sch3 - page 597 of 640 006292
TRANSCRIPT
Schedule Q-8.9 Page 10 of 12 Sponsor: Luth
2021 TX Rate Case SOUTHWESTERN PUBLIC SERVICE COMPANY
BILL COMPARISONS
Laree School Service - Secondarv A,eragc Mont}ily Consuniplion 20,000 kWh. 84 LW
Line Current Pioposed No Rates Rates Difference
1 Service Ai allabilit) Charge S 30 40 $ 32 73 233
Energ Charge per kWh S 0013964 $ 0019416 0 005452
3 Demmid Charge per LW Summer S 1] 90 S 17 68 5 78 4 Dcmatid Charge pcr kWr Wlnter 9 993 S 14 73 4 80
Energr Efficicnc) Cogl Recover Factor per kU'h S 0001327 S 0 00]327
6 Rate Case E,pcnse (RCF) Rider II percent of Base Rate 0 198192% 0 198192%
7 Fuel Factor per kWh Summer $ 0019683 $ 0014159 (0005524) 8 Fuel Factor per kWh U~ln[er $ 0019683 S 0014159 (0 005524) 9 TCRF per kW S - S - -
kWh Level 1000 2500 5000 7500 10000 15000 20000 30000 kW Level 10 10 20 30 40 60 84 120
]0 LW mimmum for LSS Current T]ll:
10 Sen ice A, Eulabihty Charge $3{140 S 30 40 S 30 40 S 3040 $ 30 40 S 3040 S 30 40 $ 3(} 40 11 Demand Charge (Summcr) S 11900 S 119 00 S 238 00 S 357 00 S 476 00 $ 714 00 S 999 60 S I 428 00 12 Demand Charge (Winter) S 9930 $ 9930 S 198 60 $ 297 90 $ 397 20 S 595.80 S 834 12 S ] ]91 60 13 Energ) Charge S 13 96 S 349] $ 69 82 S 104 73 $ 139 64 S 209 46 $ 279 28 $ 418 92 14 TIRE S-S-S - S -S - S .9 .S . 15 Base Rate Subtotal - Summer S 163 36 S 184 31 S 338.22 S 492 13 S 646.04 S 953.86 S 1.309.28 S 1,877.32 16 Base Rate Subtotal - Winter S 14366 S 164 61 S 298.82 $ 433.03 S 567.24 S 835.66 S 1,143.80 S 1,640.92 17 Annualized Rase Rate Total S 150 23 S 17118 S 31195 S 452 73 S 593 51 S 875 06 S 1,198 96 S 1,719.72 18 RCE Rldcr H (Summcr) $ 032 $ 0 37 9 0 67 $ 098 S 128 $ 189 S 2 59 $ 3 72 19 RCE Rider II (Winter) $ 028 $ 0 33 $ 0 59 S 0 86 S / ]2 $ 166 $ 2 27 $ 3 25 20 Energ E fficienc) Cost Reco, en' Factor 9 133 $ 3 32 9 664 $ 995 S 13 27 S 19 91 S 26 54 S 39 8 l 21 Current Fuel Factor (Summer) $ [9 68 S 49 21 $ 98 41 1 147 62 S 196 &3 $ 295 24 $ 393 66 $ 590 48 22 Current Fuel Factor (U,intcr) S 19 68 $ 49 2] $ 98 41 S 147 62 $ 196 83 $ 295 24 $ 393 66 $ 590 48 23 Total Cost (Summer) S 18469 $ 23721 S 443 94 $ 650 68 $ 857 42 S 127090 S 1.73207 $ 2 51133 24 Total Cost (Wmter) $ !64 95 $ 21747 $ 404 ·16 S 59146 $ 778 46 $ 1152 47 S 1 566 27 $ 2 274 46 25 Total Cost (Annualizcd) $ 171 53 9 22405 $ 417 62 S 61]20 $ 804 72 S I.19195 S 162154 $ 2353 42
Proposed Bill: 26 Sen ice Ai mlab,l,t) Charge S 32 73 S 32 73 S 32 73 $ 32 73 S 32 73 S 32 73 $ 32 73 S 32 73 27 Dema],d Charge (Summer) i 176 80 $ 176 80 $ 353 60 S 53040 S 70720 S 1060 80 $ 1.485 12 S 2 t 2]60 28 Demand Charge (Wlntcr) S ]47 30 $ 147 30 $ 294 60 9 44] 90 $ 589 20 $ 883 80 9 1237 32 $ 1 767 60 29 Enere Charge S ]942 S 48 54 S 97 08 S 145 62 S 19416 S 291 24 S 388 32 S 58248 30 TCRF S-$-$ - S - S - S -S-/-31 Base Rate Subtotal -Summer S 228.95 S 258.07 S 483.41 S 708.75 S 934.09 S 1,384 77 S 1,906.17 S 2,736 81 32 Base Rate Subtotai - Winter S 19945 S 228.S7 S 424.41 S 620.25 S 816.09 S 1,207 77 S 1,658 37 S 2381 St 33 Annuahzed Base Rate Total S 209 28 S 238 40 S 444.08 S 649.75 $ 85542 S 1,266 77 S I,740 97 S 2,50081 34 RCE Rider II (Summer) S 045 $ 051 $ 096 $ ]40 $ l 85 S 2 74 $ 378 $ 5 42 33 RCE Rider II (Winter) S 040 S 045 S 0 34 9 123 S 162 9 2 39 S 3 29 $ 472 36 Energy Efficienc) Cosl Recover, Factor $ 133 $ 3 32 $ 6 64 $ 995 $ 13 27 S I991 $ 26 54 S 39 R 1 37 Current Fuel Factor (Summer) S 1416 $ 3540 S 70 80 S 10619 $ 141 59 S 2!2 39 S 283 18 $ 424 77 38 Current Fuel Factor (Winter) S 1416 $ 35 40 S 70 80 S 106 19 S 14159 S 2 I 2 39 S 283 18 $ 424 77 39 Total Cost (Summer) $ 244 89 S 297 30 $ 561 81 $ 826 29 $ 1090 80 $ 1,619 81 $ 2 219 67 $ 3 206 81 40 Total Cost (Winter) S 215 34 $ 267 74 $ 502 69 $ 737 62 S 972 57 S ] 442 46 S ] 971 38 S 2 852 1 l 41 Total Cost (Annuatizcd) $ 225]9 $ 277 59 $ 522 40 S 76718 S 1 OIl 98 $ 150] 58 S 2054 14 $ 297034
Total Bill 42 Dollar Change (Summer) S 60 20 S 60 09 S 117 87 S 175 61 $ 233 38 $ 348 91 S 487 60 S 695 48 43 Dollar Change (Winter) S 5039 S 5027 S 98 23 S 14616 $ 194 ]] S 289 99 $ 405 11 $ 577 65 44 Dollar Change (Annuali,cd) S 53 66 S 33 54 S 104 78 S 155 98 9 207 20 S 309 63 S 432 61 $ 616 93
45 Perce„t Change (Summer) 32 60% 25 33% 2655% 26 99% 2722% 27 45% 28]5% 2769% 46 Percent Change (Winter) 30 55% 23 12% 24 29% 24 71% 24 94% 25 I 6% 35 86% 25 40% 47 Percent Change (Annualiycd) 3128% 23 90% 25 09% .5 52% 25 75% 25 98% 26 68% 26 21%
Base Rates 48 Dollar Change (Summer) S 65 59 S 73 76 $ 145 19 S 21662 $ 288 05 1 430 91 S 596 89 $ 859 49 49 Dollar Change (Winter) $ 55 79 $ 63 96 $ ]25 59 $ 187 22 $ 248 85 S 37211 S 514 57 $ 741 89 50 Dollar Change (Annualucd) S 39 06 9 67 23 S [ 33 12 S 197 02 S 26192 1 391 71 S 542 OI $ 78] 09
5 I Percent Change (Sumn~cr) 40 ] 5% 40 02% 42 93% 44 02% 4459% 45 ]8% 45 59% 45 78% 52 Percciit Chmge (Wmter) 38 83% 38 86% 42 03% 43 23% 43 87% 44 53% 44 99% 45 21% 33 Percent Change (Annuali?cd) 3931% 39 27% 42 35% 43 52% 44 13% 44 76% 45 2]% 45 42%
SCH3 - Page 597 of 640 006292
Schedule Q-8.9 Page 11 of 12 Sponsor: Luth
2021 TX Rate Case
SOUTHWESTERN PUBLIC SERVICE COMPANY
BILL COMPARISONS
Municipal and State Street Lighting Service Average Monthly Consumption 3,620 Lights, 275,000 kWh (Fuel Only)
Line Current Proposed No. Rate Rates Difference
] Aveiage Monthly Charge pet Light $ 7 57 $ 9 76 219
2 Eneigy Charge per kWh Summei $-$ 3 Energy Charge per kWh Winter $-$
4 Eneigy Efficiency Cost Recovery Factor pei kWh $ - $
5 Rate Case Expense (RCE) Rider II percent of Base Rate 0 198117% 0198117%
6 Fuel Factor per kWh Summer $ 0 019683 $ 0014159 (0 005524) 7 Fuel Factor per kWh Winter $ 0 019683 $ 0014159 (0 005524) 8 TCRF per kWh $- $-
7,000 MV Count of Lights 1 kWh Level 68
Current Bill: 9 Monthly Lighting Charge $ 7 57 10 Enei gy Charge(Summei) $ -11 Eneigy Chalge (Wmtei) $ -12 Eneigy Efficiency Cost Recovery Factor $ -13 RCE Ridet II $ 0 01 14 Cui i ent Fuel Factoi (Summer) $ 1 34 15 Current Fuel Factor (Winter) $ 1 34 16 TCRF $ -17 Total Cost (Summer) S 8 92 18 Total Cost (Winter) $ 8 92 ] 9 Total Cost (Annualized) $ 8 92
Proposed Bill: 20 Monthly Lighting Charge $ 9 76 21 Energy Chatge(Summer) $ -22 Energy Charge (Winter) $ -23 Enei gy Efficiency Cost Recover·y Factor $ -24 RCE Rider II $ 0 02 25 Pi oposed Fuel Factoi (Summer) 0 96 26 Pioposed Fuel Factoi (Winter) $ 0 96 27 TCRF $ -28 Total Cost (Summer) $ 10 74 29 Total Cost (Winter) $ 10 74 30 Total Cost (Annualized) $ 10 74
31 Dollar Change (Summer) $ 182 32 Dollar Change (Wintei) $ 1 82 33 Dollar Change (Annualized) $ 1 82
34 Percent Change (Summei ) 20 40% 35 Pei cent Change (Winter) 20 40% 36 Percent Change (Annualtzed) 20 40%
SCH3 - Page 598 of 640 006293
Schedule Q-8.9 Page 12 of 12 Sponsor: Luth
2021 TX Rate Case
SOUTHWESTERN PUBLIC SERVICE COMPANY
BILL COMPARISONS
Guard and Area Lighting Sen'ice Average Monthly Consumption 18 Lights, 2,200 kWh (Fuel Only)
Line Current Proposed No. Rate Rates Difference
1 Average Monthly Charge per Light $ 14 06 $ 11 69 (2 37)
2 Eneigy Charge per kWh Summei $-$ 3 Energy Charge per kWh Winter $-$
4 Eneigy Efficiency Cost Recovery Factor per kWh $ - $
5 Rate Case Expense (RCE) Rider II percent of Base Rate 0 198168% 0 198168%
6 Fuel Factor per kWh Summer $ 0 019683 $ 0 0]4159 (0 005524) 7 Fuel Factoi pei kWh Winter $ 0 019683 $ 0014159 (0 005524) 8 TCRFper kWh $- $- -
15,000 HPS Count of Lights 1 kWh Level 56
