288
09:56:48,880 --> 09:56:51,280
four 2022 is that number.

14289
09:56:54,552 --> 09:56:56,552
>> opc: okay.

14290
09:56:56,587 --> 09:56:58,589
You are just looking at 2022 of

14291
09:56:58,589 --> 09:56:59,757
the five year average for the

14292
09:56:59,757 --> 09:57:01,759
proxy group would be 53.4%?

14293
09:57:01,759 --> 09:57:02,860
>> teco Witness: the long-term

14294
09:57:02,860 --> 09:57:04,860
debt ratio is 53.4%.

14295
09:57:09,330 --> 09:57:10,100
>> opc: the five year average

14296
09:57:10,100 --> 09:57:11,340
for the

14297
09:57:11,340 --> 09:57:12,904
common equity is 43.26%?

14298
09:57:12,904 --> 09:57:13,170
>> teco Witness: that is

14299
09:57:13,170 --> 09:57:15,170
correct.

14300
09:57:16,107 --> 09:57:19,107
>> opc: you would agree based

14301
09:57:21,445 --> 09:57:24,445
on this average that we've

14302
09:57:24,682 --> 09:57:28,282
looked at on page 4/5 the only

14303
09:57:28,953 --> 09:57:31,953
company actually let me take

14304
09:57:32,456 --> 09:57:33,691
you to page 3 of this exhibit.

14305
09:57:33,691 --> 09:57:37,940
The only company that I see

14306
09:57:37,940 --> 09:57:40,694
that has a higher equity ratio

14307
09:57:43,300 --> 09:57:45,235
then tampa electric is I corp.

14308
09:57:45,235 --> 09:57:46,700
Which is an equity ratio of 56%

14309
09:57:46,700 --> 09:57:46,203
is that correct

14310
09:57:46,203 --> 09:57:47,605
.

14311
09:57:47,605 --> 09:57:50,500
>> teco Witness: that is

14312
09:57:50,408 --> 09:57:52,342
correct like a said my

14313
09:57:52,342 --> 09:57:54,344
testimony is that it is

14314
09:57:54,344 --> 09:57:57,414
consistent with the range if of

14315
09:57:57,414 --> 09:57:59,417
both the holding company and

14316
09:57:59,417 --> 09:58:01,417
the operating subsidiary

14317
09:58:01,752 --> 09:58:03,200
companies of the proxy group

14318
09:58:03,200 --> 09:58:06,657
companies if you take a look at

14319
09:58:06,657 --> 09:58:08,659
the page 5/5 of that document

14320
09:58:08,659 --> 09:58:09,293
you'll see that a lot of the

14321
09:58:09,293 --> 09:58:12,293
operating companies are in that

14322
09:58:22,730 --> 09:58:23,341
low 50 52 mid 50 range.

14323
09:58:23,341 --> 09:58:25,109
>> opc: these were at the proxy

14324
09:58:25,109 --> 09:58:26,177
group companies that you

14325
09:58:26,177 --> 09:58:28,577
actually chose as a

14326
09:58:30,614 --> 09:58:30,714
preventative correct

14327
09:58:30,714 --> 09:58:32,683
.

14328
09:58:32,683 --> 09:58:34,717
>> teco Witness: the issue with

14329
09:58:34,717 --> 09:58:36,252
using operating subsidiary

14330
09:58:36,252 --> 09:58:39,122
companies in a roe analysis is

14331
09:58:39,122 --> 09:58:40,257
that you cannot use them is

14332
09:58:40,257 --> 09:58:42,126
they don't have the market

14333
09:58:42,126 --> 09:58:45,726
data. In an ideal world you

14334
09:58:46,964 --> 09:58:48,198
would have publicly traded

14335
09:58:48,198 --> 09:58:50,167
utility companies to do your

14336
09:58:50,167 --> 09:58:52,350
roe analysis. In this case you

14337
09:58:52,350 --> 09:58:52,836
have to use these holding

14338
09:58:52,836 --> 09:58:54,836
companies.

14339
09:58:58,275 --> 09:59:00,760
The more appropriate proxy when

14340
09:59:00,760 --> 09:59:02,780
you look at the appropriate

14341
09:59:02,780 --> 09:59:05,780
capital structure would be the

14342
09:59:05,215 --> 09:59:07,117
operating subsidiaries. But

14343
09:59:07,117 --> 09:59:11,317
anyway you slice it if you use

14344
09:59:18,829 --> 09:59:19,263
holding companies

14345
09:59:19,263 --> 09:59:21,263
.

14346
09:59:21,331 --> 09:59:22,500
>> opc: commissioners can I ask

14347
09:59:22,500 --> 09:59:24,335
to answer the question that

14348
09:59:24,335 --> 09:59:26,270
asked witches this was the

14349
09:59:26,270 --> 09:59:27,671
proxy group that he chose?

14350
09:59:27,671 --> 09:59:29,373
That was the question.

14351
09:59:29,373 --> 09:59:31,375
>> Mike La Rosa,CHAIRMAN: if

14352
09:59:31,375 --> 09:59:33,277
you have a sufficient answer to

14353
09:59:33,277 --> 09:59:34,311
the question let's move on to

14354
09:59:34,311 --> 09:59:35,278
the next question.

14355
09:59:35,278 --> 09:59:37,278
>> opc: thank you.

14356
09:59:37,281 --> 09:59:38,482
Conversely the lower the

14357
09:59:38,482 --> 09:59:38,715
percentage of the debt the

14358
09:59:38,715 --> 09:59:40,316
company

14359
09:59:40,316 --> 09:59:41,819
has in its capital

14360
09:59:41,819 --> 09:59:43,387
structure the lower the return

14361
09:59:43,387 --> 09:59:44,488
on equity or exposure to

14362
09:59:44,488 --> 09:59:46,456
financial risk the common

14363
09:59:46,456 --> 09:59:46,590
equity investors expect correct

14364
09:59:46,590 --> 09:59:48,425
.

14365
09:59:48,425 --> 09:59:49,326
>> teco Witness: can you repeat

14366
09:59:49,326 --> 09:59:50,561
that please.

14367
09:59:50,561 --> 09:59:52,462
>> opc: let me ask you this

14368
09:59:52,462 --> 09:59:54,531
first brian would you agree

14369
09:59:54,531 --> 09:59:56,333
that the higher the percentage

14370
09:59:56,333 --> 09:59:57,568
of debt in the capital

14371
09:59:57,568 --> 09:59:59,470
structure fire at the financial

14372
09:59:59,470 --> 10:00:01,371
risk the common equity owners

14373
10:00:01,371 --> 10:00:02,506
they would expect a higher

14374
10:00:02,506 --> 10:00:04,375
return on common equity

14375
10:00:04,375 --> 10:00:04,575
forbearing desire financial

14376
10:00:04,575 --> 10:00:05,643
risk?

14377
10:00:05,643 --> 10:00:07,578
>> teco Witness: agree.

14378
10:00:07,578 --> 10:00:09,446
>> opc: conversely, the lower

14379
10:00:09,446 --> 10:00:11,381
the percentage of debt the

14380
10:00:11,381 --> 10:00:12,583
company has in its capital

14381
10:00:12,583 --> 10:00:14,451
structure the lower the return

14382
10:00:14,451 --> 10:00:15,586
on equity for exposure to

14383
10:00:15,586 --> 10:00:17,554
financial risk the common

14384
10:00:17,554 --> 10:00:19,456
equity investor would expect?

14385
10:00:19,456 --> 10:00:20,957
>> teco Witness: this is all

14386
10:00:20,957 --> 10:00:22,158
equal.

14387
10:00:22,158 --> 10:00:24,940
>> opc: all else being equal.

14388
10:00:24,940 --> 10:00:25,562
>> teco Witness: then I would

14389
10:00:25,562 --> 10:00:26,963
agree with you.

14390
10:00:26,963 --> 10:00:29,363
>> opc: looking at your

14391
10:00:30,301 --> 10:00:32,701
document number one your

14392
10:00:34,304 --> 10:00:36,704
exhibit 1 document number two

14393
10:00:47,170 --> 10:00:51,217
let me see if let's get there.

14394
10:00:52,623 --> 10:00:55,623
Okay, this shows the models

14395
10:01:00,864 --> 10:01:02,990
that you used for excuse me

14396
10:01:02,990 --> 10:01:03,000
preparation of your recommended

14397
10:01:03,000 --> 10:01:04,935
roe correct?

14398
10:01:04,935 --> 10:01:07,935
>> teco Witness: yes ma'am it

14399
10:01:15,790 --> 10:01:17,800
was superseded in my exhibit dw

14400
10:01:17,800 --> 10:01:18,148
d 2 my initial analysis is what

14401
10:01:18,148 --> 10:01:20,830
you are referring to.

14402
10:01:20,830 --> 10:01:21,317
>> opc: in other words this is

14403
10:01:21,317 --> 10:01:23,870
your 4 miles that you use with

14404
10:01:23,870 --> 10:01:24,354
your updated results.

14405
10:01:24,354 --> 10:01:26,223
>> teco Witness: the government

14406
10:01:26,223 --> 10:01:28,125
did not rely on the non-

14407
10:01:28,125 --> 10:01:29,259
regulated proxy group in this

14408
10:01:29,259 --> 10:01:31,128
case nor did I rely on the

14409
10:01:31,128 --> 10:01:32,262
pr/pm in this case. Just

14410
10:01:32,262 --> 10:01:34,197
predictive risk model.

14411
10:01:34,197 --> 10:01:34,431
>> opc: we will get that in the

14412
10:01:34,431 --> 10:01:36,431
second.

14413
10:01:36,766 --> 10:01:37,967
In this case you are

14414
10:01:37,967 --> 10:01:38,235
recommending a roe of 11.5 is

14415
10:01:38,235 --> 10:01:38,935
that

14416
10:01:38,935 --> 10:01:40,935
correct.

14417
10:01:47,760 --> 10:01:47,244
>> teco Witness: that is)

14418
10:01:47,244 --> 10:01:48,479
.

14419
10:01:48,479 --> 10:01:50,314
>> opc: you are recommending

14420
10:01:50,314 --> 10:01:52,315
the 11.5 a roe despite the

14421
10:01:52,315 --> 10:01:52,582
company's capital structure and

14422
10:01:52,582 --> 10:01:54,384
that cost.

14423
10:01:54,384 --> 10:01:56,352
>> teco Witness: despite?

14424
10:01:56,352 --> 10:01:59,952
I'm going to disagree with your

14425
10:02:02,493 --> 10:02:03,627
question. If you look at dw d1

14426
10:02:03,627 --> 10:02:05,495
or d to schedule a tour

14427
10:02:05,495 --> 10:02:07,431
document to the first thing you

14428
10:02:07,431 --> 10:02:09,333
do you look at your model

14429
10:02:09,333 --> 10:02:10,801
results then you compare them

14430
10:02:10,801 --> 10:02:14,401
with you compare teco with the

14431
10:02:15,372 --> 10:02:16,640
proxy group company.

14432
10:02:16,640 --> 10:02:18,441
To figure out whether or not

14433
10:02:18,441 --> 10:02:19,643
they have extremely risk or

14434
10:02:19,643 --> 10:02:23,243
not. When you look at lines 6

14435
10:02:28,952 --> 10:02:30,187
and seven on document number

14436
10:02:30,187 --> 10:02:32,890
two page number one. You will

14437
10:02:32,890 --> 10:02:34,240
see that the credit risk

14438
10:02:34,240 --> 10:02:36,260
adjustment on line 6 is a

14439
10:02:36,260 --> 10:02:37,260
negative risk adjustment. Based

14440
10:02:37,260 --> 10:02:38,128
on bond spreads.

14441
10:02:38,128 --> 10:02:39,996
Credit rating is a common

14442
10:02:39,996 --> 10:02:41,999
measurement of both business

14443
10:02:41,999 --> 10:02:43,660
and financial risk. Any type of

14444
10:02:43,660 --> 10:02:45,100
lower financial risk that the

14445
10:02:45,100 --> 10:02:48,100
company has like a higher

14446
10:02:48,138 --> 10:02:50,138
equity ratio would

14447
10:02:51,675 --> 10:02:54,675
>> opc: you would agree that

14448
10:02:55,879 --> 10:02:56,546
the negative credit risk

14449
10:02:56,546 --> 10:02:58,946
adjustment is your adjustment

14450
10:02:59,783 --> 10:03:03,383
because teco is less risky than

14451
10:03:04,188 --> 10:03:05,245
the proxy group that you chose,

14452
10:03:05,245 --> 10:03:05,354
correct?

14453
10:03:05,354 --> 10:03:08,354
>> teco Witness: as far as

14454
10:03:09,393 --> 10:03:10,394
credit risk, yes.

14455
10:03:10,394 --> 10:03:13,394
>> opc: in this document the

14456
10:03:15,298 --> 10:03:15,933
report to results for your

14457
10:03:15,933 --> 10:03:17,434
approaches is that correct?

14458
10:03:17,434 --> 10:03:19,434
>> yes.

14459
10:03:20,636 --> 10:03:22,973
When includes the prpm and one

14460
10:03:22,973 --> 10:03:24,973
excludes it.

14461
10:03:28,645 --> 10:03:29,313
>> opc: okay.

14462
10:03:29,313 --> 10:03:30,847
Now, looking at the column

14463
10:03:30,847 --> 10:03:33,847
which shows the results with

14464
10:03:34,618 --> 10:03:37,618
dep rpm which the commission

14465
10:03:37,754 --> 10:03:38,521
rejected previously, you would

14466
10:03:38,521 --> 10:03:40,921
agree that this commission

14467
10:03:41,925 --> 10:03:42,659
previously rejected the

14468
10:03:42,659 --> 10:03:44,729
approach because the results

14469
10:03:44,729 --> 10:03:45,228
could not be duplicated,

14470
10:03:45,228 --> 10:03:46,830
correct?

14471
10:03:46,830 --> 10:03:48,131
>> I do not agree.

14472
10:03:48,131 --> 10:03:51,131
I have given the commission

14473
10:03:51,468 --> 10:03:53,636
staff ample opportunity to

14474
10:03:53,636 --> 10:03:57,236
access my model and they have

14475
10:03:57,340 --> 10:04:00,444
not taken it up, or taken me up

14476
10:04:00,444 --> 10:04:02,444
on it.

14477
10:04:06,416 --> 10:04:06,616
In the people's case or in this

14478
10:04:06,616 --> 10:04:07,384
case.

14479
10:04:07,384 --> 10:04:07,651
>> opc: that was not the

14480
10:04:07,651 --> 10:04:08,919
question.

14481
10:04:08,919 --> 10:04:09,953
My question was whether the

14482
10:04:09,953 --> 10:04:12,353
commission rejected it because

14483
10:04:15,425 --> 10:04:16,590
they said they could not

14484
10:04:16,590 --> 10:04:16,560
duplicate the results.

14485
10:04:16,560 --> 10:04:17,527
Is that correct?

14486
10:04:17,527 --> 10:04:18,610
>> you will have to point me to

14487
10:04:18,610 --> 10:04:20,461
where it says that.

14488
10:04:22,310 --> 10:04:23,320
>> opc: looking at your range

14489
10:04:23,320 --> 10:04:24,735
of results with indicative

14490
10:04:24,735 --> 10:04:26,736
common equity and cost rate

14491
10:04:26,736 --> 10:04:28,736
before adjustments.

14492
10:04:31,641 --> 10:04:32,542
If you look further down

14493
10:04:32,542 --> 10:04:34,111
indicated in common equity cost

14494
10:04:34,111 --> 10:04:36,111
rate after adjustments.

14495
10:04:36,413 --> 10:04:38,915
those are your ranges based on

14496
10:04:38,915 --> 10:04:39,149
the four predictive models,

14497
10:04:39,149 --> 10:04:41,149
correct?

14498
10:04:41,985 --> 10:04:43,985
>> teco Witness: no.

14499
10:04:46,289 --> 10:04:47,156
I have it in my testimony.

14500
10:04:47,156 --> 10:04:47,657
I will just point to this

14501
10:04:47,657 --> 10:04:49,657
document instead.

14502
10:04:50,761 --> 10:04:54,361
If you look at line number 5,

14503
10:04:56,900 --> 10:04:57,300
it is the low number which is

14504
10:04:57,300 --> 10:04:59,300
the dcf model.

14505
10:05:02,506 --> 10:05:04,340
And the high model from the m

14506
10:05:04,340 --> 10:05:06,376
model does not contemplate or

14507
10:05:06,376 --> 10:05:09,976
use the fourth line which is

14508
10:05:11,914 --> 10:05:12,114
the market models comparable

14509
10:05:12,114 --> 10:05:14,114
risk.

14510
10:05:15,752 --> 10:05:19,352
It is the three models, the

14511
10:05:20,857 --> 10:05:23,126
dcf, the risk premium model.

14512
10:05:23,126 --> 10:05:26,126
>> opc: with that caveat that

14513
10:05:26,930 --> 10:05:27,764
the market model is applied,

14514
10:05:27,764 --> 10:05:29,764
nonprice regulated companies

14515
10:05:30,233 --> 10:05:31,134
were rooted from that range.

14516
10:05:31,134 --> 10:05:34,134
That the range of results

14517
10:05:35,972 --> 10:05:36,573
online five and then further

14518
10:05:36,573 --> 10:05:38,108
down with your other

14519
10:05:38,108 --> 10:05:41,108
adjustments, those would be the

14520
10:05:41,344 --> 10:05:41,578
results from the remodel

14521
10:05:41,578 --> 10:05:42,780
correct?

14522
10:05:42,780 --> 10:05:44,780
>> teco Witness: yes.

14523
10:05:48,551 --> 10:05:50,320
That is correct.

14524
10:05:50,320 --> 10:05:53,920
In that range without dep rmp

14525
10:05:54,791 --> 10:05:57,791
is with your adjustments as 9.9

14526
10:05:57,861 --> 10:05:59,861
to 12.42 correct?

14527
10:06:01,564 --> 10:06:01,798
>> teco Witness: yes.

14528
10:06:01,798 --> 10:06:03,798
Correct.

14529
10:06:07,537 --> 10:06:08,305
>> opc: isn't it true that your

14530
10:06:08,305 --> 10:06:11,305
recommended roe is above this

14531
10:06:18,214 --> 10:06:18,848
range which would be 11.16?

14532
10:06:18,848 --> 10:06:19,749
>> teco Witness: yes.

14533
10:06:19,749 --> 10:06:20,784
But I did explain why went

14534
10:06:20,784 --> 10:06:21,510
above the range in my rebuttal

14535
10:06:21,510 --> 10:06:21,618
testimony.

14536
10:06:21,618 --> 10:06:22,318
Believe it is

14537
10:06:22,318 --> 10:06:22,518
easier to show you on the

14538
10:06:22,518 --> 10:06:24,518
graph.

14539
10:06:27,691 --> 10:06:31,291
If you would turn to exhibit

14540
10:06:44,407 --> 10:06:46,800
dwd to.

14541
10:06:46,800 --> 10:06:48,408
>> teco Witness: I disagree.

14542
10:06:48,611 --> 10:06:52,582
You asked how it was and I am

14543
10:06:52,582 --> 10:06:54,982
explaining why it was.

14544
10:06:55,418 --> 10:06:58,418
>> teco Attorney: let's move on

14545
10:07:09,899 --> 10:07:10,834
to the next question.

14546
10:07:10,834 --> 10:07:14,434
Would you agree that teco has

14547
10:07:25,800 --> 10:07:27,283
not paid any location cost?

14548
10:07:27,283 --> 10:07:27,984
>> teco Witness: when you talk

14549
10:07:27,984 --> 10:07:30,384
about flotation cost equity

14550
10:07:36,926 --> 10:07:37,360
that's is infused has flotation

14551
10:07:37,360 --> 10:07:37,961
costs.

14552
10:07:37,961 --> 10:07:39,863
And they have to be returned

14553
10:07:39,863 --> 10:07:40,529
back or they will not be able

14554
10:07:40,529 --> 10:07:43,529
to attract the capital that

14555
10:07:45,340 --> 10:07:46,169
they are supposed to.

14556
10:07:46,169 --> 10:07:49,769
>> so the answer to my question

14557
10:07:50,406 --> 10:07:52,406
is no.

14558
10:07:57,280 --> 10:07:58,348
>> teco Witness: yes.

14559
10:07:58,348 --> 10:07:59,249
But when you're talking about

14560
10:07:59,249 --> 10:07:59,949
the cost of capital you have to

14561
10:07:59,949 --> 10:08:01,517
cover the flotation costs from

14562
10:08:01,517 --> 10:08:02,351
the parent company.

14563
10:08:02,351 --> 10:08:06,155
If you do not, they will not

14564
10:08:06,155 --> 10:08:06,456
get their full return on

14565
10:08:06,456 --> 10:08:07,156
investment.

14566
10:08:07,156 --> 10:08:10,156
>> so, and other words the

14567
10:08:11,593 --> 10:08:12,594
flotation cost that you have

14568
10:08:12,594 --> 10:08:14,230
included are costs that they

14569
10:08:14,230 --> 10:08:17,200
have for issuing stock on their

14570
10:08:17,200 --> 10:08:18,701
behalf correct?

14571
10:08:18,701 --> 10:08:21,101
>> teco Witness: the flotation

14572
10:08:24,974 --> 10:08:27,100
cost which you are including in

14573
10:08:27,100 --> 10:08:31,210
this as an adjustment is a cost

14574
10:08:35,885 --> 10:08:39,485
that is born by the company.

14575
10:08:41,891 --> 10:08:42,859
>> teco Witness: not exactly.

14576
10:08:42,859 --> 10:08:45,829
When we issue the stock, they

14577
10:08:45,829 --> 10:08:47,829
incur costs.

14578
10:08:47,931 --> 10:08:48,164
When it is in the form of a

14579
10:08:48,164 --> 10:08:50,164
percent.

14580
10:08:51,901 --> 10:08:54,636
If you take a look and this is

14581
10:08:54,636 --> 10:08:56,506
where I have to explain this.

14582
10:08:56,506 --> 10:09:00,106
If you look at document number

14583
10:09:03,512 --> 10:09:05,810
9 page 1 then you will see the

14584
10:09:05,810 --> 10:09:07,810
issuances.

14585
10:09:09,852 --> 10:09:10,753
Those issuances like I said

14586
10:09:10,753 --> 10:09:14,353
document nine page one of one.

14587
10:09:16,792 --> 10:09:17,427
The flotation costs are

14588
10:09:17,427 --> 10:09:18,294
expressed in percent.

14589
10:09:18,294 --> 10:09:19,361
So it is two percent of what

14590
10:09:19,361 --> 10:09:21,761
the net proceeds are.