Current Bill: 9 Monthly Lighting Charge $ 14 06 10 Energy Charge(Summer) $ -11 Enei gy Charge (Winter) $ -12 Eneigy Efficiency Cost Recovery Factor $ -13 RCE Rider II $ 0 03 14 Cunent Fuel Factor (Summer) $ 1 10 15 Current Fuel Factor (Winter) $ 1 10 16 TCRF $ -17 Total Cost (Summei ) $ 15 19 18 Total Cost (Winter) $ 1519 19 Total Cost (Annuahzed) $ 1519
Proposed B]11: 20 Montlily Lighting Charge $ 1169 21 Energy Charge(Summer) $ -22 Energy Charge (Winter) $ -23 Enei gy Efficiency Cost Recovery Factor -24 RCE Rider II $ 0 02 25 Current Fuel Factor (Summer) $ 0 79 26 Cunent Fuel Factor (Winter) $ 0 79 27 TCRF $ -28 Total Cost (Summei) $ 12 50 29 Total Cost (Winter) $ 12 50 30 Total Cost (Annualized) $ 12 50
31 Dollar Change (Summer) $ (2 69) 32 Dollar Change (Wintel ) $ (2 69) 33 Dollar Change (Annualized) $ (2 69)
34 Peicent Change (Summet) -17 71% 35 Pei cent Change (Winter) -17 71% 36 Percent Change (Annualized) -17 71%
SCH3 - Page 599 of 640 006294
Schedule R (all) Page 1 of l
Sponsor: Grant 2021 TX Rate Case
Southwestern Public Service Company
Financial Information (G & T Cooperatives)
Schedules: R Financial Information (G & T Cooperatives)
R-1 Plant Additions and Retirements R-2 Construction Work Plan R-3 REA/CFC Financing Terms R-4 Debt Summary R-5 Weighted Average Cost of Debt R-6 REA Notes: REA Form 41 R-7 Scheduled Debt Service R-8 Patronage Capital R-9 Capital Credit Rotation Policy R--10 General Fund Investments R--11 Description of Other Non-Operating Income R--12 G&T and Other Capital Credit Allocations R-13 Historical Financial Ratios R-14 REA Form 12 Reports R-15 Capital Requirements and Financial Ratio Projections R-16 Long-Range Financial Forecast R-17 Financial Policy It-18 Computer Models
As a vertically integrated, investor owned utility, the R schedules are not applicable to Southwestern Public Service Company.
SCH3 - Page 600 of 640 006295
Schedule S Page 1 o f 10
Sponsor: Grant 2021 TX Rate Case
Deloitte© Suite 2800 Deloitte & Touche LLP
50 South Sixth Street Minneapolis, MN 55402-1538 USA
Tel: +1 612 397 4000 Fax: +1 612 397 4450 www.deloitte.com
INDEPENDENT ACCOUNTANTS' REPORT
To the Board of Directors of Southwestern Public Service Company Amarillo, Texas
We have reviewed the historical financial information included in Schedules A through S, (the "Schedules") in the Electric Utility Rate Filing Package for Generating Utilities ("Rate Filing Package" or "RFP') of Southwestern Public Service Company (the "Company" or"SPS") for the twelve months ended September 30,2020. The Company's management is responsible for presenting the Schedules and the Rate Filing Package in accordance with Section 22.243(b) of the Rules of Practice & Procedure of the Public Utility Commission of Texas (the "Commission" or 'PUCT"). Our responsibility is to express a conclusion on the Schedules based on our review.
Our review was conducted in accordance with the attestation standards established by the American Institute of Certified Public Accountants and with the "Test Year Review" procedures established by the Public Utility Commission of Texas ("PUCT") pursuant to the PUCT Instructions for Completing Electric Utility Rate Filing Package For Generating Utilities, (the "Instructions") for Schedule S governed by Section 22.243(b) of the Procedural Rules of the PUCT. Those standards require that we plan and perform the review to obtain limited assurance about whether any material modifications should be made to the Schedules in order for them to be in accordance with Section 22.243(b). The Schedules were prepared solely for inclusion in the Rate Filing Package and are not intended to be a presentation in conformity with accounting principles generally accepted in the United States of America. A review is substantially less in scope than an examination, the objective of which is to obtain reasonable assurance about whether the Schedules are in accordance with Section 22.243(b) of the Rules of Practice & Procedure of the PUCT, in all material respects, in order to express an opinion, Accordingly, we do not express such an opinion. We believe that our review provides a reasonable basis for our conclusion.
The pro forma adjustments, as adjusted amounts, estimates, non-accounting, and non-financial information included in the Schedules in the Rate Filing Package were not reviewed by us and, accordingly, we do not express an opinion or any other form of assurance on such information.
Based on our review, we are not aware of any material modifications that should be made to the historical financial information included in the Schedules in the Rate Filing Package of the Company for the test year ended September 30,2020, in order for it be in accordance with the provisions of the Instructions governed by Section 22.243(b) of the Procedural Rules of the PUCT.
This report is intended solely for the information and use of the management and Board of Directors of Southwestern Public Service Company, and the PUCT, and is not intended to be and should not be used by anyone other than these specified parties.
-D·elooji 4 -3«ht L\_*D February 5, 2021
SCH3 - Page 601 of 640 006296
Schedule S Page 2 of 10
Sponsor: Grant 2021 TX Rate Case
Schedule S-1 Rate Filing Package
SCOPE OF REVIEW Southwestern Public Service Company For the Test Year Ended September 30,2020
Deloitte & Touche LLP ("D&T" or "we" or "us" or "our") has reviewed, in accordance with standards established by the American Institute of Certified Public Accountants and the "Test Year Review" procedures established by the Public Utility Commission of Texas ('PUCT") pursuant to the PUCT Instructions for Completing Electric Utility Rate Filing Package For Generating Utilities, (the 'Instructions") for Schedule S, governed by Section 22.243(b) of the Procedural Rules of the PUCT, the historical financial information included in Schedules A through S, (the 'Schedules") in the Electric Utility Rate Filing Package for Generating Utilities ('Rate Filing Package" or 'RFP") of SPS for the test year ended September 30,2020,
Except for the audit of the consolidated financial statements of SPS as of and for the year ended December 31, 2019, included in Schedule J-2, D&T did not audit and does not express an opinion on any financial and accounting information included in the RFP. The references detailed below refer to D&T's working papers documenting the review of the Schedules. Schedule S-6 provides contact information with respect to how the PUCT staff may request access to review our workpapers.
Certain items included in the Minimum Procedures Required for the Test Year Review ("Minimum Procedures"), which are set forth in Schedule S of the Instructions, contain subjective terminology such as 'perform adequate tests," "prepare workpapers which adequately document," and 'perform sufficient procedures.' We have limited the responses below to the specific procedures we performed for purposes of our review of the RFP Schedules. It should be understood that we make no representation regarding questions of legal interpretation or regarding the sufficiency of the procedures we performed for the purposes of SPS or the PUCT in connection with the RFP review. Such procedures would not necessarily reveal any material misstatement of the historical financial information included in the RFP.
1. Review of the PUCT Regulations, Orders and Reports [Workpaper series 13910]
We read the portions of the following documents which relate to financial and accounting matters: (a) the Public Utility Regulatory Act (as amended) effective as of September 1, 2019, (b) the Procedural Rules of the Public Utility Commission of Texas, (c) the Substantive Rules of the Public Utility Commission of Texas and (d) the Final Order and Proposal for Decision SPS's last rate case (Docket No. 49831)
2. Documentation of Materiality [Workpaper series 13100]
We performed the review, including the Minimum Procedures, using a materiality level of $50 million. Materiality was based on four benchmarks based on the Instructions of profit before tax, total assets, revenue, and other revenue requirements.
3. Consistency of RFP Schedules with Audited Financials and Annual Reports [Workpaper series 28500]
The completed portions of the RFP schedules that contain historical financial or accounting information are consistent with any similar data or disclosures included in the Company's audited financial statements, annual and interim reports.
4. Compliance of RFP Schedules with the Instructions [Workpaper series 28500]
In the course of performing our review of the RFP Schedules, we reviewed each RFP Schedule that relates to historical financial and accounting matters for compliance with the Instructions for preparation. We noted the following discrepancies between the Schedules and the Instructions.
2
SCH3 - Page 602 of 640 006297
Schedule S Page 3 of 10
Sponsor: Grant 2021 TX Rate Case
Schedule Schedule Discrepancy # D-7 Summary of Book Salvage The Company included additional columns in
the schedule that are not required by the Instructions.
E-3.1 Fuel Oil Burns The Company included additional columns in the schedule that are not required by the Instructions.
H-5.3b Fossil Production Plant The Company did not include descriptions of Capital Costs projects listed in the schedule as required by the
Instructions. I-7 Natural Gas Storage The Company did not include monthly injections
Description and withdrawals in dollars as required by the Instructions.
5, Propriety of RFP Schedules Classified as "Not Applicable' Mbrkpaper 13900A]
We reviewed the propriety of the classification of all RFP Schedules related to financial and accounting matters classified as 'Not Applicable.'
6. Consistency of Workpapers with the Filed RFP [Workpaper series 28500]
We compared the historical financial and accounting information in the RFP Schedules subject to our review with the production ready version expected to be filed with the PUCT.
7. Procedural and Internal Control Documentation [Workpaper series 13900] In the course of performing our annual audit of SPS for the year ended December 31, 2020, D&T updated its documentation of the Company's accounting procedures and internal controls procedures through September 30, 2020
8. Update Permanent File Information [Workpaper series 14102]
In the course of performing our interim review for the three, six, and nine months periods ended March 31, June 30, and September 30,2020 and annual audit of SPS for the year ended December 31, 2020, we updated permanent file information.
9, The Minutes of the Board of Directors of the Company [Workpaper series 21010]
We read the minutes of meetings of the Board of Directors of the Company that were available.
10. Management Representations Mbrkpaper series 30100]
We received a management representation letter for the test year ended September 30,2020,
11. Attorney's Letters [Workpaper series 30100]
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Schedule S Page 4 of 10
Sponsor: Grant 2021 TX Rate Case
We obtained correspondence from the Company's legal department for any outstanding litigation, claims, and assessments.
12. Cut-Off Procedures [Workpaper series 22120]
We performed cut-off procedures for balances at the beginning and end of the test year.
13. Working Capital Fluctuation Analysis [Workpaper series 22130]
We analyzed and documented all material monthly fluctuations during the test year period of working capital accounts and other items of invested capital that had fluctuations in account balances that met the following criteria: 1) greater than 20% of the recorded balance and 2) greater than $25 million. Working capital accounts consisted of all current assets and current liabilities as defined by the Federal Energy Regulatory Commission's Uniform System of Accounts ("FERC USOA')
14. Income Statement Fluctuation Analysis [Workpaper series 221401
We analyzed and documented all material annual fluctuations for the test year ended September 30,2020 of all revenue and expense accounts related to utility operations that had fluctuations in account balances that met the following criteria: 1) greater than 20% of the recorded balance and 2) greater than $25 million.
15. Cost of Service Fluduation Analysis [Workpaper series 22150]
We analyzed and documented all material monthly fluctuations during the test year period of cost of service accounts that had fluctuations in account balances that met the following criteria: 1) greater than 20% of the recorded balance and 2) greater than $25 million.
16. Balance Sheet Accounts Included in Invested Capital [Workpaper series 22160]
We performed procedures on balance sheet accounts included in invested capital as of September 30,2020.
17. Revenue and Expense Accounts Related to Utility Operations [Workpaper series 22170]
In the course of performing our annual audit procedures for the year ended December 31, 2019 and interim review for the three, six, and nine months ended March 31, June 30, and September 30,2020, respectively, related to the financial statements of the Company, D&T performed analytical procedures on revenue and expense accounts related to utility operations for such periods.
18. Balance Sheet Accounts Related to Capital Structure Mbrkpaper series 221801
We performed procedures on balance sheet accounts related to capital structure as of September 30,2020.
19. Deferred Cost Analysis [Workpaper series 22190]
We performed procedures on deferred cost accounts and related amortization as of September 30,2020.
20. Analysis of Deferred Fuel Accounts
4
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Schedule S Page 5 of 10
Sponsor: Grant 2021 TX Rate Case
Mbrkpaper series 22200]
We performed an analysis of deferred fuel accounts as of September 30,2020. We also reviewed deferred fuel entries for each month during the test year and for each month from October 2020 to December 2020 to analyze the propriety of the deferred fuel entries.
21. Historical Financial and Accounting Matters Included in RFP Schedules [Workpaper series 28500]
In the course of performing our review of the RFP Schedules, we compared test-year historical financial and accounting information to SPS's accounting records, which include the general Iedger, sub-Iedgers, and other accounting records,
22. Mathematical Accuracy of RFP Schedules [Workpaper series 28500]
We tested the mathematical accuracy of financial information included in the RFP Schedules that relate to historical financial and accounting matters.
23. Compliance with PUCT Final Orders [Workpaper series 28500]
We read the Final Order and Proposal for Decision from SPS's last rate case (Docket No. 49831) to identify whether there were any matters that SPS should take into consideration in reporting the historical financial information in the RFP Schedules to comply with the Commission Final Order; no such matters came to our attention.
24. Compliance with PUCT Rules [Workpaper series 28500]
We compared the amounts related to historical financial and accounting matters that are presented in the RFP Schedules for consistency with the Company's books and for presentation in accordance with applicable commission rules.
25. Compliance with System of Accounts [Workpaper series 222501
On a test basis, we compared SPS's account classifications for compliance with the PUCT-approved system of accounts.
26. RFP Workpapers [Workpaper series 30000]
We documented the nature, scope and results of the review procedures performed, including the evaluation and conclusion as to the disposition of all errors, exceptions, and omissions noted during the course of the review as noted herein on Schedules S-1, S-2, S-3, S-4, and S-5.
5
SCH3 - Page 605 of 640 006300
Schedule S Page 6 of 10
Sponsor: Grant 2021 TX Rate Case
Schedule S-2 Rate Filing Package
ERRORS AND EXCEPTIONS NOTED BY INDEPENDENT ACCOUNTANTS Southwestern Public Service Company For the Test Year Ended September 30,2020
No uncorrected errors, exceptions, or omissions related to the historical financial and accounting information were identified by Deloitte & Touche LLP during our review of the RPF Schedules for the test year period ended September 30,2020,
Discrepancies identified between the Schedules and the Instructions in conjunction with the Minimum Procedures for SPS's Rate Filing Package for the twelve months ended September 30,2020, are outlined in procedure 4 of Schedule S-1.
6
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Schedule S Page 7 of 10
Sponsor: Grant 2021 TX Rate Case
Schedule S-3 Rate Filing Package
COMMUNICATIONS FROM INDEPENDENT ACCOUNTANTS Southwestern Public Service Company For the Test Year Ended September 30,2020
PCAOB Auditing Standard No , 2201 , An Audit of Internal Control Over Finandal Reporting That Is Integrated with An Audi ' t of Financial Statements . PCAOB Auditing Standard No . 2201 , defines the term « significant deficiency " and requires the auditor to communicate all significant deficiencies, in writing, to management and those charged with governance as a part of each audit, including significant deficiencies and material weaknesses that were communicated to management and those charged with governance in previous audits and have not yet been remediated.
There were no such communications regarding significant deficiencies or material weaknesses in SPS's internal control over financial reporting from the annual audit of SPS's financial statements as of and for the year ended December 31, 2019, nor from the interim reviews of SPS's interim financial information for the periods ended March 31,2020, June 30, 2020, and September 30, 2020
1
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Schedule S Page 8 of 10
Sponsor: Grant 2021 TX Rate Case
Schedule S-4 Rate Filing Package
ADJUSTING JOURNAL ENTRIES Southwestern Public Service Company For the Test Year Ended September 30,2020
No adjusting journal entries were identified by Deloitte & Touche LLP and provided to management to post to the Company's general Iedger in conjunction with the audit of the financial statements of the Company for the year ended December 31, 2019 and the interim reviews for the three, six, and nine months periods ended March 31, June 30, and September 30,2020.