14591
10:09:24,934 --> 10:09:25,635
>> teco Attorney: can I ask a

14592
10:09:25,635 --> 10:09:27,300
question and get him to answer

14593
10:09:27,300 --> 10:09:29,403
a yes, sir no?

14594
10:09:31,541 --> 10:09:31,807
>> opc: please restate the

14595
10:09:31,807 --> 10:09:33,807
question.

14596
10:09:34,911 --> 10:09:35,811
>> teco Attorney: is a correct

14597
10:09:35,811 --> 10:09:38,140
that they are issuing stock at

14598
10:09:38,140 --> 10:09:40,140
their level?

14599
10:09:43,286 --> 10:09:44,287
>> teco Witness: yes.

14600
10:09:44,287 --> 10:09:44,921
>> teco Attorney: thank you.

14601
10:09:44,921 --> 10:09:45,989
I'll move on.

14602
10:09:45,989 --> 10:09:47,989
He highest roe

14603
10:09:49,625 --> 10:09:52,250
is 12.9 percent for your

14604
10:09:53,696 --> 10:09:55,696
nonregulated group, correct?

14605
10:09:57,300 --> 10:09:59,700
>> teco Witness: it is 12.95.

14606
10:10:00,269 --> 10:10:01,203
>> okay.

14607
10:10:01,203 --> 10:10:02,710
You did not include that in

14608
10:10:02,710 --> 10:10:04,710
your range correct?

14609
10:10:09,779 --> 10:10:10,813
>> I did not.

14610
10:10:10,813 --> 10:10:11,814
>> looking at document three,

14611
10:10:11,814 --> 10:10:14,283
your cash flow model is 9.89

14612
10:10:14,283 --> 10:10:15,184
percent, correct?

14613
10:10:15,184 --> 10:10:17,153
>> teco Witness: it is

14614
10:10:17,153 --> 10:10:17,420
superseded by my rebuttal

14615
10:10:17,420 --> 10:10:18,721
testimony.

14616
10:10:18,721 --> 10:10:18,954
And that result is 10.29

14617
10:10:18,954 --> 10:10:20,954
percent.

14618
10:10:28,931 --> 10:10:29,799
If you look up dwd, a

14619
10:10:29,799 --> 10:10:32,199
discounted model using updated

14620
10:10:35,671 --> 10:10:37,671
data is 10.29 percent.

14621
10:10:37,807 --> 10:10:41,407
This model does not require you

14622
10:10:44,881 --> 10:10:47,281
to estimate risk, correct?

14623
10:10:47,617 --> 10:10:51,217
>> the risk is in the stock

14624
10:10:52,288 --> 10:10:52,655
prices which runs in the

14625
10:10:52,655 --> 10:10:54,623
dividend yield.

14626
10:10:54,623 --> 10:10:57,293
I am not estimating risk.

14627
10:10:57,293 --> 10:11:00,763
It is estimated in the price

14628
10:11:00,763 --> 10:11:00,963
that we used to calculate the

14629
10:11:00,963 --> 10:11:02,963
model.

14630
10:11:05,868 --> 10:11:06,803
>> teco Attorney: so I believe

14631
10:11:06,803 --> 10:11:07,103
the answer to my question is

14632
10:11:07,103 --> 10:11:09,103
yes.

14633
10:11:11,474 --> 10:11:12,441
You did not calculate risk.

14634
10:11:12,441 --> 10:11:13,509
>> teco Witness: the point of

14635
10:11:13,509 --> 10:11:16,679
every cost of capital model is

14636
10:11:16,679 --> 10:11:20,879
to get a measure of risk to

14637
10:11:21,284 --> 10:11:22,185
have a return on the risk.

14638
10:11:22,185 --> 10:11:25,588
So, in that aspect the answer

14639
10:11:25,588 --> 10:11:27,588
is yes.

14640
10:11:28,570 --> 10:11:28,758
>> teco Attorney: your two

14641
10:11:28,758 --> 10:11:31,758
highest results are for your

14642
10:11:31,761 --> 10:11:31,993
risk premium model, is that

14643
10:11:31,993 --> 10:11:33,993
correct?

14644
10:11:41,700 --> 10:11:42,105
>> teco Witness: yes.

14645
10:11:42,105 --> 10:11:43,390
>> teco Attorney: and in both

14646
10:11:43,390 --> 10:11:47,839
of those you had to give a risk

14647
10:11:51,414 --> 10:11:51,647
premium for those is that

14648
10:11:51,647 --> 10:11:52,148
correct?

14649
10:11:52,148 --> 10:11:53,150
>> teco Witness: yes.

14650
10:11:53,150 --> 10:11:54,830
>> teco Attorney: you would

14651
10:11:54,830 --> 10:11:54,650
agree that the 30 year treasury

14652
10:11:54,650 --> 10:11:55,885
is about 4.61 percent.

14653
10:11:55,885 --> 10:11:57,885
Is that current?

14654
10:11:58,821 --> 10:12:00,422
>> it is not.

14655
10:12:00,422 --> 10:12:02,858
>> what is the current 30 year

14656
10:12:02,858 --> 10:12:04,858
treasury yield?

14657
10:12:06,796 --> 10:12:09,796
>> I believe it is around 4.2.

14658
10:12:10,266 --> 10:12:13,266
It is generally around her

14659
10:12:16,606 --> 10:12:18,606
projected interest rates.

14660
10:12:20,420 --> 10:12:22,244
So, it is not, the current

14661
10:12:22,244 --> 10:12:25,244
interest rate sometimes is not

14662
10:12:25,548 --> 10:12:28,548
as accurate or applicable as

14663
10:12:32,321 --> 10:12:33,256
the others.

14664
10:12:33,256 --> 10:12:33,923
>> teco Attorney: you would

14665
10:12:33,923 --> 10:12:36,558
agree that the 30 year treasury

14666
10:12:36,558 --> 10:12:39,558
yield is down about five

14667
10:12:41,364 --> 10:12:41,597
percent from earlier this year

14668
10:12:41,597 --> 10:12:42,970
correct?

14669
10:12:42,970 --> 10:12:43,990
>> teco Witness: yes.

14670
10:12:43,990 --> 10:12:46,569
But it is up one percent from

14671
10:12:46,569 --> 10:12:47,903
the pandemic.

14672
10:12:47,903 --> 10:12:48,404
>> teco Attorney: and you have

14673
10:12:48,404 --> 10:12:49,138
included a credit risk

14674
10:12:49,138 --> 10:12:49,405
adjustment for your roe

14675
10:12:49,405 --> 10:12:50,172
correct:

14676
10:12:50,172 --> 10:12:52,572
>> teco Witness: that is

14677
10:13:04,787 --> 10:13:05,454
correct.

14678
10:13:05,454 --> 10:13:06,321
>> teco Attorney: would you

14679
10:13:06,321 --> 10:13:08,524
have any reason to disagree

14680
10:13:08,524 --> 10:13:12,495
with me if I said, are you

14681
10:13:12,495 --> 10:13:15,197
aware that the commission has

14682
10:13:15,197 --> 10:13:17,597
recently approved a 10.3 rop

14683
10:13:19,935 --> 10:13:20,169
for duke energy operating in

14684
10:13:20,169 --> 10:13:22,169
florida?

14685
10:13:32,948 --> 10:13:33,215
>> MR. CHAIRMAN, same

14686
10:13:33,215 --> 10:13:35,215
objection.

14687
10:13:45,428 --> 10:13:46,429
Which is f21 6124.

14688
10:13:46,429 --> 10:13:47,296
This is opc's exhibit of the rr

14689
10:13:47,296 --> 10:13:49,696
inventory of awarded and

14690
10:13:53,869 --> 10:13:54,904
historic roe's.

14691
10:13:54,904 --> 10:13:57,904
>> MR. CHAIRMAN, I would object

14692
10:13:59,800 --> 10:13:59,674
to this as showing out-of-state

14693
10:13:59,674 --> 10:14:00,875
decisions that are irrelevant

14694
10:14:00,875 --> 10:14:02,875
in this matter.

14695
10:14:03,779 --> 10:14:06,779
i request other utilities that

14696
10:14:07,983 --> 10:14:08,751
fit these conditions.

14697
10:14:08,751 --> 10:14:11,751
>> not the kind that this

14698
10:14:15,791 --> 10:14:17,126
commission considers.

14699
10:14:17,126 --> 10:14:17,592
>> one, I think we've already

14700
10:14:17,592 --> 10:14:19,592
admitted the exhibit.

14701
10:14:20,562 --> 10:14:21,297
Two, the gentleman is actually

14702
10:14:21,297 --> 10:14:24,297
estimating roe's based on what

14703
10:14:29,271 --> 10:14:29,571
the market will actually hold

14704
10:14:29,571 --> 10:14:30,506
and approve.

14705
10:14:30,506 --> 10:14:33,506
And what kind of competition

14706
10:14:34,376 --> 10:14:35,111
for capital that teco would

14707
10:14:35,111 --> 10:14:38,111
have to be up against.

14708
10:14:45,353 --> 10:14:46,540
In fact, approved roe's are

14709
10:14:46,540 --> 10:14:46,555
extremely relevant information.

14710
10:14:46,555 --> 10:14:47,422
He is the witness.

14711
10:14:47,422 --> 10:14:48,557
So he would be the person to

14712
10:14:48,557 --> 10:14:50,957
ask about this information.

14713
10:14:53,195 --> 10:14:53,662
I do think it is highly

14714
10:14:53,662 --> 10:14:54,263
relevant.

14715
10:14:54,263 --> 10:14:57,263
>> and this was entered into

14716
10:14:58,501 --> 10:15:00,501
the record.

14717
10:15:04,473 --> 10:15:08,730
>> this is the exhibit that MR.

14718
10:15:15,116 --> 10:15:16,151
Weiland took issue with.

14719
10:15:16,151 --> 10:15:19,151
>> could I approach the witness

14720
10:15:20,589 --> 10:15:22,124
and provide him a copy with of

14721
10:15:22,124 --> 10:15:24,124
this.

14722
10:15:25,594 --> 10:15:26,161
>> approved.

14723
10:15:26,161 --> 10:15:28,764
>> could we have a couple

14724
10:15:28,764 --> 10:15:29,798
minutes to confer with the

14725
10:15:29,798 --> 10:15:30,299
staff who deals with this on a

14726
10:15:30,299 --> 10:15:32,299
regular basis?

14727
10:15:35,236 --> 10:15:35,737
That would not be me.

14728
10:15:35,737 --> 10:15:37,737
>> absolutely.

14729
10:17:20,342 --> 10:17:22,742
Let's take three minutes.

14730
10:22:03,658 --> 10:22:04,992
>> just rehashing a little bit

14731
10:22:04,992 --> 10:22:06,992
of all discussion.

14732
10:22:08,429 --> 10:22:10,429
Let's reconvene.

14733
10:22:10,932 --> 10:22:15,132
And I will go to marianne on

14734
10:22:15,904 --> 10:22:17,305
what we just discussed.

14735
10:22:17,305 --> 10:22:19,705
>> thank you MR. CHAIRMAN.

14736
10:22:25,146 --> 10:22:26,130
My suggestion is to go forward

14737
10:22:26,130 --> 10:22:26,681
and allow MS. Christiansen to

14738
10:22:26,681 --> 10:22:29,681
ask a couple of questions.

14739
10:22:30,151 --> 10:22:33,751
From there, I think you can

14740
10:22:35,991 --> 10:22:36,891
determine whether we think that

14741
10:22:36,891 --> 10:22:39,891
the questions are relevant to

14742
10:22:42,797 --> 10:22:43,698
this proceeding in the way that

14743
10:22:43,698 --> 10:22:44,599
this commission sets the rotc

14744
10:22:44,599 --> 10:22:47,869
based on the filings that have

14745
10:22:47,869 --> 10:22:48,837
been made.

14746
10:22:48,837 --> 10:22:51,237
>> commissioner, MAY I be

14747
10:22:53,974 --> 10:22:54,208
briefly heard?

14748
10:22:54,208 --> 10:22:55,843
>> yes.

14749
10:22:55,843 --> 10:22:58,243
In order number pse 2023 038

14750
10:23:01,749 --> 10:23:03,749
eight fo

14751
10:23:05,286 --> 10:23:07,286
, the rate proceeding

14752
10:23:09,157 --> 10:23:12,157
on page 71 and the conclusion

14753
10:23:17,965 --> 10:23:18,500
staff indicated that it relied

14754
10:23:18,500 --> 10:23:20,500
on, I apologize.

14755
10:23:24,505 --> 10:23:25,473
The commission relied on the

14756
10:23:25,473 --> 10:23:27,873
national average of awarded

14757
10:23:27,942 --> 10:23:29,942
roadies of approximately 9.5

14758
10:23:36,283 --> 10:23:37,510
percent and should enable us to

14759
10:23:37,510 --> 10:23:37,751
enable the cash flow for

14760
10:23:37,751 --> 10:23:38,586
near-term financial obligations

14761
10:23:38,586 --> 10:23:39,621
and make the capital

14762
10:23:39,621 --> 10:23:41,289
investments needed to maintain

14763
10:23:41,289 --> 10:23:43,689
expanded systems to fund

14764
10:23:44,425 --> 10:23:46,825
unexpected events and sustained

14765
10:23:55,300 --> 10:23:56,360
confidence in florida's

14766
10:23:56,360 --> 10:23:57,500
regulatory environment among

14767
10:23:57,500 --> 10:23:57,271
the created agencies and

14768
10:23:57,271 --> 10:23:58,206
investors.

14769
10:23:58,206 --> 10:23:59,140
This is the type of information

14770
10:23:59,140 --> 10:24:00,174
that this commission has relied

14771
10:24:00,174 --> 10:24:03,174
on to make a recommendation.

14772
10:24:04,912 --> 10:24:07,348
I would suggest that this is

14773
10:24:07,348 --> 10:24:09,348
highly relevant information.

14774
10:24:10,985 --> 10:24:12,200
I am sure if the company

14775
10:24:12,200 --> 10:24:12,654
believes that we are being

14776
10:24:12,654 --> 10:24:15,540
repetitive they can certainly

14777
10:24:17,725 --> 10:24:18,493
make whatever interjections

14778
10:24:18,493 --> 10:24:21,362
they like at the time.

14779
10:24:21,362 --> 10:24:22,330
But I believe I should be given

14780
10:24:22,330 --> 10:24:25,330
the leeway necessary to explore

14781
10:24:27,535 --> 10:24:28,202
this relevant information.

14782
10:24:28,202 --> 10:24:30,939
>> I will not respond by saying

14783
10:24:30,939 --> 10:24:31,773
this is in the record.

14784
10:24:31,773 --> 10:24:35,973
If we want to spend the next

14785
10:24:38,947 --> 10:24:39,981
three hours having our witness

14786
10:24:39,981 --> 10:24:41,616
questions about what ever other

14787
10:24:41,616 --> 10:24:44,160
information they have about

14788
10:24:47,355 --> 10:24:47,554
other states, I guess we can do

14789
10:24:47,554 --> 10:24:48,355
that.

14790
10:24:48,355 --> 10:24:50,580
But we are trying to move this

14791
10:24:50,580 --> 10:24:52,580
thing along.

14792
10:24:55,562 --> 10:24:55,730
I know it does not feel like

14793
10:24:55,730 --> 10:24:56,564
it.

14794
10:24:56,564 --> 10:24:57,165
But the commission has

14795
10:24:57,165 --> 10:24:59,165
historically relied primarily

14796
10:24:59,767 --> 10:25:03,367
on the models and the models

14797
10:25:04,472 --> 10:25:08,720
are not based on returns or

14798
10:25:11,450 --> 10:25:11,612
requested returns.

14799
10:25:11,612 --> 10:25:12,512
This is in the record.

14800
10:25:12,512 --> 10:25:13,414
I hope we do not have to go

14801
10:25:13,414 --> 10:25:15,283
line by line through every one

14802
10:25:15,283 --> 10:25:15,950
of these decisions and talk

14803
10:25:15,950 --> 10:25:17,950
about it.

14804
10:25:19,721 --> 10:25:19,988
I was asked yesterday to object

14805
10:25:19,988 --> 10:25:21,988
to early.

14806
10:25:22,957 --> 10:25:26,127
So that is what I am doing.

14807
10:25:26,127 --> 10:25:27,962
>> okay.

14808
10:25:27,962 --> 10:25:28,162
I will allow the questions to

14809
10:25:28,162 --> 10:25:30,162
start.

14810
10:25:31,799 --> 10:25:33,768
We will take the direction and

14811
10:25:33,768 --> 10:25:34,680
see how relevant they are in

14812
10:25:34,680 --> 10:25:36,680
comparison.

14813
10:25:38,740 --> 10:25:38,973
And of course how the witness

14814
10:25:38,973 --> 10:25:40,973
answers.

14815
10:25:43,100 --> 10:25:43,211
I will allow questions to

14816
10:25:43,211 --> 10:25:44,145
begin.

14817
10:25:44,145 --> 10:25:46,848
>> MAY I approach the witness

14818
10:25:46,848 --> 10:25:47,247
to give him the larger copy?

14819
10:25:47,247 --> 10:25:49,247
>> yes.

14820
10:25:56,657 --> 10:25:57,591
Thank you.

14821
10:25:57,591 --> 10:26:00,591
Are you familiar with smp's

14822
10:26:05,660 --> 10:26:07,466
capital iq rate history?

14823
10:26:10,705 --> 10:26:11,639
>> yes.

14824
10:26:11,639 --> 10:26:13,173
>> and you would agree this is

14825
10:26:13,173 --> 10:26:15,573
the summary of awarded

14826
10:26:16,644 --> 10:26:17,611
summaries by smp.

14827
10:26:17,611 --> 10:26:18,313
Otherwise you are generally

14828
10:26:18,313 --> 10:26:20,713
familiar with the content,

14829
10:26:20,748 --> 10:26:21,549
correct?

14830
10:26:21,549 --> 10:26:22,750
>> I have not gotten through

14831
10:26:22,750 --> 10:26:24,750
the entire document.

14832
10:26:27,554 --> 10:26:27,755
Is there pending roe's, further

14833
10:26:27,755 --> 10:26:29,755
down?

14834
10:26:39,166 --> 10:26:42,766
>> looking at page I think it

14835
10:26:46,540 --> 10:26:46,807
is the last page of the

14836
10:26:46,807 --> 10:26:48,807
document.

14837
10:26:50,278 --> 10:26:52,846
This list of pending cases.

14838
10:26:52,846 --> 10:26:55,246
Do you see that?

14839
10:26:57,885 --> 10:26:58,786
>> sure.

14840
10:26:58,786 --> 10:27:01,389
>> there are cases listed there

14841
10:27:01,389 --> 10:27:01,922
for pennsylvania electric and

14842
10:27:01,922 --> 10:27:03,922
pennsylvania power.

14843
10:27:05,159 --> 10:27:05,359
O you see

14844
10:27:05,359 --> 10:27:07,359
those?

14845
10:27:08,896 --> 10:27:13,960
>> do you mean the next next to

14846
10:27:15,769 --> 10:27:16,300
the last page?

14847
10:27:16,300 --> 10:27:16,770
>> yes.

14848
10:27:16,770 --> 10:27:19,974
Do you see that there is a

14849
10:27:19,974 --> 10:27:20,141
request for an 11.3 percent are

14850
10:27:20,141 --> 10:27:20,374
oe?

14851
10:27:20,374 --> 10:27:22,374
>> yes.

14852
10:27:24,879 --> 10:27:25,780
I am the witness in that case.

14853
10:27:25,780 --> 10:27:26,848
>> so you are the witness in

14854
10:27:26,848 --> 10:27:28,848
those cases.

14855
10:27:31,552 --> 10:27:31,719
Are you also the witness in

14856
10:27:31,719 --> 10:27:33,719
the.

14857
10:27:39,827 --> 10:27:41,827
[Listing names] Case?

14858
10:27:46,320 --> 10:27:48,320
>> no.

14859
10:27:50,705 --> 10:27:51,271
Do you know.

14860
10:27:51,271 --> 10:27:53,271
[Listing names]?

14861
10:27:55,750 --> 10:27:56,100
>> professionally, yes.

14862
10:27:56,100 --> 10:27:57,878
>> and are you closely aligned

14863
10:27:57,878 --> 10:28:00,878
with him in providing these

14864
10:28:03,184 --> 10:28:06,184
roe's on behalf of the

14865
10:28:07,269 --> 10:28:07,402
utilities?

14866
10:28:07,402 --> 10:28:08,823
>> I disagree with everything

14867
10:28:08,823 --> 10:28:09,557
you just said.

14868
10:28:09,557 --> 10:28:12,557
>> in 2020 when did you conduct

14869
10:28:14,228 --> 10:28:17,828
his testimony in a kentucky ray

14870
10:28:20,340 --> 10:28:20,668
case?

14871
10:28:20,668 --> 10:28:24,868
>> he was in a coma and the

14872
10:28:26,440 --> 10:28:26,974
company reached out for me to

14873
10:28:26,974 --> 10:28:30,574
do what was it, it was

14874
10:28:30,978 --> 10:28:31,812
discovery responses.

14875
10:28:31,812 --> 10:28:34,148
So no I did not adopt his

14876
10:28:34,148 --> 10:28:35,349
testimony nor defendant.

14877
10:28:35,349 --> 10:28:38,949
While he was in the hospital

14878
10:28:41,188 --> 10:28:42,189
recovering, I did the right

14879
10:28:42,189 --> 10:28:45,189
thing and gave responses to

14880
10:28:45,559 --> 10:28:45,760
discovery for a client that we

14881
10:28:45,760 --> 10:28:47,760
share.

14882
10:28:52,266 --> 10:28:54,266
>> okay.

14883
10:29:01,909 --> 10:29:02,777
One moment please.

14884
10:29:02,777 --> 10:29:05,880
I think that MAY be all the

14885
10:29:05,880 --> 10:29:06,112
questions I have for this

14886
10:29:06,112 --> 10:29:08,112
exhibit.

14887
10:29:49,789 --> 10:29:49,990
There MAY be others.

14888
10:29:49,990 --> 10:29:50,190
Sure.

14889
10:29:50,190 --> 10:29:52,190
Okay.

14890
10:29:54,528 --> 10:29:54,761
Are we ready again?

14891
10:29:54,761 --> 10:29:55,595
>> yes.

14892
10:29:55,595 --> 10:29:58,595
>> would you agree that the

14893
10:30:01,401 --> 10:30:02,336
florida commission has made roe

14894
10:30:02,336 --> 10:30:05,336
rewards that are higher than

14895
10:30:05,405 --> 10:30:05,640
the national average?

14896
10:30:05,640 --> 10:30:06,507
>> yes.