8
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Schedule S Page 9 of 10
Sponsor: Grant 2021 TX Rate Case
Schedule S-5 Rate Filing Package
PASSED ADJUSTING JOURNAL ENTRIES Southwestern Public Service Company For the Test Year Ended September 30,2020
There were no passed adjusting journal entries that were identified by Deloitte & Touche LLP, but not recorded by management, during the course of the audit of the Company's financial statements forthe year ended December 31, 2019 and the interim reviews for the three, six, and nine months periods ended March 31, June 30, and September 30,2020.
9
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Schedule S Page 10 of 10
Sponsor: Grant 2021 TX Rate Case
Schedule S-6 Rate Filing Package
WORKPAPER REVIEW Southwestern Public Service Company For the Test Year Ended September 30,2020
In order to make arrangements with Deloitte & Touche LLP to obtain access to the workpapers that support our review of the RFP Schedules, please contact:
Mr. Jeffrey Savage Xcel Energy, Inc. 414 Nicollet Mall Minneapolis, Minnesota 55401
Phone: (612) 330-5658
If electronic access to workpapers is not acceptable to the Commission, arrangements can be made for access to take place in the Deloitte & Touche LLP, Austin, Texas office.
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Schedule T Page 1 of 3
Sponsor: Grant 2021 TX Rate Case
Proposed Form of Notice
Notice of Rate Change Request
Public Notice of Filing by Southwestern Public Service Company, doing business as Xcel Energy Inc., of
Statement of Intent and Application for Authority to Change Rates
On February 8, 2021, Southwestern Public Service Company ("SPS"), doing business as Xcel Energy Inc., filed a statement of intent and application for authority to change rates ("Application") with the Public Utility Commission of Texas ("Commission") and with each Texas municipality that has original jurisdiction over SPS's electric rates.
SPS has 271,393 Texas retail customers. All customers in each of SPS's Texas retail customer classes will be affected by the relief requested in this Application.
Statement of Intent to Change Rates
SPS requests that the Commission approve an overall increase in annual base rate revenues of $143,365,836 which represents an increase of 23% in base rate revenues (the portion of the bill not including fuel costs and rate riders) and an increase of 9.2% in overall adjusted revenues. The effect of the proposed rate change on individual customer classes is set forth in the section entitled "Effect on Customer Classes" below. SPS's proposed effective date for this rate change is 35 days after the date of this filing, which is March 15, 2021. That proposed effective date is subject to suspension and extension by actions ofthe Commission or other regulatory authorities.
Effect on Customer Classes
The average Residential Service customer using 1,000 kilowatt-hours of energy per month will see an increase in base rates (the portion of the bill not including fuel costs and rate riders) of $13.22 per month, or 13.57%, which results in an overall increase of 6.71%, compared to the rates established in SPS's last base rate case.
The following table presents the percentage annual revenue increases, by type of service, under the proposed rates in this proceeding:
SCH3 - Page 611 of 640 006306
Schedule T Page 2 of 3
Sponsor: Grant 2021 TX Rate Case
$143,365,787 Increase
Applicable Service Base Rate Increase/(Decrease)
($)
Base Rate Overall Bill Increase/(Decrease) Increase/(Decrease)
(%) (04)*
Residential Service $ 30,652,441 12.81% 6.7%
Small General Service 3,101,151 13.35% 5.6%
Secondary General Service 21,098,228 17.38% 5.9%
Primary General Service 16,849,292 24.68% 6.0%
Large General Service - 63,322,103 44.56% 11.7% Transmission
Small Municipal and School 552,080 43.24% 25.1% Service
Large Municipal Service 3,218,571 38.0% 17.8%
Large School Service 4,099,552 45.17% 27.0%
Municipal and State Street 1,194,019 25.09% 20.7% Lighting
Guard and Flood Lighting (7215~50) -17.02%
Total $143,365,787 23.04%
* Includes fuel factor and energy efficiency cost recovery factor revenues.
-17.7%
Contact Information
Persons with questions or who want more information on this Application may contact SPS at 790 S. Buchanan St., Amarillo, Texas 79101, or call 1-800-895-4999 during normal business hours. A complete copy ofthis Application is available for inspection at the address listed in the previous sentence.
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Schedule T Page 3 of 3
Sponsor: Grant 2021 TX Rate Case
Persons who wish to intervene in or comment upon these proceedings should notify the Commission as soon as possible, as an intervention deadline will be imposed. The deadline for intervention in the proceeding is 45 days after the date the Application was filed with the Commission, which makes the intervention deadline Thursday, March 25, 2021. A request to intervene or for further information should refer to Docket No. . A request to intervene or for further information should be mailed to the Public Utility Commission of Texas, P.O. Box 13326, Austin, Texas 78711-3326. Further information also may be obtained by calling the Public Utility Commission at (512) 936-7120 or (888) 782-8477. Hearing- and speech-impaired individuals with text telephones (TTY-) may contact the Commission at (512) 936-7136.
Due to the COVID-19 pandemic, the preferred method for you to file your request for intervention or comments on the Application is electronically, and you will be required to serve the request on other parties by email. Therefore, please include your email address (and/or fax number if available) on the intervention request. Instructions for electronic filings via the "PUC Filer" on the Commission's website can be found at: https://interchange.puc.texas.gov/filer. Instructions for using the PUC Filer are available at: http://www.puc.texas.gov/industry/filings/New_PUC_Web_Filer_Presentation.pdf. Once you obtain a tracking sheet associated with your filing from the PUC Filer, you may email the tracking sheet and the document you wish to file to: [email protected]. For assistance with your electronic filing, please contact the Commission's Help Desk at (512) 936-7100 or [email protected]. You can review materials filed in this docket on the PUC Interchange at: http://interchange.puc.texas.gov/.
SCH3 - Page 613 of 640 006308
Southwestern Public Se]·vice Company
Compliance with PUC Orders
Line Docket/Project Summary of Requirements to be Addressed in No. No. Reference the Utility's Next Rate Case Proceeding
1 Docket No 49831 SPS must suspend the collection from customers of the historical-period expense related to Attachment Z2 of the Southwest Power Pool Open Access Transmission Tariff and must maintain the current iegulatory asset with a balance of $4,402,191 55 as of September 12, 2019, adjusted for the resolution of the related, currently pending cases at FERC SPS must include a proposal to addiess this regulatory asset in its next base-iate proceeding following the resolution of the htigation at FERC regaiding Attachment Z2 [Final Order, Section III, Ordering Paragraph 9]
2 Docket No 47527 SPS must continue to unwind its excess accumulated deferred income tax and net operating loss-related balances resulting fi om the change in tax rates under the Tax Cuts and Jobs Act (TCJA) [Final Ordei, Section IV, Oidenng Paragraph 8]
3 Docket No 47527 SPS must continue to unwind the acess accumulated deferred income tax balances associated with pi otected plant items based on the average i ate assumption method [Final Order, Section IV, Ordering Paiagraph 9]
4 Docket No 47527 SPS must addiess its excess accumulated deferred income tax balances and the unwinding of those balances, associated with protected and unprotected plant items, non-plant items, and net opeiating loss-related balances that may have accrued from the end of the updated test year in Docket No 47527 (June 30, 2017) through December 31, 2017 [Final Order, Section IV, Ordering Paragiaph 10]
Schedule U Page 1 of 1
Sponsor: Grant 2021 TX Rate Case
Reference to Parts of RFP Addressing Requirement
Direct Testimony of William B Grant
Direct Testimony of Mark P Moeller (Revenue Requirements Phase) Direct Testimony of Arthur P Fieitas (Revenue Requirements Phase) Direct Testimony ofNaomi Koch (Revenue Requirements Phase)
Direct Testimony of Mai k P Moeller (Revenue Requirements Phase) Direct Testimony of Arthui P Fieitas (Revenue Requirements Phase) Direct Testimony ofNaomi Koch (Revenue Requirements Phase)
Direct Testimony of Matk P Moeller (Revenue Requliements Phase) Direct Testimony of Arthur P Fieitas (Revenue Requliements Phase) Direct Testimony ofNaomi Koch (Revenue Requirements Phase)
SCH3 - Page 614 of 640 006309
Schedule V Page 1 of 4
Sponsor: Grant 2021 TX Rate Case
Southwestern Public Service Company
Request for Waiver of Rate Filing Package Requirements
A. Fuel Reconciliation-Related Schedules As discussed in the Direct Testimony of William A. Grant Southwestern Public Service Company ("SPS") has not filed a fuel reconciliation with its current base rate case in accordance with the Order in Project No. 41905 and 16 Tex. Admin. Code § 25.236 ("TAC") as revised in that project. Accordingly, SPS is not seeking a change in its fuel factor under 16 TAC § 25.237. SPS therefore requests waiver of providing projected or Rate Year information or Reconciliation Period information (as indicated below) for all or a portion of the following schedules:
Line No. Schedule Description Specific Waiver
l H-12.1 Supply and Load Data Information for Rate Year and Reconciliation Period
2 H-12.2a Summary of Production by Unit Data Information for Rate Year and Reconciliation Period
3 H-12.2b Summary ofProduction by Unit Data Information for Rate Year and Reconciliation Period
4 H-12.2C Summary ofProduction by Unit Data Information for Rate Year and Reconciliation Period
5 H-12.3a Summary of Generating Unit Data Information for Rate Year and Reconciliation Period
6 H-12.4a & c Summary of Purchased Power Data Information for Rate Year and Reconciliation Period
7 H-12.5a-12.5f
Summary of System Sales Data Information for Rate Year and Reconciliation Period
8 I-7 Natural Gas Storage Description Information for Rate Year
9 I-11 Fuel and Purchased Power Assumptions Information for Rate Year Narrative
10 I-12 Fossil Fuel Mix Information for Rate Year
11 Q-2 Power Cost Recovery Information for Rate Year
SCH3 - Page 615 of 640 006310
Schedule V Page 2 of 4
Sponsor: Grant 2021 TX Rate Case
Some information contained in the following schedules relates to costs not at issue in this base rate case proceeding, therefore SPS requests waiver of providing certain information on reconcilable fuel costs in the following schedules:
Line No. Schedule Description Specific Waiver 12 I-4 Fuel and Fuel Related Contracts Contract summaries for fuel
and fuel-related contracts that do not contain costs recovered through base rates.
13 I-15 Fuel Contract Analyses - Reconciliation Fuel and fuel-related Period contracts that do not contain
costs recovered through base rates.
Additionally, information contained in the following schedules relates to costs not at issue in this base rate case proceeding. Therefore, SPS requests a waiver of all of the following schedules:
Line No. Schedule Description Specific Waiver 14 H-12.4b Firm Purchased Power Energy Costs Costs recovered through fuel
factor
15 H-12.4d Firm Purchased Power Energy Cost per MWh
Costs recovered through fuel factor
16 H-12.4e Non-Firm Purchased Power Costs recovered through fuel factor
17 H-12.4f Non-Firm Purchased Power Energy Costs Costs recovered through fuel factor
18 H-12.4g Non-Firm Purchased Power Energy Costs Costs recovered through fuel Per MWh factor
19 I-16 Reconcilable Fuel Costs Costs recovered through fuel factor
20 I-16.1 Fossil Fuel Mix (Burned) Costs recovered through fuel factor
SCH3 - Page 616 of 640 006311
Schedule V Page 3 of 4
Sponsor: Grant 2021 TX Rate Case
Line No. Schedule Description Specific Waiver
21 I-162 Fossil Fuel Mix (Purchased) Costs recovered through fuel factor
22 I-16.3 Competitive Spot Fossil Fuel Purchases Costs recovered through fuel factor
23 I-16.4 Other Spot Fossil Fuel Purchases Costs recovered through fuel factor
24 I-22 Fuel Costs Over/Under Recovery Costs recovered through fuel factor
25 O-5 Variability ofAverage Fuel Costs with Costs recovered through fuel kWh Sales factor
B. Updated Test Year Data in Lieu of Test Year Data As discussed in the Direct Testimony of William A. Grant and Richard M. Luth, SPS is using billing determinants for the Updated Test Year, rather than from the Test Year, to allocate costs among the Texas retail classes and to design rates. Therefore, SPS requests a waiver to provide Updated Test Year data (January 1,2020 through December 31, 2020) rather than Test Year data in the following schedules:
Line No. Schedule Description
26 O-1.1 Test Year Data by Rate Class
27 O-1.7 Adjustments to Billing Demand
28 O-3.3 Other Customer Adjustment Information
29 0-4.1 kWh Sales and kW Demand
3 O O-6.1 Unadjusted kWh Sales by Month ofthe Test Year
31 O-6.2 Adjusted kWh Sales Data
32 p-10 Payroll Expense Distribution
33 p-11 Distribution Plant Study
SCH3 - Page 617 of 640
Specific Waiver
Does not provide information for the full Test Year; provides nine months of Test Year information and the three months o f the Update Period
006312
Schedule V Page 4 of 4
Sponsor: Grant 2021 TX Rate Case
Line No. Schedule Description Specific Waiver 34 Q-1 Revenue Summary
35 Q-7 Proo f o f Revenue Statement
C. Confidentiality Disclosure Agreement (Schedule W) As discussed in the Direct Testimony of William A. Grant, SPS requests a waiver so it can use the current version of a Commission-approved protective order rather than the confidentiality disclosure agreement specified in the Schedule W, which is from 1992. Specifically, and as explained in Schedule W, SPS proposes to use the protective order from its most recent rate case, Docket No. 49831, updated with the style and blanks in place of the docket number, and refined citations to the Public Utility Regulatory Act and the Texas Government Code.
Line No. Schedule Description Specific Waiver
36 W Confidentiality Disclosure Agreement Requirement to use the 1992 Confidentiality Disclosure Agreement
SCH3 - Page 618 of 640 006313
Schedule W Page l of 21
Sponsor: Grant 2021 TX Rate Case
Southwestern Public Service Company
Confidentiality Disclosure Agreement
In lieu ofthe confidentiality disclosure agreement set out in the rate filing package, Southwestern Public Service Company ("SPS") proposes to use the Public Utility Commission's Standard Protective Order, approved in SPS's last rate case , Docket No. 49831, as the basis for the protective order in this new docket. The protective order that starts on the next page of this schedule is identical to the Protective Order proposed and adopted in Docket No. 49831, with the exception of the style and blanks in place of the docket number, and refined citations to the Public Utility Regulatory Act and the Texas Government Code. Commission Staff is in agreement with the use of the Commission's most recent Standard Protective Order.
SCH3 - Page 619 of 640 006314
Schedule W Page 2 of 21
Sponsor: Grant 2021 TX Rate Case
DOCKET NO.
APPLICATION OF SOUTHWESTERN § PUBLIC UTILITY COMMISSION PUBLIC SERVICE COMPANY FOR § AUTHORITY TO CHANGE RATES § OF TEXAS
PROTECTIVE ORDER
This Protective Order governs the use of all information deemed confidential
(Protected Materials) or highly confidential (Highly Sensitive Protected Materials), including
information whose confidentiality is currently under dispute, by a party providing information to the Public Utility Commission of Texas (Commission) or to any other party to this proceeding.
It is ORDERED that:
1. Desienation of Protected Materials. Upon producing or filing a document, including,
but not limited to, records on a computer disk or other similar electronic storage medium in this proceeding, the producing party may designate that document, or any portion of it, as confidential pursuant to this Protective Order by typing or stamping on its face
"PROTECTED PURSUANT TO PROTECTIVE ORDER ISSUED IN DOCKET
NO. " (or words to this effect) and consecutively Bates Stamping each page.
Protected Materials and Highly Sensitive Protected Materials include the documents so
designated, as well as the substance of the information contained in the documents and any description, report, summary, or statement about the substance of the information
contained in the documents.
2. Materials Excluded from Protected Materials Designation. Protected Materials must
not include any information or document contained in the public files of the Commission
or any other federal or state agency, court, or local governmental authority subject to the Public Information Act. 1 Protected Materials also must not include documents or
information which at the time of, or prior to disclosure in, a proceeding is or was public
' Tex. Gov't Code § 552.001-.353.
SCH3 - Page 620 of 640 006315
Schedule W Page 3 of 21
Sponsor: Grant 2021 TX Rate Case
knowledge, or which becomes public knowledge other than through disclosure in
violation ofthis Protective Order.
3. Reviewing Party. For the purposes of this Protective Order, a "Reviewing Party" is any
party to this docket.
4. Procedures for Designation of Protected Materials. On or before the date the
Protected Materials or Highly Sensitive Protected Materials are provided to the
Commission, the producing party is required to file with the Commission and deliver to
each party to the proceeding a written statement, which may be in the form of an objection, indicating: (a) any exemptions to the Public Information Act claimed to apply
to the alleged Protected Materials; (b) the reasons supporting the producing party's claim
that the responsive information is exempt from public disclosure under the Public
Information Act and subject to treatment as protected materials; and (c) that counsel for
the producing party has reviewed the information sufficiently to state in good faith that
the information is exempt from public disclosure under the Public Information Act and
merits the Protected Materials designation.
5. Persons Permitted Access to Protected Materials. Except as otherwise provided in
this Protective Order, a Reviewing Party may access Protected Materials only through its
"Reviewing Representatives" who have signed the Protective Order Certification Form
(see Attachment A). Reviewing Representatives of a Reviewing Party include its counsel
of record in this proceeding and associated attorneys, paralegals, economists, statisticians, accountants, consultants, or other persons employed or retained by the Reviewing Party
and directly engaged in this proceeding. At the request of the PUC Commissioners,
copies of Protected Materials may be produced by Commission Staff. The
Commissioners and their staff must be informed of the existence and coverage of this
Protective Order and will observe the restrictions ofthe Protective Order.
6. Hiehlv Sensitive Protected Material Described. The term "Highly Sensitive Protected
Materials" is a subset of Protected Materials and refers to documents or information that
a producing party claims is of such a highly sensitive nature that making copies of such
SCH3 - Page 621 of 640 006316
Schedule W Page 4 of21
Sponsor: Grant 2021 TX Rate Case
documents or information or providing access to such documents to employees of the
Reviewing Party (except as specified herein) would expose a producing party to
unreasonable risk of harm. Highly Sensitive Protected Materials include but are not
limited to: (a) customer-specific information protected by § 32.101(c) of the Public
Utility Regulatory Act;2 (b) contractual information pertaining to contracts that specify
that their terms are confidential or that are confidential pursuant to an order entered in
litigation to which the producing party is a party; (c) market-sensitive fuel price forecasts,
wholesale transactions information and/or market-sensitive marketing plans; and (d)
business operations or financial information that is commercially sensitive. Documents
or information so classified by a producing party must bear the designation "HIGHLY
SENSITIVE PROTECTED MATERIALS PROVIDED PURSUANT TO PROTECTIVE
ORDER ISSUED IN DOCKET NO. (or words to this effect) and must be consecutively Bates Stamped. The provisions of this Protective Order pertaining to
Protected Materials also apply to Highly Sensitive Protected Materials, except where this
Protective Order provides for additional protections for Highly Sensitive Protected
Materials. In particular, the procedures herein for challenging the producing party's
designation of information as Protected Materials also apply to information that a
producing party designates as Highly Sensitive Protected Materials.