14897
10:30:06,507 --> 10:30:10,707
I would like to take some time

14898
10:30:10,710 --> 10:30:11,445
and talk about that.

14899
10:30:11,445 --> 10:30:13,445
>> I will object.

14900
10:30:13,714 --> 10:30:16,714
This is going well beyond.

14901
10:30:23,591 --> 10:30:24,225
I did not even ask him the

14902
10:30:24,225 --> 10:30:24,858
question.

14903
10:30:24,858 --> 10:30:25,559
>> would you agree that doctor

14904
10:30:25,559 --> 10:30:25,892
woolrich has recommended a roe

14905
10:30:25,892 --> 10:30:27,892
of 9.54 teco?

14906
10:30:31,970 --> 10:30:34,970
>> yes, in this case, yes.

14907
10:30:36,704 --> 10:30:37,404
>> isn't it true that on page 9

14908
10:30:37,404 --> 10:30:40,404
of your direct testimony, line

14909
10:30:41,709 --> 10:30:42,275
14 that you acknowledged that

14910
10:30:42,275 --> 10:30:44,675
authorized roe's, I believe

14911
10:30:44,879 --> 10:30:47,879
this is actually on your

14912
10:30:50,183 --> 10:30:52,183
rebuttal testimony.

14913
10:30:56,990 --> 10:30:57,991
>> yes, ma'am, I am there.

14914
10:30:57,991 --> 10:30:58,926
>> looking at line 14 which you

14915
10:30:58,926 --> 10:31:00,926
acknowledged that authorized

14916
10:31:08,969 --> 10:31:09,803
roe's are reasonable benchmarks

14917
10:31:09,803 --> 10:31:10,504
of acceptable roe's?

14918
10:31:10,504 --> 10:31:11,438
>> the end of the sentence says

14919
10:31:11,438 --> 10:31:12,500
they do not reflect the current

14920
10:31:12,500 --> 10:31:14,405
cost of common equity.

14921
10:31:16,810 --> 10:31:17,745
>> if you go to the top of the

14922
10:31:17,745 --> 10:31:21,345
next page, you then claim that

14923
10:31:24,351 --> 10:31:24,985
simple comparisons of roe are

14924
10:31:24,985 --> 10:31:26,953
of little value, correct?

14925
10:31:26,953 --> 10:31:27,187
>> yes, ma'am. They are not

14926
10:31:27,187 --> 10:31:29,187
timely.

14927
10:31:31,910 --> 10:31:32,526
They do not reflect the risks

14928
10:31:32,526 --> 10:31:32,793
of the specific companies

14929
10:31:32,793 --> 10:31:34,793
involved.

14930
10:31:37,597 --> 10:31:40,833
Some of these, if we want to go

14931
10:31:40,833 --> 10:31:45,330
back to this, you could take a

14932
10:31:49,900 --> 10:31:50,900
look and see that you have

14933
10:31:50,900 --> 10:31:53,900
companies that start their rate

14934
10:31:54,580 --> 10:31:54,189
case in 2020 and do not get

14935
10:31:54,189 --> 10:31:56,189
resolved until 2022 or 2023.

14936
10:31:57,384 --> 10:32:00,984
Even though the data MAY seem

14937
10:32:01,788 --> 10:32:02,220
recent, it is not recent nor

14938
10:32:02,220 --> 10:32:02,956
timely.

14939
10:32:02,956 --> 10:32:06,556
>> I believe he is going past

14940
10:32:14,368 --> 10:32:15,302
the questions.

14941
10:32:15,302 --> 10:32:17,637
>> do you know what the most

14942
10:32:17,637 --> 10:32:20,370
recently authorized roe was?

14943
10:32:20,340 --> 10:32:22,340
>> fully litigated?

14944
10:32:24,393 --> 10:32:24,524
>> no.

14945
10:32:24,524 --> 10:32:25,812
settled.

14946
10:32:25,812 --> 10:32:27,812
>> objection.

14947
10:32:30,184 --> 10:32:32,184
>> sustained.

14948
10:32:35,210 --> 10:32:37,210
>> hold on.

14949
10:32:38,792 --> 10:32:39,260
Can I have just a moment

14950
10:32:39,260 --> 10:32:39,392
please?

14951
10:32:39,392 --> 10:32:41,392
>> sure.

14952
10:35:32,365 --> 10:35:34,765
Let's take two minutes.

14953
10:35:37,571 --> 10:35:39,571
>> MR. CHAIRMAN?

14954
10:35:44,177 --> 10:35:46,177
Yes, sir?

14955
10:35:49,249 --> 10:35:52,249
>> public council is in a

14956
10:35:53,686 --> 10:35:54,621
difficult spot.

14957
10:35:54,621 --> 10:35:56,556
We asked the question and we

14958
10:35:56,556 --> 10:35:57,390
were given an answer.

14959
10:35:57,390 --> 10:36:00,927
We have a document from the

14960
10:36:00,927 --> 10:36:02,161
state of kentucky, in order

14961
10:36:02,161 --> 10:36:05,161
that shows that the witness's

14962
10:36:05,498 --> 10:36:07,667
statement was inconsistent with

14963
10:36:07,667 --> 10:36:10,667
the state of kentucky's order.

14964
10:36:11,700 --> 10:36:14,670
We have no way of impeaching

14965
10:36:17,311 --> 10:36:19,311
the witness.

14966
10:36:19,545 --> 10:36:22,715
We have advised council for the

14967
10:36:22,715 --> 10:36:25,115
company about the situation.

14968
10:36:25,652 --> 10:36:29,852
It is a serious matter and we

14969
10:36:33,250 --> 10:36:33,192
need to get to the bottom of

14970
10:36:33,192 --> 10:36:34,270
it.

14971
10:36:34,270 --> 10:36:37,630
>> we are happy to have them

14972
10:36:37,630 --> 10:36:37,997
read the order to him.

14973
10:36:37,997 --> 10:36:41,568
He can answer if he thinks that

14974
10:36:41,568 --> 10:36:42,168
is what happened.

14975
10:36:42,168 --> 10:36:45,768
This is not a big deal.

14976
10:36:46,439 --> 10:36:47,406
We are not going to get hung up

14977
10:36:47,406 --> 10:36:50,310
on whether or not the document

14978
10:36:50,310 --> 10:36:52,710
is in case center.

14979
10:36:54,713 --> 10:36:57,713
>> we heard testimony that did

14980
10:36:58,818 --> 10:36:59,819
not adopt testimony.

14981
10:36:59,819 --> 10:37:03,419
When he said that, we abandoned

14982
10:37:12,798 --> 10:37:12,965
a plot of questioning about

14983
10:37:12,965 --> 10:37:14,965
321.

14984
10:37:16,803 --> 10:37:17,837
I don't know if it's possible

14985
10:37:17,837 --> 10:37:19,505
here to get a court reporter to

14986
10:37:19,505 --> 10:37:21,905
read the question back.

14987
10:37:27,580 --> 10:37:28,481
But this is a serious matter.

14988
10:37:28,481 --> 10:37:30,683
>> I have suggested that they

14989
10:37:30,683 --> 10:37:33,683
just ask about the order.

14990
10:37:37,590 --> 10:37:38,558
And then see what happens.

14991
10:37:38,558 --> 10:37:42,758
>> I will go to my advisor from

14992
10:37:47,233 --> 10:37:48,267
a procedural position.

14993
10:37:48,267 --> 10:37:51,267
>> MR. Wallin, as I understand

14994
10:37:51,904 --> 10:37:52,572
it has offered to allow

14995
10:37:52,572 --> 10:37:54,572
cross-examination about the

14996
10:37:57,610 --> 10:37:59,178
order from kentucky.

14997
10:37:59,178 --> 10:38:03,883
It seems to me that we could go

14998
10:38:03,883 --> 10:38:06,283
forward on that way.

14999
10:38:09,121 --> 10:38:09,789
Do we need to stop and make a

15000
10:38:09,789 --> 10:38:13,389
couple of copies of the order

15001
10:38:15,294 --> 10:38:15,528
for people to have it?

15002
10:38:15,528 --> 10:38:17,196
>> okay.

15003
10:38:17,196 --> 10:38:19,465
>> so, procedurally they will

15004
10:38:19,465 --> 10:38:22,465
make the copies is there

15005
10:38:26,472 --> 10:38:28,908
anything else that we need?

15006
10:38:28,908 --> 10:38:31,908
Should we awake the copies?

15007
10:38:34,647 --> 10:38:35,348
>> before we do that, is there

15008
10:38:35,348 --> 10:38:36,582
anything else that we need to

15009
10:38:36,582 --> 10:38:36,749
do to instruct during this time

15010
10:38:36,749 --> 10:38:38,749
out?

15011
10:38:39,952 --> 10:38:40,820
>> not that I am aware of.

15012
10:38:40,820 --> 10:38:45,200
I'm not sure if anyone else has

15013
10:38:45,657 --> 10:38:46,592
the suggestion.

15014
10:38:46,592 --> 10:38:47,427
>> let's take five minutes.

15015
10:38:47,427 --> 10:38:47,760
When the copies are ready we

15016
10:38:47,760 --> 10:38:49,760
can reconvene.

15017
10:38:50,897 --> 10:38:51,531
And then we will go from there.

15018
10:38:51,531 --> 10:38:53,531
>> certainly.

15019
10:58:21,632 --> 10:58:23,632
Thank you.

15020
10:58:24,101 --> 10:58:26,101
>> we are good.

15021
10:58:26,703 --> 10:58:28,703
All right.

15022
10:58:32,709 --> 10:58:34,709
Let's reconvene here.

15023
10:58:36,446 --> 10:58:38,249
I will go to opc who handed out

15024
10:58:38,249 --> 10:58:40,249
some paperwork.

15025
10:58:46,323 --> 10:58:48,323
>> yes we did.

15026
10:58:53,530 --> 10:58:56,320
Once we are ready to roll,

15027
10:58:56,320 --> 10:58:56,901
>> before we get started, we

15028
10:58:56,901 --> 10:58:58,369
are getting a couple of other

15029
10:58:58,369 --> 10:59:01,369
items printed out that are

15030
10:59:02,673 --> 10:59:03,540
relevant to this.

15031
10:59:03,540 --> 10:59:07,377
I do not know if you want to

15032
10:59:07,377 --> 10:59:07,611
wait for all of it.

15033
10:59:07,611 --> 10:59:09,611
>> I do.

15034
10:59:11,810 --> 10:59:11,681
I would prefer not to stop

15035
10:59:11,681 --> 10:59:13,681
again.

15036
10:59:16,153 --> 10:59:16,653
How far along are we in that

15037
10:59:16,653 --> 10:59:17,254
process?

15038
10:59:17,254 --> 10:59:21,454
>> I am not sure who is doing

15039
10:59:25,996 --> 10:59:26,930
the printing.

15040
10:59:26,930 --> 10:59:27,164
>> let's hold tight and not go

15041
10:59:27,164 --> 10:59:27,831
too far.

15042
10:59:27,831 --> 10:59:30,231
We will reconvene once

15043
10:59:38,542 --> 10:59:40,542
everything is back.

15044
10:59:41,845 --> 10:59:42,747
>> commissioner, they MAY have

15045
10:59:42,747 --> 10:59:45,950
their copies ready by the time

15046
10:59:45,950 --> 10:59:46,984
redirect is up.

15047
10:59:46,984 --> 10:59:48,180
He can introduce those as part

15048
10:59:48,180 --> 10:59:50,180
of his redirect.

15049
10:59:50,200 --> 10:59:53,620
We can continue to move along

15050
10:59:56,560 --> 10:59:57,227
if that is the CHAIRMAN's wish.

15051
10:59:57,227 --> 10:59:57,561
>> let's still hold for a few

15052
10:59:57,561 --> 10:59:59,561
seconds.

15053
11:01:07,831 --> 11:01:07,998
But I MAY take you up on that.

15054
11:01:07,998 --> 11:01:09,998
>>.

15055
11:01:11,801 --> 11:01:12,869
>> okay.

15056
11:01:12,869 --> 11:01:16,469
Let's go ahead and get started.

15057
11:01:16,639 --> 11:01:19,175
There is something printed but

15058
11:01:19,175 --> 11:01:22,175
we should have it shortly.

15059
11:01:23,614 --> 11:01:27,500
We were about to start to talk

15060
11:01:27,500 --> 11:01:29,450
about the other things.

15061
11:01:32,789 --> 11:01:33,590
>> have you had an opportunity

15062
11:01:33,590 --> 11:01:34,257
to have a conversation with

15063
11:01:34,257 --> 11:01:37,257
your attorney about the order

15064
11:01:40,497 --> 11:01:44,697
that I am about to show you?

15065
11:01:45,736 --> 11:01:47,736
>> yes.

15066
11:01:51,942 --> 11:01:52,609
>> for clarification of the

15067
11:01:52,609 --> 11:01:56,209
record, can we ask that the

15068
11:02:02,485 --> 11:02:03,153
court reporter read back the

15069
11:02:03,153 --> 11:02:03,954
question regarding the kentucky

15070
11:02:03,954 --> 11:02:06,954
in the adoption of the

15071
11:02:07,291 --> 11:02:07,624
testimony in kentucky in your

15072
11:02:07,624 --> 11:02:09,624
response.

15073
11:02:11,628 --> 11:02:11,895
>> court reporter, is that

15074
11:02:11,895 --> 11:02:13,895
possible?

15075
11:02:15,265 --> 11:02:15,766
We MAY have to give a bit of

15076
11:02:15,766 --> 11:02:17,766
direction.

15077
11:02:21,204 --> 11:02:23,204
>> how far back?

15078
11:02:26,109 --> 11:02:26,310
>> I don't think it was too far

15079
11:02:26,310 --> 11:02:27,144
back.

15080
11:02:27,144 --> 11:02:28,845
>> I would say in the last two

15081
11:02:28,845 --> 11:02:29,813
or three minutes.

15082
11:02:29,813 --> 11:02:34,130
>> I will give her a moment to

15083
11:02:51,335 --> 11:02:53,335
find it.

15084
11:03:17,794 --> 11:03:18,661
>> take your time please.

15085
11:03:18,661 --> 11:03:22,261
>> if you could play back the

15086
11:03:22,709 --> 11:03:22,856
question in response, that

15087
11:03:22,856 --> 11:03:24,856
would be helpful.

15088
11:03:28,371 --> 11:03:28,538
Thank you.

15089
11:03:28,538 --> 11:03:30,538
>>

15090
11:04:11,514 --> 11:04:13,514
[Audio unclear]

15091
11:04:15,252 --> 11:04:17,652
>> thank you MADAM Court

15092
11:04:18,121 --> 11:04:18,855
reporter.

15093
11:04:18,855 --> 11:04:23,550
Sir, can you see the order from

15094
11:04:26,563 --> 11:04:27,530
the commonwealth of kentucky

15095
11:04:27,530 --> 11:04:28,264
and the matter of electronic

15096
11:04:28,264 --> 11:04:29,650
application of delta natural

15097
11:04:29,650 --> 11:04:32,650
gas company inc. For an

15098
11:04:39,375 --> 11:04:40,343
adjustment in its rates for

15099
11:04:40,343 --> 11:04:41,244
being public convenience and

15100
11:04:41,244 --> 11:04:41,477
necessity case number 2020

15101
11:04:41,477 --> 11:04:41,644
100185?

15102
11:04:41,644 --> 11:04:42,211
> I do.

15103
11:04:42,211 --> 11:04:42,945
>> can you read the second

15104
11:04:42,945 --> 11:04:43,446
paragraph of that order on the

15105
11:04:43,446 --> 11:04:45,446
first page?

15106
11:04:50,530 --> 11:04:50,787
>> sure.

15107
11:04:50,787 --> 11:04:51,788
>> in support of this motion,

15108
11:04:51,788 --> 11:04:54,357
delta explains that it learned

15109
11:04:54,357 --> 11:04:55,291
on JULY 20 that one of its

15110
11:04:55,291 --> 11:04:58,195
witness MR. [Listing names] Was

15111
11:04:58,195 --> 11:04:59,529
in a bicycle accident which

15112
11:04:59,529 --> 11:05:00,300
prohibits him from giving

15113
11:05:00,300 --> 11:05:02,300
responses.

15114
11:05:02,966 --> 11:05:06,566
Further it delta states that we

15115
11:05:08,400 --> 11:05:11,400
have adopted another person for

15116
11:05:13,677 --> 11:05:16,677
direct testimony which seeks an

15117
11:05:20,917 --> 11:05:21,818
extension of time.

15118
11:05:21,818 --> 11:05:22,119
>> let me take you back to

15119
11:05:22,119 --> 11:05:23,853
exhibit 96.

15120
11:05:23,853 --> 11:05:24,387
Which is the list of the rra

15121
11:05:24,387 --> 11:05:26,387
comparative.

15122
11:05:29,692 --> 11:05:33,892
Do you see on that second to

15123
11:05:34,960 --> 11:05:34,731
last page where it says

15124
11:05:34,731 --> 11:05:36,731
pennsylvania light company?

15125
11:05:37,333 --> 11:05:39,690
>> yes, ma'am.

15126
11:05:39,690 --> 11:05:41,690
>> well, not yet.

15127
11:05:47,444 --> 11:05:48,440
But I am sure it is there.

15128
11:05:48,440 --> 11:05:49,245
>> yes.

15129
11:05:49,245 --> 11:05:49,446
And do you see the 11.5 percent

15130
11:05:49,446 --> 11:05:51,147
there?

15131
11:05:51,147 --> 11:05:53,147
>> yes, ma'am.

15132
11:05:58,121 --> 11:06:01,721
>> is not testimony where he is

15133
11:06:04,194 --> 11:06:06,594
seeking an 11.5 are roe.

15134
11:06:10,700 --> 11:06:11,401
>> I have no further questions.

15135
11:06:11,401 --> 11:06:13,801
>> commissioner, could I get

15136
11:06:18,408 --> 11:06:19,175
the order marked for

15137
11:06:19,175 --> 11:06:19,910
identification?

15138
11:06:19,910 --> 11:06:20,677
Or given an identification

15139
11:06:20,677 --> 11:06:23,546
number to move it into evidence

15140
11:06:23,546 --> 11:06:25,248
at the end?

15141
11:06:25,248 --> 11:06:27,417
>> let's give it a number.

15142
11:06:27,417 --> 11:06:31,654
I will have to ask my staff for

15143
11:06:31,654 --> 11:06:32,722
a little bit of help.

15144
11:06:32,722 --> 11:06:34,257
>> MR. CHAIRMAN, I do believe

15145
11:06:34,257 --> 11:06:34,624
that is 839.

15146
11:06:34,624 --> 11:06:36,624
>> thank you.

15147
11:06:37,160 --> 11:06:39,160
>> moving on to

15148
11:06:41,931 --> 11:06:42,599
florida rising.

15149
11:06:42,599 --> 11:06:44,999
>> good evening MR. CHAIRMAN.

15150
11:06:48,805 --> 11:06:49,805
>> good evening!

15151
11:06:49,805 --> 11:06:52,805
>> if I could direct your

15152
11:06:52,909 --> 11:06:53,409
attention to master number

15153
11:06:53,409 --> 11:06:55,409
83443.

15154
11:07:00,116 --> 11:07:00,617
It should splash up on your

15155
11:07:00,617 --> 11:07:01,284
screen.

15156
11:07:01,284 --> 11:07:04,284
This is from admitted exhibits

15157
11:07:06,556 --> 11:07:07,557
staff 177.

15158
11:07:07,557 --> 11:07:09,859
So, this document contains the

15159
11:07:09,859 --> 11:07:10,227
reference documents for your

15160
11:07:10,227 --> 11:07:12,227
testimony.

15161
11:07:17,600 --> 11:07:18,000
Is that correct?

15162
11:07:18,000 --> 11:07:18,735
>> okay.

15163
11:07:18,735 --> 11:07:19,602
The specific one that we are

15164
11:07:19,602 --> 11:07:20,170
looking at is the smp global

15165
11:07:20,170 --> 11:07:21,237
rating score snapshot.

15166
11:07:21,237 --> 11:07:25,437
If you look at the bottom of

15167
11:07:26,750 --> 11:07:29,675
the page there is a key

15168
11:07:32,150 --> 11:07:32,782
strength that the electric

15169
11:07:32,782 --> 11:07:33,149
company says that this is a low

15170
11:07:33,149 --> 11:07:35,149
risk utility.

15171
11:07:39,956 --> 11:07:40,189
Is that correct?

15172
11:07:40,189 --> 11:07:40,957
>> yes.

15173
11:07:40,957 --> 11:07:41,991
It is the same description it

15174
11:07:41,991 --> 11:07:42,492
gives to every single utility

15175
11:07:42,492 --> 11:07:44,394
company that it covers.

15176
11:07:44,394 --> 11:07:46,997
>> as a key risk it says very

15177
11:07:46,997 --> 11:07:48,598
large capital programs will

15178
11:07:48,598 --> 11:07:50,598
pressure credit metrics.

15179
11:07:50,633 --> 11:07:52,633
>> yes, sir.

15180
11:07:53,904 --> 11:07:56,904
>> if I could direct your

15181
11:07:57,173 --> 11:07:58,408
attention to two pages later.

15182
11:07:58,408 --> 11:08:00,408
>> that is 23632.

15183
11:08:02,845 --> 11:08:03,213
On the bottom.

15184
11:08:03,213 --> 11:08:05,213
>> yes.

15185
11:08:08,317 --> 11:08:10,317
That is correct.

15186
11:08:14,657 --> 11:08:15,491
>> it says that the negative

15187
11:08:15,491 --> 11:08:18,491
outlook on tec reflects the

15188
11:08:19,620 --> 11:08:19,629
negative outlook of its parent.

15189
11:08:19,629 --> 11:08:21,629
[Listing names].

15190
11:08:22,640 --> 11:08:23,990
It reflects its current minimal

15191
11:08:23,990 --> 11:08:25,499
financial condition from the

15192
11:08:27,236 --> 11:08:29,236
downgrade threshold.

15193
11:08:36,145 --> 11:08:37,800
>> yes, sir.

15194
11:08:37,800 --> 11:08:37,680
>> if I could direct your

15195
11:08:37,680 --> 11:08:40,800
attention to master number

15196
11:08:45,722 --> 11:08:46,355
e3454 within the same document.

15197
11:08:46,355 --> 11:08:48,624
>> you said e3454 correct?

15198
11:08:48,624 --> 11:08:49,492
>> yes.

15199
11:08:49,492 --> 11:08:52,492
This would be moody's credit

15200
11:08:57,167 --> 11:08:57,366
opinion for teco from DECEMBER

15201
11:08:57,366 --> 11:08:58,168
2023.

15202
11:08:58,168 --> 11:08:58,935
If I could direct your

15203
11:08:58,935 --> 11:09:01,935
attention to the last paragraph

15204
11:09:08,430 --> 11:09:08,945
of that page.

15205
11:09:08,945 --> 11:09:09,679
It says that tampa electric's

15206
11:09:09,679 --> 11:09:12,381
credit rating is restrained by

15207
11:09:12,381 --> 11:09:15,981
the week parent company of its

15208
11:09:20,589 --> 11:09:21,491
parent company.

15209
11:09:21,491 --> 11:09:22,458
Most notably, this puts

15210
11:09:22,458 --> 11:09:23,126
pressure on tampa electric.

15211
11:09:23,126 --> 11:09:23,993
Therefore they MAY rely more

15212
11:09:23,993 --> 11:09:24,761
heavily on tampa electric and

15213
11:09:24,761 --> 11:09:27,761
MAY need the utility to

15214
11:09:28,464 --> 11:09:30,864
upstream dividends for high

15215
11:09:33,136 --> 11:09:33,436
company debt and other

15216
11:09:33,436 --> 11:09:34,303
obligations.

15217
11:09:34,303 --> 11:09:35,805
>> did I read that correctly?

15218
11:09:35,805 --> 11:09:36,672
>> yes.

15219
11:09:36,672 --> 11:09:39,672
If I could direct your

15220
11:09:42,545 --> 11:09:42,745
attention next to master number

15221
11:09:42,745 --> 11:09:44,745
83459.

15222
11:09:49,419 --> 11:09:53,619
This is just a few pages down.

15223
11:10:04,100 --> 11:10:04,367
That is part of that same

15224
11:10:04,367 --> 11:10:06,367
document.

15225
11:10:10,907 --> 11:10:11,941
It says under the second

15226
11:10:11,941 --> 11:10:14,444
heading that they issued a

15227
11:10:14,444 --> 11:10:16,790
significant amount of debt and

15228
11:10:16,790 --> 11:10:17,790
subordinated hybrid notes to

15229
11:10:17,790 --> 11:10:19,790
finances acquisition of.

15230
11:10:22,451 --> 11:10:22,919
[Listing teco.

15231
11:10:22,919 --> 11:10:24,919
Is that right?

15232
11:10:28,558 --> 11:10:29,492
>> yes, sir.

15233
11:10:29,492 --> 11:10:30,492
>> you are not aware of any

15234
11:10:30,492 --> 11:10:33,262
time that you have recommended

15235
11:10:33,262 --> 11:10:33,495
a lower returnreturn on equity

15236
11:10:33,495 --> 11:10:35,495
correct?

15237
11:10:36,232 --> 11:10:38,632
>> I am not aware.

15238
11:10:41,670 --> 11:10:42,338
>> as far as you are aware of,

15239
11:10:42,338 --> 11:10:43,239
as far as their subsidiaries,

15240
11:10:43,239 --> 11:10:43,605
the author's return is highest

15241
11:10:43,605 --> 11:10:45,605
at teco.

15242
11:10:49,345 --> 11:10:51,345
>> yes.

15243
11:10:53,830 --> 11:10:54,150
Based on basis points.

15244
11:10:54,150 --> 11:10:54,984
Ask and that is at the current

15245
11:10:54,984 --> 11:10:55,217
authorized rate of return

15246
11:10:55,217 --> 11:10:57,217
correct?

15247
11:10:57,620 --> 11:10:59,620
>> that's right.

15248
11:11:08,564 --> 11:11:09,165
>> you say that the roe should

15249
11:11:09,165 --> 11:11:09,398
be raised correct?

15250
11:11:09,398 --> 11:11:09,999
>> yes.

15251
11:11:09,999 --> 11:11:10,966
Based on my analysis.

15252
11:11:10,966 --> 11:11:13,966
>> who would agree that canada

15253
11:11:18,808 --> 11:11:20,242
generally has lower roe's?

15254
11:11:20,242 --> 11:11:23,242
They provide an opportunity for

15255
11:11:23,479 --> 11:11:26,479
higher return as compared to

15256
11:11:26,849 --> 11:11:27,349
for example, nova scotia power?

15257
11:11:27,349 --> 11:11:29,349
>> yes.

15258
11:11:31,153 --> 11:11:32,154
This was all in my deposition.

15259
11:11:32,154 --> 11:11:34,890
We were talking about how other

15260
11:11:34,890 --> 11:11:35,570
canadian companies have

15261
11:11:35,570 --> 11:11:37,457
invested in american companies

15262
11:11:38,727 --> 11:11:39,328
because generally, the risk is

15263
11:11:39,328 --> 11:11:42,928
the same but the return is

15264
11:11:45,934 --> 11:11:46,602
higher in america.

15265
11:11:46,602 --> 11:11:47,436
Given basic financial precepts

15266
11:11:47,436 --> 11:11:51,360
you will want to spend money

15267
11:11:53,643 --> 11:11:54,430
where you can get the highest

15268
11:11:54,430 --> 11:11:54,710
return.

15269
11:11:54,710 --> 11:11:55,510
>> other than in alaska you are

15270
11:11:55,510 --> 11:11:57,113
not aware of any other

15271
11:11:57,113 --> 11:11:57,613
utilities being returned 11.5

15272
11:11:57,613 --> 11:11:59,613
percent or higher?

15273
11:11:59,816 --> 11:12:02,216
>> I am not aware.

15274
11:12:06,210 --> 11:12:06,222
But we use it generally this

15275
11:12:06,222 --> 11:12:07,900
stuff.

15276
11:12:07,900 --> 11:12:10,900
They don't have an entire

15277
11:12:12,228 --> 11:12:12,862
picture of roe's.

15278
11:12:12,862 --> 11:12:14,862
But generally, no.

15279
11:12:19,568 --> 11:12:20,503
Not at the size.

15280
11:12:20,503 --> 11:12:20,770
>> and just to clarify your

15281
11:12:20,770 --> 11:12:21,637
testimony.

15282
11:12:21,637 --> 11:12:23,572
You are not offering an opinion

15283
11:12:23,572 --> 11:12:24,239
on whether customer costs are

15284
11:12:24,239 --> 11:12:24,540
reasonable, correct?

15285
11:12:24,540 --> 11:12:26,540
>> correct.

15286
11:12:27,176 --> 11:12:29,678
My testimony is the appropriate

15287
11:12:29,678 --> 11:12:32,678
rate of return that investors

15288
11:12:33,816 --> 11:12:35,551
require on, equity investors

15289
11:12:35,551 --> 11:12:37,551
require in teco.

15290
11:12:45,327 --> 11:12:46,261
>> thank you.

15291
11:12:46,261 --> 11:12:46,529
>> I have a handful of

15292
11:12:46,529 --> 11:12:47,363
questions.

15293
11:12:47,363 --> 11:12:48,897
I would like to refer to the

15294
11:12:48,897 --> 11:12:49,431
witness if I could just

15295
11:12:49,431 --> 11:12:50,666
briefly.

15296
11:12:50,666 --> 11:12:53,101
They have a chart that MR.

15297
11:12:53,101 --> 11:12:53,736
Pollick will talk about

15298
11:12:53,736 --> 11:12:55,736
tomorrow.

15299
11:12:57,172 --> 11:13:00,772
It has not been admitted yet.

15300
11:13:09,718 --> 11:13:10,586
It is 6027? 2859.

15301
11:13:10,586 --> 11:13:14,786
It should be pulled up on the

15302
11:13:14,924 --> 11:13:17,924
screen in front of you.

15303
11:13:19,228 --> 11:13:20,290
>> this is a two-page chart.

15304
11:13:20,290 --> 11:13:23,290
This is the first page.

15305
11:13:30,940 --> 11:13:33,340
Page one of two.

15306
11:13:36,546 --> 11:13:37,513
And on the second page the

15307
11:13:37,513 --> 11:13:37,713
screen will need to be scroll

15308
11:13:37,713 --> 11:13:39,713
down.

15309
11:13:41,417 --> 11:13:42,317
That is the second page.

15310
11:13:42,317 --> 11:13:43,219
I know you briefly looked at

15311
11:13:43,219 --> 11:13:45,219
the first page.

15312
11:13:46,188 --> 11:13:47,156
Do you see any cases in their

15313
11:13:47,156 --> 11:13:50,756
that you testified upon on the

15314
11:13:54,797 --> 11:13:55,731
first page?

15315
11:13:55,731 --> 11:13:57,731
>> louisiana southwestern

15316
11:14:00,303 --> 11:14:01,700
electrical power company.

15317
11:14:01,700 --> 11:14:01,303
>> that is number 5.

15318
11:14:01,303 --> 11:14:03,303
>> yes.

15319
11:14:13,415 --> 11:14:15,415
Number 5, number 9, maybe

15320
11:14:18,920 --> 11:14:19,788
number 20.

15321
11:14:19,788 --> 11:14:20,389
I did testify in kentucky.

15322
11:14:20,389 --> 11:14:25,189
I do not know if it is the

15323
11:14:31,701 --> 11:14:34,101
recent one or not.

15324
11:14:36,710 --> 11:14:36,238
21, if we go on the next page,

15325
11:14:36,238 --> 11:14:38,238
50.

15326
11:14:44,480 --> 11:14:44,647
>> 50.

15327
11:14:44,647 --> 11:14:46,647
Yes.

15328
11:14:52,588 --> 11:14:53,522
What they did is similar to the

15329
11:14:53,522 --> 11:14:54,222
other exhibit where he has gone

15330
11:14:54,222 --> 11:14:56,425
back and looked at the last

15331
11:14:56,425 --> 11:14:59,895
couple of years and looked at

15332
11:14:59,895 --> 11:15:00,162
the roe's that have been

15333
11:15:00,162 --> 11:15:01,620
reported.

15334
11:15:01,620 --> 11:15:04,620
And has calculated an average

15335
11:15:06,602 --> 11:15:07,603
for 2023.

15336
11:15:07,603 --> 11:15:08,137
In an average for 2024 of 9.72.

15337
11:15:08,137 --> 11:15:09,638
Is that correct?

15338
11:15:09,638 --> 11:15:11,638
>> that is correct.

15339
11:15:14,420 --> 11:15:14,876
>> I assume that you identified

15340
11:15:14,876 --> 11:15:16,645
and testified about all of

15341
11:15:16,645 --> 11:15:19,450
those with the exception.

15342
11:15:23,520 --> 11:15:23,886
Number 8 in california.

15343
11:15:23,886 --> 11:15:24,386
They all ended up at

15344
11:15:24,386 --> 11:15:24,853
single-digit roe.

15345
11:15:24,853 --> 11:15:26,823
is that correct?

15346
11:15:26,823 --> 11:15:27,789
>> yes.

15347
11:15:27,789 --> 11:15:28,791
There were some gas cases that

15348
11:15:28,791 --> 11:15:30,791
were over time.

15349
11:15:31,861 --> 11:15:34,497
But they are not on this list.

15350
11:15:34,497 --> 11:15:35,631
>> I want to spend a moment and

15351
11:15:35,631 --> 11:15:35,831
talk about what has been done

15352
11:15:35,831 --> 11:15:37,831
here.

15353
11:15:41,537 --> 11:15:41,803
I think walmart has a similar

15354
11:15:41,803 --> 11:15:43,803
approach.

15355
11:15:43,839 --> 11:15:46,839
I asked the PRESIDENT Yesterday

15356
11:15:50,278 --> 11:15:50,946
whether this type of

15357
11:15:50,946 --> 11:15:53,946
information had a lot of

15358
11:15:54,817 --> 11:15:55,751
comparisons being made.

15359
11:15:55,751 --> 11:15:57,520
This type of information is

15360
11:15:57,520 --> 11:15:59,520
probative and meaningful.

15361
11:15:59,521 --> 11:16:01,521
He said yes.

15362
11:16:04,393 --> 11:16:05,361
Do you similarly agree that

15363
11:16:05,361 --> 11:16:09,561
this can be used as an approach

15364
11:16:11,133 --> 11:16:13,133
to roe.

15365
11:16:16,905 --> 11:16:17,906
It is different ways of perhaps

15366
11:16:17,906 --> 11:16:19,375
getting to a similar point.

15367
11:16:19,375 --> 11:16:20,176
It's a long-winded question.

15368
11:16:20,176 --> 11:16:20,976
But if you can answer it I

15369
11:16:20,976 --> 11:16:22,976
would appreciate it.

15370
11:16:23,211 --> 11:16:25,211
>> sure.

15371
11:16:27,215 --> 11:16:28,830
I will start with no.

15372
11:16:28,830 --> 11:16:31,453
It is because of a couple

15373
11:16:31,453 --> 11:16:32,354
things that I said earlier.

15374
11:16:32,354 --> 11:16:33,488
There are different companies

15375
11:16:33,488 --> 11:16:33,989
with different sets of

15376
11:16:33,989 --> 11:16:35,624
circumstances.

15377
11:16:35,624 --> 11:16:40,424
All you have to do is look at

15378
11:16:42,230 --> 11:16:42,898
the people discuss and what the

15379
11:16:42,898 --> 11:16:43,732
commission did in that case.

15380
11:16:43,732 --> 11:16:44,900
They ran their models and

15381
11:16:44,900 --> 11:16:47,269
looked at the companies.

15382
11:16:47,269 --> 11:16:50,869
They looked at the models and

15383
11:16:52,741 --> 11:16:53,242
then they made the

15384
11:16:53,242 --> 11:16:53,943
determination.

15385
11:16:53,943 --> 11:16:55,210
MS. Christiansen was right when

15386
11:16:55,210 --> 11:16:57,610
she read her order.

15387
11:16:57,813 --> 11:17:00,282
But, they did not adjust their

15388
11:17:00,282 --> 11:17:03,882
model results up or down based

15389
11:17:08,590 --> 11:17:09,525
on what the average was.

15390
11:17:09,525 --> 11:17:10,125
So it MAY be a guidepost.

15391
11:17:10,125 --> 11:17:10,759
But like the commission has

15392
11:17:10,759 --> 11:17:11,794
done so much in the past and

15393
11:17:11,794 --> 11:17:13,361
what they should continue to do

15394
11:17:13,361 --> 11:17:16,231
is to follow the model.

15395
11:17:16,231 --> 11:17:19,231
the model is the market.

15396
11:17:19,835 --> 11:17:21,570
The outcomes of these cases are

15397
11:17:21,570 --> 11:17:24,570
results of things like this.

15398
11:17:24,906 --> 11:17:28,506
Where I have my number, the

15399
11:17:29,100 --> 11:17:29,845
doctor has his number, MR.

15400
11:17:29,845 --> 11:17:33,445
Walters has his number and it

15401
11:17:33,582 --> 11:17:35,985
is up to the commission to try

15402
11:17:35,985 --> 11:17:38,385
and balance those interests.

15403
11:17:38,520 --> 11:17:42,720
My opinion is that the roe is

15404
11:17:44,793 --> 11:17:45,460
11.5 percent.

15405
11:17:45,460 --> 11:17:45,660
A lot of the parties don't have

15406
11:17:45,660 --> 11:17:46,528
that.

15407
11:17:46,528 --> 11:17:47,963
But when you are talking about

15408
11:17:47,963 --> 11:17:50,165
using that as market data, it

15409
11:17:50,165 --> 11:17:51,133
is not.

15410
11:17:51,133 --> 11:17:54,503
Because it does not move with

15411
11:17:54,503 --> 11:17:55,537
market rates.

15412
11:17:55,537 --> 11:17:57,773
When the stock price changes,

15413
11:17:57,773 --> 11:17:59,773
or dcf changes.

15414
11:18:00,909 --> 11:18:02,909
Everything affects everything.

15415
11:18:04,790 --> 11:18:05,130
These are stuck in the mud.

15416
11:18:05,130 --> 11:18:05,714
There are several different

15417
11:18:05,714 --> 11:18:09,351
things of why you do not use

15418
11:18:09,351 --> 11:18:11,751
author's returns as reference

15419
11:18:18,260 --> 11:18:19,228
to roe.

15420
11:18:19,228 --> 11:18:20,429
That is your opinion, correct?

15421
11:18:20,429 --> 11:18:22,429
>> yes.

15422
11:18:24,833 --> 11:18:25,768
>> and you are aware that

15423
11:18:25,768 --> 11:18:28,168
others have different opinions.

15424
11:18:29,437 --> 11:18:31,437
Orrect?

15425
11:18:31,640 --> 11:18:33,640
>> no.

15426
11:18:35,977 --> 11:18:36,912
The witnesses that are expert

15427
11:18:36,912 --> 11:18:38,780
witnesses and they do these

15428
11:18:38,780 --> 11:18:41,649
types of things, they have

15429
11:18:41,649 --> 11:18:43,418
these models and don't use

15430
11:18:43,418 --> 11:18:45,418
author's returns.

15431
11:18:48,723 --> 11:18:49,758
And neither does MR. Walters.

15432
11:18:49,758 --> 11:18:50,920
And neither does MR. Garrett

15433
11:18:50,920 --> 11:18:50,759
before him.

15434
11:18:50,759 --> 11:18:52,759
One of the

15435
11:18:55,130 --> 11:18:57,530
witnesses use author's returns

15436
11:18:58,433 --> 11:19:00,302
as their number.

15437
11:19:00,302 --> 11:19:00,869
As opposed to some of the other

15438
11:19:00,869 --> 11:19:02,869
witnesses.

15439
11:19:04,205 --> 11:19:07,805
It is not high or low.

15440
11:19:08,310 --> 11:19:08,510
He does not say what number he

15441
11:19:08,510 --> 11:19:09,411
wants.

15442
11:19:09,411 --> 11:19:13,110
He just cautions you about one

15443
11:19:18,854 --> 11:19:19,520
thing or another.

15444
11:19:19,520 --> 11:19:20,388
>> the five cases that you

15445
11:19:20,388 --> 11:19:21,890
testified here today, do they

15446
11:19:21,890 --> 11:19:24,689
all go through the process that

15447
11:19:27,830 --> 11:19:28,696
you are describing?

15448
11:19:28,696 --> 11:19:32,296
>> the models that you use and

15449
11:19:35,370 --> 11:19:36,438
the discounted cash flow model.

15450
11:19:36,438 --> 11:19:37,439
Do they provide that testimony

15451
11:19:37,439 --> 11:19:38,573
in the five that you referenced

15452
11:19:38,573 --> 11:19:39,207
here?

15453
11:19:39,207 --> 11:19:41,207
>> yes.

15454
11:19:43,411 --> 11:19:44,479
Because you bring it up?

15455
11:19:44,479 --> 11:19:46,715
If it is settled, it is based

15456
11:19:46,715 --> 11:19:47,716
on other things.

15457
11:19:47,716 --> 11:19:51,316
If you could bring that exhibit

15458
11:19:51,953 --> 11:19:52,920
up again,

15459
11:19:52,920 --> 11:19:55,920
>> there is nowhere that tells

15460
11:19:57,492 --> 11:19:59,394
you if it was or it was not.

15461
11:19:59,394 --> 11:20:01,794
>> here is the question.

15462
11:20:06,735 --> 11:20:08,603
With respect to the ability, if

15463
11:20:08,603 --> 11:20:11,205
all the states do these things

15464
11:20:11,205 --> 11:20:14,205
with these approaches and this

15465
11:20:15,710 --> 11:20:16,645
is a high-level document that

15466
11:20:16,645 --> 11:20:20,245
just says well, they don't all

15467
11:20:21,383 --> 11:20:21,883
work, here is where the rates

15468
11:20:21,883 --> 11:20:22,451
are.

15469
11:20:22,451 --> 11:20:24,385
That is a way in which you

15470
11:20:24,385 --> 11:20:24,920
could determine relevant

15471
11:20:24,920 --> 11:20:25,487
information.

15472
11:20:25,487 --> 11:20:28,487
Do you agree with that?

15473
11:20:30,392 --> 11:20:31,325
>> I do not.

15474
11:20:31,325 --> 11:20:33,725
>> there are further reasons

15475
11:20:34,195 --> 11:20:34,929
why I said it already.

15476
11:20:34,929 --> 11:20:37,929
>> if you are satisfied with

15477
11:20:44,106 --> 11:20:44,439
the answer, that is

15478
11:20:44,439 --> 11:20:46,439
satisfactory.

15479
11:20:48,142 --> 11:20:51,742
>> were you here today or did

15480
11:20:54,916 --> 11:20:55,617
you listen to the witness talk

15481
11:20:55,617 --> 11:20:58,170
about how duke establishes

15482
11:20:59,540 --> 11:21:01,540
their salaries?

15483
11:21:04,493 --> 11:21:06,493
>> which witness?

15484
11:21:06,527 --> 11:21:07,280
>> I do apologize.

15485
11:21:07,280 --> 11:21:09,280
Teco.

15486
11:21:09,964 --> 11:21:10,966
It was a witness today from

15487
11:21:10,966 --> 11:21:14,566
teco who talked about how they

15488
11:21:15,937 --> 11:21:16,337
establish their salaries.

15489
11:21:16,337 --> 11:21:16,538
Are you familiar?

15490
11:21:16,538 --> 11:21:17,672
>> no.

15491
11:21:17,672 --> 11:21:20,342
>> do you know that some

15492
11:21:20,342 --> 11:21:23,942
utilities use the median as a

15493
11:21:27,582 --> 11:21:28,283
way for establishing salaries?

15494
11:21:28,283 --> 11:21:29,952
>> some utilities will use a

15495
11:21:29,952 --> 11:21:30,652
median to look at their other

15496
11:21:30,652 --> 11:21:33,621
utilities and say what is the

15497
11:21:33,621 --> 11:21:35,724
median price that other

15498
11:21:35,724 --> 11:21:38,124
utilities are paying executives

15499
11:21:41,960 --> 11:21:45,296
for a way of making a decision?

15500
11:21:46,101 --> 11:21:46,968
>> that is not relevant.

15501
11:21:46,968 --> 11:21:49,437
It MAY be relevant to how you

15502
11:21:49,437 --> 11:21:51,437
do compensation.

15503
11:21:51,606 --> 11:21:54,606
>> I will ask the question.

15504
11:21:58,713 --> 11:22:01,713
If this similar to teco?

15505
11:22:02,584 --> 11:22:02,818
>> this is a comparison of the

15506
11:22:02,818 --> 11:22:03,451
median.

15507
11:22:03,451 --> 11:22:04,486
It is the same thing.

15508
11:22:04,486 --> 11:22:08,686
It's just the point I wanted to

15509
11:22:19,701 --> 11:22:21,701
make.

15510
11:22:28,276 --> 11:22:30,178
>> sierra club?

15511
11:22:30,178 --> 11:22:32,800
>> f rf?