7. Restrictions on Copvine and Inspection of Highly Sensitive Protected Material.
Except as expressly provided herein, only one copy may be made of any Highly Sensitive
Protected Materials except that additional copies may be made to have sufficient copies
for introduction of the material into the evidentiary record if the material is to be offered
for admission into the record. The Reviewing Party is required to maintain a record of all
copies made of Highly Sensitive Protected Material and must send a duplicate of the
record to the producing party when the copy or copies are made. The record must specify
the location and the person possessing the copy. Highly Sensitive Protected Material
must be made available for inspection only at the location or locations provided by the
producing party, except as specified by Paragraph 9. Limited notes may be made of
2 Public Utility Regulatory Act, Tex. Util. Code §§ 11.001-66.016 (PURA).
SCH3 - Page 622 of 640 006317
Schedule W Page 5 of 21
Sponsor: Grant 2021 TX Rate Case
Highly Sensitive Protected Materials, and such notes must themselves be treated as
Highly Sensitive Protected Materials unless such notes are limited to a description of the
document and a general characterization of its subject matter in a manner that does not state any substantive information contained in the document.
8. Restricting Persons Who Mav Have Access to Highly Sensitive Protected Material.
With the exception of Commission Staff, the Office of the Attorney General (OAG), and
the Office ofPublic Utility Counsel (OPC), and except as provided herein, the Reviewing
Representatives for the purpose of access to Highly Sensitive Protected Materials may be
persons who are (a) outside counsel for the Reviewing Party, (b) outside consultants for
the Reviewing Party working under the direction of Reviewing Party's counsel, or (c)
employees of the Reviewing Party working with and under the direction of Reviewing
Party's counsel who have been authorized by the presiding officer to review Highly
Sensitive Protected Materials. The Reviewing Party must limit the number of Reviewing
Representatives that review Highly Sensitive Protected Materials to the minimum number
of persons necessary. The Reviewing Party is under a good faith obligation to limit
access to each portion of any Highly Sensitive Protected Materials to two Reviewing
Representatives whenever possible. Reviewing Representatives for Commission Staff,
OAG, and OPC, for the purpose of access to Highly Sensitive Protected Materials, must
consist of their respective counsel of record in this proceeding and associated attorneys,
paralegals, economists, statisticians, accountants, consultants, or other persons employed
or retained by them and directly engaged in these proceedings.
9. Copies Provided of Hiehlv Sensitive Protected Material. A producing party is
required to provide one copy of Highly Sensitive Protected Materials specifically
requested by the Reviewing Party to the person designated by the Reviewing Party who
must be a person authorized to review Highly Sensitive Protected Material under
Paragraph 8. Representatives of the Reviewing Party who are authorized to view Highly
Sensitive Protected Material may review the copy of Highly Sensitive Protected
Materials at the office of the Reviewing Party's representative designated to receive the
information. Any Highly Sensitive Protected Materials provided to a Reviewing Party
SCH3 - Page 623 of 640 006318
Schedule W Page 6 of21
Sponsor: Grant 2021 TX Rate Case
may not be copied except as provided in Paragraph 7. The restrictions contained herein
do not apply to Commission Staff, OPC, and the OAG when the OAG is a representing a
party to the proceeding.
10. Procedures in Para!!raphs 10-14 Applv to Commission Staff, OPC, and the OAG
and Control in the Event of Conflict. The procedures in Paragraphs 10 through 14
apply to responses to requests for documents or information that the producing party
designates as Highly Sensitive Protected Materials and provides to Commission Staff,
OPC, and the OAG in recognition of their purely public functions. To the extent the
requirements of Paragraphs 10 through 14 conflict with any requirements contained in
other paragraphs ofthis Protective Order, the requirements ofthese Paragraphs control.
11. Copv of Hiehlv Sensitive Protected Material to be Provided to Commission Staff,
OPC and the OAG. When, in response to a request for information by a Reviewing
Party, the producing party makes available for review documents or information claimed
to be Highly Sensitive Protected Materials, the producing party is required to also deliver
one copy of the Highly Sensitive Protected Materials to the Commission Staff, OPC (if
OPC is a party), and the OAG (if the OAG is representing a party) in Austin, Texas.
Provided however, that in the event such Highly Sensitive Protected Materials are
voluminous, the materials will be made available for review by Commission Staff, OPC
(if OPC is a party), and the OAG (if the OAG is representing a party) at the designated
office in Austin, Texas. The Commission Staff, OPC (if OPC is a party) and the OAG (if
the OAG is representing a party) may request such copies as are necessary of such
voluminous material under the copying procedures specified herein.
12. Delivery of the Copv of Highly Sensitive Protected Material to Commission Staff
and Outside Consultants. The Commission Staff, OPC (if OPC is a party), and the
OAG (if the OAG is representing a party) may deliver the copy of Highly Sensitive
Protected Materials received by them to the appropriate members of their staff for review,
provided such staff members first sign the certification specified by Paragraph 15. After
obtaining the agreement of the producing party, Commission Staff, OPC (if OPC is a
party), and the OAG (if the OAG is representing a party) may deliver the copy of Highly
SCH3 - Page 624 of 640 006319
Schedule W Page 7 of 21
Sponsor: Grant 2021 TX Rate Case
Sensitive Protected Materials received by it to the agreed, appropriate members of their
outside consultants for review, provided such outside consultants first sign the certification in Attachment A.
13. Restriction on Copying bv Commission Staff, OPC and the OAG. Except as allowed
by Paragraph 7, Commission Staff, OPC and the OAG may not make additional copies of
the Highly Sensitive Protected Materials furnished to them unless the producing party
agrees in writing otherwise, or, upon a showing of good cause, the presiding officer directs otherwise. Commission Staff, OPC, and the OAG may make limited notes of
Highly Sensitive Protected Materials furnished to them, and all such handwritten notes
will be treated as Highly Sensitive Protected Materials as are the materials from which
the notes are taken.
14. Public Information Requests. In the event of a request for any of the Highly Sensitive
Protected Materials under the Public Information Act, an authorized representative of the
Commission, OPC, or the OAG may furnish a copy of the requested Highly Sensitive
Protected Materials to the Open Records Division at the OAG together with a copy of
this Protective Order after notifying the producing party that such documents are being
furnished to the OAG. Such notification may be provided simultaneously with the
delivery ofthe Highly Sensitive Protected Materials to the OAG.
15. Required Certification. Each person who inspects the Protected Materials must, before
such inspection, agree in writing to the following certification found in Attachment A to
this Protective Order:
I certify my understanding that the Protected Materials are provided to me pursuant to the terms and restrictions of the Protective Order in this docket, and that I have been given a copy of it and have read the Protective Order and agree to be bound by it. I understand that the contents of the Protected Materials, any notes, memoranda, or any other form of information regarding or derived from the Protected Materials must not be disclosed to anyone other than in accordance with the Protective Order and unless I am an employee ofthe Commission or OPC will be used only for the purpose of the proceeding in Docket No.
. I acknowledge that the obligations imposed by this certification are pursuant to such Protective Order. Provided, however, if the
SCH3 - Page 625 of 640 006320
Schedule W Page 8 of 21
Sponsor: Grant 2021 TX Rate Case
information contained in the Protected Materials is obtained from independent public sources, the understanding stated herein must not apply.
In addition, Reviewing Representatives who are permitted access to Highly Sensitive
Protected Material under the terms of this Protective Order must, before inspection of
such material, agree in writing to the following certification found in Attachment A to
this Protective Order:
I certify that I am eligible to have access to Highly Sensitive Protected Material under the terms ofthe Protective Order in this docket.
The Reviewing Party is required to provide a copy of each signed certification to Counsel
for the producing party and serve a copy upon all parties of record.
16. Disclosures between Reviewing Representatives and Continuation of Disclosure
Restrictions after a Person is no Longer Engaged in the Proceeding. Any Reviewing
Representative may disclose Protected Materials, other than Highly Sensitive Protected
Materials, to any other person who is a Reviewing Representative provided that, if the
person to whom disclosure is to be made has not executed and provided for delivery of a
signed certification to the party asserting confidentiality, that certification must be
executed prior to any disclosure. A Reviewing Representative may disclose Highly
Sensitive Protected Material to other Reviewing Representatives who are permitted
access to such material and have executed the additional certification required for persons
who receive access to Highly Sensitive Protected Material. In the event that any
Reviewing Representative to whom Protected Materials are disclosed ceases to be
engaged in these proceedings, access to Protected Materials by that person must be
terminated and all notes, memoranda, or other information derived from the protected material must either be destroyed or given to another Reviewing Representative of that
party who is authorized pursuant to this Protective Order to receive the protected
materials. Any person who has agreed to the foregoing certification is required to
continue to be bound by the provisions of this Protective Order so long as it is in effect,
even if no longer engaged in these proceedings.