15512
11:22:32,800 --> 11:22:34,480
Thank you MR. CHAIRMAN.

15513
11:22:43,791 --> 11:22:45,791
Good evening.

15514
11:22:51,233 --> 11:22:52,167
Quick question if I could ask

15515
11:22:52,167 --> 11:22:55,103
MR. Schultz to please bring up

15516
11:22:55,103 --> 11:22:55,636
what is identified as f rf

15517
11:22:55,636 --> 11:22:57,636
five.

15518
11:22:59,600 --> 11:23:02,606
They are in our exhibit list.

15519
11:23:05,313 --> 11:23:08,313
F7? 44 and f7? 79 is the

15520
11:23:10,385 --> 11:23:12,385
first page.

15521
11:23:15,560 --> 11:23:15,924
These are simply copies of hope

15522
11:23:15,924 --> 11:23:19,524
and bluefield to which you are

15523
11:23:19,761 --> 11:23:20,661
referring your testimony.

15524
11:23:20,661 --> 11:23:22,898
I would just like to say yes,

15525
11:23:22,898 --> 11:23:25,898
this is what they are.

15526
11:23:27,936 --> 11:23:28,770
Thank you.

15527
11:23:28,770 --> 11:23:29,470
I will move these later.

15528
11:23:29,470 --> 11:23:33,174
But that is all I need to do

15529
11:23:33,174 --> 11:23:35,574
with those for now.

15530
11:23:36,430 --> 11:23:38,113
I will ask a few questions.

15531
11:23:38,113 --> 11:23:40,513
About exhibit 321 out of

15532
11:23:45,954 --> 11:23:46,555
respect for my friend and

15533
11:23:46,555 --> 11:23:47,422
everybody's time, I will

15534
11:23:47,422 --> 11:23:50,422
condense my questions and not

15535
11:23:51,259 --> 11:23:52,226
go line by line.

15536
11:23:52,226 --> 11:23:55,226
I have identified results for

15537
11:23:55,763 --> 11:23:56,798
several of the operating

15538
11:23:56,798 --> 11:23:59,567
companies that are owned by the

15539
11:23:59,567 --> 11:23:59,767
parent companies in your proxy

15540
11:23:59,767 --> 11:24:00,601
group.

15541
11:24:00,601 --> 11:24:04,801
Your proxy group is as shown on

15542
11:24:05,506 --> 11:24:06,700
page 19 of your direct

15543
11:24:06,700 --> 11:24:06,174
testimony, correct?

15544
11:24:06,174 --> 11:24:06,808
> I do

15545
11:24:06,808 --> 11:24:09,208
believe I updated it.

15546
11:24:14,215 --> 11:24:17,215
But I get the just.

15547
11:24:18,119 --> 11:24:21,255
>> I will ask you is this

15548
11:24:21,255 --> 11:24:23,791
company owned by such and such?

15549
11:24:23,791 --> 11:24:24,325
And then we will go on from

15550
11:24:24,325 --> 11:24:26,325
there.

15551
11:24:26,961 --> 11:24:27,428
I don't think it will take

15552
11:24:27,428 --> 11:24:29,428
long.

15553
11:24:29,998 --> 11:24:30,798
Is it true that duke energy

15554
11:24:30,798 --> 11:24:33,198
carolinas into energy progress

15555
11:24:34,302 --> 11:24:34,602
are owned by duke energy

15556
11:24:34,602 --> 11:24:36,237
corporation?

15557
11:24:36,237 --> 11:24:38,720
In wisconsin power and light is

15558
11:24:38,720 --> 11:24:40,720
owned by.

15559
11:24:44,345 --> 11:24:45,213
[Listing names].

15560
11:24:45,213 --> 11:24:46,881
Brooklyn general electric

15561
11:24:46,881 --> 11:24:48,550
company appears to be the same

15562
11:24:48,550 --> 11:24:48,782
name as the operating utility

15563
11:24:48,782 --> 11:24:50,782
company.

15564
11:24:53,354 --> 11:24:54,355
Is that correct?

15565
11:24:54,355 --> 11:24:56,924
>> it MAY be the only operating

15566
11:24:56,924 --> 11:24:57,158
company that is publicly

15567
11:24:57,158 --> 11:24:57,958
traded.

15568
11:24:57,958 --> 11:24:59,460
>> and they are owned by

15569
11:24:59,460 --> 11:25:01,460
southern company?

15570
11:25:04,732 --> 11:25:04,865
And nsp is owned by xl?

15571
11:25:04,865 --> 11:25:05,320
> it

15572
11:25:05,320 --> 11:25:07,320
is.

15573
11:25:07,601 --> 11:25:08,870
>> thank you.

15574
11:25:08,870 --> 11:25:09,103
>> my next question is very

15575
11:25:09,103 --> 11:25:11,103
simple.

15576
11:25:13,730 --> 11:25:16,673
Would you agree that the smp

15577
11:25:19,413 --> 11:25:20,315
global exhibit compilation that

15578
11:25:20,315 --> 11:25:20,981
is shown as exhibit 321 which

15579
11:25:20,981 --> 11:25:23,381
does include both recently

15580
11:25:25,520 --> 11:25:26,870
awarded and pending rate

15581
11:25:26,870 --> 11:25:27,588
increase requests shows what it

15582
11:25:27,588 --> 11:25:28,220
purports to show.

15583
11:25:28,220 --> 11:25:30,220
>> yes.

15584
11:25:30,570 --> 11:25:32,570
Thank you.

15585
11:25:38,533 --> 11:25:39,466
>> if we could go back to the

15586
11:25:39,466 --> 11:25:42,466
document that MR. Boyle was

15587
11:25:43,738 --> 11:25:46,738
just asking, it is identified

15588
11:25:54,248 --> 11:25:55,182
as c 27? 2859.

15589
11:25:55,182 --> 11:25:58,182
In your discussion with MR.

15590
11:25:59,253 --> 11:26:00,210
Boyle just now, you identified

15591
11:26:00,210 --> 11:26:00,655
several of the cases in which

15592
11:26:00,655 --> 11:26:02,655
you testified.

15593
11:26:12,199 --> 11:26:12,834
My question for you is which of

15594
11:26:12,834 --> 11:26:13,735
these are operating utility

15595
11:26:13,735 --> 11:26:14,368
companies owned by members of

15596
11:26:14,368 --> 11:26:15,200
your proxy group?

15597
11:26:15,200 --> 11:26:19,202
If you could just run down the

15598
11:26:25,680 --> 11:26:26,614
list, that would be great.

15599
11:26:26,614 --> 11:26:27,281
>> out of these 52 companies,

15600
11:26:27,281 --> 11:26:28,182
you want me to tell you which

15601
11:26:28,182 --> 11:26:29,150
ones I testified for and if

15602
11:26:29,150 --> 11:26:29,350
they are a member of my proxy

15603
11:26:29,350 --> 11:26:31,350
group?

15604
11:26:32,686 --> 11:26:33,654
>> no sir.

15605
11:26:33,654 --> 11:26:34,255
I just wanted to ask you which

15606
11:26:34,255 --> 11:26:37,855
of these are members of your

15607
11:26:38,859 --> 11:26:39,760
proxy group?

15608
11:26:39,760 --> 11:26:41,996
You already told us which ones

15609
11:26:41,996 --> 11:26:43,996
you testified in.

15610
11:26:46,768 --> 11:26:50,368
>> I believe it is five, nine,

15611
11:27:12,660 --> 11:27:14,660
12, 13, 15, 18, 20, 21, 23, 25,

15612
11:27:26,240 --> 11:27:28,240
26, 35, 36, 39, 31, I think 42

15613
11:27:34,480 --> 11:27:37,480
came in on my rebuttal.

15614
11:27:37,652 --> 11:27:38,419
43.

15615
11:27:38,419 --> 11:27:40,419
And 52.

15616
11:27:41,189 --> 11:27:41,356
And this is just looking at it

15617
11:27:41,356 --> 11:27:42,190
now.

15618
11:27:42,190 --> 11:27:45,790
I could have gotten some and

15619
11:27:46,695 --> 11:27:47,628
missed some.

15620
11:27:47,628 --> 11:27:48,329
But looking at it right now,

15621
11:27:48,329 --> 11:27:48,529
that is what sounds about

15622
11:27:48,529 --> 11:27:50,529
right.

15623
11:27:58,573 --> 11:27:59,206
>> thank you.

15624
11:27:59,206 --> 11:28:01,576
>> are you aware of any

15625
11:28:01,576 --> 11:28:02,276
evidence that any of these

15626
11:28:02,276 --> 11:28:05,276
utilities, the ones that you

15627
11:28:09,283 --> 11:28:10,251
just identified as members of

15628
11:28:10,251 --> 11:28:11,252
operating utility companies

15629
11:28:11,252 --> 11:28:11,885
owned by the members of your

15630
11:28:11,885 --> 11:28:13,654
proxy group, any evidence that

15631
11:28:13,654 --> 11:28:15,623
any of these utilities has not

15632
11:28:15,623 --> 11:28:18,859
been able to provide safe and

15633
11:28:18,859 --> 11:28:20,859
reliable service?

15634
11:28:21,762 --> 11:28:24,162
>> I cannot tell you.

15635
11:28:25,933 --> 11:28:26,568
>> similar question any

15636
11:28:26,568 --> 11:28:28,968
evidence that these utilities

15637
11:28:31,806 --> 11:28:34,475
have not been able to obtain

15638
11:28:34,475 --> 11:28:36,475
significant capital?

15639
11:28:49,223 --> 11:28:49,924
>> I could not tell you.

15640
11:28:49,924 --> 11:28:52,324
>> I'm pretty confident that

15641
11:28:55,562 --> 11:28:56,230
you are aware that since

15642
11:28:56,230 --> 11:28:58,230
JANUARY 2022, tampa electric

15643
11:29:00,201 --> 11:29:03,201
has operated first, for the

15644
11:29:17,718 --> 11:29:18,720
first six months of an.

15645
11:29:18,720 --> 11:29:19,620
during that time, their equity

15646
11:29:19,620 --> 11:29:19,853
ratio has been 54 percent,

15647
11:29:19,853 --> 11:29:21,853
correct?

15648
11:29:25,626 --> 11:29:26,527
>> yes.

15649
11:29:26,527 --> 11:29:27,194
>> are you aware of any

15650
11:29:27,194 --> 11:29:28,262
evidence that they have been

15651
11:29:28,262 --> 11:29:28,896
unable to provide the needed

15652
11:29:28,896 --> 11:29:29,163
capital to provide service at

15653
11:29:29,163 --> 11:29:31,163
the time?

15654
11:29:38,138 --> 11:29:38,706
>> I do not think so.

15655
11:29:38,706 --> 11:29:39,674
>> are you aware of any

15656
11:29:39,674 --> 11:29:40,675
evidence that in 2025 tampa

15657
11:29:40,675 --> 11:29:41,275
electric would not be able to

15658
11:29:41,275 --> 11:29:42,343
obtain the needed capital to

15659
11:29:42,343 --> 11:29:44,743
make the necessary investments?

15660
11:29:45,846 --> 11:29:48,246
>> I do not know.

15661
11:29:51,752 --> 11:29:52,487
>> is it not true that tampa's

15662
11:29:52,487 --> 11:29:53,353
affiliate has been able to make

15663
11:29:53,353 --> 11:29:55,189
needed investments with rates

15664
11:29:55,189 --> 11:29:58,789
based on its approved board of

15665
11:30:01,496 --> 11:30:02,429
public service commission

15666
11:30:02,429 --> 11:30:03,364
approved roe of 10.15 percent

15667
11:30:03,364 --> 11:30:06,500
since the rates took effect in

15668
11:30:06,500 --> 11:30:07,368
JANUARY of this year?

15669
11:30:07,368 --> 11:30:10,905
>> I am not part of the

15670
11:30:10,905 --> 11:30:11,839
treasury team.

15671
11:30:11,839 --> 11:30:15,776
I do not know what kind of

15672
11:30:15,776 --> 11:30:16,410
issues they have raising

15673
11:30:16,410 --> 11:30:18,410
capital.

15674
11:30:22,917 --> 11:30:23,184
>> I will ask you a similar

15675
11:30:23,184 --> 11:30:24,117
question.

15676
11:30:24,117 --> 11:30:25,190
Have you been aware of anything

15677
11:30:25,190 --> 11:30:26,554
that they have not been able to

15678
11:30:26,554 --> 11:30:27,540
make and necessary investments?

15679
11:30:27,540 --> 11:30:29,454
>> I do not know.

15680
11:30:31,692 --> 11:30:32,660
Probably, probably not.

15681
11:30:32,660 --> 11:30:33,494
>> and you were a witness in

15682
11:30:33,494 --> 11:30:35,494
the case correct?

15683
11:30:43,270 --> 11:30:44,238
>> yes I was.

15684
11:30:44,238 --> 11:30:44,438
>> I think we have covered

15685
11:30:44,438 --> 11:30:46,438
this.

15686
11:30:48,275 --> 11:30:49,277
Is it true that the 10.15

15687
11:30:49,277 --> 11:30:51,545
percent at the psc approved for

15688
11:30:51,545 --> 11:30:52,546
peoples was 65 basis points

15689
11:30:52,546 --> 11:30:55,546
above the us national average

15690
11:30:57,818 --> 11:30:58,850
for gas utilities.

15691
11:30:58,850 --> 11:30:58,886
>> yes.

15692
11:30:58,886 --> 11:31:00,886
Octor shows how

15693
11:31:01,822 --> 11:31:04,222
little weight the commission

15694
11:31:07,762 --> 11:31:07,961
staff have on national average

15695
11:31:07,961 --> 11:31:09,961
roe's.

15696
11:31:12,320 --> 11:31:14,101
>> I think we will allow them

15697
11:31:14,101 --> 11:31:16,704
to decide on their averages.

15698
11:31:16,704 --> 11:31:16,938
Do you agree with that?

15699
11:31:16,938 --> 11:31:18,938
>> sure.

15700
11:31:20,440 --> 11:31:21,108
>> thank you.

15701
11:31:21,108 --> 11:31:24,108
That is all my questions.

15702
11:31:24,278 --> 11:31:24,945
I told you I would be quick.

15703
11:31:24,945 --> 11:31:25,179
How about walmart?

15704
11:31:25,179 --> 11:31:27,179
>> yes.

15705
11:31:34,155 --> 11:31:35,190
Thank you.

15706
11:31:35,190 --> 11:31:35,589
You are not a teco employee are

15707
11:31:35,589 --> 11:31:35,889
you?

15708
11:31:35,889 --> 11:31:36,523
>> I am not.

15709
11:31:36,523 --> 11:31:37,240
>> and you are not an employee

15710
11:31:37,240 --> 11:31:39,424
of the teco affiliate?

15711
11:31:44,332 --> 11:31:45,232
>> I am not.

15712
11:31:45,232 --> 11:31:45,866
You are part of the consulting

15713
11:31:45,866 --> 11:31:46,734
firm in new jersey, correct?

15714
11:31:46,734 --> 11:31:49,470
>> it is based in raleigh.

15715
11:31:49,470 --> 11:31:49,703
But I am stationed in new

15716
11:31:49,703 --> 11:31:50,571
jersey.

15717
11:31:50,571 --> 11:31:54,171
>> and that is where you have

15718
11:31:56,877 --> 11:31:57,378
come from to testify for us

15719
11:31:57,378 --> 11:31:57,978
today?

15720
11:31:57,978 --> 11:31:58,545
You are a paid consultant for

15721
11:31:58,545 --> 11:31:59,146
teco in this matter.

15722
11:31:59,146 --> 11:32:01,146
Is that correct?

15723
11:32:03,217 --> 11:32:03,917
>> I am.

15724
11:32:03,917 --> 11:32:04,885
>> like some of my colleagues,

15725
11:32:04,885 --> 11:32:05,820
I will ask you a few questions

15726
11:32:05,820 --> 11:32:07,200
about your opinions on your

15727
11:32:07,200 --> 11:32:09,200
return in equity.

15728
11:32:10,624 --> 11:32:13,624
On page 31 of your direct

15729
11:32:15,695 --> 11:32:16,129
testimony, you discussed the

15730
11:32:16,129 --> 11:32:18,990
risk premium model.

15731
11:32:18,990 --> 11:32:18,366
Do you recall that discussion,

15732
11:32:18,366 --> 11:32:20,366
generally?

15733
11:32:21,635 --> 11:32:23,635
>> sure.

15734
11:32:28,108 --> 11:32:29,143
>> then, on page 38 you also

15735
11:32:29,143 --> 11:32:31,543
discussed a predictive risk

15736
11:32:33,680 --> 11:32:37,880
premium model or prp m. Do you

15737
11:32:40,420 --> 11:32:40,854
recall that discussion?

15738
11:32:40,854 --> 11:32:41,355
>> yes.

15739
11:32:41,355 --> 11:32:43,755
It is a mouthful.

15740
11:32:52,366 --> 11:32:53,133
I believe on page 41, at lines

15741
11:32:53,133 --> 11:32:54,680
13? 14 of your direct

15742
11:32:54,680 --> 11:32:54,768
testimony, you mentioned that

15743
11:32:54,768 --> 11:32:55,736
the south carolina public

15744
11:32:55,736 --> 11:32:56,771
service commission found your

15745
11:32:56,771 --> 11:32:57,838
arguments persuasive in a 2017

15746
11:32:57,838 --> 11:32:58,338
document involving blue-green

15747
11:32:58,338 --> 11:32:58,973
water company.

15748
11:32:58,973 --> 11:33:01,373
Do you recall that?

15749
11:33:06,547 --> 11:33:07,681
>> yes.

15750
11:33:07,681 --> 11:33:08,482
Would you agree that it is not

15751
11:33:08,482 --> 11:33:08,816
an electric utility case?

15752
11:33:08,816 --> 11:33:09,517
>> it is not.

15753
11:33:09,517 --> 11:33:09,783
>> and that decision was six

15754
11:33:09,783 --> 11:33:11,783
years ago.

15755
11:33:12,186 --> 11:33:13,119
>> that is right.

15756
11:33:13,119 --> 11:33:13,720
>> on page 42 at lines 7

15757
11:33:13,720 --> 11:33:15,189
through 19 you then also

15758
11:33:15,189 --> 11:33:18,189
reference a north carolina city

15759
11:33:19,593 --> 11:33:22,593
commission approval of your rpn

15760
11:33:27,968 --> 11:33:28,468
analyses and docket w3 54 sides

15761
11:33:28,468 --> 11:33:30,468
363, 364, and 365.

15762
11:33:40,814 --> 11:33:41,281
Do you see that?

15763
11:33:41,281 --> 11:33:42,283
>> yes, ma'am.

15764
11:33:42,283 --> 11:33:42,883
>> and would you also agree

15765
11:33:42,883 --> 11:33:43,650
that it was a water case?

15766
11:33:43,650 --> 11:33:44,385
>> yes, ma'am.

15767
11:33:44,385 --> 11:33:45,186
>> for your direct testimony

15768
11:33:45,186 --> 11:33:48,186
exhibit, dwt one which I

15769
11:33:50,891 --> 11:33:51,524
believe is cl exhibit 20 a.

15770
11:33:51,524 --> 11:33:54,940
That north carolina case looks

15771
11:33:54,940 --> 11:33:57,940
like it occurred in JUNE 2019.

15772
11:33:59,633 --> 11:34:00,401
>> that sounds correct.

15773
11:34:00,401 --> 11:34:03,803
It MAY have gone into 2020 by

15774
11:34:03,803 --> 11:34:06,803
the time the decision went.

15775
11:34:08,208 --> 11:34:10,208
>> sure.

15776
11:34:10,377 --> 11:34:11,345
In your direct testimony

15777
11:34:11,345 --> 11:34:12,780
exhibit, was that you were

15778
11:34:12,780 --> 11:34:15,780
trying to capture times where

15779
11:34:22,823 --> 11:34:23,690
you worked on those cases the

15780
11:34:23,690 --> 11:34:24,258
month or the year that you

15781
11:34:24,258 --> 11:34:24,692
worked on this case is?

15782
11:34:24,692 --> 11:34:25,392
>> yes.

15783
11:34:25,392 --> 11:34:26,193
Generally witnesses have their

15784
11:34:26,193 --> 11:34:26,927
cvs and expert witness

15785
11:34:26,927 --> 11:34:28,927
appearances.

15786
11:34:29,196 --> 11:34:31,596
It is simply that.

15787
11:34:32,299 --> 11:34:34,299
>> sure.

15788
11:34:36,103 --> 11:34:39,103
I heard you tell MS.

15789
11:34:42,843 --> 11:34:43,777
Christiansen that you have

15790
11:34:43,777 --> 11:34:44,411
provided testimony and many

15791
11:34:44,411 --> 11:34:45,120
other states which includes

15792
11:34:45,120 --> 11:34:46,460
kentucky and maryland.

15793
11:34:46,460 --> 11:34:48,460
Is that correct?

15794
11:34:49,749 --> 11:34:50,651
>> yes.

15795
11:34:50,651 --> 11:34:51,285
i believe in kentucky you

15796
11:34:51,285 --> 11:34:53,685
presented testimony in case

15797
11:34:58,826 --> 11:34:59,893
number 2020 100190 which was

15798
11:34:59,893 --> 11:35:00,827
the electric application duke

15799
11:35:00,827 --> 11:35:01,695
energy kentucky inc. For an

15800
11:35:01,695 --> 11:35:01,896
adjustment of the natural gas

15801
11:35:01,896 --> 11:35:03,896
rates.

15802
11:35:07,167 --> 11:35:10,167
And all required waivers which

15803
11:35:12,380 --> 11:35:14,438
is kentucky psc ordered

15804
11:35:17,944 --> 11:35:18,578
DECEMBER 20, 2021.

15805
11:35:18,578 --> 11:35:18,979
Does that sound familiar?

15806
11:35:18,979 --> 11:35:20,979
>> yes.

15807
11:35:23,583 --> 11:35:24,251
I believe it was a settlement.

15808
11:35:24,251 --> 11:35:27,251
>> do you recall the duke

15809
11:35:28,322 --> 11:35:29,290
equity recommended at 10.3?

15810
11:35:29,290 --> 11:35:30,560
>> that sounds about right.

15811
11:35:30,560 --> 11:35:32,560
>>

15812
11:35:32,226 --> 11:35:33,860
and you recall whether you

15813
11:35:33,860 --> 11:35:36,860
provided testimony on the stand

15814
11:35:36,964 --> 11:35:38,298
or simply provided testimony

15815
11:35:38,298 --> 11:35:38,565
prior to the matter at

15816
11:35:38,565 --> 11:35:40,565
resolving?

15817
11:35:43,636 --> 11:35:44,704
>> settled and we did go to

15818
11:35:44,704 --> 11:35:44,971
frankfurt and there was no

15819
11:35:44,971 --> 11:35:46,971
questions.

15820
11:35:51,378 --> 11:35:52,279
I was there.

15821
11:35:52,279 --> 11:35:53,313
>> do you recall what the

15822
11:35:53,313 --> 11:35:53,980
kentucky commission said in its

15823
11:35:53,980 --> 11:35:56,980
order about your testimony on

15824
11:36:00,421 --> 11:36:01,388
behalf of of duke kentucky?

15825
11:36:01,388 --> 11:36:02,756
>> I believe they talked about

15826
11:36:02,756 --> 11:36:05,156
the nonregulated proxy group

15827
11:36:06,600 --> 11:36:06,927
giving little weight to it and

15828
11:36:06,927 --> 11:36:07,860
rejecting the prp m and

15829
11:36:07,860 --> 11:36:08,862
similarly, I believe we

15830
11:36:08,862 --> 11:36:09,997
explained earlier that I did

15831
11:36:09,997 --> 11:36:13,597
not consider those in this case

15832
11:36:13,834 --> 11:36:14,167
for my recommendation.

15833
11:36:14,167 --> 11:36:16,167
>> sure.

15834
11:36:16,704 --> 11:36:18,171
Just for the record and to make

15835
11:36:18,171 --> 11:36:21,771
sure that that is accurate, can

15836
11:36:23,610 --> 11:36:26,130
you pull up walmart five which

15837
11:36:26,130 --> 11:36:26,946
is cl 820?

15838
11:36:26,946 --> 11:36:30,546
That is the order in kentucky

15839
11:36:34,321 --> 11:36:36,321
case number 2021? 00110.

15840
11:36:39,225 --> 11:36:39,726
>> and again, that is a

15841
11:36:39,726 --> 11:36:40,427
settlement.

15842
11:36:40,427 --> 11:36:43,427
>> and there is a commission

15843
11:36:45,365 --> 11:36:45,966
order following that case I

15844
11:36:45,966 --> 11:36:46,166
wanted to ask you about that

15845
11:36:46,166 --> 11:36:46,900
order.

15846
11:36:46,900 --> 11:36:47,368
You said you provided

15847
11:36:47,368 --> 11:36:48,902
testimony.

15848
11:36:48,902 --> 11:36:49,503
Correct?

15849
11:36:49,503 --> 11:36:51,903
>> you provided testimony on

15850
11:36:52,940 --> 11:36:53,173
behalf of of duke kentucky,

15851
11:36:53,173 --> 11:36:55,173
correct?

15852
11:36:55,175 --> 11:36:57,175
>> yes.

15853
11:37:02,616 --> 11:37:02,982
I was characterizing this order

15854
11:37:02,982 --> 11:37:03,683
as a settlement.

15855
11:37:03,683 --> 11:37:04,251
>> can you turn to page 14 of

15856
11:37:04,251 --> 11:37:06,251
the commission please?

15857
11:37:10,624 --> 11:37:11,358
>> sure.

15858
11:37:11,358 --> 11:37:14,495
>> I do apologize that I do not

15859
11:37:14,495 --> 11:37:16,895
have the jump page.

15860
11:37:21,467 --> 11:37:21,634
>> it looks like it is fine at

15861
11:37:21,634 --> 11:37:22,469
127.

15862
11:37:22,469 --> 11:37:24,804
>> on page 14 do you agree that

15863
11:37:24,804 --> 11:37:25,705
the commission stated quote due

15864
11:37:25,705 --> 11:37:26,740
to kentucky's use of the

15865
11:37:26,740 --> 11:37:29,140
predictive use premium model

15866
11:37:34,648 --> 11:37:35,549
the the prpm has only been

15867
11:37:35,549 --> 11:37:36,449
addressed and three regulatory

15868
11:37:36,449 --> 11:37:38,849
commissions and is not

15869
11:37:38,919 --> 11:37:39,919
universally accepted in the

15870
11:37:39,919 --> 11:37:40,820
commission further stated that

15871
11:37:40,820 --> 11:37:43,820
they are concerned about the

15872
11:37:51,231 --> 11:37:51,864
blackhawk aspects of the prpm.

15873
11:37:51,864 --> 11:37:52,599
>> MR. CHAIRMAN, I am not sure

15874
11:37:52,599 --> 11:37:54,999
why this is relevant.

15875
11:37:56,370 --> 11:37:57,400
He has indicated that he has

15876
11:37:57,400 --> 11:37:57,204
not used that model in this

15877
11:37:57,204 --> 11:37:57,837
case.

15878
11:37:57,837 --> 11:37:59,873
I do not know why we are

15879
11:37:59,873 --> 11:38:00,808
cross-examining about a model

15880
11:38:00,808 --> 11:38:04,408
that MAY have been rejected by

15881
11:38:05,745 --> 11:38:08,745
another commission and had not

15882
11:38:10,216 --> 11:38:11,217
been used in this commission.

15883
11:38:11,217 --> 11:38:13,820
>> it is included in his direct

15884
11:38:13,820 --> 11:38:14,587
testimony.

15885
11:38:14,587 --> 11:38:15,822
He also said that he did still

15886
11:38:15,822 --> 11:38:18,822
model it in this case.

15887
11:38:19,893 --> 11:38:23,493
In addition, I believe he said

15888
11:38:27,330 --> 11:38:27,768
that he offered commission

15889
11:38:27,768 --> 11:38:28,268
staff and opc the opportunity

15890
11:38:28,268 --> 11:38:29,680
to use this model.

15891
11:38:29,680 --> 11:38:30,270
He disagreed with this

15892
11:38:30,270 --> 11:38:32,270
commission's opinion.

15893
11:38:41,481 --> 11:38:42,482
But it was relevant.

15894
11:38:42,482 --> 11:38:42,949
>> he can answer the question.

15895
11:38:42,949 --> 11:38:44,949
that is fine.

15896
11:38:48,622 --> 11:38:49,389
I do not think he has used it.

15897
11:38:49,389 --> 11:38:51,240
>> that is fine.

15898
11:38:51,240 --> 11:38:51,224
I agree with what the order

15899
11:38:51,224 --> 11:38:53,224
says.

15900
11:38:54,600 --> 11:38:56,629
Like MR. Whelan said, if you

15901
11:38:56,629 --> 11:38:59,632
take a look at page 44 of my

15902
11:38:59,632 --> 11:39:01,632
direct testimony, line 12

15903
11:39:08,608 --> 11:39:10,243
through 45 line 4 says that I

15904
11:39:10,243 --> 11:39:13,243
have changed my application of

15905
11:39:15,482 --> 11:39:17,617
the prpm and I have not

15906
11:39:17,617 --> 11:39:18,518
considered it in my analysis

15907
11:39:18,518 --> 11:39:20,753
while leaving it for you to

15908
11:39:20,753 --> 11:39:21,855
look at.

15909
11:39:21,855 --> 11:39:25,455
In my analysis, this does not

15910
11:39:28,695 --> 11:39:29,663
hold any weight.

15911
11:39:29,663 --> 11:39:32,633
>> in your direct on page 44,

15912
11:39:32,633 --> 11:39:35,633
starting at line 24 that is

15913
11:39:36,936 --> 11:39:38,400
your full answer.

15914
11:39:38,400 --> 11:39:40,404
While I respectfully disagree

15915
11:39:41,975 --> 11:39:42,942
with the commission and by the

15916
11:39:42,942 --> 11:39:44,110
commission you are speaking of

15917
11:39:44,110 --> 11:39:45,945
this commission, correct.

15918
11:39:45,945 --> 11:39:47,945
>> yes.

15919
11:39:49,549 --> 11:39:50,583
>> while you respectfully

15920
11:39:50,583 --> 11:39:52,983
disagree with this commission's

15921
11:39:55,880 --> 11:39:57,880
finding order esc 2023? 3088?

15922
11:40:03,763 --> 11:40:07,363
Fof? G you have presented my

15923
11:40:09,336 --> 11:40:12,172
roe prp m as can be gleaned

15924
11:40:12,172 --> 11:40:12,939
from document number 2. My

15925
11:40:12,939 --> 11:40:15,339
recommendation is still within

15926
11:40:20,130 --> 11:40:20,881
the range of roe's produce

15927
11:40:20,881 --> 11:40:21,414
without the prpm.

15928
11:40:21,414 --> 11:40:22,815
Did I read that correctly?

15929
11:40:22,815 --> 11:40:24,815
>> yes you did.

15930
11:40:26,190 --> 11:40:29,589
But if you look at, I do not

15931
11:40:29,589 --> 11:40:32,589
want to get into semantics.

15932
11:40:38,598 --> 11:40:38,798
I am not considering it in this

15933
11:40:38,798 --> 11:40:39,990
case.

15934
11:40:39,990 --> 11:40:39,766
>> sure.

15935
11:40:39,766 --> 11:40:40,666
I was presenting this kentucky

15936
11:40:40,666 --> 11:40:41,367
order because I did not want

15937
11:40:41,367 --> 11:40:42,769
you to have to just recall it

15938
11:40:42,769 --> 11:40:43,669
off memory.

15939
11:40:43,669 --> 11:40:45,505
I believe you have answered my

15940
11:40:45,505 --> 11:40:47,874
questions as to what it stated.

15941
11:40:47,874 --> 11:40:49,709
I would like to move on to

15942
11:40:49,709 --> 11:40:52,709
asking you some questions about

15943
11:41:00,860 --> 11:41:00,620
a case you presented testimony

15944
11:41:00,620 --> 11:41:01,554
for in maryland.

15945
11:41:01,554 --> 11:41:02,121
do you recall presenting our ot

15946
11:41:02,121 --> 11:41:04,121
testimony in maryland.

15947
11:41:08,940 --> 11:41:09,950
Case number 9490 in the matter

15948
11:41:09,950 --> 11:41:10,630
of the potomac edison company

15949
11:41:10,630 --> 11:41:10,997
to reach retail rates for the

15950
11:41:10,997 --> 11:41:11,231
distribution of electric

15951
11:41:11,231 --> 11:41:13,231
energy.

15952
11:41:16,102 --> 11:41:16,670
Which was a maryland decision.

15953
11:41:16,670 --> 11:41:18,204
MARCH 22, 2019.

15954
11:41:18,204 --> 11:41:18,371
Do you recall?

15955
11:41:18,371 --> 11:41:20,371
>>.

15956
11:41:25,211 --> 11:41:25,912
It was five years ago.

15957
11:41:25,912 --> 11:41:26,680
I do recognize it.

15958
11:41:26,680 --> 11:41:27,614
>> do you recall that you

15959
11:41:27,614 --> 11:41:29,549
recommended a roe of 10.8

15960
11:41:29,549 --> 11:41:31,549
percent?

15961
11:41:35,870 --> 11:41:38,687
>> can I see the order please?

15962
11:41:40,893 --> 11:41:41,427
>> yes it is cl 821.

15963
11:41:41,427 --> 11:41:44,427
And on page 2 of that

15964
11:41:47,834 --> 11:41:50,804
commission order, can you see

15965
11:41:50,804 --> 11:41:51,704
what the maryland commission,

15966
11:41:51,704 --> 11:41:54,104
do you have that?

15967
11:41:54,407 --> 11:41:56,407
>> not yet.

15968
11:41:58,911 --> 11:41:59,579
I do apologize.

15969
11:41:59,579 --> 11:41:59,746
It takes a second to pull it

15970
11:41:59,746 --> 11:42:01,514
up.

15971
11:42:01,514 --> 11:42:04,514
It's very good technology but

15972
11:42:12,459 --> 11:42:12,925
there is definitely a bit of a

15973
11:42:12,925 --> 11:42:13,425
lag.

15974
11:42:13,425 --> 11:42:16,425
>> I will let you know.

15975
11:42:22,736 --> 11:42:22,935
It is still chugging along.

15976
11:42:22,935 --> 11:42:24,935
Okay.

15977
11:42:25,639 --> 11:42:28,639
I think I am there.

15978
11:42:31,745 --> 11:42:33,745
Master of 1974?

15979
11:42:38,485 --> 11:42:39,119
>> do you recall that you had

15980
11:42:39,119 --> 11:42:39,986
recommended a roe of 10.8.

15981
11:42:39,986 --> 11:42:40,654
And that the maryland

15982
11:42:40,654 --> 11:42:43,654
commission ordered a roe of

15983
11:42:45,525 --> 11:42:45,992
9.65 percent?

15984
11:42:45,992 --> 11:42:46,626
>> yes.

15985
11:42:46,626 --> 11:42:49,626
This thing is breaking down.

15986
11:42:52,599 --> 11:42:53,466
But I do recall.

15987
11:42:53,466 --> 11:42:53,666
Can we go to page 74 of that

15988
11:42:53,666 --> 11:42:55,666
order?

15989
11:43:03,943 --> 11:43:06,943
>> I do not think so.

15990
11:43:10,450 --> 11:43:11,384
>> this is pollock staff.

15991
11:43:11,384 --> 11:43:12,419
>> by pollock you are

15992
11:43:12,419 --> 11:43:12,986
referencing MR. Pollick who is

15993
11:43:12,986 --> 11:43:13,319
referenced in this case

15994
11:43:13,319 --> 11:43:15,319
correct?

15995
11:43:21,695 --> 11:43:22,695
>> this is old stuff.

15996
11:43:22,695 --> 11:43:23,697
Do you see on page 74 where the

15997
11:43:23,697 --> 11:43:24,663
maryland commission refers to

15998
11:43:24,663 --> 11:43:26,933
the baltimore gas and electric

15999
11:43:26,933 --> 11:43:27,433
case?

16000
11:43:27,433 --> 11:43:29,433
2011.

16001
11:43:32,104 --> 11:43:35,104
Do you see that reference?

16002
11:43:39,110 --> 11:43:40,130
>> yes.

16003
11:43:40,130 --> 11:43:40,980
>> in that footnote 269, the

16004
11:43:40,980 --> 11:43:41,648
maryland commission states that

16005
11:43:41,648 --> 11:43:44,648
they have previously found that

16006
11:43:45,185 --> 11:43:47,585
included regulated proxy groups

16007
11:43:48,921 --> 11:43:51,921
that are significantly out of

16008
11:43:53,392 --> 11:43:53,626
line for regulated distribution

16009
11:43:53,626 --> 11:43:54,270
company.

16010
11:43:54,270 --> 11:43:56,162
Do you see that?

16011
11:43:56,162 --> 11:43:58,162
>> yes.

16012
11:43:59,320 --> 11:44:00,833
On page 75, the commission

16013
11:44:00,833 --> 11:44:03,233
further finds that the

16014
11:44:05,939 --> 11:44:06,939
adjustments proposed by potomac

16015
11:44:06,939 --> 11:44:09,339
edison were business risk,

16016
11:44:11,778 --> 11:44:12,278
credit risk, and flotation

16017
11:44:12,278 --> 11:44:12,479
should be rejected.

16018
11:44:12,479 --> 11:44:12,912
O you see

16019
11:44:12,912 --> 11:44:14,912
that?

16020
11:44:15,515 --> 11:44:16,282
>> yes.

16021
11:44:16,282 --> 11:44:16,983
>> and those are

16022
11:44:16,983 --> 11:44:19,383
recommendations that you made,

16023
11:44:22,555 --> 11:44:23,560
correct?

16024
11:44:23,560 --> 11:44:23,656
>> yes.

16025
11:44:23,656 --> 11:44:24,557
But in the people's gas case,

16026
11:44:24,557 --> 11:44:25,591
they accepted my flotation cost

16027
11:44:25,591 --> 11:44:28,394
analysis using the same parent

16028
11:44:28,394 --> 11:44:28,627
company and same sister

16029
11:44:28,627 --> 11:44:29,128
company.

16030
11:44:29,128 --> 11:44:32,128
And that was last year.

16031
11:44:32,265 --> 11:44:32,866
Not five years ago.

16032
11:44:32,866 --> 11:44:34,867
It was in florida.

16033
11:44:34,867 --> 11:44:36,867
Not in maryland.

16034
11:44:38,137 --> 11:44:40,537
The more relevant decision

16035
11:44:41,841 --> 11:44:45,441
would be the people's gas case.

16036
11:44:46,712 --> 11:44:47,446
As far as my recommendation as

16037
11:44:47,446 --> 11:44:51,500
compared to if we want to go up

16038
11:44:51,500 --> 11:44:51,250
to page 73,

16039
11:44:51,250 --> 11:44:52,952
>> no.

16040
11:44:52,952 --> 11:44:55,352
I finished my questions.

16041
11:45:00,225 --> 11:45:03,825
I would like to move along.

16042
11:45:07,600 --> 11:45:08,501
I have prepared a chart which

16043
11:45:08,501 --> 11:45:09,469
charts the kentucky case that

16044
11:45:09,469 --> 11:45:11,869
we just looked at.

16045
11:45:12,939 --> 11:45:13,573
in the maryland case as well as

16046
11:45:13,573 --> 11:45:16,900
others for which you have

16047
11:45:16,900 --> 11:45:18,409
testified the information about

16048
11:45:18,944 --> 11:45:21,881
which cases you have testified

16049
11:45:21,881 --> 11:45:22,882
in comes from your cv.

16050
11:45:22,882 --> 11:45:26,119
Which is exhibit dwd one to

16051
11:45:26,119 --> 11:45:29,119
your direct testimony I would

16052
11:45:30,456 --> 11:45:32,925
like to pull up chart which has

16053
11:45:32,925 --> 11:45:36,862
been marked as cl 819 and it is

16054
11:45:36,862 --> 11:45:38,862
walmart four.

16055
11:45:43,803 --> 11:45:44,736
This is intended to make it a

16056
11:45:44,736 --> 11:45:45,405
little bit faster and easier

16057
11:45:45,405 --> 11:45:45,838
than going through all the

16058
11:45:45,838 --> 11:45:47,390
cases.

16059
11:45:47,390 --> 11:45:50,639
I have simply selected a few.

16060
11:45:52,944 --> 11:45:53,979
Do you see the chart yet?

16061
11:45:53,979 --> 11:45:56,379
>> the kentucky and maryland

16062
11:45:57,684 --> 11:45:58,117
cases are on the chart as well

16063
11:45:58,117 --> 11:46:00,117
as others.

16064
11:46:03,523 --> 11:46:04,190
Is that correct?

16065
11:46:04,190 --> 11:46:05,191
>> kentucky is a settlement.

16066
11:46:05,191 --> 11:46:06,159
New jersey is a settlement.

16067
11:46:06,159 --> 11:46:06,459
The north carolina ones are

16068
11:46:06,459 --> 11:46:08,459
settlements.

16069
11:46:09,528 --> 11:46:11,898
Both texas are settlements.

16070
11:46:11,898 --> 11:46:14,298
These are fully litigated.

16071
11:46:18,805 --> 11:46:19,739
In the second one is not.

16072
11:46:19,739 --> 11:46:20,740
>> to do all of these cases

16073
11:46:20,740 --> 11:46:21,274
appear to be cases in which you

16074
11:46:21,274 --> 11:46:22,341
have provided testimony?

16075
11:46:22,341 --> 11:46:22,507
>

16076
11:46:22,507 --> 11:46:24,507
yes.

16077
11:46:26,279 --> 11:46:29,248
Does the chart show recommended

16078
11:46:29,248 --> 11:46:32,848
rotc made as well as either

16079
11:46:38,124 --> 11:46:38,391
stipulated or litigated

16080
11:46:38,391 --> 11:46:39,258
outcomes?

16081
11:46:39,258 --> 11:46:40,159
>> subject to check, do you

16082
11:46:40,159 --> 11:46:41,127
agree that the recommendations

16083
11:46:41,127 --> 11:46:43,127
accurately reflect your

16084
11:46:45,531 --> 11:46:46,465
recommendations in these cases?

16085
11:46:46,465 --> 11:46:48,301
>> there MAY be times where

16086
11:46:48,301 --> 11:46:49,167
recommended a range.

16087
11:46:49,167 --> 11:46:52,767
But I would take that subject

16088
11:46:58,678 --> 11:46:59,512
to change.

16089
11:46:59,512 --> 11:47:00,513
>> do you agree that these

16090
11:47:00,513 --> 11:47:01,546
outcomes reflect the actual

16091
11:47:01,546 --> 11:47:04,546
release that were stipulated or

16092
11:47:05,284 --> 11:47:05,651
authorized after litigation?

16093
11:47:05,651 --> 11:47:06,585
>> yes.

16094
11:47:06,585 --> 11:47:07,586
I do believe we have talked

16095
11:47:07,586 --> 11:47:09,550
enough about the circumstances

16096
11:47:09,550 --> 11:47:11,550
surrounding settled roe's.

16097
11:47:11,900 --> 11:47:14,600
They are part of a package.

16098
11:47:14,600 --> 11:47:16,862
If one piece falls apart then

16099
11:47:16,862 --> 11:47:18,862
everything falls apart.

16100
11:47:19,966 --> 11:47:20,166
It is a product of give and

16101
11:47:20,166 --> 11:47:20,967
take.

16102
11:47:20,967 --> 11:47:22,869
These are not specifically

16103
11:47:22,869 --> 11:47:24,869
market-based numbers.

16104
11:47:27,473 --> 11:47:29,174
Or precedent-setting.

16105
11:47:29,174 --> 11:47:29,842
>> I do appreciate your

16106
11:47:29,842 --> 11:47:30,977
opinion.

16107
11:47:30,977 --> 11:47:31,711
I need you to stick to the

16108
11:47:31,711 --> 11:47:35,311
questions so that we can get

16109
11:47:35,947 --> 11:47:36,849
through this.

16110
11:47:36,849 --> 11:47:37,583
Have any stipulated or

16111
11:47:37,583 --> 11:47:39,452
litigated outcomes come out on

16112
11:47:39,452 --> 11:47:42,452
this chart match the release

16113
11:47:48,600 --> 11:47:48,394
that you have recommended?

16114
11:47:48,394 --> 11:47:49,361
>> no.

16115
11:47:49,361 --> 11:47:50,290
>> many of these outcomes are

16116
11:47:50,290 --> 11:47:52,429
100 basis points lower than

16117
11:47:56,769 --> 11:47:57,200
your recommendation is that

16118
11:47:57,200 --> 11:47:59,200
correct?

16119
11:48:07,613 --> 11:48:08,581
>> if you are.

16120
11:48:08,581 --> 11:48:09,548
>> would you not agree that the

16121
11:48:09,548 --> 11:48:10,149
roe's that utilities agree to

16122
11:48:10,149 --> 11:48:12,549
reflect roe's that the

16123
11:48:14,887 --> 11:48:17,287
utilities agree can support

16124
11:48:18,824 --> 11:48:19,325
sufficient capital needed for

16125
11:48:19,325 --> 11:48:20,590
investments?