SCH3 - Page 626 of 640 006321
Schedule W Page 9 of 21
Sponsor: Grant 2021 TX Rate Case
17. Producing Party to Provide One Copv of Certain Protected Material and
Procedures for Making Additional Copies of Such Materials. Except for Highly
Sensitive Protected Materials, which must be provided to the Reviewing Parties under
Paragraph 9, and voluminous Protected Materials, the producing party is required to
provide a Reviewing Party one copy of the Protected Materials upon receipt of the signed
certification described in Paragraph 15. Except for Highly Sensitive Protected Materials,
a Reviewing Party may make further copies of Protected Materials for use in this
proceeding according to this Protective Order, but a record must be maintained as to the
documents reproduced and the number of copies made, and upon request the Reviewing
Party is required to provide the party asserting confidentiality with a copy ofthat record.
18. Procedures Reearding Voluminous Protected Materials. 16 Texas Administrative
Code (TAC) § 22.144(h) will govern production of voluminous Protected Materials.
Voluminous Protected Materials will be made available in the producing party's
voluminous room, in Austin, Texas, or at a mutually agreed upon location, Monday
through Friday, 9:00 a.m. to 5:00 p.m. (except on state or Federal holidays), and at other
mutually convenient times upon reasonable request.
19. Reviewing Period Defined. The Protected Materials may be reviewed only during the
Reviewing Period5 which will commence upon entry of this Protective Order and
continue until the expiration of the Commission's plenary jurisdiction. The Reviewing
Period will reopen ifthe Commission regains jurisdiction due to a remand as provided by
law. Protected materials that are admitted into the evidentiary record or accompanying
the evidentiary record as offers of proof may be reviewed throughout the pendency of this
proceeding and any appeals.
20. Procedures for Making Copies of Voluminous Protected Materials. Other than
Highly Sensitive Protected Materials, Reviewing Parties may take notes regarding the
information contained in voluminous Protected Materials made available for inspection
or they may make photographic, mechanical or electronic copies of the Protected
Materials, subject to the conditions in this Protective Order; provided, however, that
before photographic, mechanical or electronic copies may be made, the Reviewing Party
SCH3 - Page 627 of 640 006322
Schedule W Page 10 of 21
Sponsor: Grant 2021 TX Rate Case
seeking photographic, mechanical or electronic copies must provide written confirmation
of the receipt of copies listed on Attachment B of this Protective Order identifying each
piece of Protected Materials or portions thereofthe Reviewing Party will need.
21. Protected Materials to be Used Solely for the Purposes of These Proceedings. All
Protected Materials must be made available to the Reviewing Parties and their Reviewing
Representatives solely for the purposes of these proceedings. Access to the Protected
Materials may not be used in the furtherance of any other purpose, including, without
limitation: (a) any other pending or potential proceeding involving any claim, complaint,
or other grievance ofwhatever nature, except appellate review proceedings that may arise
from or be subject to these proceedings; or (b) any business or competitive endeavor of whatever nature. Because of their statutory regulatory obligations, these restrictions do
not apply to Commission Staff or OPC.
22. Procedures for Confidential Treatment of Protected Materials and Information
Derived from Those Materials. Protected Materials, as well as a Reviewing Party' s
notes, memoranda, or other information regarding or derived from the Protected
Materials are to be treated confidentially by the Reviewing Party and must not be
disclosed or used by the Reviewing Party except as permitted and provided in this
Protective Order. Information derived from or describing the Protected Materials must
be maintained in a secure place and must not be placed in the public or general files of the Reviewing Party except in accordance with the provisions ofthis Protective Order. A
Reviewing Party must take all reasonable precautions to insure that the Protected
Materials including notes and analyses made from Protected Materials that disclose
Protected Materials are not viewed or taken by any person other than a Reviewing
Representative of a Reviewing Party.
23. Procedures for Submission of Protected Materials. If a Reviewing Party lenders for
filing any Protected Materials, including Highly Sensitive Protected Materials, or any
written testimony, exhibit, brief, motion or other type of pleading or other submission at
the Commission or before any other judicial body that quotes from Protected Materials or
discloses the content of Protected Materials, the confidential portion of such submission
SCH3 - Page 628 of 640 006323
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must be filed and served in sealed envelopes or other appropriate containers endorsed to
the effect that they contain Protected Material or Highly Sensitive Protected Material and
are sealed pursuant to this Protective Order. If filed at the Commission, such documents
must be marked "PROTECTED MATERIAL" and must be filed under seal with the
presiding officer and served under seal to the counsel of record for the Reviewing Parties.
The presiding officer may subsequently, on his/her own motion or on motion of a party,
issue a ruling respecting whether or not the inclusion, incorporation or reference to
Protected Materials is such that such submission should remain under seal. If filing
before a judicial body, the filing party: (a) must notify the party which provided the
information within sufficient time so that the producing party may seek a temporary
sealing order; and (b) must otherwise follow the procedures in Rule 76a, Texas Rules of
Civil Procedure.
24. Maintenance of Protected Status of Materials during Pendencv of Appeal of Order
Holding Materials are not Protected Materials. In the event that the presiding officer
at any time in the course of this proceeding finds that all or part of the Protected
Materials are not confidential or proprietary, by finding, for example, that such materials
have entered the public domain or materials claimed to be Highly Sensitive Protected
Materials are only Protected Materials, those materials will nevertheless be subject to the
protection afforded by this Protective Order for three (3) full working days, unless
otherwise ordered, from the date the party asserting confidentiality receives notice of the
presiding officer's order. Such notification will be by written communication. This
provision establishes a deadline for appeal of a presiding officer's order to the
Commission. In the event an appeal to the Commissioners is filed within those three (3)
working days from notice, the Protected Materials must be afforded the confidential
treatment and status provided in this Protective Order during the pendency of such
appeal. Neither the party asserting confidentiality nor any Reviewing Party waives its
right to seek additional administrative or judicial remedies after the Commission' s denial
of any appeal.
SCH3 - Page 629 of 640 006324
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Sponsor: Grant 2021 TX Rate Case
25. Notice of Intent to Use Protected Materials or Change Materials Desienation.
Parties intending to use Protected Materials must notify the other parties prior to offering
them into evidence or otherwise disclosing such information into the record of the
proceeding. During the pendency of Docket No. at the Commission, in the
event that a Reviewing Party wishes to disclose Protected Materials to any person to
whom disclosure is not authorized by this Protective Order, or wishes to have changed
the designation of certain information or material as Protected Materials by alleging, for
example, that such information or material has entered the public domain, such
Reviewing Party must first file and serve on all parties written notice of such proposed
disclosure or request for change in designation, identifying with particularity each of such
Protected Materials. A Reviewing Party will at any time be able to file a written motion
to challenge the designation of information as Protected Materials.
26. Procedures to Contest Disclosure or Change in Designation. In the event that the
party asserting confidentiality wishes to contest a proposed disclosure or request for change in designation, the party asserting confidentiality must file with the appropriate
presiding officer its objection to a proposal, with supporting affidavits, if any, within five
(5) working days after receiving such notice of proposed disclosure or change in
designation. Failure ofthe party asserting confidentiality to file such an objection within
this period will be deemed a waiver of objection to the proposed disclosure or request for
change in designation. Within five (5) working days after the party asserting
confidentiality files its objection and supporting materials, the party challenging
confidentiality may respond. Any such response must include a statement by counsel for
the party challenging such confidentiality that he or she has reviewed all portions of the materials in dispute and, without disclosing the Protected Materials, a statement as to
why the Protected Materials should not be held to be confidential under current legal
standards, or that the party asserting confidentiality for some reason did not allow such
counsel to review such materials. If either party wishes to submit the material in question
for in camera inspection, it must do so no later than five (5) working days after the party
challenging confidentiality has made its written filing.
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27. Procedures for Presiding Officer Determination Regarding Proposed Disclosure or
Change in Designation. If the party asserting confidentiality files an objection, the
appropriate presiding officer will determine whether the proposed disclosure or change in designation is appropriate . Upon the request of either the producing or Reviewing Party
or upon the presiding officer's own initiative, the presiding officer may conduct a
prehearing conference. The burden is on the party asserting confidentiality to show that
such proposed disclosure or change in designation should not be made. If the presiding
officer determines that such proposed disclosure or change in designation should be
made, disclosure must not take place earlier than three (3) full working days after such
determination unless otherwise ordered. No party waives any right to seek additional
administrative or judicial remedies concerning such presiding officer's ruling.
28. Maintenance of Protected Status during Periods Specified for Challenging Various
Orders. Any party electing to challenge, in the courts of this state, a Commission or
presiding officer determination allowing disclosure or a change in designation will have a
period of ten (10) days from: (a) the date of an unfavorable Commission order; or (b) if
the Commission does not rule on an appeal of an interim order, the date an appeal of an
interim order to the Commission is overruled by operation of law, to obtain a favorable
ruling in state district court. Any party challenging a state district court determination
allowing disclosure or a change in designation will have an additional period of ten (10)
days from the date of the order to obtain a favorable ruling from a state appeals court. Finally, any party challenging a determination of a state appeals court allowing disclosure
or a change in designation will have an additional period of ten (10) days from the date of
the order to obtain a favorable ruling from the state supreme court, or other appellate court. All Protected Materials must be afforded the confidential treatment and status
provided for in this Protective Order during the periods for challenging the various orders
referenced in this paragraph. For purposes of this paragraph, a favorable ruling of a state
district court, state appeals court, Supreme Court or other appellate court includes any
order extending the deadlines in this paragraph.
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29. Other Grounds for Objection to Use of Protected Materials Remain Applicable.