16126
11:48:20,590 --> 11:48:21,627
>> I do not know why they enter

16127
11:48:21,627 --> 11:48:23,627
the settlements.

16128
11:48:26,665 --> 11:48:27,199
I am never in the room with

16129
11:48:27,199 --> 11:48:27,799
them.

16130
11:48:27,799 --> 11:48:29,168
Generally they come up with a

16131
11:48:29,168 --> 11:48:31,568
package with the other

16132
11:48:34,139 --> 11:48:35,740
interveners and they move on.

16133
11:48:35,740 --> 11:48:38,674
>> do you contend that any of

16134
11:48:40,646 --> 11:48:41,581
the utilities on this chart

16135
11:48:41,581 --> 11:48:42,314
have not been able to provide

16136
11:48:42,314 --> 11:48:43,949
safe and reliable service with

16137
11:48:43,949 --> 11:48:44,182
the roe's that they were

16138
11:48:44,182 --> 11:48:46,182
awarded?

16139
11:48:47,587 --> 11:48:48,554
>> it depends.

16140
11:48:48,554 --> 11:48:50,289
Some of them went right back in

16141
11:48:50,289 --> 11:48:51,323
and filed these cases.

16142
11:48:51,323 --> 11:48:54,923
Because they did not get what

16143
11:48:56,461 --> 11:48:58,461
they wanted.

16144
11:48:59,231 --> 11:49:01,231
Like sps.

16145
11:49:01,801 --> 11:49:04,801
they went right back in.

16146
11:49:11,210 --> 11:49:12,780
The next year.

16147
11:49:12,780 --> 11:49:12,845
>> would you consider duke

16148
11:49:12,845 --> 11:49:15,845
energy florida the closest peer

16149
11:49:16,649 --> 11:49:19,151
to teco in the same state?

16150
11:49:19,151 --> 11:49:22,151
As in a similar environment

16151
11:49:27,930 --> 11:49:27,526
I.E., in florida coastal and

16152
11:49:27,526 --> 11:49:27,660
hurricane risk?

16153
11:49:27,660 --> 11:49:28,961
> no.

16154
11:49:28,961 --> 11:49:31,961
>> what would you consider a

16155
11:49:34,567 --> 11:49:36,567
look closest peer?

16156
11:49:41,340 --> 11:49:42,307
>> you cannot compare the two.

16157
11:49:42,307 --> 11:49:42,908
There is a fair amount of

16158
11:49:42,908 --> 11:49:45,308
discussion with MR. Collins

16159
11:49:45,378 --> 11:49:46,846
about how much bigger duke

16160
11:49:46,846 --> 11:49:49,846
florida is compared to teco.

16161
11:49:53,919 --> 11:49:55,221
In preparation of my testimony

16162
11:49:55,221 --> 11:49:57,621
and of this cross-examination,

16163
11:50:02,761 --> 11:50:03,596
I reviewed the teco danger

16164
11:50:03,596 --> 11:50:05,765
scores of the counties served

16165
11:50:05,765 --> 11:50:06,640
by duke florida and tampa

16166
11:50:06,640 --> 11:50:08,640
electric.

16167
11:50:11,737 --> 11:50:11,903
The danger score for teco is

16168
11:50:11,903 --> 11:50:13,473
98.

16169
11:50:13,473 --> 11:50:15,873
Which is categorically high.

16170
11:50:16,642 --> 11:50:19,244
And the danger score for duke

16171
11:50:19,244 --> 11:50:21,644
florida is 83 which is

16172
11:50:23,849 --> 11:50:25,849
significantly less.

16173
11:50:27,753 --> 11:50:28,254
You cannot talk about

16174
11:50:28,254 --> 11:50:30,254
comparability.

16175
11:50:33,224 --> 11:50:33,859
Every company has unique risks.

16176
11:50:33,859 --> 11:50:34,994
>> we have to stick to the

16177
11:50:34,994 --> 11:50:37,394
question I ask you.

16178
11:50:38,597 --> 11:50:40,597
You said no.

16179
11:50:43,969 --> 11:50:44,837
So with respect to duke energy,

16180
11:50:44,837 --> 11:50:47,837
is it duke energy corporation

16181
11:50:48,474 --> 11:50:49,374
and some of its subsidiaries

16182
11:50:49,374 --> 11:50:52,374
part of your proxy group?

16183
11:50:52,944 --> 11:50:53,544
>> yes.

16184
11:50:53,544 --> 11:50:57,144
When you select a proxy group

16185
11:50:59,151 --> 11:51:01,920
you do not get exact replicas

16186
11:51:01,920 --> 11:51:03,920
of teco energy.

16187
11:51:04,690 --> 11:51:05,423
I am asking you whether or not

16188
11:51:05,423 --> 11:51:08,694
it is okay to say yes, sir no

16189
11:51:08,694 --> 11:51:09,628
to this?

16190
11:51:09,628 --> 11:51:12,628
Is duke energy florida the

16191
11:51:19,805 --> 11:51:20,339
closest peer utility to teco in

16192
11:51:20,339 --> 11:51:21,600
florida?

16193
11:51:21,600 --> 11:51:23,406
>> how many more qualifiers.

16194
11:51:24,209 --> 11:51:27,809
I would say they are similar.

16195
11:51:28,814 --> 11:51:31,214
as they are 100 percent

16196
11:51:41,626 --> 11:51:44,260
regulated it electric utility

16197
11:51:47,320 --> 11:51:47,933
companies.

16198
11:51:47,933 --> 11:51:50,803
>> want to ask you some

16199
11:51:50,803 --> 11:51:51,303
questions about your rebuttal

16200
11:51:51,303 --> 11:51:53,104
testimony.

16201
11:51:53,104 --> 11:51:56,104
On page 3 line 6? Seven you

16202
11:51:58,142 --> 11:51:59,378
reiterate your recommendation

16203
11:51:59,378 --> 11:51:59,745
of the 11 and a half roe.

16204
11:51:59,745 --> 11:51:59,979
Is that correct?

16205
11:51:59,979 --> 11:52:01,979
>> yes.

16206
11:52:03,549 --> 11:52:06,549
In your rebuttal you responded

16207
11:52:08,754 --> 11:52:09,621
with witnesses direct testimony

16208
11:52:09,621 --> 11:52:09,889
on the issue 39 which is the

16209
11:52:09,889 --> 11:52:10,356
roe issue.

16210
11:52:10,356 --> 11:52:12,356
Is that correct?

16211
11:52:15,527 --> 11:52:16,494
>> yes.

16212
11:52:16,494 --> 11:52:19,494
>> on page 2 of your rebuttal,

16213
11:52:24,970 --> 11:52:25,971
line 6? 19 you identified the

16214
11:52:25,971 --> 11:52:28,971
opposing roe witnesses that you

16215
11:52:29,341 --> 11:52:31,341
are addressing.

16216
11:52:37,315 --> 11:52:37,482
But as

16217
11:52:37,482 --> 11:52:37,982
.

16218
11:52:37,982 --> 11:52:38,450
That is.

16219
11:52:38,450 --> 11:52:40,450
[Listing names].

16220
11:52:41,953 --> 11:52:44,953
Do you understand that doctor.

16221
11:52:49,294 --> 11:52:52,294
[Listing names] Is working with

16222
11:52:56,969 --> 11:52:57,502
the other people.

16223
11:52:57,502 --> 11:52:58,336
>> subject to check.

16224
11:52:58,336 --> 11:52:59,338
That is what the office of

16225
11:52:59,338 --> 11:53:00,390
public council represents.

16226
11:53:00,390 --> 11:53:01,840
Christopher walters, the

16227
11:53:01,840 --> 11:53:04,240
federal executive agencies is

16228
11:53:05,343 --> 11:53:06,211
testifying on behalf of of

16229
11:53:06,211 --> 11:53:08,611
those military and other

16230
11:53:10,816 --> 11:53:12,816
federal agencies.

16231
11:53:14,186 --> 11:53:17,786
>> steve chris is a witness for

16232
11:53:18,557 --> 11:53:20,759
the florida retail iteration

16233
11:53:20,759 --> 11:53:21,920
including my client, walmart

16234
11:53:21,920 --> 11:53:23,920
incorporated.

16235
11:53:23,729 --> 11:53:26,698
And MR. Pollick is a witness on

16236
11:53:26,698 --> 11:53:28,990
behalf of of all industrial

16237
11:53:28,990 --> 11:53:29,901
user customers.

16238
11:53:29,901 --> 11:53:31,901
>> yes.

16239
11:53:35,273 --> 11:53:36,508
And carl is also representing

16240
11:53:36,508 --> 11:53:38,508
residential customers correct?

16241
11:53:40,279 --> 11:53:41,212
>> yes.

16242
11:53:41,212 --> 11:53:42,280
>> that means that all five

16243
11:53:42,280 --> 11:53:44,680
witnesses disagreed that teco

16244
11:53:47,352 --> 11:53:47,853
should be given an 11.5 hourly

16245
11:53:47,853 --> 11:53:49,853
is that correct?

16246
11:53:49,854 --> 11:53:50,789
>> yes.

16247
11:53:50,789 --> 11:53:53,789
Only two of them provided

16248
11:54:03,635 --> 11:54:04,602
market analysis.

16249
11:54:04,602 --> 11:54:08,202
>> I believe that was one of

16250
11:54:12,411 --> 11:54:12,944
the criticisms that you had of

16251
11:54:12,944 --> 11:54:13,779
MR. Chris's testimony.

16252
11:54:13,779 --> 11:54:17,379
But he did not undertake a

16253
11:54:21,320 --> 11:54:23,320
market-based analysis of.

16254
11:54:23,688 --> 11:54:25,688
Teco's roe.

16255
11:54:29,361 --> 11:54:32,361
When you look at regulated

16256
11:54:38,403 --> 11:54:38,637
teco, they do not look at

16257
11:54:38,637 --> 11:54:39,538
market.

16258
11:54:39,538 --> 11:54:40,439
>> when you're talking about

16259
11:54:40,439 --> 11:54:41,440
market-based analyses, the

16260
11:54:41,440 --> 11:54:41,940
market data moves with market

16261
11:54:41,940 --> 11:54:43,940
actions.

16262
11:54:47,379 --> 11:54:48,280
Authoress returns do not.

16263
11:54:48,280 --> 11:54:49,347
>> do you consider what MR.

16264
11:54:49,347 --> 11:54:49,548
Chris did was analyze market

16265
11:54:49,548 --> 11:54:51,548
data.

16266
11:54:52,684 --> 11:54:54,684
>> yes.

16267
11:54:57,789 --> 11:54:59,791
More observations and analysis.

16268
11:54:59,791 --> 11:55:02,791
>> so, they did use analytical

16269
11:55:06,931 --> 11:55:07,990
models because they used the

16270
11:55:07,990 --> 11:55:07,532
dcf.

16271
11:55:07,532 --> 11:55:07,899
Is that correct?

16272
11:55:07,899 --> 11:55:08,900
>> yes.

16273
11:55:08,900 --> 11:55:12,500
And MR. Walters uses the risk

16274
11:55:12,637 --> 11:55:13,237
premium model.

16275
11:55:13,237 --> 11:55:13,972
>> would you agree that this

16276
11:55:13,972 --> 11:55:16,740
commission is not bound to

16277
11:55:16,740 --> 11:55:19,740
adopt any analysis and setting

16278
11:55:23,482 --> 11:55:23,649
an authorized early?

16279
11:55:23,649 --> 11:55:24,483
Roe?

16280
11:55:24,483 --> 11:55:25,283
>> and you would say that this

16281
11:55:25,283 --> 11:55:27,683
commission has broad discretion

16282
11:55:29,754 --> 11:55:30,254
to talk about a number of

16283
11:55:30,254 --> 11:55:32,254
variables correct?

16284
11:55:34,358 --> 11:55:35,293
>> yes.

16285
11:55:35,293 --> 11:55:35,927
In fact we MAY talk about

16286
11:55:35,927 --> 11:55:37,563
recent roe's that we have

16287
11:55:37,563 --> 11:55:38,596
approved correct?

16288
11:55:38,596 --> 11:55:42,670
>> it would be against what is

16289
11:55:42,670 --> 11:55:44,670
usually done.

16290
11:55:45,304 --> 11:55:47,304
But yes.

16291
11:55:50,976 --> 11:55:51,877
Isn't that true?

16292
11:55:51,877 --> 11:55:52,377
>> again, it's against what

16293
11:55:52,377 --> 11:55:54,377
they usually do.

16294
11:55:54,979 --> 11:55:56,515
But yes, they could.

16295
11:55:56,515 --> 11:56:00,115
>> I would like to return to

16296
11:56:01,987 --> 11:56:02,220
the previous roe's in this

16297
11:56:02,220 --> 11:56:04,220
docket.

16298
11:56:10,361 --> 11:56:10,662
Do you recall these were

16299
11:56:10,662 --> 11:56:12,662
recommended?

16300
11:56:13,131 --> 11:56:15,131
>> idea.

16301
11:56:17,535 --> 11:56:18,170
>> I can list them off.

16302
11:56:18,170 --> 11:56:21,770
And ask you for subject to

16303
11:56:25,677 --> 11:56:26,244
check if you would like.

16304
11:56:26,244 --> 11:56:28,780
>> I'm sure you will try.

16305
11:56:28,780 --> 11:56:31,780
Subject to check, to doctor

16306
11:56:31,983 --> 11:56:33,983
woolridge, the witness

16307
11:56:39,924 --> 11:56:40,158
recommend an rotc of 9.5

16308
11:56:40,158 --> 11:56:40,959
percent?

16309
11:56:40,959 --> 11:56:41,993
>> for christopher walters

16310
11:56:41,993 --> 11:56:42,226
recommended an rotc of 9.6

16311
11:56:42,226 --> 11:56:44,226
percent?

16312
11:56:51,103 --> 11:56:54,103
>> within a range of 880? It

16313
11:56:54,539 --> 11:56:56,341
looks like 1143.

16314
11:56:56,341 --> 11:56:59,341
MR. Walters at an indicated

16315
11:57:01,579 --> 11:57:02,480
rotc of 1143.

16316
11:57:02,480 --> 11:57:04,348
This is all shown in my

16317
11:57:04,348 --> 11:57:07,348
document number 11 which is the

16318
11:57:09,530 --> 11:57:09,253
histogram of his indicated

16319
11:57:09,253 --> 11:57:09,788
rotc.

16320
11:57:09,788 --> 11:57:12,788
>> what did you call it?

16321
11:57:14,492 --> 11:57:15,327
I histogram?

16322
11:57:15,327 --> 11:57:18,327
>> if you could pull up

16323
11:57:19,970 --> 11:57:20,980
document number 11, page 1.

16324
11:57:20,980 --> 11:57:23,980
Could you describe in words

16325
11:57:24,969 --> 11:57:26,103
what you mean as a histogram?

16326
11:57:26,103 --> 11:57:28,503
>> pictures are typically more

16327
11:57:32,243 --> 11:57:33,344
than words.

16328
11:57:33,344 --> 11:57:33,511
>> it is exhibit w d2, document

16329
11:57:33,511 --> 11:57:35,511
11.

16330
11:58:14,819 --> 11:58:15,353
Page 101.

16331
11:58:15,353 --> 11:58:17,353
So,

16332
11:58:18,824 --> 11:58:20,824
>> there it is.

16333
11:58:27,199 --> 11:58:27,832
This is a histogram of MR.

16334
11:58:27,832 --> 11:58:28,766
Walters our ot results.

16335
11:58:28,766 --> 11:58:32,366
This is the history of data.

16336
11:58:34,500 --> 11:58:34,939
Within a population of results.

16337
11:58:34,939 --> 11:58:37,542
If you see the histogram, you

16338
11:58:37,542 --> 11:58:40,678
could see that the majority of

16339
11:58:40,678 --> 11:58:42,380
this is beyond recommendation.

16340
11:58:42,380 --> 11:58:44,780
>> are you calling the

16341
11:58:44,782 --> 11:58:47,182
histogram the bar chart?

16342
11:58:50,288 --> 11:58:51,556
>> that's all I was asking you.

16343
11:58:51,556 --> 11:58:54,556
So, you disagreed that MR.

16344
11:58:55,993 --> 11:58:58,393
Walters in this case

16345
11:58:58,797 --> 11:58:59,431
recommended a roe of 9.6

16346
11:58:59,431 --> 11:59:01,431
percent?

16347
11:59:03,901 --> 11:59:04,436
>> I was expressing a range.

16348
11:59:04,436 --> 11:59:06,703
>> did you see his

16349
11:59:06,703 --> 11:59:08,703
recommendation at 9.6?

16350
11:59:09,700 --> 11:59:09,240
>> that does not reflect his

16351
11:59:09,240 --> 11:59:11,240
results.

16352
11:59:13,444 --> 11:59:13,845
And it was in my rebuttal

16353
11:59:13,845 --> 11:59:14,445
testimony.

16354
11:59:14,445 --> 11:59:17,445
>> did you see MR. Pollick

16355
11:59:19,784 --> 11:59:20,751
recommend a roe of 9.8 percent?

16356
11:59:20,751 --> 11:59:22,487
>> I do believe that was based

16357
11:59:22,487 --> 11:59:24,487
on the average.

16358
11:59:25,222 --> 11:59:27,222
>> subject to check.

16359
11:59:30,929 --> 11:59:33,731
>> do you recall the doctor

16360
11:59:33,731 --> 11:59:33,964
recommending a roe of 9.5

16361
11:59:33,964 --> 11:59:35,964
percent?

16362
11:59:36,768 --> 11:59:39,871
Do you recall MR. Chris, the

16363
11:59:39,871 --> 11:59:42,871
witness for f art of

16364
11:59:44,308 --> 11:59:47,908
referencing a range to date the

16365
11:59:48,313 --> 11:59:50,713
2021? 2024 average as of the

16366
11:59:50,748 --> 11:59:53,748
time his testimony was 9.62 and

16367
11:59:55,152 --> 11:59:56,540
thus far was 9.72?

16368
11:59:56,540 --> 11:59:58,889
>> I do not believe he provided

16369
11:59:58,889 --> 12:00:00,889
a recommendation.

16370
12:00:02,627 --> 12:00:02,827
>> he did not recommend a

16371
12:00:02,827 --> 12:00:04,827
range.

16372
12:00:07,980 --> 12:00:07,365
Frankly, he did not conduct an

16373
12:00:07,365 --> 12:00:08,132
analysis.

16374
12:00:08,132 --> 12:00:08,399
>> do you recall that

16375
12:00:08,399 --> 12:00:10,399
testimony?

16376
12:00:12,137 --> 12:00:13,104
>> yes.

16377
12:00:13,104 --> 12:00:14,339
>> would you agree that none of

16378
12:00:14,339 --> 12:00:16,739
these witnesses recommend or

16379
12:00:19,100 --> 12:00:19,343
support a roe above 9.7

16380
12:00:19,343 --> 12:00:21,343
percent?

16381
12:00:21,479 --> 12:00:23,247
>> I agree with that.

16382
12:00:23,247 --> 12:00:25,647
Their individual model results

16383
12:00:28,386 --> 12:00:30,386
indicate higher roe's.

16384
12:00:31,550 --> 12:00:31,922
>> would you say that there is

16385
12:00:31,922 --> 12:00:33,922
a significant difference

16386
12:00:35,793 --> 12:00:36,728
between these?

16387
12:00:36,728 --> 12:00:37,495
>> would you also agree that

16388
12:00:37,495 --> 12:00:39,895
the difference between 11 and

16389
12:00:40,732 --> 12:00:43,732
half percent and 9.8 percent is

16390
12:00:48,600 --> 12:00:48,206
over $100 million subject to

16391
12:00:48,206 --> 12:00:50,206
check?

16392
12:00:54,312 --> 12:00:57,312
>> still, I do not know.

16393
12:01:00,484 --> 12:01:01,520
>> stop has no questions.

16394
12:01:01,520 --> 12:01:03,520
Commissioners:

16395
12:01:03,921 --> 12:01:05,921
>> this is quick.

16396
12:01:07,425 --> 12:01:09,260
When you pick proxy groups, a

16397
12:01:09,260 --> 12:01:10,280
number that you put in for your

16398
12:01:10,280 --> 12:01:13,628
analysis, is that the same for

16399
12:01:13,931 --> 12:01:16,931
every time there appears a

16400
12:01:19,537 --> 12:01:21,937
witness for another utility?

16401
12:01:24,909 --> 12:01:25,142
>> it depends on the type of

16402
12:01:25,142 --> 12:01:25,877
company.

16403
12:01:25,877 --> 12:01:26,511
If it is an electric group,

16404
12:01:26,511 --> 12:01:27,378
since there is a large

16405
12:01:27,378 --> 12:01:29,680
population of them, I am able

16406
12:01:29,680 --> 12:01:32,680
to tighten the screws down

16407
12:01:33,151 --> 12:01:35,860
unregulated assets attributable

16408
12:01:35,860 --> 12:01:38,686
to regulated service to try and

16409
12:01:39,823 --> 12:01:42,594
get them closer to 100 percent

16410
12:01:42,594 --> 12:01:44,562
pure play.

16411
12:01:44,562 --> 12:01:48,162
But, if there is a water

16412
12:01:48,599 --> 12:01:49,667
company that has a limited

16413
12:01:49,667 --> 12:01:49,868
number, you kind of relax the

16414
12:01:49,868 --> 12:01:51,868
range.

16415
12:01:54,238 --> 12:01:58,209
To get where you can to have a

16416
12:01:58,209 --> 12:01:58,576
robust analysis.

16417
12:01:58,576 --> 12:02:00,576
>> thank you.

16418
12:02:01,145 --> 12:02:03,145
>> no further questions.

16419
12:02:03,615 --> 12:02:04,582
>> thank you MR. CHAIRMAN.

16420
12:02:04,582 --> 12:02:06,684
And thank you for the help of

16421
12:02:06,684 --> 12:02:10,284
the staff getting a couple of

16422
12:02:11,122 --> 12:02:12,256
these things printed out.

16423
12:02:12,256 --> 12:02:16,456
We are handing out a couple of

16424
12:02:20,631 --> 12:02:24,231
orders and filings in the case

16425
12:02:26,137 --> 12:02:27,380
that was subject to the

16426
12:02:27,380 --> 12:02:29,438
document and identified as

16427
12:02:29,740 --> 12:02:31,740
exhibit 839.

16428
12:03:13,185 --> 12:03:16,295
I would like to ask about

16429
12:03:16,295 --> 12:03:16,396
these.

16430
12:03:16,396 --> 12:03:16,489
MR. CHAIRMAN, just for

16431
12:03:16,489 --> 12:03:17,788
simplicity purposes, I wonder

16432
12:03:17,788 --> 12:03:20,858
if we could get a document

16433
12:03:20,858 --> 12:03:20,992
number four and exhibit number

16434
12:03:20,992 --> 12:03:22,992
4.

16435
12:03:23,894 --> 12:03:26,294
Delta natural gas companies

16436
12:03:26,964 --> 12:03:27,298
notice of witness every

16437
12:03:27,298 --> 12:03:29,298
substitution.

16438
12:03:29,899 --> 12:03:31,899
That would be 8:40.

16439
12:03:38,309 --> 12:03:39,210
>> I believe we are at 8:40.

16440
12:03:39,210 --> 12:03:40,845
Within the second document

16441
12:03:40,845 --> 12:03:43,845
which is entitled order and

16442
12:03:47,418 --> 12:03:50,418
appears to be dated NOVEMBER

16443
12:03:53,623 --> 12:03:55,526
12, we can make that 841?

16444
12:03:55,526 --> 12:03:57,526
>> yes.

16445
12:03:59,463 --> 12:04:02,463
>> if you recall, you were

16446
12:04:02,633 --> 12:04:05,330
asked about document 839 which

16447
12:04:05,936 --> 12:04:09,536
is an order that indicates that

16448
12:04:16,615 --> 12:04:17,316
you adopted MR. Mel's direct

16449
12:04:17,316 --> 12:04:20,916
testimony after he had been in

16450
12:04:23,387 --> 12:04:24,155
a bicycle accident?

16451
12:04:24,155 --> 12:04:24,488
I would like you to look at

16452
12:04:24,488 --> 12:04:25,255
document 840.

16453
12:04:25,255 --> 12:04:25,523
Are you familiar with that

16454
12:04:25,523 --> 12:04:27,523
document?

16455
12:04:30,660 --> 12:04:32,296
>> yes.

16456
12:04:32,296 --> 12:04:36,496
And is that a filing that the

16457
12:04:38,135 --> 12:04:39,470
utility made is not based

16458
12:04:39,470 --> 12:04:41,470
number 202100185?

16459
12:04:42,572 --> 12:04:44,572
>> yes.

16460
12:04:47,211 --> 12:04:50,811
Would you read for the record,

16461
12:04:53,483 --> 12:04:53,950
just read the whole thing.

16462
12:04:53,950 --> 12:04:54,485
>> sure.

16463
12:04:54,485 --> 12:04:56,485
>> on JULY 27, 2021 delta

16464
12:04:56,754 --> 12:04:59,154
natural gas company provided

16465
12:05:04,562 --> 12:05:05,596
the notice that the direct

16466
12:05:05,596 --> 12:05:06,296
testimony was directed by.

16467
12:05:06,296 --> 12:05:09,296
[Listing names] Due to a

16468
12:05:12,638 --> 12:05:13,303
serious accident that prevented

16469
12:05:13,303 --> 12:05:13,738
MR. [Listing names] As serving

16470
12:05:13,738 --> 12:05:15,738
as a witness.

16471
12:05:17,874 --> 12:05:20,274
On AUGUST 13, MR. [Listing

16472
12:05:22,790 --> 12:05:23,140
names] Had data requests that

16473
12:05:23,140 --> 12:05:26,140
were important to MR. [Listing

16474
12:05:28,286 --> 12:05:29,221
names]'s testimony.

16475
12:05:29,221 --> 12:05:30,756
His health now does not allow

16476
12:05:30,756 --> 12:05:31,220
him to continue with equity

16477
12:05:31,220 --> 12:05:33,220
matters.

16478
12:05:34,958 --> 12:05:37,958
As such, he redirects his

16479
12:05:38,629 --> 12:05:38,863
testimony to MR. [Listing

16480
12:05:38,863 --> 12:05:40,863
names].

16481
12:05:41,640 --> 12:05:43,464
The commission staff requests

16482
12:05:50,807 --> 12:05:51,708
for information from the

16483
12:05:51,708 --> 12:05:52,410
attorney general's first

16484
12:05:52,410 --> 12:05:53,311
request for information.

16485
12:05:53,311 --> 12:05:54,211
MR. [Listing names] Is not

16486
12:05:54,211 --> 12:05:55,947
expected to have further

16487
12:05:55,947 --> 12:05:56,813
involvement in this proceeding.

16488
12:05:56,813 --> 12:05:58,916
>> did you have any further

16489
12:05:58,916 --> 12:06:01,685
involvement in that case after

16490
12:06:01,685 --> 12:06:01,885
SEPTEMBER 20?

16491
12:06:01,885 --> 12:06:02,520
>> no.

16492
12:06:02,520 --> 12:06:05,489
>> I would not ask you to look

16493
12:06:05,489 --> 12:06:08,489
at the document we have

16494
12:06:10,127 --> 12:06:10,661
identified as number 841.

16495
12:06:10,661 --> 12:06:13,610
do you see that?

16496
12:06:14,864 --> 12:06:15,533
>> yes.

16497
12:06:15,533 --> 12:06:15,833
>> without reading the whole

16498
12:06:15,833 --> 12:06:17,833
thing.

16499
12:06:17,935 --> 12:06:21,535
Could you just focus on the

16500
12:06:22,940 --> 12:06:23,607
second paragraph.

16501
12:06:23,607 --> 12:06:26,700
Generally describe what this

16502
12:06:27,812 --> 12:06:29,614
order does.

16503
12:06:29,614 --> 12:06:33,214
>> it says that there is good

16504
12:06:36,554 --> 12:06:37,422
cause to grant delta's notion.

16505
12:06:37,422 --> 12:06:39,822
>> so he readopted his

16506
12:06:40,900 --> 12:06:40,791
additional testimony and then

16507
12:06:40,791 --> 12:06:41,250
testified on behalf of the

16508
12:06:41,250 --> 12:06:43,250
utility.

16509
12:06:45,195 --> 12:06:45,429
And you did not?

16510
12:06:45,429 --> 12:06:47,429
>> yes.

16511
12:06:47,765 --> 12:06:49,765
That is correct.

16512
12:06:50,268 --> 12:06:53,638
Do you think that explains the

16513
12:06:53,638 --> 12:06:55,873
confusion for the order that

16514
12:06:55,873 --> 12:06:57,873
was identified as 349?

16515
12:07:06,984 --> 12:07:08,984
>> absolutely.

16516
12:07:10,388 --> 12:07:12,388
>> during your

16517
12:07:13,823 --> 12:07:14,525
cross-examination by MS.

16518
12:07:14,525 --> 12:07:16,925
Christiansen, she was asking

16519
12:07:17,495 --> 12:07:20,495
you some questions and you

16520
12:07:23,401 --> 12:07:25,270
wanted to explain your

16521
12:07:25,270 --> 12:07:28,870
histogram and why you ended up

16522
12:07:33,577 --> 12:07:34,611
with your 11.5 roe and MS.

16523
12:07:34,611 --> 12:07:37,415
Christiansen did not allow you

16524
12:07:37,415 --> 12:07:38,315
to answer that question.

16525
12:07:38,315 --> 12:07:41,315
Could you briefly explain why

16526
12:07:42,352 --> 12:07:44,352
you landed on 11.5?

16527
12:07:45,890 --> 12:07:46,220
>> yes I can.

16528
12:07:46,220 --> 12:07:49,622
If you look at my document

16529
12:07:52,530 --> 12:07:55,530
number 2, that would be the

16530
12:07:58,568 --> 12:08:00,568
rebuttal testimony 187 the

16531
12:08:07,979 --> 12:08:08,212
number the number is at the

16532
12:08:08,212 --> 12:08:10,212
bottom.

16533
12:08:14,751 --> 12:08:15,753
I will wait.

16534
12:08:15,753 --> 12:08:19,953
It would start at page 1 and go

16535
12:08:21,558 --> 12:08:25,758
to page 4. It will show that I

16536
12:08:25,795 --> 12:08:29,333
did a similar analysis to what

16537
12:08:29,333 --> 12:08:31,935
I did with MR. Walters about my

16538
12:08:31,935 --> 12:08:33,870
indicated results.

16539
12:08:33,870 --> 12:08:36,870
In the distribution of them.

16540
12:08:38,276 --> 12:08:40,877
If you look at those and look

16541
12:08:40,877 --> 12:08:43,877
at the bottom percentile rank

16542
12:08:54,324 --> 12:08:55,226
of my recommended roe of 11.5

16543
12:08:55,226 --> 12:08:55,725
and falls in the middle of my

16544
12:08:55,725 --> 12:08:56,526
indicated results.

16545
12:08:56,526 --> 12:08:57,327
even though my recommendation

16546
12:08:57,327 --> 12:08:57,595
is about the midpoint of my

16547
12:08:57,595 --> 12:08:58,395
analyses.

16548
12:08:58,395 --> 12:09:01,395
My recommendation is right in

16549
12:09:06,436 --> 12:09:06,903
the middle of my indicative

16550
12:09:06,903 --> 12:09:07,238
roe's.

16551
12:09:07,238 --> 12:09:09,238
>> thank you.

16552
12:09:18,382 --> 12:09:18,548
No further questions.

16553
12:09:18,548 --> 12:09:20,548
>>.

16554
12:09:22,453 --> 12:09:23,322
>> any objection?

16555
12:09:23,322 --> 12:09:26,322
>> seen him, I show them

16556
12:09:27,425 --> 12:09:29,825
entered into the record.

16557
12:09:31,161 --> 12:09:34,161
>> opc would ask to have

16558
12:09:34,297 --> 12:09:36,399
exhibit 321, which I believe

16559
12:09:36,399 --> 12:09:38,536
has already been admitted in

16560
12:09:38,536 --> 12:09:40,536
the record.

16561
12:09:44,443 --> 12:09:44,674
And 839 admitted into the

16562
12:09:44,674 --> 12:09:45,109
record.

16563
12:09:45,109 --> 12:09:47,109
>> any objection?

16564
12:09:47,410 --> 12:09:48,412
>> no objection.

16565
12:09:48,412 --> 12:09:52,120
Seeing none, it is entered into

16566
12:09:53,451 --> 12:09:54,451
the record.

16567
12:09:54,451 --> 12:09:56,851
>> MR. CHAIRMAN, florida retail

16568
12:09:59,357 --> 12:10:00,323
federation is 814 and 815.

16569
12:10:00,323 --> 12:10:01,559
Those are the two cases that we

16570
12:10:01,559 --> 12:10:03,559
identified already.

16571
12:10:05,896 --> 12:10:06,930
>> is there objection?

16572
12:10:06,930 --> 12:10:09,930
>> seeing none, show it entered

16573
12:10:10,635 --> 12:10:12,635
into the record.

16574
12:10:13,371 --> 12:10:15,740
>> j p1 exhibit 82 for a

16575
12:10:15,740 --> 12:10:17,740
comprehensive exhibit list.

16576
12:10:18,708 --> 12:10:21,645
>> I will object to that.

16577
12:10:21,645 --> 12:10:24,450
That is MR. Pollock's

16578
12:10:27,385 --> 12:10:29,385
testimony.

16579
12:10:31,322 --> 12:10:34,322
>> it is not his exhibit.

16580
12:10:34,624 --> 12:10:36,626
I cannot object it when MR.

16581
12:10:36,626 --> 12:10:36,893
Pollock talks about it

16582
12:10:36,893 --> 12:10:38,893
tomorrow.

16583
12:10:39,729 --> 12:10:44,529
I'm not sure I want him to talk

16584
12:10:46,504 --> 12:10:47,237
about it tomorrow.

16585
12:10:47,237 --> 12:10:49,105
>> whichever way you want to do

16586
12:10:49,105 --> 12:10:50,410
it is fine with me.

16587
12:10:50,410 --> 12:10:53,641
I do not have strong feelings

16588
12:10:56,120 --> 12:10:56,948
about it.

16589
12:10:56,948 --> 12:10:57,715
>> I believe it is better when

16590
12:10:57,715 --> 12:10:58,316
MR. Pollock comes up to admit

16591
12:10:58,316 --> 12:11:00,316
that one.

16592
12:11:05,823 --> 12:11:06,357
It has already been used.

16593
12:11:06,357 --> 12:11:06,791
Anything else?

16594
12:11:06,791 --> 12:11:08,791
>> yes.

16595
12:11:10,193 --> 12:11:13,193
we would like walmart 819 on

16596
12:11:13,998 --> 12:11:15,998
the cal through 828.

16597
12:11:18,436 --> 12:11:19,302
That is the chart that I showed

16598
12:11:19,302 --> 12:11:21,439
as well as the orders that

16599
12:11:21,439 --> 12:11:22,720
support the information on the

16600
12:11:22,720 --> 12:11:24,720
chart.

16601
12:11:26,420 --> 12:11:26,876
>> any objection?

16602
12:11:26,876 --> 12:11:29,876
Seeing none, I show those

16603
12:11:32,850 --> 12:11:33,752
entered into the record.

16604
12:11:33,752 --> 12:11:36,752
>> we have a scheduling matter

16605
12:11:41,460 --> 12:11:41,992
before we adjourn tonight.

16606
12:11:41,992 --> 12:11:42,840
Let's excuse the witness.

16607
12:11:42,840 --> 12:11:44,840
S

16608
12:11:44,861 --> 12:11:46,664
that fair?

16609
12:11:46,664 --> 12:11:47,132
>> we are paying him by the

16610
12:11:47,132 --> 12:11:49,132
minute.

16611
12:11:51,969 --> 12:11:52,903
So let's get him.

16612
12:11:52,903 --> 12:11:55,606
>> thank you sir for your

16613
12:11:55,606 --> 12:11:57,606
witness testimony.

16614
12:11:58,141 --> 12:12:01,141
>> we have had some very

16615
12:12:01,946 --> 12:12:02,848
productive discussions today

16616
12:12:02,848 --> 12:12:05,248
with the consumer parties.

16617
12:12:05,517 --> 12:12:06,652
I do appreciate it.

16618
12:12:06,652 --> 12:12:07,285
Our proposal for the

16619
12:12:07,285 --> 12:12:09,285
commission's consideration, if

16620
12:12:09,553 --> 12:12:11,220
I get it wrong I will invite

16621
12:12:11,220 --> 12:12:13,658
the interveners to correct me.

16622
12:12:13,658 --> 12:12:16,658
We would propose that beginning

16623
12:12:17,128 --> 12:12:19,998
tomorrow morning we would start

16624
12:12:19,998 --> 12:12:21,400
with the intervener witnesses

16625
12:12:21,400 --> 12:12:21,598
as listed in the prehearing

16626
12:12:21,598 --> 12:12:23,598
order.

16627
12:12:25,770 --> 12:12:29,370
On page 6 and try to get

16628
12:12:31,175 --> 12:12:32,742
through all of them.

16629
12:12:32,742 --> 12:12:35,742
>> is starting off with MR.

16630
12:12:39,150 --> 12:12:41,150
[Listing names]

16631
12:12:48,693 --> 12:12:52,293
>> once we are through with all

16632
12:12:53,731 --> 12:12:54,664
the intervener witnesses, we

16633
12:12:54,664 --> 12:12:55,498
can pick back up with the tampa

16634
12:12:55,498 --> 12:12:57,898
electric border of witnesses

16635
12:12:59,636 --> 12:13:00,236
with type c strickland

16636
12:13:00,236 --> 12:13:02,236
chronister sizemore and

16637
12:13:02,405 --> 12:13:04,875
williams with a twist that we

16638
12:13:04,875 --> 12:13:07,780
would go ahead and have MR.

16639
12:13:07,780 --> 12:13:09,478
[Listing names] And MR.

16640
12:13:10,648 --> 12:13:13,480
Williams present their direct

16641
12:13:13,250 --> 12:13:13,551
rebuttal together instead of

16642
12:13:13,551 --> 12:13:14,719
separately.

16643
12:13:14,719 --> 12:13:15,186
Which I believe will be more

16644
12:13:15,186 --> 12:13:17,186
efficient.

16645
12:13:20,991 --> 12:13:21,492
i got that wrong, somebody

16646
12:13:21,492 --> 12:13:22,226
please pipe up.

16647
12:13:22,226 --> 12:13:25,826
But I do believe that's what

16648
12:13:25,930 --> 12:13:27,930
was contemplated.

16649
12:13:28,165 --> 12:13:29,467
>> MR. Wallin is correct.

16650
12:13:29,467 --> 12:13:31,867
With one other twist.

16651
12:13:34,738 --> 12:13:36,240
Which is I would hope there is

16652
12:13:36,240 --> 12:13:39,240
a little bit of flexibility

16653
12:13:40,778 --> 12:13:41,779
that we can take by agreement

16654
12:13:41,779 --> 12:13:44,179
with the intervener witnesses

16655
12:13:44,215 --> 12:13:45,150
among ourselves.

16656
12:13:45,150 --> 12:13:48,150
Doctor woolridge asked to give

16657
12:13:48,219 --> 12:13:50,721
a deposition in the morning

16658
12:13:50,721 --> 12:13:50,988
that he is going to do

16659
12:13:50,988 --> 12:13:52,988
remotely.

16660
12:13:54,910 --> 12:13:54,392
From some location here in

16661
12:13:54,392 --> 12:13:55,292
tallahassee.

16662
12:13:55,292 --> 12:13:58,796
He expects that it will be 10

16663
12:13:58,796 --> 12:13:59,563
by 11.

16664
12:13:59,563 --> 12:14:00,831
I do ask for some flexibility

16665
12:14:00,831 --> 12:14:04,201
to work through that among the

16666
12:14:04,201 --> 12:14:04,502
parties if it suits the

16667
12:14:04,502 --> 12:14:06,502
commission.

16668
12:14:08,673 --> 12:14:09,675
>> we have no objection.

16669
12:14:09,675 --> 12:14:12,376
>> I think we can definitely

16670
12:14:12,376 --> 12:14:14,376
accommodate that.

16671
12:14:14,378 --> 12:14:15,347
>> MR. CHAIRMAN, stop and offer

16672
12:14:15,347 --> 12:14:18,316
that staff witnesses could go

16673
12:14:18,316 --> 12:14:21,118
first then tomorrow to provide

16674
12:14:21,118 --> 12:14:23,518
more time to accommodate

16675
12:14:26,490 --> 12:14:27,240
everyone's schedule as they are

16676
12:14:27,240 --> 12:14:27,591
proposing.

16677
12:14:27,591 --> 12:14:29,393
>> that could definitely be

16678
12:14:29,393 --> 12:14:31,262
better for the witnesses.

16679
12:14:31,262 --> 12:14:34,632
So, tomorrow we will start with

16680
12:14:34,632 --> 12:14:36,632
stops witnesses.

16681
12:14:37,501 --> 12:14:38,235
Then we will go to opc's

16682
12:14:38,235 --> 12:14:41,835
witnesses and then we will pick

16683
12:14:43,274 --> 12:14:46,210
back up where we left off.

16684
12:14:46,210 --> 12:14:49,810
>> I think the idea was that

16685
12:14:52,783 --> 12:14:53,751
they were all fine.

16686
12:14:53,751 --> 12:14:57,822
I think we would go through all

16687
12:14:57,822 --> 12:15:00,424
of the witnesses and then go

16688
12:15:00,424 --> 12:15:02,426
back and resume with the

16689
12:15:02,426 --> 12:15:04,826
witnesses as my understanding.

16690
12:15:05,729 --> 12:15:06,197
>> that was my mistake.

16691
12:15:06,197 --> 12:15:08,197
All right.

16692
12:15:08,966 --> 12:15:09,835
Good deal.

16693
12:15:09,835 --> 12:15:13,435
I think we have a reshuffled

16694
12:15:13,638 --> 12:15:15,638
deck for tomorrow.

16695
12:15:16,730 --> 12:15:18,473
>> MR. CHAIRMAN, sierra club

16696
12:15:19,577 --> 12:15:23,177
would like to waive the rights

16697
12:15:23,247 --> 12:15:24,480
of the rest of the cross and be

16698
12:15:24,480 --> 12:15:27,648
excused for the last couple of

16699
12:15:28,520 --> 12:15:28,286
days while remaining a pretty

16700
12:15:28,286 --> 12:15:29,453
record.

16701
12:15:29,453 --> 12:15:32,453
>> you don't want to say?

16702
12:15:38,729 --> 12:15:39,397
>> I'd love to.

16703
12:15:39,397 --> 12:15:40,130
>> that is fine.

16704
12:15:40,130 --> 12:15:40,431
If no other parties have any

16705
12:15:40,431 --> 12:15:42,431
objections.

16706
12:15:43,467 --> 12:15:45,235
>> no objections.

16707
12:15:45,235 --> 12:15:47,171
>> thank you.

16708
12:15:47,171 --> 12:15:49,571
>> tomorrow morning, we will

16709
12:15:50,107 --> 12:15:52,343
start at 8:00 A.M.. Similarly

16710
12:15:52,343 --> 12:15:55,179
to how we did today.

16711
12:15:55,179 --> 12:15:55,913
We will gauge it as we go

16712
12:15:55,913 --> 12:15:57,913
along.

16713
12:16:02,152 --> 12:16:02,787
Every two hours we will have a

16714
12:16:02,787 --> 12:16:05,189
break and try to break for

16715
12:16:05,189 --> 12:16:06,124
lunch around the 12:00 hour.

16716
12:16:06,124 --> 12:16:06,657
If we have to go into the

16717
12:16:06,657 --> 12:16:09,657
evening and we will again.

16718
12:16:10,661 --> 12:16:10,861
Similarly with the dinner

16719
12:16:10,861 --> 12:16:11,663
break.

16720
12:16:11,663 --> 12:16:15,863
I will keep you guys updated as

16721
12:16:18,537 --> 12:16:19,203
we go along.

16722
12:16:19,203 --> 12:16:20,370
>> before sierra club gets

16723
12:16:20,370 --> 12:16:21,873
excused, do you need to move

16724
12:16:21,873 --> 12:16:22,107
your witness testimony into the

16725
12:16:22,107 --> 12:16:22,907
record?

16726
12:16:22,907 --> 12:16:25,307
>> we stipulated at the

16727
12:16:27,511 --> 12:16:28,480
beginning of his hearing.

16728
12:16:28,480 --> 12:16:29,580
>> just wanted to make sure.

16729
12:16:29,580 --> 12:16:31,580
>> I appreciate that.

16730
12:16:38,589 --> 12:16:38,856
>> that will be tomorrow's

16731
12:16:38,856 --> 12:16:39,824
schedule.

16732
12:16:39,824 --> 12:16:40,625
If we are all good, no further

16733
12:16:40,625 --> 12:16:41,000
business we will reconvene