Nothing in this Protective Order precludes any party from objecting to the use of
Protected Materials on grounds other than confidentiality, including the lack of required
relevance. Nothing in this Protective Order constitutes a waiver of the right to argue for
more disclosure, provided, however, that unless the Commission or a court orders such
additional disclosure, all parties will abide by the restrictions imposed by the Protective
Order.
30. Protection of Materials from Unauthorized Disclosure. All notices, applications,
responses or other correspondence must be made in a manner which protects Protected
Materials from unauthorized disclosure.
31. Return of Copies of Protected Materials and Destruction of Information Derived
from Protected Materials. Following the conclusion of these proceedings, each
Reviewing Party must, no later than thirty (30) days following receipt of the notice
described below, return to the party asserting confidentiality all copies of the Protected Materials provided by that party pursuant to this Protective Order and all copies
reproduced by a Reviewing Party, and counsel for each Reviewing Party must provide to
the party asserting confidentiality a letter by counsel that, to the best of his or her knowledge, information, and belief, all copies of notes, memoranda, and other documents regarding or derived from the Protected Materials (including copies of Protected
Materials) that have not been so returned, if any, have been destroyed, other than notes,
memoranda, or other documents which contain information in a form which, if made
public, would not cause disclosure of the substance of Protected Materials. As used in
this Protective Order, "conclusion of these proceedings" refers to the exhaustion of
available appeals, or the running of the time for the making of such appeals, as provided
by applicable law. If, following any appeal, the Commission conducts a remand
proceeding, then the "conclusion of these proceedings" is extended by the remand to the exhaustion of available appeals ofthe remand, or the running of the time for making such appeals ofthe remand, as provided by applicable law. Promptly following the conclusion
of these proceedings, counsel for the party asserting confidentiality will send a written
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notice to all other parties, reminding them of their obligations under this Paragraph.
Nothing in this Paragraph prohibits counsel for each Reviewing Party from retaining two
(2) copies of any filed testimony, brief, application for rehearing, hearing exhibit or other
pleading which refers to Protected Materials provided that any such Protected Materials
retained by counsel will remain subject to the provisions of this Protective Order.
32. Applicabilitv of Other Law. This Protective Order is subject to the requirements of the
Public Information Act, the Open Meetings Act,3 the Texas Securities Act4 and any other
applicable law, provided that parties subject to those acts will notify the party asserting
confidentiality, if possible under those acts, prior to disclosure pursuant to those acts.
Such notice is not required where the Protected Materials are sought by governmental
officials authorized to conduct a criminal or civil investigation that relates to or involves
the Protected Materials, and those governmental officials aver in writing that such notice
could compromise the investigation and that the governmental entity involved will
maintain the confidentiality ofthe Protected Materials.
33. Procedures for Release of Information under Order. If required by order of a
governmental or judicial body, the Reviewing Party may release to such body the
confidential information required by such order; provided, however, that: (a) the
Reviewing Party must notify the producing party of the order requiring the release of
such information within five (5) calendar days of the date the Reviewing Party has notice
of the order; (b) the Reviewing Party must notify the producing party at least five (5)
calendar days in advance of the release of the information to allow the producing party to
contest any release of the confidential information; and (c) the Reviewing Party must use
its best efforts to prevent such materials from being disclosed to the public. The terms of
this Protective Order do not preclude the Reviewing Party from complying with any valid
and enforceable order of a state or federal court with competent jurisdiction specifically
requiring disclosure of Protected Materials earlier than contemplated herein. The notice
specified in this section is not required where the Protected Materials are sought by
3 Tex. Gov't Code § 551.001-.146. 4 Tex. Rev. Civ. Stat. Ann. arts. 581-1 to 581-43.
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governmental officials authorized to conduct a criminal or civil investigation that relates
to or involves the Protected Materials, and those governmental officials aver in writing
that such notice could compromise the investigation and that the governmental entity
involved will maintain the confidentiality ofthe Protected Materials.
34. Best Efforts Defined. The term "best efforts" as used in the preceding paragraph
requires that the Reviewing Party attempt to ensure that disclosure is not made unless
such disclosure is pursuant to a final order of a Texas governmental or Texas judicial
body, the written opinion of the Texas Attorney General sought in compliance with the
Public Information Act, or the request of governmental officials authorized to conduct a
criminal or civil investigation that relates to or involves the Protected Materials. The
Reviewing Party is not required to delay compliance with a lawful order to disclose such
information but is simply required to timely notify the party asserting confidentiality, or
its counsel, that it has received a challenge to the confidentiality of the information and
that the Reviewing Party will either proceed under the provisions of §552.301 of the
Public Information Act, or intends to comply with the final governmental or court order.
Provided, however, that no notice is required where the Protected Materials are sought by
governmental officials authorized to conduct a criminal or civil investigation that relates
to or involves the Protected Materials, and those governmental officials aver in writing
that such notice could compromise the investigation and that the governmental entity
involved will maintain the confidentiality ofthe Protected Materials.
35. Notify Defined. "Notify" for purposes of Paragraphs 32,33 and 34 means written notice
to the party asserting confidentiality at least five (5) calendar days prior to release;
including when a Reviewing Party receives a request under the Public Information Act.
However, the Commission, OAG, or OPC may provide a copy of Protected Materials to
the Open Records Division ofthe OAG as provided herein.
36. Requests for Non-Disclosure. If the producing party asserts that the requested
information should not be disclosed at all, or should not be disclosed to certain parties
under the protection afforded by this Protective Order, the producing party must tender
the information for in camera review to the presiding officer within ten (10) calendar
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days of the request. At the same time, the producing party is required to file and serve on
all parties its argument, including any supporting affidavits, in support of its position of non-disclosure. The burden is on the producing party to establish that the material should
not be disclosed. The producing party must serve a copy of the information under the
classification of Highly Sensitive Protected Material to all parties requesting the
information that the producing party has not alleged should be prohibited from reviewing
the information.
Parties wishing to respond to the producing party's argument for non-disclosure must do
so within five working days. Responding parties should explain why the information
should be disclosed to them, including why disclosure is necessary for a fair adjudication of the case if the material is determined to constitute a trade secret. If the presiding
officer finds that the information should be disclosed as Protected Material under the
terms of this Protective Order, the presiding officer will stay the order of disclosure for
such period of time as the presiding officer deems necessary to allow the producing party
to appeal the ruling to the Commission.
37. Sanctions Available for Abuse of Designation. If the presiding officer finds that a
producing party unreasonably designated material as Protected Material or as Highly
Sensitive Protected Material, or unreasonably attempted to prevent disclosure pursuant to
Paragraph 36, the presiding officer may sanction the producing party pursuant to 16 TAC
§22.161.
38. Modification of Protective Order. Each party will have the right to seek changes in this
Protective Order as appropriate from the presiding officer.
39. Breach of Protective Order. In the event of a breach ofthe provisions ofthis Protective
Order, the producing party, if it sustains its burden of proof required to establish the right
to injunctive relief, will be entitled to an injunction against such breach without any
requirements to post bond as a condition of such relief. The producing party will not be
relieved of proof of any element required to establish the right to injunctive relief. In
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addition to injunctive relief, the producing party will be entitled to pursue any other form ofreliefto which it is entitled.
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ATTACHMENT A
Protective Order Certification
I certify my understanding that the Protected Materials are provided to me pursuant to the
terms and restrictions of the Protective Order in this docket and that I have received a copy of it
and have read the Protective Order and agree to be bound by it. I understand that the contents of
the Protected Materials, any notes, memoranda, or any other form of information regarding or
derived from the Protected Materials must not be disclosed to anyone other than in accordance
with the Protective Order and unless I am an employee of the Commission or OPC will be used
only for the purpose of the proceeding in Docket No. . I acknowledge that the
obligations imposed by this certification are pursuant to such Protective Order. Provided,
however, if the information contained in the Protected Materials is obtained from independent
public sources, the understanding stated here will not apply.
Signature Party Represented
Printed Name Date
I certify that I am eligible to have access to Highly Sensitive Protected Material under the terms
ofthe Protective Order in this docket.
Signature Party Represented
Printed Name Date
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ATTACHMENT B
I request to view/copy the following documents:
Document Requested
Protected Materials and/or Highly # of Copies Non-Confidential Sensitive Protected
Materials
Signature Party Represented
Printed Name Date
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ATTACHMENT 1
Schedules Designated as Confidential or Highly Sensitive
• E-2.4(CONF); • G-5.1(CONF; ' G-5.4(CONF); • G-7.1(HS); • G-7.la(HS); • G-7.9*HS); • H-6.2®HS); • I-1.3(CONF); • I-10(V)(CONF); • I-17.1(CONF); ' O-2(all)(CONF)(CD); ' 0-7.1; and, • O-9(all)(CONF)(CD)
Schedule Workpapers Designated as Confidential or Highly Sensitive
• WP/E-4(CONF)(CD); • WP/G-2.3(CONF)(CD); • WP/G-7.1(HS)(CD); • WP/G-7.la(HS)(CD); ' WP/G-7.6a(HS)(CD); • WP/G-7.9a(HS)(CD); • WP/G-7.13(HS)(CD); • WP/I-4(CONF)(CD); and, • WP/K-6(CONF)(CD).
Please also refer to SPS's Index of Documents Containing Confidential or Highly Sensitive Protected Materials Included in its Rate Filing Package.
SCH3 - Page 639 of 640 006334